EPA Superfund
Record of Decision:
PB96-964101
EPA/ROD/R05-96/295
June 1996
Lauer 1 Sanitary Landfill,
(Boundary Road), Menomonee Falls, WI
3/11/1996
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RECORD OF DECISION" DECLARATION
FINAL REMEDIAL ACTION
Boundary Road Landfill (f.(
Menomonee Falls, WI
Site Name and Location
The Boundary Road Landfill (formerly known as the Lauer 1 Landfill) is located
in the northeastern portion of the Village of Menomonee Falls. The site
address Is W124 N8925 Boundary Road and the section location is the SE^ of
Section 1, Tn8N, R20E. The site occupies approximately 58 acres of a 75 acre
tract of land. The site Is situated In an urbanizing area, with mixed
surrounding land uses, including some residential, industrial and agricultural
uses.
Statement of Basis and Purpose
This decision document represents the selected final remedial action for the
Boundary Road site. This action was developed pursuant to section 144.442,
Wis. Stats., the Environmental Repair Contract #SF-90-01 entered into by Waste
Management of Wisconsin, Inc. (WMWI) and the Department of Natural Resources
(the Department) and is consistent with and in substantial compliance with the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and Reauthorization Act of
1986 (SARA), and the National Contingency Plan (NCP). This decision is based
on the administrative record for the site.
The U.S. EPA concurs with the selected final action. U.S. EPA's letter of
concurrence is attached to this Record of Decision (ROD).
Assessment of the Site
Actual or threatened releases of hazardous substances from the site, if not
addressed by implementing the remedial action selected in this Record of
Decision, may present an imminent and substantial danger to public health,
welfare, or the environment.
Description of the Remedy
The selected remedy, Alternative 3, includes:
• Construction of a new multi-layer soil cover system over the landfill
• Installation of leachate extraction measures, in the northeastern
portion of the site
• Installation of an active landfill gas extraction system
• Construction of a new leachate conveyance, likely a forcemain
(pressure pipe), to transmit all extracted leachate from the site to the
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local sanitary sewer system
• Continued operation and maintenance of an existing s]urry cui-off wa1
and leachate collection system, including conveyance of :eacnaie from
the collection system to the new forcemain
• Implementation of proper institutional controls
• Installation of new fencing and improvement of existing fencing to
restrict site access
• Long-term monitoring of groundwater, surface water and landfill gas
• Supplementary studies of groundwater quality and internal landfill
leachate elevations
• Implementation of additional remedial actions found to be necessary
under the additional studies of groundwater quality and internal
leachate elevations
Statutory Determinations
This final remedy is protective of human health and the environment, complies
with Federal and State requirements that are legally applicable or relevant
and appropriate to the remedial action, and is cost effective. This remedy
satisfies the statutory preference for remedies which reduce the toxicity.
mobility or volume of hazardous substances.
Because this remedy will result in hazardous substances remaining on-site, a
review will be conducted to ensure that the remedy continues to provide
adequate protection of human health and the environment within 5 years after
the commencement of this source control remedial action.
3 /
George Meyer,\SecretaryrjDate
W/sconsin Department of Natural Resources
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RECORD OF DECISION SUMMARY
FINAL REMEDIAL ACTION
Boundary Road Landfill (f/k/a Lauer 1 Landfill)
Menomonee Falls. WI•
Table of Contents
I. SITE DESCRIPTION, HISTORY AND ENFORCEMENT ACTIVITIES 2
II. COMMUNITY PARTICIPATION 3
III. SCOPE AND ROLE OF THE RESPONSE ACTION 4
IV. SUMMARY OF SITE CHARACTERISTICS . 5
A. Topography 5
B. Landfill Characteristics . 5
C. Surface Water Hydrology 5
D. Geology/Hydrogeology 6
E. Contaminant Summary 12
V. SUMMARY OF SITE RISKS 22
VI. Description of the Remedial Alternatives 27
A. Remedial Action Objectives 27
B. Development of Alternatives , 28
C. Description of Alternatives 28
VII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES .30
A. Introduction 30
B. Evaluation of the Remedial Alternatives 32
VIII. THE SELECTED REMEDY 35
IX. STATUTORY DETERMINATION 39
A. Protection of Human Health and the Environment 39
B. Attainment of ARARs 39
C. Cost Effectiveness 43
D. Use of Permanent Solutions and Alternative Treatment
Technologies . 43
E. Preference for Treatment as a Principal Element 44
RESPONSIVENESS SUMMARY 45
Figures
Tables
U.S. EPA Region 5 Concurrence Letter
Administrative Record Index
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RECORD OF DECISION SUMMARY
Boundary Road Landfill (f/k/a Lauer 1 Landfill)
Menomonee Fa 1 Is, wl
I. SITE DESCRIPTION, HISTORY AND ENFORCEMENT ACTIVITIES
The 58-acre Boundary Road Landfill (formerly known as the Lauer 1 Landfill).
owned since 1971 by Waste Management of Wisconsin, Inc. (WMWI). opened in 1954
and accepted waste until at least 1971. The site was not properly closed.
through the placement of adequate amounts of cover material and the
establishment of a proper vegetative cover, until the late 1970's. The site
is located in the northeast corner of the Village of Menomonee Falls, and is
just south of the Waste Management Parkview landfill and the Waste Management
Controlled Waste Solidification/Storage facility. The site is situated in an
urbanizing area, with mixed surrounding land uses, including some residential,
industrial and agricultural uses. Figure 1 (Drawing 1537101-A2) shows the
site location and surrounding land uses.
Wastes disposed at the site included both municipal and industrial materials.
WMWI submitted a Superfund notification form to U.S. EPA in 1981 indicating
that the site accepted 10 million gallons of hazardous waste, and general
waste types and sources were listed, but no specific waste codes were provided
on the form. No further spectfic information on the waste types accepted are
available at this time.
Because leachate was seeping to surface water next to the site, a slurry
cutoff wall and leachate collection system was installed by WMWI in the early
1980s along the southern perimeter of the site to reduce leachate movement to
surface water. The leachate from this system is collected and hauled to the
Omega Hills leachate pretreatment facility, which discharges to the Milwaukee
Metropolitan Sewerage District (MMSD) system.
Enforcement action by the Department was necessary to achieve final site
closure (proper cover placement and vegetation) and the installation of the
slurry cutoff wall and leachate collection system.
The site was used as a soccer field for the Milwaukee Kickers until the
Superfund investigation began in 1991.
The site was nominated by the Department to be placed on the Superfund
National Priorities List in 1983 and was placed on the list in 1985. WMWI
entered into Environmental Repair Contract #SF-90-01 for the Boundary
Corporation Landfill (the name it was known by at the time) with the
Department in 1990 to investigate and remediate the site pursuant to s.
144.442, Wisconsin Statutes. WMWI has been monitoring and maintaining the
site since its closure in 1972.
The Remedial Investigation (RI) was completed in August. 1993 and the
Feasibility Study (FS) was completed in November, 1994. The Department issued
a proposed plan in February. 1995. The proposed plan recommended the
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selection of Alternative 4A, an alternative utilizing a composite cover
system, as the final remedy. Information submitted during the public comment
period caused the Department to change the recommendation outlined in the
proposed plan. Factors considered by the Department in making its decision
are listed in Section II. Community Participation.
II. COMMUNITY PARTICIPATION
A Community Relations Plan for the site was finalized in. February. 1991. This
document lists contacts and interested parties throughout the local and
government community. It also establishes communication pathways to ensure
timely dissemination of pertinent information. An information repository has
been established at the Maude Shunk Library in Menomonee Falls. The
administrative record is available to the public at the Department's Madison
and Southeast Regional offices.
In July, 1991, the Department issued a Superfund Fact Sheet which provided a
summary of the site history, explained the Superfund process and delineated
the approved RI work plan. On August 8, 1991 the Department and the Wisconsin
Department of Health and Social Services (WDHSS) held a public informational
meeting at the Menomonee Falls Municipal Building. The meeting was held to
present information about the site and to explain the RI field work which was
about to start. t
In August, 1993, the Department issued a Superfund Fact Sheet which provided a
summary of the RI results. On September 9, 1993 the Department and WDHSS held
a second public informational meeting at the Menomonee Falls Municipal
Building to discuss the RI results.
The Proposed Plan for the site was made available for public comment in early
February, 1995. A public meeting to explain the Proposed Plan, and to receive
public comments was held on February 16, 1995. The public comment period was
originally between February 16 and March 16, 1.995, and was extended twice at
the request of WMWI for a total extension of 60 days (2 30-day extensions).
All comments which were received by the Department prior to the end of the
public comment period, including those expressed verbally at the public
meeting, were considered in making the final decision and are addressed in the
Responsiveness Summary, which is part of this ROD.
The proposed plan recommended the selection of Alternative 4A, an alternative
utilizing a composite cover system, as the final remedy. Information
submitted during the public comment period caused the Department to change the
recommendation outlined in the proposed plan. The main reasons for this are:
1. Alternatives 3, 4 (which also includes a composite cover system design)
and 4A meet the threshold criteria for remedy selection (protective and meets
state and federal laws) under the federal Superfund program. Therefore, the
Department could select any of these alternatives in this decision, after
considering the balancing and modifying criteria (these'criteria are described
in section VII, below).
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2. There was public support expressed for alternative 3 and no public support
expressed for alternative 4A. All comments received by the Department, were
in opposition to the selection of alternative 4A and favored the selection of
alternative 3. One of the modifying criteria >s community acceptance, e.g.,
the public's response to the proposed plan.
3. Alternative 4A would have additional construction and maintenance
difficulties (implementability problems) as compared to alternatives 3 and 4.
The Department received improved information on these difficulties during the
public comment period. This difficulties are discussed in the Responsiveness
Summary, attached to this Decision Summary, and section VII.B., below. Based
on the improved information, the Department has determined that
implementability problems preclude the selection of alternative 4A. Based on
criteria outlined in section VIII, below, the Department could subsequently
revise this decision to select alternative 4. Any subsequent revisions to
this decision would require a public notice of the proposed change and an
opportunity for public comment.
4. Alternatives 4 and 4A would allow less infiltration into the site as
compared to alternative 3. However, despite the increased infiltration, it is
expected that alternative 3 will reduce the movement of leachate to
groundwater and surface water at a similar rate to the other alternatives.
provided alternative 3 is implemented and maintained with aggressive leachate
extraction.
The public participation requirements of s. 144.442(6)(f), Wisconsin
Statutes, and the community relations requirements in the National Contingency
Plan under 40 CFR s. 300.430(f)(3) have been met in this remedy selection
process. All the documents listed above are available in the Administrative
Record maintained at the Department's Madison and Southeast Regional offices.
III. SCOPE AND ROLE OF THE RESPONSE ACTION
The landfilled waste, landfill gas and leachate within the waste are sources
of contamination to the affected media around the site. The landfilled waste
and. leachate are considered low level threat waste, because it is expected
that they can be contained reliably and likely would present only a low level
risk if they were directly released. Contaminated groundwater, soil and
surface water at the site are the affected media that pose a threat to human
health and the environment because of the current and future risks identified.
Contaminated groundwater at the site poses a possible future threat to human
health and the environment because of the risks from possible ingestion of or
dermal contact with the groundwater should wells intercepting the contaminated
groundwater be installed in the contaminated zone. Contaminated soil at the
site poses a possible future threat because of the risks of possible ingestion
of the soils should the land use at the site change. Contaminated surface
water poses a threat to the environment because sensitive water organisms
could be affected by contaminants in the surface water.
The selected remedial action, described as alternative 3, addresses the
threats posed by the site conditions by eliminating the potential for direct
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contact with contaminants of concern in the soil and reducing the levels of
contamination in the ground and surface waters. The selected action is
expected to reliably contain the landfilled waste and leachate, as well as
remove and treat the landfill leachate and gas.
IV. SUMMARY OF SITE CHARACTERISTICS
A. Topography
The landscape surrounding the site is gently sloping to nearly level, with
little relief, except for the Omega Hills Landfill located to the north of the
site. This landfill currently rises approximately 150 feet above the original
land surface. A curving low ridge with a north-south orientation also exists
immediately west of the site. Regional geomorphology is primarily the result
of depositional processes which occurred during continental glaciation.
The site is situated in an area of glacial ground moraine associated with the
Lake Michigan glacier which flowed westerly across the area 13,000 to 15,000
years ago, during the Wisconsin glaciation. The immediate area surrounding
the site exhibits the topographic characteristics of ground moraine; gentle
undulation with little to moderate relief.
B. Landfill Characteristics t
The area of waste disposal is approximately 58 acres. The fill volume is
about 1.3 million cubic yards of waste, with an average depth of 30 feet. The
waste is overlain by a soil cover that is partially vegetated. Areas of
stressed vegetation were noted on the cover, possibly due to landfill gas
stress. A large portion of the cover is very flat and was once used for
soccer fields. Portions of the site are used for buildings, parking and
storage for a waste hauling business. Testing of the existing cover showed it
to be from 0.5 to 8 feet deep with a average depth of 3.5 feet. Landfill gas
is being produced at the site and is monitored with a series of soil probes.
Gas migration is a potential concern. Figure 2 (Drawing 1537101-B20) shows
the landfill site area and on-site and adjacent land uses.
C. Surface Water Hydrology
The site is located in the Menomonee River watershed, which has a drainage
basin of approximately 137 square miles. The Menomonee River originates in
the northeastern corner of the Village of Germantown in Washington County and
flows southeasterly through Waukesha and Milwaukee Counties and into Lake
Michigan at the confluence of the Menomonee, Milwaukee, and Kinmckinnic
Rivers.
The local surface water features include a pond located in the southwest
corner of the site which covers approximately 11 acres. This pond is referred
to as the site pond. Another pond is located north of the site, adjacent to
the auto salvage yard and an intermittent stream along the western edge of the
site. The 11-acre site pond originated at the site around 1970 in an area
which had been excavated for the landfill but was never used for refuse
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disposal. An aerial photograph taken in 1971 shows the area of the present
day site pond to consist of small surface accumulations of standing liquid.
During the early 1970s, soil from this area was excavated as :a^: :r a sc~'
borrow operation and the resulting depression accumulated surface runoff ana
inflow of leachate to form two separate ponds. These two ponds consisted of
the existing large site pond and a separate smaller pond directly to its
north. In 1981, the smaller of the two ponds was drained and backfilled with
clean soil. A bentonite slurry cutoff wall was placed between the large site
pond and the landfill. The site appearance has remained unchanged since then.
The other surface water feature present at the site is an intermittent stream
which flows along the western edge of the site. It was diverted to its
current position along the western and southern perimeters of the site during
the late 1960s, as a consequence of the landfill operations. This stream is
an unnamed tributary to the Menomonee River and is separated from the west
side of the pond by a clay berm. Surface runoff from the site flows into
either this stream (at the northwest and southeast corners of the site), or
into the site pond. Outflow from the site pond into the stream is governed by
an outflow control structure located at the southeast corner of the pond.
Discharge from this pond is regulated under a Wisconsin Pollutant Discharge
Elimination System (WPDES) permit.
D. Geology/Hydrogeology *
Site Geology • The geology of the site consists primarily of a stiff, brown to
gray, silty to lean, clay till (CD. This till is found in most borings from
ground surface to the terminus of the deepest borings (100 feet). There are -
varying degrees of heterogeneity contained within the relatively uniform
matrix of silty clay to lean clay soils. The surficial till material
(approximately upper 30 feet) contains numerous heterogeneities including
silt, sand and gravel, topsoil, and peat. The clay till at depth is more
homogeneous than the upper 30 feet. The variable hydraulic conductivity of
the surficial till resulted in the need for installation of the slurry trench
cut-off wall and leachate collection system.(SCW/LCS) along the southern
perimeter of the refuse, to limit the potential flow beyond these features.
Below these surficial heterogeneities, the till deposit is much more uniform,
with only a limited number of sand deposits.
Two lenticular sand deposits were identified during the drillina of the
piezometer boreholes (P101, P102, P103, P104, P105C, and P106CK The top of
the first sand deposit is located 28 feet to 35 feet below ground surface and
is approximately 3.5 feet to 11.5 feet thick. This sand deposit is identified
at borings P102 and P103. It is not apparent whether this deposit is
continuous across the site. The composition of the deposit varies from a
silty sand (SM) to a fine to coarse sand and gravel (SP-GP). The top of the
second sand deposit is located 67 feet to 78 feet below ground surface and is
approximately 7 feet to 13 feet thick. The composition of the zone is a fine
to medium sand with some silt (SP-SM).
The results of cone penetration tests (CPT) which were performed at eight
locations on the north, east, and west sides of the site, were used to further
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define the surficial geology along the perimeter of the landfill
It is apparent that surface, or near surface sard deposes are present along
the west/northwest, and east/northeast sides of the site. These sand deposits
range In thickness from 7 to 10 feet on the west/northwest sides of the site,
and from 5 to 7 feet on the east/northeast sides of the site. These sand
deposits may be continuous, however, the near surface glacial deposits are
quite heterogeneous. Therefore, It Is also possible that silt and/or clay
deposits may exist between the CRT test locations, making the sand units less
continuous.
The majority of the surficial glacial deposits Identified during the CRT
program were clays and silts. The thin, Interspersed glacial sands and silts
are characteristic of near-Ice meltwater deposits from the retreating glacier.
The silty clayey material underlying the surficial sands and silts Is basal
clay till deposited during glacial advances. As such, this deeper clay till
Is generally more laterally extensive than the near surface sand and silt
deposits.
Landfill Hydraulics Summary - Based on a comparison between leachate and
groundwater head elevations at the site, It Is apparent that there is a close
hydraulic connection between the landfill and the groundwater system. The
base grades of the site are below the surrounding water table over a large
portion of the site. The base grade of the site consists of fine grain
deposits. The leachate collection system/slurry cut-off wall (LCS/SCW) Is
operated with the Intent of maintaining inward gradients. The landfill was
not designed as a zone-of-saturation landfill, but would be considered a
zone-of-saturation landfill based on the fact that the base grade is lower
than the present elevation of the water table. The water elevations and
water/1eachate elevations observed in the RI illustrate that there is a
potential for increased leachate levels at various times of the year. The RI
indicates there were outward gradients to the north and east In the
northeastern portion of the site In May 1992. The potential for outward
gradients is greater in the northern portions of the site because the LCS
withdraws leachate from the south side of the landfill. The current leachate
head maintenance level does not allow for additional leachate head reduction
across the entire site due to the gradients across the site.
The landfill is unlined, allowing a hydraulic connection between the
underlying and adjacent glacial till to the landfill. Although boring logs
Indicate that the majority of the landfill is underlain by clay till, there Is
some sand and gravel in the northeast corner of the site. The perimeter of
the landfill is surrounded by various thin sand/sand and gravel deposits (from
0 feet to 30 feet). If these deposits are laterally extensive, they may be
the primary flow route for groundwater entering the landfill. However, the
leachate level on the east side of the site averages approximately 5 feet
above the base grade and the leachate level on the west side of the site
averages approximately 10 feet above the base grade with a maximum of
approximately 15 feet at well TW15R (May 8, 1992). where a trough occurs in
the base grade of the landfill. Note that the leachate/groundwater levels
listed above do not represent head levels above the surrounding water table
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since the base of the landfill is below the surrounding water table. The
leachate level is a maximum of 4 feet greater than the water table at the
Leachate levels within the landfill show a strong southward gradient within
the landfill due to the operation of the LCS/SCW located along the southern
perimeter of the landfill. A regular schedule of leachate extraction from the
LCS/SCW maintains the leachate head along the collection system at an
elevation of approximately 748 feet mean sea level (MSL).
The leachate extraction in the LCS helps to minimize leachate head levels in
the southern portions of the site. There is an apparent groundwater divide
within the northeast corner of the landfill. Based on the available
monitoring points, the leachate head contours show a small divide centered
across the northeastern limits of refuse. The highest leachate level is in
the northeast corner of the refuse.
Outward gradients exist along the western half of the northern border of the
landfill. The outward movement of leachate/groundwater in this area likely
occurs in the surficial sand unit located along the northwest corner of the
site. This surficial sand unit was identified by the cone penetrometer
survey.
t
Leachate head along the western portion of the landfill is strongly affected
by the presence of a clay berm constructed from the northwest corner of the
refuse area to the southwest corner of the refuse area. The clay berm acts
essentially as a low permeability boundary and the leachate in this area is -
directed south toward the LCS/SCW. Although the clay berm is saturated with
groundwater and/or leachate, it is possible that the rate of movement of
leachate through the berm is limited. However, the exact rate of movement is
unknown. There appears to be evidence of very limited contamination
associated with landfill leachate migrating to the creek that borders the west
side of the landfill, given that low levels of VOCs were detected there. This
interpretation is supported by the absence of contamination within the
sediments of the creek that borders the west side of the landfill, and the
limited detects of contaminants in the surface water of the creek
(chloroethane = 2, 7, 15 ug/L and 1,1-dichloroethane 0.7, 2 ug/L).
Leachate movement within the refuse along the eastern side of the landfill is
also affected by the hydraulic sink created within the LCS/SCW. Leachate
movement within the refuse along the east side of the landfill appears to be
mostly southward toward the LCS/SCW.
Leachate movement within the refuse along the southern portion of the landfill
is controlled by the LCS/SCW (Figure 4). The LCS was constructed from the
southwest corner of the landfill to the southeast corner of the landfill. The
LCS borders the limits of refuse along the entire south side of the landfill
and consists of approximately 2,100 feet of 6-in. diameter perforated PVC
pipe, twelve 6-in. diameter solid PVC clean-out risers, and four 4-feet
diameter manholes. Clean gravel was used as a bedding material and cover for
the leachate collection pipe. A 4-mil thick geotextile fabric was placed
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between the gravel and general backfill. Six gravel windows were installed
between the LCS and refuse where the collection line was not located in
refuse, in order to provide better hydraulic connection. The lengtn of these
windows vary from 8 to 20 feet. The collection line is sloped at 0.5% from
either end of the system toward a primary leachate collection point at manhole
MH3.
The SCW was designed to tie into the laterally continuous and relatively
impermeable clay till underlying the site at a depth of 20 to 30 feet. It is
approximately 2,200 feet long with a designed minimum width of 2 feet. The
SCW was constructed to a base elevation of approximately 725 to 730 feet MSL.
which is approximately 20 to 30 feet below ground surface. Laboratory tests
conducted on samples of the SCW showed values of hydraulic conductivity
ranging from 1.5xlO"8 cm/s to 4.8xlO"8 cm/s were achieved.
The leachate elevation data (1987 to present) in Appendix G2 in the RI Report
was evaluated to determine the effectiveness of the LCS/SCW. The leachate
head within the LCS has exceeded the LCS maintenance level (748 feet MSL) by
greater than a foot, five times during the period of record. These periods of
slightly elevated-leachate head ranged from less than one week, up to
11 weeks. During the periods of elevated leachate head in the LCS. the head
within the refuse area was also elevated. Consequently, those areas of the
site which experience outward gradients (i.e., the north-central edge of
refuse) would experience a somewhat greater outward transport of contaminants
during these periods. It is probable that additional periods of elevated
leachate head existed within the LCS prior to the period of available record
(1980 - 1987). However, the head in the LCS is currently being maintained "at
required levels (748 MSL) and seems to be performing efficiently.
A LCS evaluation test was conducted during the RI to evaluate the depth to
which the LCS was able to capture groundwater flow. Pre-test monitoring of
groundwater elevations was performed for 72 hours prior to pumping. Pumping
lasted 72 hours, and post-test monitoring was performed for 96 hours after the
pumps were shut off. The head in the LCS was lowered by pumping and the
effect on groundwater levels in wells below, and on both sides of the LCS were
measured. The test was monitored by installation of piezometer nests P105A,
B, and C and P106A, B, and C, and instrumenting 10 wells with pressure
transducers. The purpose of the test was achieved, as evidenced by the
drawdown plots in Figures 2 and 3 in the RI. The water table observation
wells on the inside of the slurry wall (TW21R, P105A, MW113, and P106A) had
significant drawdowns and showed immediate responses when the pumping began
(approximately 3,900 minutes after the start of water level monitoring).
These wells remained at a constant head or had slight increases in additional
drawdown when the pumping was stabilized at the collection line invert
(approximately 4,200 to 8,600 minutes), and recovered quickly when the pump
was shut off (approximately 8,600 minutes). This type of response is expected
since this group of wells is located so close to the LCS, both laterally and
vertically.
The two water table observation wells located outside of the slurry wall, TW22
and TW24, showed very little or no response. Both wells had a 0.4 feet head
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loss during the entire length of the test, compared to the approximately
8 feet of head drop Inside of the slurry wall. This 0.4 feet head loss may be
due to regional groundwater fluctuation caused by a recent rair:V event or
may have been caused by the test.
The Intermediate depth piezometers, P105B and P106B, are located between the
leachate collection line and the slurry wall, and screened within the first
sand deposits encountered beneath the LCS (P105B - 36 feet deep, P106B - 45
feet deep). Each had less than 0.5 feet of drawdown over the entire duration
of the test. The drawdown versus time plot for these wells was flat, and
showed little (very subdued with a long lag time) or no direct response to the
Initiation or termination of the pumping. This apparently Indicates there Is
very little or limited hydraulic connection between these sand seams and the
LCS system. This helps to show that the silty clay till between the base of
refuse and the underlying sand deposits has a low hydraulic conductivity.
The lower piezometers, P105C and P106C, had almost Identical response plots as
the Intermediate piezometers. These wells were screened In the second sand
seams located beneath the LCS system (P105C - 48 feet deep, P106C - 79 feet
deep). These wells Indicate that there Is an Insignificant hydraulic
connection between these lower sand seams and the LCS and, therefore, the
refuse.
t
Groundwater Flow Summary • Water level Information obtained from groundwater
monitoring wells and leachate head wells Is Included In the RI. Ten rounds of
water level measurements were taken during the RI. Historical levels obtained
by WMWI are also located In Appendix G of the RI. Two groundwater contour .
drawings prepared for the RI Illustrate groundwater conditions. One of those
drawings, Figure 4, shows conditions in May, 1992. At the Boundary Road
Landfill, the water table is unconfined and therefore, the water table
drawings illustrates local groundwater flow directions. The potentiometric
surface map illustrates the flow directions within the sand seam beneath the
site. The groundwater flow systems at .the site are described in the following
sections.
Water Table • As discussed above, a small groundwater divide exists along the
northeast side of the landfill. The divide has an east-west orientation,
approximately parallel to the northern limits of refuse. This divide would
serve as a boundary for contaminant migration in groundwater along the north
side of the site.
Groundwater flow in the area northwest of the landfill and the north pond is
directly toward the south. Groundwater flow from the north'of the site
converges at the north pond (north of the site). Groundwater is directed
westward from the north pond toward the northwest corner of the site. At this
location groundwater discharges into the creek which flows along the west side
of the site. Shallow groundwater west of the site also discharges into the
western creek. Horizontal groundwater gradients west of the site range from
O.Q3 ft/ft to 0.01 ft/ft. The large horizontal gradients, due to the low
hydraulic conductivity of the silty clay soils, are caused by a shallow
groundwater table which closely parallels the steep topography west of the
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site dipping toward the western creek.
Groundwater flow east of the landfill is directed toward the creek, (east of
Boundary Road), which is also a groundwater discharge point. This eastern
creek is a topographic low along the entire eastern side of the site and
accepts groundwater influx along both banks.
Groundwater flow in the area south of the site is influenced by the LCS/SCW
and the site pond. By controlling the water levels in the pond and the LCS it
is possible to induce a gradient from the pond toward the LCS.
Groundwater head south of the pond can be evaluated based on water levels
measured in wells TW5R, TW6R, TW7, TW13, and TW16. Groundwater flow south of
the property limits is directed north toward the creek. This is a wetland
area and groundwater is located very close to the ground surface. Water table
elevation reflects that the surface topography and horizontal gradients are
small.
The water table is present in the surficial sand deposits identified by the
cone penetrometer testing program. These sand deposits may be hydraulically
connected to the refuse in the landfill. However, the inward gradients
produced by the LCS may be limiting outward migration of contaminants from the
refuse into the adjacent sands. This is supported by the lack of
contamination in the surrounding monitoring wells screened within these sand
units. It is possible that these sands are actually contributing groundwater
into the site which is ultimately removed by the LCS. The volume of
groundwater flowing into the landfill from these sand deposits depends on the
transmissivity of the sands (rate at which groundwater can move) and the head
differential between the groundwater in the sand units and the leachate within
the LCS.
Potentiometric Surface - The head within the lower sand deposits is at an
elevation of approximately 680 feet MSL. The sand deposits indicate a small
horizontal gradient of approximately 0.0007 ft/ft to the northeast. The flow
direction within the lower sand deposits is parallel to the southwest to
northeast trending bedrock valley (dolomite) which lies directly beneath the
site at a depth of approximately 185 feet from ground surface.
Vertical Gradients - Vertical groundwater gradients were measured at eight
locations throughout the site. The gradients on the west side of the site
(MW110/P102) were generally low and fluctuating between positive and negative.
This is indicative of areas where horizontal flow is dominant. Downward
gradients did exist on the east side of the site (nest MW111/P103) and were
greater than the horizontal gradients, indicating some potential for downward
flow of groundwater in this area. The shallow well nests on the south side of
the site were located close to the LCS/SCW (P105A/P105B, P106A/P106B, and
TW22/P104). The vertical gradients in these nests were small and fluctuating.
The fluctuations were likely caused by the large head changes within the LCS
due to leachate withdrawal. The vertical gradients in well nest P106B/P106C
were extremely small and fluctuating, indicating primarily horizontal flow at
this location. The upward gradients identified in well nest P105B/P105C.
- 11 -
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located along the LCS/SCW, enhance the performance of the slurry cutoff wall
by reducing the potential for movement of groundwater beneath the base of the
wall.
Hydraulic Conductivity - Hydraulic conductivity tests were performed on all
new well Installations during the RI (Warzyn, July 1993). The data were
analyzed using the AQTESOLV aquifer test - software (Duffield and Rumbaugh,
1989). The Cooper, Bredehoeft, and Papadopulos method was used to evaluate
data for those wells under confined conditions (i.e., piezometers) and the
Cooper, Jacobs method was used to evaluate data for unconfined conditions
(i.e., water table wells).
The hydraulic conductivities for the groundwater monitoring wells ranged from
1x10 cm/s to 4.1xlO"6 cm/s. Most wells were installed in sand, so the
hydraulic conductivity test results are not representative of most of the
soils at the site (i.e., clay till). Most of the piezometers had hydraulic
conductivities of approximately IxlO"3 cm/s, because they were screened in
sand seams or sand layers beneath the site. Most of the water table
observation wells exhibited lower hydraulic conductivities, because the
screened intervals often encountered tighter materials such as silty clays.
The water table observation wells were usually screened across both thin sands
and silty clay tills. This was necessary due to the predominance of clay
tills across the site. *
E. Contaminant Summary
The locations of monitoring wells, private wells and leachate/gas wells at the
site are shown on Figure 3 (Drawing 1537101-B22)
Organic Compound Groups- Organic compounds were grouped together, where
possible, to aid in the evaluation of contaminant distribution. Compounds
were grouped based on similar chemical characteristics. In addition, there
were certain organic compounds associated with degradation sequences
(i.e., the formation of breakdown products from the parent compound), which
were grouped separately, such as the chlorinated ethanes and ethenes. The
specific organic compound groups are set forth below.
Volatiles
• Ketones - Compounds found in resins, paint removers, cement adhesives,
and cleaning fluids (e.g., acetone, 2-butanone, 2-hexanone,
4-methyl-2-pentanone, isophorone).
• Benzene. Ethyl benzene. Toluene. Xvlene (BETX) Compounds - Partially
water-soluble products from gasoline, oil. and other hydrocarbon
products.
• Chlorinated Ethenes - Chlorinated ethenes, including tetrachloroethene
(PCE), trichloroethene (TCE), dichloroethene (DCE), and vinyl chloride.
These compounds are common industrial compounds, and represent a
potential degradation sequence.
- 12 -
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Chlorinated Ethanes - Chlorinated ethanes, including
1.1,2,2-tetrachloroethane, 1,1,2-trichloroethane, 1,1,1-trichloroethane,
1.2-dichloroethane. 1.1-dichloroethane. and chloroethane. These
compounds are common industrial solvents and represent a potential
degradation sequence.
Semivolatlies
• Phenols - A group of chemicals of similar composition used in adhesives.
epoxies, plastics, and a variety of synthetic fibers and dyes.
Compounds in the group include chlorinated, methylated, and nitrified
phenols. Benzoic acid, a carbolic acid, is also included with the
phenols because it may be a degradation product of these compounds.
• Chlorinated Benzenes - Used as solvents and reagents in a variety of
chemical manufacturing processes and materials, including certain
pesticides (e.g., DDT). Compounds in this group include chlorobenzene,
hexachlorobenzene, 1,3-dichlorobenzene, 1,4-dichlorobenzene,
1,2-dichlorobenzene, and 1,2,4-trichlorobenzene.
• Polvcvclic Aromatic Hydrocarbons (PAHs) - A group of compounds
associated with, and derived from, coal and oil (e.g., naphthalene,
pyrene, etc.). They are*also by-products of the incomplete combustion
of carbonaceous materials.
• Phthalates - Compounds associated with plastics and plastic-making
processes.
Pesticides/PCBs
• Polvchlorinated Biphenyls (PCBs) - Mixtures of chlorinated biphenyls
identified as Aroclors, formerly used extensively in industrial
applications.
• Pesticides - A group of chlorinated compounds used for insect control
(e.g., Aldrin, Endrin, etc.). The use of these pesticides have for the
most part been discontinued.
Leachate Sample Results - Leachate samples were collected during the RI from
the following locations: LHG101 to LHG107, TW10A, TW14, TW15R, TW18. TW20R,
TW21R, and manhole MH03. Dense non-aqueous phase liquids were not found in
any of the leachate samples.
Total BETX was the most frequently detected organic .group in leachate samples,
from both Round 1 (November/December 1991) and Round 2 (March/April 1992)
samples. BETX compounds were detected in 13 of 14 Round 1 samples and in each
of the 14 Round 2 samples. Total BETX concentrations in the leachate samples
ranged from 5 ug/L (TW10A) to 45,000 ug/L (LHG103).
Total chlorinated benzenes were the second most frequently detected organic
compound in leachate. This group was detected in 10 of 14 Round 1 samples and
- 13 -
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11 of 14 Round 2 samples. Total chlorinated benzene concentrations ranged
from 2 ug/L (TW14, TW15R) to 68 ug/L (LHG104).
Total phenols and PAHs were both detected more frequently during Round 2 than
Round 1. Total phenols were detected in 4 of 14 Round 1 samples, compared to
10 of 14 Round 2 samples. Total phenol concentrations ranged from 3 ug/L
(MH03) to 499 ug/L (LHG105). Total PAHs were detected in 4 of 14 Round 1
samples, compared to 13 of 14 Round 2 samples: the concentration range for the
total PAHs was from 2 ug/L (TVI21R) to 554 ug/L (LHG106).
The remaining organic compound groupings detected in leachate during the RI
include:
• Chlorinated ethenes - detected in 3 of 14 Round 1 samples and 2 of 14
Round 2 samples, at concentrations ranging from
13 ug/L (MH03) to 182 ug/L (LHG103).
• Chlorinated ethanes - detected in 8 of 14 Round 1 and Round 2 samples,
at concentrations ranging from 7 ug/L (TW10A) to
5,730 ug/L (LHG107).
• Total ketones - detected in 4 of 14 Round 1 samples and 2 of 14 Round
2 samples, at concentrations ranging from 13 ug/L
(TW14) to 2,820 ug/L (LHG103).
Pesticides and PCBs were not detected in leachate.
Compounds not included in the organic groupings, yet detected in leachate
during the RI include:
• Tetrahydrofuran (THF)- detected in 9 out of 14 Round 2 samples ranging
from 50 ug/L (MHOS) to 370 ug/L (LHG106).
• Styrene - detected in one out of 14 Round 1 samples at 3 ug/L
(LHG102).
• Methylene chloride - detected in one out of 14 Round 2 samples at
88 ug/L (LHG103).
• Nitrobenzene - detected in one out of 14 Round 1 samples at 130 ug/L
(LHG105).
• N-nitrosodiphenylamine - detected in 3 of 14 Round 1 samples and 7
of 14 Round 2 samples ranging from 1 ug/L
(LHG104) to 32 ug/L (LHG105).
• Carbazole - detected in 1 of 14 Round 1 samples and 5 of 14 Round 2
samples ranging from 2 ug/L (MH03) to 32 ug/L (LHG104).
• Dibenzofuran - detected in 3 out of 14 Round 2 samples ranging from
1 ug/L (TW15R) to 4 ug/L (LHG107).
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Groundwater Monitoring Well Sample Results • This section discusses the
analytical results obtained from wells sampled during the RI and not discussed
in the previous section. Included in this discussion are wells installed bom
inside and outside the leachate collection system/slurry cut-off wall
(LCS/SCW). A distinction between these two types of wells has been made,
based on chemistry, and the results are discussed (and presented in the
tables) to reflect this distinction.
Monitoring well locations are shown on Figure 3 (Drawing 1537101-B22). Based
on groundwater flow direction at the site, four monitoring wells have been
selected for background (upgradient) purposes as used within the baseline risk
assessment:
• MW109 • P102
• MW110 • TW7
The following wells are located just inside the SCW:
• TW10B •MW113
• TW23 •PIOSA
• TW25 •P106A
The remaining monitoring wel?s are potentially downgradient or side gradient
to the area containing refuse, or isolated vertically from refuse by the
presence of clay till (piezometers)..
Groundwater Monitoring Wells Installed Outside of
Areas of Refuse Disposal that are
Considered Points of Standards Application
TW5R
TW6R
TW7
TW8
Wells screened or partially screened in saturated refuse or waste may be
classified as monitoring leachate. Wells screened in any other material are
classified as monitoring groundwater. Wells installed in borings going
through areas of waste disposal, regardless of what they monitor, be it
groundwater or leachate, are not points of groundwater standards application
at the site. Wells just inside the SCW that are not installed in borings
going through areas of waste disposal have now been determined to not be
points of standards application, given the role the LCS/SCW plays in the final
remedy.
The following wells are located within the waste management area:
Leachate Wells/Groundwater Monitoring Wells
- 15 -
TVJll
TW13
TW16
TW22
TW24
MW108
MW109
MW110
MW111
MW112
MW114
MW115
P101
P102
P103
P104
-------
Installed Inside Areas of Refuse Disposal that are Not
Considered Points of Standards Application
TW1R
TW2R
TW3R
TW9R
TW10A
TW10B
TW14
TW15R
TW18
TW19R
TW20R
TW21R
TW23
TW25
LHG101
LHHI02
LHG103
LHG104
LHG105
LHG106
LHG107
MW113
P105A
P105B
P105C
P106A
P106B
P106C
Results obtained from groundwater monitoring wells located outside the waste
management area were evaluated with regard to existing State groundwater
quality standards. To aid in the evaluation of groundwater constituent
concentrations, Table 1 provides a summary of Rounds 1
(November/December 1991), 2 (March/April 1992), 3 (May 1992), and 4
(November/December 1992) sampling results compared to ch. NR 140 Wis. Adm.
Code Preventive Action Limits (PAL) and Enforcement Standards (ES).
Dense non-aqueous phase liquids were not found in any of the monitoring wells
and are likely not present at this site.
The following discussion describes the nature and extent of organic groups •
detected in wells located both inside and outside the SCW. Three rounds of
samples were collected from each well with the exception of wells P105A,
P105B, P105C, P106A, P106B, and P106C, which were sampled during Round 2,
only, and wells MW114 and MW115, which were sampled only twice during the
investigative phase of the RI. A summary of total organics found in
monitoring wells for the 3 RI monitoring rounds is presented on Figure 5,
U.S. EPA target compound list (TCL) organic constituents were not detected in
the background (upgradient) wells MW109, MW110. P102, and TW7 located west of
the refuse area, with the following exceptions:
• MW109 - THF was detected during Round 3 sampling at 6 ug/L.
• MW110 - Chloroethene was detected during Rounds 2 and 3 sampling at
concentrations of 2 ug/1 and 3 ug/L, respectively.
Organic compound groupings were not detected in the three rounds of samples
collected from the following well locations:
• MW108, TW3R, and P101 located to the north of the refuse fill area.
• TW8, TW11, and P104 located southwest of the refuse area.
• MW112 located east of the refuse area.
Organic group constituents also were not detected in the single round of
- 16 -
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samples collected from the P105B, P105C, P106B, and P106C wells located south
of the refuse area.
The following well locations had organic group constituents detected in only
one of two or three sampling rounds:
• TW5R - 1,1-Dichloroethane was detected during Round 1 at a
concentration of 1 ug/L.
• TW6R - Benzene was detected during Round 1 at a concentration of 1
ug/L.
• TW13 - Acetone was detected during Round 1 at a concentration of 21
ug/L. Acetone is a common lab contaminant, detected at similar
concentrations in field blanks collected the day prior to this
sample.
• MW114 - Benzene was detected in Round 1 (Phase 4) at a concentration of
2 ug/L. Carbon disulfide, ethyl benzene, and styrene were
detected in Round 1 (Phase 4) at a concentration of 1 ug/L.
• MW115 - Di-n-butylphthalate was detected in Round 2 (Phase 4), at a
concentration t>f 9 ug/L. Since this compound was detected in
only one round and is a common laboratory or sampling
contaminant, it is likely that this result is not
representative of actual site conditions,
BETX was the most frequently detected and highest concentration organic group
in the samples. The highest BETX concentrations were detected in the samples
from:
• TW1R and TW2R located north of the refuse area and south of a railroad
right of way and auto salvage pond.
• MW113 located south of the refuse area, but inside the slurry wall, and
leachate collection system.
• P106A located south of the refuse area, outside the collection system, but
inside the slurry wall.
Chlorinated ethenes were detected only in samples collected from well MW113
(location described above). Chlorinated ethene concentrations at this
location ranged from 488 ug/L (Round 2) to 628 ug/L (Round 1).
Chlorinated ethanes were the second most frequently detected organic group.
Generally, this group was detected at the same well locations as the BETX
group, although the higher chlorinated ethane concentrations tended to be
located in the southern portions of the site. The highest total chlorinated
ethane concentration was at P106A (location described above).
The remaining organic groupings were less frequently detected and at generally
- 17 -
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lower concentrations than the three groups described above. The highest
concentrations for the total chlorinated benzenes, total phenols, and total
PAHs occurred in samples from well locations T\1R and Tw2R 1 oca-tec at the
north edge of the refuse area. As these compounds were also detected in the
landfill leachate, the likely source of contamination In these wells Is the
landfill.
Compounds not Included In organic groups, but which were detected at low
concentrations In samples, Include:
THF - detected In five Round 2 samples and eight Round
3 samples, Including the sample from background
well MW109.
Bis(2-chloroisopropyl)ether - detected In one Round 3 sample from well TW2R
at a concentration of 2 ug/L.
N-nitrosodiphenyl amirie - detected in each of the three rounds of samples
collected from well TW1R at concentrations
ranging from 1 to 3 ug/L. Detected in one
Round 3 sample from well TW2R at a concentration
of 2 ug/L. Detected in a field blank sample
'during Round 2 at a concentration of 3 ug/L.
Styrene - detected In one Round 2 (Phase 4) sample (MW114).
Pesticides/PCBs were not detected In samples collected from this site.
Samples were also analyzed for U.S. EPA target analyte list (TAD metals and
cyanide, and general groundwater quality indicators.
Calcium, magnesium, sodium, bicarbonate, chloride, and sulfate are typical
major constituents common to naturally occurring groundwater. Concentrations
of these constituents in groundwater are primarily a function of the
composition, hydrology, chemistry of the aquifer, and the source of
groundwater recharge.
Iron, potassium, fluoride, and nitrate are typically minor constituents In
naturally occurring groundwater (Davis and DeWiest. 1966 and Table 20 of the
RI). The concentration of these constituents In groundwater may be indirectly
affected by wastes (e.g., oxygen deficient conditions), or attributable to
direct migration from the wastes. Variability In the geologic composition of
the aquifer matrix, and the source of groundwater recharge may also influence
concentrations of these constituents in groundwater samples.
Aluminum, antimony, arsenic, barium, beryllium, cadmium, chromium, cobalt,
copper, lead, manganese, mercury, nickel, phosphate, selenium, silver.
thallium, vanadium, and zinc are considered trace constituents in naturally
occurring groundwater (Davis and DeWiest, 1966 and Table 20 of the RI).
Concentrations of these constituents may or may not be directly related to the
wastes. Natural and contaminant-related variations in pH. redox potential.
- 18 -
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competing Ions, etc., in groundwater may enhance the solubility of some of
these metals in the aquifer, resulting in higher concentrations not
necessarily originating from the waste.
Fifteen of the trace element constituents were detected in one or more
sample(s) at levels higher than those detected in background wells MW109,
MW110. P102. or TW7. The fifteen constituents are as follows:
• Antimony • Cobalt • Nickel
• Arsenic '• • Copper • Selenium
• Barium • Lead • Silver
• Cadmium • Manganese • Vanadium
• Chromium • Mercury • Zinc
Private Well Sample Results - This section discusses the analytical results
from sampling private wells PW1, PW2, PW4, PW5, PW6, PW7, PW8, PW9, and PW10
during the RI. The locations are shown on Figure 3 (Drawing 1537101-B22).
The following organic constituents were detected in samples collected from
private wells:
• Ethyl benzene - detected at 1 ug/L in private well PW7 during Round 1.
• Phenol - detected St 0.6 ug/L in private well PW8, and at 0.5 ug/L
in private well PW9 during Round 1.
Pesticides and PCBs were not detected in the private well samples.
Four naturally occurring groundwater constituents exceed State NR 140
groundwater standards in the private well samples (See Table 1). Each of
these constituents were also detected in one or more background well samples
at concentrations exceeding State groundwater standards. In summary, these
constituents were found to exceed NR 140 standards:
• Arsenic - exceeds the NR 140 Public Health PAL (5 ug/L) in each
private well sample. Concentrations ranged from 5.5 to 8.2
ug/L in private well samples. This constituent was also
detected in samples from background wells MW110 (6.1 ug/L)
and P102 (7.5 ug/L).
• Fluoride - is at or just exceeds the NR 140 Public Health PAL
(0.8 mg/L) in 2 private well samples. This parameter also
was detected in samples from background wells P102 and TW7.
• Iron - exceeds the NR 140 Public Welfare ES (0.3 mg/L) in each
private well sampled with the exception of private well PW9
(Round 2). This constituent also exceeded the ES in the
sample from background well MW110.
- 19 -
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Manganese - exceeds the NR 140 Public Welfare PAL (0.025 mg/L) i
samples from private well PW6 and private well PW9.
^opc;i~~>t"'jppi~ p;iso fixcoodr>d th^ ^^' ~in sam^l^^ f^om h,^
wel'ls MW109 and MWllO^
in
This
The available private well logs near the site (Appendix A of the RI) indicate
that the private wells are cased in bedrock at depths of greater than 180 ft.
Due to the thickness of clay till between the landfill and bedrock, and the
limited extent of landfill related contamination, as documented by vertical
profiling, it is very unlikely that the landfill could impact the private
wells. Inorganic exceedances in the private wells have all appeared in the
site background wells.
Surface Water Sample Results • Ten surface water samples were collected during
the RI from locations along the drainage ways, the pond located on the site,
and the pond north of the site. Samples collected from locations SW01 and
SW02 are considered representative of background conditions. The following
organic compounds were detected in surface water samples:
• Chloroethane - detected at 2 ug/1 in SW04, 15 ug/L and 7 ug/L in
SW05 (Rounds 1 and 2, respectively).
• 1,2-Dichloroethene - detected at 2 ug/L at SW05.
• 1,1-Dichloroethane - detected at 0.7 ug/L at SW05.
• Toluene - • detected at 2 ug/L at SW07.
• Phenanthrene, Fluoranthene, and Pyrene - detected at SW06 during Rounds 1
and 2 at concentrations ranging
from 0.6 ug/L to 1 ug/L.
Pesticides and PCBs were not detected in the surface water samples.
The following nine metals were detected in one or more surface water samples
at concentrations slightly higher than background surface water results (SW01
and SW02):
• Aluminum • Zinc • Manganese
• Chromium • Barium • Potassium
• Lead • Iron • Sodium
Surface water background exceedances were presented in Table 24 in the RI
(Warzyn, July 1993). Generally, the higher metal concentrations were in
samples from SW03, located southeast of the site, and SW04, SW05, and SW08,
located west of the site.
Sediment Sample Results • Sediment samples were collected from ten locations
at the site during the RI. Samples collected from locations SD01 and SD02 are
considered representative of background.
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PAHs were detected in each sediment sample, including background, with the
exception of SD07 and SD08. Total PAH concentrations "in the sediment samples
were as follows:
Sample
Location
SD01
SD02
SD03
SD04
SD05
SD06
SD09
SD10
Total
PAH (uq/Kg)
936
2,960
25,530
98
395
683
20,550
49
PAHs found in sediment samples may be due to nonpoint contaminant sources in
the area. In addition to the PAHs, the following organic compounds were
detected in sediment samples:
• Acetone and 4-methyl phenol -
Dibenzofuran and Carbazole -
Methoxychlor and Endrin-ketone -
detected in samples from SD06 at
concentrations of 110 ug/Kg and 77
ug/Kg, respectively (acetone is a
common laboratory contaminant).
detected in samples from SD03 at
concentrations of 100 ug/Kg and 330
ug/Kg, respectively.
detected in samples from SD03 at
concentrations of 6.1 and 3.9 ug/Kg,
respectively.
Aroclor 1254 - detected at SD06 at a concentration of 90 ug/Kg.
Endrin, 4,4-DDE, and 4,4-DDT -
detected at SD10 at concentrations
from 1.6 to 4.2 ug/Kg.
Generally, metals concentrations at sediment locations SD04, SD05, SD09, and
SD10 tended to be slightly higher than, background locations SD01 and SD02.
Surface Soil Sample Results - Surface soil samples were collected from seven
locations at the site during the RI. Sample locations SS101 and SS102 were
collected to represent background conditions. PAHs'were detected in each of
the surface soil samples collected. The following is a summary of total PAH
results:
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Sample Total
Location PAH (tig/Kg)
SS101 339
SS102 4,613
SS103 235
SS104 1,291
SS105 177
SS106 34,270
SS107 538
All of the surface soil samples, including samples from background locations.
contained pesticide DDT residues (refer to Appendix M of the RI for individual
sample results). Organic compounds detected in surface soil samples other
than background include: xylenes, bis(2-ethyl hexyl)phthalate, Aroclor 1260
(SS104 at 20 ug/Kg; SS107 at 17 ug/Kg), and Aroclor 1254 (SS106 at 160 ug/Kg).
PAHs found in surface soil may be due to anthropogenic sources unrelated to
site activity. Ubiquitous anthropogenic background sources of PAHs include
residues from the incomplete combustion of coal, oil, refuse, diesel fuel, and
tars. A possible source of these residues is the heavy truck traffic on and
around the site.
Metals concentrations in the surface soil samples were similar to background
samples SS101 and SS102.
V. SUMMARY OF SITE RISKS
A quantitative risk assessment was completed for the site. The purpose of the
assessment was to identify human health hazards posed by environmental
contamination from the site. The quantitative risk assessment evaluates
current as well as future potential exposures to site related contamination.
Sample results from the remedial investigation were used to evaluate all
environmental pathways with potential human exposure routes.
The RI included an evaluation of risks at the site to human health and the
environment if no remedial actions were taken. This process is called a
Baseline Risk Assessment (Risk Assessment). The Risk Assessment involves
assessing the toxicity, or degree of hazard, posed by substances related to
the site, and describing the routes by which these substances could come into
contact with humans and the environment. Separate calculations are made for
those substances that can cause cancer (carcinogenic) and for those that can
cause other, non-carcinogenic health effects. The results are also used to
identify the nature and extent of remediation required.
Selection of Chemicals of Potential Concern • The baseline risk assessment was
based on data and information regarding the site and surrounding area obtained
primarily during the RI and during a site visit. Using this information, the
first step of the assessment was to select chemicals of potential concern for
detailed evaluation. This was conducted by summarizing and evaluating the RI
data, including a consideration of naturally occurring background levels in
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soil and groundwater and the presence of chemicals in blank samples. Based on
these evaluations, 69 chemicals of potential concern were selected for
detailed assessment. ^^95^ chemicals Include t'°cse most V'kelv to be of
concern to human health and the environment.
For each chemical of potential concern, toxicity information was then
compiled. This included brief descriptions of the potential toxicity of each
chemical to human health and quantitative toxicity criteria used to calculate
risks. The toxicity criteria were primarily obtained from U.S. EPA's
Integrated Risk Information System (IRIS) and Health Effects Assessment
Summary Tables (HEASTs).
Exposure Assessment - An exposure assessment was conducted to identify
potential pathways of concern to human health under both current and future
site and surrounding land use conditions. The following pathways were
selected for detailed evaluation under current land use conditions:
• Incidental ingestion of surface soil by child/teenager trespassers on the
site
• Dermal absorption of chemicals in surface soil by child/teenager
trespassers on the site
t
•• Incidental ingestion of surface water by child/teenager trespassers on the
site
• Dermal absorption of chemicals in surface water by child/teenager
trespassers on the site
• Incidental ingestion of sediment by child/teenager trespassers on the site
• Dermal absorption of chemicals in sediment by child/teenager trespassers
on the site
• Ingestion of groundwater by nearby residents
• Inhalation of volatile organic compounds (VOCs) while showering by nearby
residents
Under future use conditions, the following hypothetical pathways were selected
for evaluation:
• Incidental ingestion of surface soil by child residents on the site
• Dermal absorption of chemicals in surface soil by child residents on the
site
• Incidental ingestion of surface soil by adult residents on the site
• Dermal absorption of chemicals in surface soil by adult residents on the
site
- 23 -
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• Incidental ingestion of surface water by child/teenager residents on the
site
• Dermal absorption of chemicals in surface water by child/teenager
residents on the site
• Incidental ingestion of sediment by child/teenager residents on the site
• Dermal absorption of chemicals in sediment by child/teenager residents on
the site
• Ingestion of groundwater by on-site residents
• Inhalation of VOCs while showering by on-site residents
Toxicity Assessment • Exposures to each of the above pathways were calculated.
In accordance with U.S. EPA guidance, the baseline risk assessment examined a
reasonable maximum exposure (RME) associated with each pathway of concern.
RME risk estimates for future land use of a site, involving exposure pathways
that are typically more conservative than current land use pathways, can
provide an important basis for evaluating potential remediation of a site
(U.S. EPA, 1990). The National Contingency Plan (NCP) defines "reasonable
maximum" such that "only potential exposures that are likely to occur will be
included in the assessment of exposure" (U.S. EPA, 1990). U.S. EPA risk
assessment guidance further defines the RME to be "the highest exposure that
is reasonably expected to occur at a site" (U.S. EPA, 1989). The RME is
intended to place a conservative upper bound on the potential risks, meaning
that the risk estimate is unlikely to be underestimated but it may be over"
estimated.
Risk Characterization • Chemical concentrations at the potential points of
exposure (exposure point concentrations) were calculated and combined with
information on the magnitude, frequency, and duration of potential exposures.
The exposure point concentrations were based on the RI data where possible
following the approach recommended in U.S. EPA's Risk Assessment Guidance for
Superfund [the 95th upper confidence limit (UCL) on the arithmetic mean
concentration or the maximum, whichever was less]. A mathematical model was
used to estimate exposure point concentrations in indoor air while showering.
In the next step, exposure parameters were combined with the exposure point
concentrations. The exposure parameters were primarily based on values
specified by U.S. EPA in guidance documents. Where regional or national
U.S. EPA values were available for the RME case, they were used in this
assessment. In the absence of such values, exposure parameter information was
derived from the scientific literature.
Summary of Health Risks • Human Health Evaluation • Tables 2 and 3 present the
cumulative risks for those pathways that were considered to be appropriate for
summation in accordance with U.S. EPA guidance (U.S. EPA, 1989) for combining
risks across exposure pathways. The guidance states that one must "examine
whether it is likely that the same individuals would consistently face the RME
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by more than one pathway".
The cumulative upper bound lifetime cancer risk ard hazard index values
presented in Tables 2 and 3 can be put into context by considering U.S. EPA's
OSWER Directive 9355.0-30 (U.S. EPA, 1991b) as follows:
"Where the cumulative carcinogenic site risk to an individual based on
reasonable maximum exposure for current and future land use is less than 10"4.
and the noncarcinogenic hazard quotient is less than one, action generally is
not warranted unless there are adverse environmental impacts."
Results of the baseline risk assessment indicated that cumulative cancer risks
are less than IxlO"4 for all receptors except adult residents under
hypothetical future land use conditions. The cumulative risk of IxlO"4 for
this pathway is primarily due to potential contact with groundwater from
on-site northern perimeter monitoring wells. Cumulative hazard indices are
less than one for all receptors except under a hypothetical scenario of adult
residents ingesting groundwater from monitoring wells. These hazard indices
are primarily due to contact with groundwater from off-site southern and
on-site northern perimeter monitoring wells.
In the event that exposure to landfill waste were to occur, the primary
pathway for exposure would be dermal contact with the landfill waste itself.
No chemical analyses were conducted, on the waste material, therefore, it is
not possible to quantify potential risks under this hypothetical scenario. In
addition, the landfill waste is a non-homogeneous mixture, and therefore the
magnitude of exposure would vary considerably depending on the type of waste
contacted.
Risks from landfill gas were not evaluated in the baseline risk assessment
because these risks are difficult to quantify (relative to other media) and a
landfill gas extraction system is included as a component of all alternatives
other than the no action alternative.
Ecological Assessment • An ecological risk assessment was conducted to
evaluate potential impacts on nonhuman receptors associated with the site.
This evaluation involved the identification of potential receptors and
exposure pathways, including the determination of the presence of endangered
or threatened species in the area. Potential risks were evaluated by
comparison with chemical-specific toxicity criteria (toxicity reference values
or TRVs). Based on information obtained during the RI and a site visit.
exposure of terrestrial plants and soil organisms (earthworms) to chemicals of
potential concern in sediment and surface water were selected for detailed
evaluation. Exposure of birds and mammals to chemicals with potential to
bioaccumulate through the .food chain was also evaluated.
Adverse impacts to terrestrial plants are unlikely from the chemicals of
potential concern in soil. Although potential risks for 16 of the chemicals
could not be quantitatively evaluated because toxicity values were
unavailable, 15 of those chemicals were PAHs, which do not appear to be toxic
to plants. The available toxicity information for earthworms suggests that
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adverse effects from chemicals in soil are unlikely. However, all of the
chemicals could not be evaluated because toxicity values were not available.
Although there Is some potential for adverse impacts to sensitive aauatic
organisms from exposure to benzo(k)fluoranthene, oenzo(g.h,i)perylene. endrin,
fluoranthene, and indeno(l,2,3-c,d)pyrene in sediments, no significant impacts
are expected due to the uncertainty associated with the sediment toxicity
values and the estimate of organic carbon in the sediments. RME
concentrations of aluminum and iron in surface water, which consists of both
pond and ditch samples, exceeded their TRVs indicating potential risk to
sensitive aquatic organisms. However, aquatic organisms in the ponds would
not be affected because pond concentrations are at levels that are not
harmful. Sensitive aquatic organisms in the ditches, where concentrations are
higher, may be impacted from these chemicals, although the ephemeral nature of
the ditches might minimize the impacts. No significant impacts to birds and
mammals from chemicals that bioaccumulate are expected.
Media of Concern Determined in the Baseline Risk Assessment - Results of the
baseline risk assessment indicated that cumulative cancer risks are less than
IxlO"4 for all receptors except adult residents under hypothetical future land
use conditions. The cumulative risk of IxlO"4 for this pathway is primarily
due to potential contact with groundwater from the on-site northern perimeter
monitoring well grouping. Cumulative hazard indices are less than one for all
receptors except under a hypothetical scenario of adult residents ingesting
groundwater from monitoring wells. These hazard indices are primarily due to
contact with groundwater from the off-site southern and the on-site northern
perimeter monitoring well groupings.
As a result of the baseline risk assessment, several media were found to be of
concern under particular exposure conditions to human and/or ecological
populations. The following is a summary of the media which were estimated to
pose a health concern, as well as the nature of the exposure (e.g, ingestion
of groundwater) that poses a health concern:
• Groundwater - It was assumed currently and in the future that people
ingest contaminated groundwater from on-site or off-site monitoring
wells, or inhale contaminants released from using water, such as
showering, from on-site or off-site monitoring wells.
• Surface soils - It was assumed that in the future on-site residents
ingest or come into dermal contact with contaminated surface soils at
the site.
• Sediment - It was assumed that in the future on-site residents ingest
contaminated sediment.
• Surface water - It was assumed that currently and in the future
sensitive aquatic organisms may be impacted from chemicals detected in
surface water.
Groundwater is a medium of concern as a result of a baseline risk assessment
hazard index estimate greater than one. Surface soils, sediment, and surface
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water are potential media of concern Abased on a baseline risk assessment
cancer risk estimate greater than 10~6, but less than 10'4.
Rationale for Further Action - Actual or threatened releases of hazardous
substances from this site, If not addressed by the response action selected in
this ROD, may present an Imminent and substantial endangerment to public
health, welfare, or the environment.
VI. Description of the Remedial Alternatives
A. Remedial Action Objectives
Remedial action objectives were developed for this site to address the source
of contamination, groundwater contamination, to provide short and long-term
protection of human health and the environment and to meet applicable or
relevant and appropriate requirements.
The remedial action objective for surface soils is as follows:
• Reduce potential future exposure to contaminants by IngestIon and dermal
contact.
The remedial action objectives for landfill gas are as follows:
• Reduce off-site migration of landfill gas.
• Control the release of on-slte landfill gas to the atmosphere.
The remedial action objective for surface water Is as follows:
• Minimize the landfill's potential impact on surface water quality.
The remedial action objectives for groundwater include the following:
• Maintain leachate levels at the leachate head maintenance levels
established for the site.
• Maintain an inward groundwater gradient (head inside the landfill is
lower than the head in the adjacent area outside the landfill) at the
site.
• Reduce the concentration of contaminants that exceed NR 140 groundwater
quality standards at site wells outside the waste management area.
The purpose of the groundwater portion of the remedy is to return groundwater
at the site to its beneficial use, as an actual or potential groundwater
source, within a reasonable period of time. Contaminated groundwater will be
returned to its beneficial use when the concentrations of groundwater meet
groundwater cleanup standards: the groundwater preventive action limits (PALs)
found in NR 140, Wis. Adm. Code. These groundwater cleanup standards are
applicable requirements for the groundwater cleanup.
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The location of the point of compliance for the groundwater cleanup standards
is the edge of the waste management area. e.g.. the waste boundary for the
landfill and the outside edge of the existing SCW. Groundwater cleanup
standards shall be attained throughout the contaminated plume, excluding the
area underneath the landfilled waste. This area of attainment includes areas
outside the site property as well as the area within the site property up to
the waste boundary for landfilled waste.
B. Development of Alternatives
The FS identified groundwater and landfill gas as actual media of concern and
surface soils and surface water as potential media of concern to be addressed
by the developed remedial alternatives. An extensive list of possible
remedial technologies to address the media of concern were screened and
narrowed down based on cost, implementability and effectiveness. Alternatives
were then assembled from the technologies that survived the screening process.
In addition to the remedial action alternatives, the NCP requires that a no-
action alternative also be considered for the site. The no-action alternative
serves primarily as a point of comparison for the other alternatives.
C. Description of Alternatives
The following alternatives are based on the alternatives in the FS, as
modified by the Department iVi the Proposed Plan (PP) and in this Decision
Summary. The Department's modifications are described below.
1. Alternative 1 • No Action
The No Action alternative is included to serve as a baseline against which all
other alternatives are compared. This alternative consists of continued
monitoring of groundwater, maintaining the existing cover and partial fence,
and continued operation and maintenance of the southern leachate collection
and slurry cut-off wall.
There is no capital cost for this alternative and the annual operation and
maintenance (O&M) cost is estimated at $569,000. The total present worth cost
for this alternative is $7,061,000.
2. Alternative 2 • Landfill Cap Enhancement, Groundwater, Leachate and Gas
Extraction and Additional Investigations
This alternative consists of regrading the landfill cover to allow better
drainage of surface water away from the wastes, establishing new vegetation,
installing an active landfill gas extraction system to prevent gas migration,
repairing and repaving the existing paved and graveled areas, continuing
leachate extraction in the northern and southern portions of the site with a
new leachate extraction system in the north central portion of the site,
extracting contaminated groundwater at the southeast edge of the site (if
found to be necessary after an additional study), constructing a new fence (or
using existing fence, where possible), and continuous monitoring of
groundwater, leachate, and the environment. Leachate and groundwater removed
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from the landfill would be pumped directly to the Milwaukee Metropolitan
Sewerage District for treatment. It may also be possible to treat extracted
groundwater and discharge it to surface water. The active gas extraction
system would use slotted pipes buried in the waste to collect landfill gas
that would be sent to a flare or to a gas turbine, if feasible. The flare or
turbine would burn the gas, destroying the contaminants. Air emissions would
be monitored to make sure they meet standards. New groundwater monitoring
wells and other monitoring devices would be added to the site to replace
and/or supplement existing monitoring devices. Additional studies of the
groundwater quality and leachate head levels would be conducted to determine
if additional remedial actions are necessary.
Alternative 2 in the feasibility study assumed that leachate extraction in the
northern part of the site would only be done if a study showed it was
necessary. This action is now considered necessary, and this action has been
included* in Alternatives 2, 3, 4 and 4a. The action is necessary to minimize
the amount of leachate escaping through the base and sides of the site, as
there are downward gradients within the site, contamination has already
migrated away from the sides in some areas, and if this migration continues,
there continues to be the potential for additional surface and/or groundwater
contamination away from the edges of the site.
The capital cost for this action is estimated at $3,189,000. The annual O&M
cost is estimated at $565,000. The total present worth cost for this action
is $10,200,000.
3. Alternative 3 - Clay Cap, Groundwater, Leachate and Gas Extraction and
Additional Investigations (Selected Alternative)
This alternative consists of the same actions described for Alternative 2,
with the addition of a new soil cover system. This cover would be constructed
with useable soils from the site with some soils brought in from off site, if
necessary, as determined during the design. The cover would consist of, from
bottom to top: a 6 inch grading layer, 2 feet of compacted clay liner, 1.5
feet of frost protection/rooting zone and 6 inches of topsoil. The top slope
steepness would be determined during the design, based on site conditions and
rule requirements in effect at the time. Currently,, the requirement is for
the minimum top slope not to be less than 2%. The cover would be seeded to
establish new vegetation.
Alternative 3 in the Feasibility Study assumed that all of the clay needed for
the liner would be found on-site, but the proposed plan assumed that 20
percent of the volume of clay would be brought from off-site. The FS also
assumed the minimum top slope would be 2%. while the proposed plan assumed it
would be S%. For the purposes of the cost estimate in this document, no clay
is assumed to be brought from off site, and the minimum slope is assumed to be
2%: The reasons for these changes are outlined in the responsiveness summary.
attached. However, the final determination on the amount of soil needed from
off site and the minimum slope would be made during the design phase.
The capital cost for this alternative is estimated at $5,416,000. The annual
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O&M cost is estimated at $565,000. The total present worth cost for this
alternative is $12,427.000.
4. Alternative 4 - Composite Cap, Groundwater, Leachate and Gas Extraction
and Additional Investigations
This alternative consists of the same actions for Alternative 2, with the
addition of a new composite cover system. The cover would consist of, from
bottom to top: 2 feet of compacted clay, plastic geomembrane, 1 foot of sand
for a drainage layer, a felt-like filter fabric to prevent fine soils from
entering the drainage layer, 1.5 feet of frost protection/rooting zone and 6
inches of topsoil. The top slope would be set at a minimum of 2 percent. The
cover would be seeded for new vegetation.
A plastic geomembrane is a rubber-like sheet over the entire landfill that
water cannot penetrate. The geomembrane is an extra layer of protection over
the dense clay cover.
The capital cost for this alternative is estimated at $8,446,000. The annual
O&M cost is estimated at $546,000. The total present worth cost for this
alternative is $15,221,000.
5. Alternative 4A -Modified-Composite Cap, Groundwater, Leachate and Gas
Extraction and Additional Investigations
This alternative is the same as Alternative 4, with changes to the landfill
cover. The cover would consist of, from bottom to top: 1 foot of compacted
clay (instead of 2 feet as proposed in Alternative 4), plastic geomembrane; 1
foot drainage layer, filter fabric, 1.5 feet of frost protection/rooting zone
and 6 inches of topsoil. The top slope would be set at a minimum of 2
percent. The cover would be seeded to establish new vegetation.
This alternative is slightly different from Alternative 4A in the Feasibility
Study. It assumes that a different type and thickness of plastic geomembrane
would be used, the drainage layer and fabric would only be needed in areas
with steeper slopes, and no additional soil would need to be brought in for
the frost protection/rooting zone.
The capital cost for this alternative is estimated at $5,952,000. The annual
O&M cost is estimated at $546,000. The total present worth cost for this
alternative is $12,727,000.
VII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
A. Introduction
U.S. EPA has established in the NCP nine criteria that balance health,
technical, and cost considerations to determine the most appropriate remedial
alternative. The criteria are designed to select a remedy that will be
protective of human health and the environment, attain ARARs, utilize
permanent solutions and treatment technologies to the maximum extent
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practicable, and be cost effective. The relative performance of each of the
remedial alternatives listed above has been evaluated using the nine criteria
set forth in the NCR at 40 CFR 300.430(6)(9)(ii1} as the basis of comparison.
These nine criteria are summarized as follows:
THRESHOLD CRITERIA - The selected remedy must meet the threshold criteria.
1. Overall Protection of Human Health and the Environment
A remedy must provide adequate protection and describe how risks are
eliminated, reduced or controlled through treatment, engineering controls
or Institutional controls.
2. Compliance with Applicable or Relevant and Appropriate Requirements
(ARARs)
A remedy must meet all applicable or relevant and appropriate requirements
of federal/state laws. If not, a waiver may be applied.
PRIMARY BALANCING CRITERIA are used to compare the effectiveness of the
remedies.
3. Long-term Effectiveness and Permanence
Once clean up goals have been met, this refers to expected residual risk
and the ability of a remedy to maintain reliable protection of human
health and the environment over time.
4. Reduction of Toxlclty, Mobility or Volume Through Treatment
The purpose of this- criterion is to anticipate the performance of the
treatment technologies that may be employed.
5. Short-term Effectiveness
This refers to how fast a remedy achieves protection. Also, it weighs
potential adverse impacts on human health and the environment during the
construction and implementation period.
6. Implementability
This criterion requires consideration of the technical and administrative
feasibility of a remedy, including whether needed services and materials
are available.
7. Cost
Capital, operation and maintenance, and 30 year present worth costs are
addressed.
MODIFYING CRITERIA deal with support agency and community response to the
alternatives.
8. State or Federal Acceptance
After review of the Feasibility Study and the Proposed Plan, the support
agency's concurrence or objections are taken into consideration.
9. Community Acceptance
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This criterion summarizes the public's response to the alternative
remedies after the public comment period. The comments from the public
are addressed in the Responsiveness Summary attached to this document
B. Evaluation of the Remedial Alternatives
THRESHOLD CRITERIA - The selected remedy must meet the threshold criteria.
1. Overall Protection of Human Health and the Environment
Alternative 1 is not protective of human health and the environment. The
risks from contaminated soils and groundwater would not be addressed. The
potential impacts on aquatic organisms in surface water would not be
addressed. Because this alternative would not be protective of human health
and the environment, it can't be selected and will not be evaluated further.
Alternative 2 may or may not be protective of human health and the
environment, depending on how it would be implemented. Cover regrading would
have to assure that contaminated soils are well covered with clean soils.
Reducing risks in groundwater and surface water will depend on how
aggressively groundwater and leachate were extracted and the amount of water
that filters into the regraded cover. This alternative would allow the most
infiltration into the cover, which would make it harder for the leachate and
groundwater extraction systefhs to meet cleanup goals.
Alternatives 3, 4 and 4A are expected to be protective of human health and the
environment. These, alternatives would provide new cover systems that would
reduce the risks from contaminated soils and significantly reduce the amount
of water that filters into the site. The operation of leachate and
groundwater extraction systems, along with the reduction of water in the site,
is expected to meet groundwater and surface water quality goals and prevent
discharges to surface water. Alternatives 4 and 4A are likely more protective
than Alternative 3 because they allow less water to filter into the site.
Groundwater and surface water quality goals would likely be reached sooner
with Alternatives 4 or 4A. However, if Alternative 3 was implemented and
maintained so leachate was removed aggressively from the site, that may
provide a similar protectiveness to Alternatives 4 and 4A, as the additional
infiltration would expected to be collected as leachate before it could move
away from the site and cause additional groundwater and/or surface water
impacts.
2. Compliance with State Laws
Alternative 2 does not meet the s. NR 504.07, Wis. Adm. Code, landfill cover
requirements, which apply to the site because it is causing groundwater
contamination that exceed the ch. NR 140, Wis. Adm. Code, groundwater
standards. Because this alternative does not meet state requirements, it will
not be evaluated further.
Alternatives 3, 4 and 4A all comply with s. NR 504.07, Wis. Adm. Code,
landfill cover requirements.
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Chapter NR 140, Wis. Adm. Code, requires that groundwater must be cleaned up
to meet state standards in a reasonable amount of time, when it is technically
and economically feasible. Alternatives 3. 4 and 4A are expected to meet
these standards over time. Provided Alternative 3 is implemented and
maintained such that leachate is removed aggressively, it would be expected
that all 3 alternatives would meet the standards in a similar time frame.
Section NR 506.08(6), Wis. Adm. Code, requires the control of landfill gas
emissions at landfill sites that accepted more than 500,000 cubic yards of
waste and contain municipal refuse. The active landfill gas extraction and
flaring system are expected to meet this requirement for Alternatives 3, 4 and
4A.
PRIMARY BALANCING CRITERIA - Alternatives which satisfy the two threshold
criteria are then evaluated according to the five primary balancing criteria.
3. Long-term Effectiveness and Permanence
Provided Alternative 3 is implemented and maintained such that leachate is
removed aggressively after standards are met initially, it would be expected
that all 3 alternatives would have similar effectiveness in the long term in
reducing the amount of leachate that escapes from the site and the
corresponding surface and groundwater impacts.
v_ui i cropui luiuy oui la^c anu yiuui ivjwa ut;i i ui|juv* uo .
Alternative 4 is a bit more reliable than 4A in the long-term because it uses
a thicker clay layer under the plastic geomembrane and has a drainage layer
over the entire capped area.
Alternative 4A may not be a reliable design in the long-term due to the lack
of a drainage layer over all portions of the cover. Areas without a drainage
layer may be subject to water ponding on the membrane and slope stability
problems. If the membrane was damaged during the construction of the frost
protection zone due to the lack of a drainage layer to protect it, then the
membrane would allow additional infiltration into the site over time.
Alternatives 4 and 4A would be more difficult to maintain in the long-term if
settlement causes tears in the plastic geomembrane layer. Landfills of this
age normally are not subject to significant settlement. However, the leachate
and gas removal activities that are part of Alternatives 2, 3, 4 and 4A could
cause significant settlement of the waste.
4. Reduction of Toxicity, Mobility or Volume through Treatment
Alternatives 3, 4 and 4A all include leachate and gas extraction and treatment
through the same means. They all include treatment of leachate at the sewage
treatment plant and burn landfill gasses in a flare system, eliminating toxic
emissions. Alternatives 3, 4 and 4A will reduce the movement of leachate to
groundwater and surface water at a similar rate, provided alternative 3 is
implemented and maintained with aggressive leachate extraction.
5. Short-term Effectiveness
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Alternatives 3. 4 and 4A would be effective to quickly reduce any possible
exposure to landfill gasses.
Alternatives 3, 4 and 4A have similar construction time periods and
construction impacts. Alternatives 3 and 4 require a greater volume of soil
for construction of their final cover systems. If this soil is not available
from on-site sources, these alternatives require more soil be hauled to the
site from off-site sources than Alternative 4A. They will have greater
impacts from truck traffic and the operation of heavy soil moving equipment.
Provided Alternative 3 is implemented and maintained with aggressive leachate
extraction, all the alternatives would take a similar amount of time to meet
cleanup objectives.
6. Ease of Implementation
Alternatives 4 and 4A would be slightly more difficult to implement than
Alternative 3 because they involve using plastic liners, which require more
careful construction quality control.
The lack of a drainage layer over all portions of the cover may result in
problems with punctures or tears of the plastic geomembrane if the quality of
the rooting/frost protection zone is not controlled properly.
Alternative 4 would take slightly more effort to implement than alternative 4A
because more clay and drainage layer sand would be placed.
Alternatives 3 and 4 would require a greater volume of soil from off-site
sources, so they would require slightly more effort than alternative 4A.
7. Cost
The costs for the alternatives are presented with each alternative.
Alternative 4 is the most expensive alternative.
Alternatives 3 and 4A have very similar present worth costs.
8. Agency Acceptance
The Department prepared this decision document and selected Alternative 3 for
the site. The Environmental Protection Agency, the federal agency that
administers the Superfund program, agrees with this recommendation. Their
letter concurring with the selected action is attached to this document
9. Community Acceptance
There was public support expressed for alternative 3 and no public support
expressed for alternative 4A. All comments received by the Department,
including those expressed verbally at the public meeting, were in opposition
to the selection of alternative 4A and favored the selection of alternative 3.
The comments and the Department's responses to them are provided in the
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responsiveness summary, attached.
VIII. THE SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, as amended by SARA,
and the NCR, the detailed analysis of the alternatives and public comments,
the Wisconsin Department of Natural Resources, (in consultation with U.S.
EPA), believes that Alternative 3, the selected remedy, will be the most
appropriate remedy for this site. The selected remedy for the site includes
the following:
1. Construction of a new landfill soil cover system meeting state solid waste
requirements as outlined in ss. NR 504.07 and 506.08. Wis. Adm. Code. The
cover shall consist of, from bottom to top: a minimum 6 inch grading layer, 2
feet of compacted clay soil liner, 1.5 feet of frost protection/rooting zone
soil and 6 inches of topsoil. The top slope steepness shall be determined
during the design, based on site conditions and rule requirements in effect at
the time. Currently, the requirement in s. NR 506.08(3)(c), Wis. Adm. Code,
is for the minimum top slope not to be less than 2%. The cover shall be
seeded to establish new vegetation.
Design, investigations meeting the intent of the requirements of s. NR 512.18,
Wis. Adm. Code, will examine the quality of clay available on the site and the
volume of soil potentially needed from off-site to construct the cover system.
Due to site conditions, a site specific protocol for the on-site soils
investigation that does not meet the exact requirements of s. NR 512.18, Wis.
Adm. Code, may need to be established. It may be determined during the design
that a composite (soil and plastic membrane) design may be more economical to
construct. Should that be the case, the design described in Alternative 4'
shall be required, because the design in Alternative 4A would have reliability
problems, as described above. The decision to change the design of the cover
system to the composite design described in alternative 4 shall be documented
with a revision to this decision.
The existing paved and graveled areas currently used by the waste hauling
business on the eastern portion of the site shall be repaired and/or repaved
and maintained to prevent contact with the waste and minimize infiltration.
The exact extent of these areas will be determined during the design. If any
of these areas ceased to be used by the hauling business, the new cover system
will be constructed over them in the future.
2. Installation of leachate control measures (vertical dual extraction wells
or a horizontal collection trench or trenches) in the northeast area of the
site. These measures and the existing leachate collection system adjacent to
the slurry cut-off wall will be connected to a new leachate forcemain
(pressure pipe) to convey the leachate to the sanitary sewer system (Milwaukee
Metropolitan Sewerage District system). The leachate may be discharged
directly to the sewer system or it could be pretreated at the Omega Hills
leachate pretreatment system. It may also be possible to treat extracted
groundwater and discharge it to surface water, if it is found that discharge
to the sanitary sewer is not available.
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Initial leachate head level goals within the site will be set at "dry base".
as defined by the most current Solid Waste Program rules and guidance. WMWI
may propose and implement a detailed monitoring and evaluation program during
remedial design to evaluate whether or not it is feasible to achieve the "dry
base" initiaTleachate head level goal. If the Department determines that it
is not feasible to achieve "dry base" conditions, then an alternative head
level goal of maintaining an inward gradient will replace the initial leachate
head level goal. A revision to this decision is not required to revise the
leachate head level goals.
3. Installation of an active landfill gas extraction system to prevent gas
migration. This system will consist of vertical and/or horizontal extraction
pipes, tied to a vacuum extraction system that should efficiently extract gas
from the depths of the waste. Extracted gas would be flared or used to
generate electricity. Air emissions will be monitored to make sure they
remain in compliance with air emission standards.
4. Institutional controls shall be put in place, including land use/deed
restrictions. These shall be designed to prevent unauthorized excavation,
groundwater use or installation of water supply wells on the site.
5. Existing access controls shall be evaluated during the design and
roved/replaced where necessary. Existing and new fencing is expected to be
d. Temporary fencing may*be used during the construction of the final
edy.
remedy
6. A groundwater quality evaluation and potential contaminant source removal
in the area of monitoring well TW24. The evaluation shall consist of
monitoring groundwater quality in the area of that well, through the
installation of additional monitoring wells and additional investigations to
determine the potential sources of the contamination, such as test pits and
soil borings. Any waste contaminant sources that are located shall be removed
by excavation as soon as possible. This monitoring and potential source
removal shall begin during the design phase. Groundwater quality shall be
monitored for 3 years after the completion of the investigation of any
potential sources of contamination and the removal of any such sources.
Unless the results of the evaluation and potential source removal, to be
reported at the end of the 3-year evaluation period, show a significant
improvement in groundwater quality in that area, showing a trend towards
meeting ch. NR 140, Wis. Adm. Code, PALs within a reasonable amount of time
(as determined by applying the criteria listed in s. NR 722.07(4)(a)4, Wis.
Adm. Code), groundwater extraction measures utilizing extraction trenches or
wells or other suitable technology shall be implemented in that area at the
end of the 3-year period to achieve ch. NR 140, Wis. Adm. Code, PALs within a
reasonable amount of time (as determined by applying the criteria listed in s.
NR 722.07(4)(a)4, Wis. Adm. Code). A revision to this decision is not
required to implement these additional groundwater extraction measures.
7. To address contamination found along the north, east and west sides of the
site, the selected remedy includes a gradient and water quality evaluation,
starting after the remedy is implemented, and completed and reported on during
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the first 5-year review pursuant to CERCLA requirements. The monitoring in
this evaluation shall Include groundwater and surface water contaminant
concentrations. Unless the results of the evaluation show the following, a
slurry wall or sealable sheet piles (full or partial), leachate extraction
measures, or other suitable technology shall be added to help achieve inward
gradients and reduce groundwater flow Into the site. These shall be located
In areas where groundwater Inflow results In difficulty in maintaining
required gradients in the site. These additional measures shall be taken
after the evaluation period unless:
a. A significant improvement in groundwater quality on the north and
east sides of the site and surface water quality on the west side
of the site is found, and groundwater quality results show a trend
towards meeting ch. NR 140, Wis. Adm. Code, PALs within a
reasonable amount of time (as determined by applying the criteria
listed in s. NR 722.07(4)(a)4, Wis. Adm. Code) in groundwater; and
b. Inward gradients are observed throughout the site and the leachate
head levels within the site are at, or expected to reach in a
short amount of time, the leachate head level goals ("dry base")
outlined above.
If a slurry wall or sealable*sheet piles (full or partial), leachate
extraction measures, or other suitable technology are constructed in
accordance with the above, then a north and east side groundwater water
quality evaluation will be conducted after the measures are constructed. The
evaluation shall consist of a 3-year period of monitoring groundwater quality
in areas outside the waste management area to the north and east of the site.
If possible, this evaluation could be timed to be completed at the same time
the second 5-year review is completed. Unless the results of the evaluation
show a significant improvement in groundwater quality outside of the waste
management area on the north and east sides of the site, showing a trend
towards meeting ch. NR 140, Wis. Adm. Code, PALs within a reasonable amount of
time (as determined by applying the criteria listed in s. NR 722.07(4)(a)4,
Wis. Adm. Code), additional groundwater extraction measures utilizing
extraction trenches, wells or other suitable technology shall be implemented
outside of the waste management area to achieve ch. NR 140, Wis. Adm. Code,
PALs within a reasonable amount of time (as determined by applying the
criteria listed in s. NR 722.07(4)(a)4, Wis. Adm. Code). A revision to this
decision is not required to implement any of the additional future remedial
measures described in this point.
8. Long-term environmental monitoring shall initially consist of the
following, with a detailed proposal developed during the remedial design:
a. Semi-annual visual inspection of the cap to identify for repair
any erosion, differential settlement, or leachate seepage. Cap
visual inspections are expected to be more frequent (monthly
during the first year and quarterly during the second year) during
the first two growing seasons after cap completion, and semi -
annually after that.
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b. Semi-annual visual Inspection of paved surfaces on the landfill to
Identify any cracks or damaged areas which require repair.
c. Quarterly monitoring at up to 30 new and existing groundwater
monitoring wells, leachate wells and private wells for the
following analytes:
1. Indicator parameters (chloride, fluoride, nitrate+nitrite.
and sulfate)
11. Field parameters (pH, conductivity, temperature) on all
wells and groundwater levels on all wells except private
wells
ill. Volatile organic compounds (VOCs)
d. Semi-annual monitoring at up to 30 new and existing groundwater
monitoring wells and leachate wells and private wells for the
following analytes:
1. Metals (Al, Sb. As, Ba. Cd, Cr, Fe. Mn, Hg, and Se)
e. Semi-annual monitoring of surface water in drainage ditches on the
site and site pond outfall for VOCs.
f. Annual monitoring of surface water in drainage ditches on the site
and pond outfall for the following analytes:
i. Semi-volatile organic compounds
ii . Metals (Al and Fe)
g. Monitoring of the pond outfall to comply with any additional WPDES
permit requirements.
h. Quarterly monitoring of landfill gas at up to 25 gas probes for
the following analytes:
1. Oxygen
ii . Methane
ill. Pressure
i. Quarterly monitoring of the landfill gas extraction system air
emissions for the first year in accordance with the requirements
of the WDNR Air Management Section and ch. NR 445. Subsequent
monitoring shall be performed periodically as indicated by the
results obtained during the first year.
The Department may approve revisions to the monitoring frequency and the
parameters to be sampled for during the design, construction or implementation
of the remedy without a revision to this decision document. The existing
monitoring well network shall be evaluated during the design to determine if
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any wells need to be rehabilitated, abandoned and/or replaced. This
evaluation shall examine the usefulness of the well(s). their location
relative to the edge of the waste management area (especially wells TW1-3) and
potential construction related damage.
IX. STATUTORY DETERMINATION
A. Protection of Human Health and the Environment
The selected remedy provides adequate protection of human health and the
environment through the Implementation of a new cover system, leachate and gas
extraction and treatment, access controls and additional future remedial
actions, If found to be necessary after additional studies and monitoring.
The remedy is expected to prevent persons from being exposed to site
contaminants in the soil, surface water and groundwater and to restore
groundwater quality to meet ch. NR 140, Wis. Adm. Code, requirements and to
minimize or eliminate the movement of contaminants into surface water and
groundwater.
B. Attainment of ARARs
The selected remedy will be designed to meet all applicable, or relevant and
appropriate requirements under federal and state environmental laws. Since
the Boundary Road Landfill il a state lead cleanup, no CERCLA on site permit
exemption is available. All permits and approvals required to implement the
remedy must be obtained and strictly complied with. The primary ARARs that
will be achieved by the selected alternative are:
1. Action Specific ARARs
Resource Conservation and Recovery Act, as amended [42 U.S.C. Sec. 6901 et
seq.], Subtitle C; Wisconsin Environmental Protection Law, Hazardous Waste
Management Act [Wis. Stat. Sec. 144.60-74]
Most RCRA Subtitle C (hazardous waste) requirements are administered under the
State of Wisconsin's implementing regulations. Leachate, groundwater, spoils
from any extraction system construction and any other contaminated material or
waste that is to be managed as part of any remedy construction and operation
shall be managed in accordance with applicable solid and/or hazardous waste
requirements. The Department has determined at this time that ch. NR 600,
Wis. Adm. Code, hazardous waste requirements for listed hazardous waste are
not applicable to this material because there is no information available to
the Department indicating that what is now described as a listed hazardous
waste was accepted at the site. While the site was operated as a co-disposal
(industrial and municipal waste) landfill and appeared to accept a significant
amount of what might be hazardous waste, there is no specific information to
describe that waste. The Department reserves the right to re-examine this
issue in the future, based on any new waste acceptance information that may be
compiled for the purpose of identifying potentially responsible parties.
Hazardous waste requirements are therefore not applicable to the site at this
time, except to the extent that new hazardous wastes (such as excavated wastes
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showing a characteristic) are generated during the course of the remedy.
The Department has determined that the only reason the s. NR 660.15. Wis. Adm.
Code, composite hazardous waste cover system requirements are not appropriate
at this time Is that they would be no more effective for reducing infiltration
and surface soil exposure than a s. NR 504.07, Wis. Adm. Code, composite cover
system, which was evaluated In the FS, PP and this Decision Summary. The s.
NR 660.16, Wis. Adm. Code, composite hazardous waste cover system requirements
could be relevant because the site was operated as a co-disposal landfill and
appeared to accept a significant amount of what might be hazardous waste. The
Department reserves the right to re-examine the relevance and appropriateness
of the s. NR 660.16, Wis. Adm. Code, composite hazardous waste cover system
requirements In the future, based on design considerations and any new waste
acceptance Information that may be compiled for the purpose of Identifying
additional potentially responsible parties.
The selected remedy will comply with the following applicable requirements:
Wis. Adm. Code NR 605; 40 CFR 261 - Identification of Hazardous Wastes. These
regulations provide requirements for determining when a waste Is hazardous.
The substantive requirements of these regulations will apply to any on-slte
TCLP testing of residuals which may be.disposed of off-site.
Wis. Adm. Code NR 615; 40 CFR 262 - Standards Applicable to Generators of
Hazardous Waste. These regulations provide requirements for the shipment of
wastes to treatment, storage or disposal facilities. These requirements may
apply to on-site preparations for off-site shipment of treatment residuals and
other wastes.
Wis. Adm. Code NR 620; Department of Transportation Hazardous Materials
Transportation Act [49 U.S.C. Sec. 1801]; 40 CFR 263 - Standards Applicable to
Transporters of Hazardous Waste. These statutes and regulations require
record keeping, reporting and manifesting of waste shipments. These
requirements may apply to on-site preparations for off-site shipment of
treatment residuals and other wastes.
Wis. Adm. Code NR 630.10-17; 40 CFR 264, Subpart B - General Facility
Requirements. These regulations establish substantive requirements for
security, inspection, personnel training, and materials handling which are
relevant and appropriate to on-site activities involving handling of hazardous
materials. These requirements may apply to on-site preparations for off-site
shipment of treatment residuals and other wastes.
Wis. Adm. Code NR 630.21-22; 40 CFR 264, Subpart D - Contingency Plan and
Emergency Procedures. These regulations establish' substantive requirements
for emergency planning which are relevant and appropriate for on-site
activities which may Involving handling of hazardous substances.
Wis. Adm. Code NR 675; 40 CFR 268 - Land Disposal Restrictions. These
regulations require that hazardous wastes cannot be land disposed unless they
satisfy specified treatment standards. These regulations also impose record
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keeping requirements on such wastes. These requirements apply to on-site
activities related to off-site disposal of any treatment residues or other
hazardous wastes.Wis. Adm. Code NR 605: 40 CFR 261 - Identification o^
Hazardous Wastes. This code provides requirements for determining when a waste
is hazardous. The substantive requirements of these regulations will apply to
any on-site TCLP testing of residuals which may be disposed of off-site.
Resource Conservation and Recovery Act, as amended [42 U.S.C. Sec. 6901 et
seq.], Subtitle D; Wisconsin Environmental Protection Law, Subchapter IV •
Solid Waste [Wis. Stat. Sec. 144.43-47]
The Department has determined that the RCRA Subtitle D closure standards for
new or expanding solid waste disposal sites (composite cover system
requirements) are not relevant and appropriate requirements at this time
because they would be no more effective for reducing infiltration and surface
soil exposure than a s. NR 504.07, Wis. Adm. Code, composite cover system,
which was evaluated in the FS. The Department reserves the right to re-
examine the relevance and appropriateness of the cover system requirements in
the future, based on design considerations.
The following requirements are applicable:
Wis. Adm. Code NR 504; - Landfill Location, Performance, and Design Criteria -
This code specifies locational criteria, performance standards and minimum
design requirements for solid waste disposal facilities.
Wis. Adm. Code NR 504.04, 506.08(6), 506.07, 508.04 - Landfill Gas Control -
These codes establish standards for landfill gas control and monitoring
practices. These requirements apply to the landfill gas recovery operations
at the site.
Wis. Adm. Code NR 506.08 - Additional Closure Standards - This code requires
runoff control from closed portions of a landfill. These requirements also
apply during construction activities at the Site. In addition, this
requirement establishes hazardous air contaminant control for facilities over
500,000 cubic yards.
Wis. Adm. Code NR 504.07, 506.08, 514.07, and 516 - Landfill Closure
Requirements - These codes establish substantive requirements for design.
operation and maintenance of landfill caps which are applicable to the design
and long-term maintenance of the cover system.
Wis. Adm. Code NR 508 - Landfill Monitoring, Remedial Actions and In-field
Conditions Reports - This code specifies monitoring requirements for
groundwater, leachate, gas, surface water and air.
Wis. Adm. Code NR 512.18 - Borrow Reports - This code establishes the
requirements for soil borrow reports.
Wis. Adm. Code NR 700-736 - Investigation and Remediation of Environmental
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Contamination - This code specifies standards and procedures pertaining to the
identification, investigation, and remediation of sites.
Wis. Adm. Code NR 141 - Monitoring Well Requirements - Any new or replacement
monitoring wells shall meet these requirements.
Occupational Safety and Health Administration (OSHA) - Regulates worker
safety.
Clean Water Act of 1977, as amended [33 U.S.C. Sec. 1317]
Wis. Adm. Code 108 and 211; 40 CFR 403 - Pretreatment Standards - These
regulations prohibit discharges to POTWs which pass through or interfere with
the operation or performance of the POTW. The requirements of these
regulations apply to the leachate which is collected and discharged to the
Milwaukee Metropolitan Sewerage District.
Wis. Adm. Code NR 147, NR 214- Pollution Discharge Elimination - These
regulations require point source discharges to obtain a permit from the WDNR.
The requirements of the existing permit for the pond discharge and any new
treated leachate discharge, if necessary, shall apply.
2. Chemical Specific ARAR$.
Clean Air Act [42 U.S.C. Sec. 7401 et seq;]; Wisconsin Environmental
Protection Law, Subchapter III • Air Pollution [Wis. Stat. 144.30-144.426]
Wis. Adm Code 404, 415-449; 40 CFR 50 - Emissions Standards. These codes
establish standards for emission of pollutants into ambient air and procedures
for measuring specific air pollutants. These requirements apply to the
emissions from the active gas extraction system.
Safe Drinking Water Act [40 U.S.C. Sec. 300 et seq.]
Wis. Adm. Code NR 109; 40 CFR 141 - Maximum Contaminant Levels (MCLs) - MCLs
establish drinking water standards for potential and actual drinking water
sources. The selected remedy is intended to achieve compliance with MCLs and
non-zero Maximum Contaminant Level Goals.
Wis. Adm. Code NR 140 - Groundwater Quality Standards - This code provides for
groundwater quality standards including Preventive Action Limits (PALs),
Enforcement Standards (ESs) and (Wisconsin) Alternative Concentration Limits
(WACLs). The selected remedy is intended to achieve compliance with PALs at
and beyond the waste boundary (edge of waste, or edge of the slurry cut-off
wall). To the extent the Department subsequently determines that it is not
technically or economically feasible to achieve PALs, NR 140.28 provides
substantive standards for granting exemptions from the requirement to achieve
PALs. Such exemption levels may not be higher than the ESs. for the compounds
of concern at this site.
Clean Water Act of 1977, as amended [33 U.S.C. Sec. 1311-17]; Wisconsin
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Environmental Protection Law, Subchapter II - Water and Sewage [Wis. Stat. Se.
144.02-27]
Wis. Adm. Codes NR 102. 105, and 220 - Surface water quality standards. NR
102 prohibits toxic substances in surface waters at concentrations which
adversely affect public health or welfare, present or prospective water supply
uses, or protection of animal life. NR 105 sets compound-specific surface
water quality standards. The selected remedy will achieve compliance with any
requirements of these regulations for discharges to surface water from the
ponds or potential leachate treatment, if necessary, including NR 220, Wis.
Adm. Code WPDES Best Available Technology (BAT) requirements.
Wis. Adm. Code NR 207; 40 CFR 131 - Ambient Water Quality Criteria.
Establishes pollutant concentration limits to protect surface waters. These
and other water pollution discharge limits are administered under the
Wisconsin Pollutant Discharge Elimination System (WPDES) permit program. The
selected remedy shall satisfy both general and specific substantive
requirements for discharge to surface water. Any wastewater discharged to a
surface water must, if necessary, be treated to satisfy these standards prior
to discharge. These treatment requirements are administered under NR 200 and
220, Wis. Adm. Code.
3. Location Specific ARAR$
Clean Water Act of 1977, as amended [33 U.S.C. Sec. 1344]
Wis. Adm. Code NR 103 - Water Quality Standards for Wetlands; Executive Order
11990 and 40 CFR 6 - Protection of Wetlands - These requirements provide
protection against loss or degradation of wetlands. A wetland is located
south of the Boundary Road site. The proposed remedy should not have an
adverse impact on the nearby wetland. If wetlands are encountered at any off-
site borrow sources, these requirements shall be met at those sources to
minimize the impacts on those wetlands.
Ch. 30, Wis. Stats.
A permit may be required in accordance with ch. 30, Stats., if remedial
activities change ditches or streams at the site or borrow source sites.
C. Cost Effectiveness
The selected remedy provides for overall cost effectiveness. It is the lowest
cost alternative that meets the threshold criteria.
D. Use of Permanent Solutions and Alternative Treatment Technologies
The selected alternative represents the best balance of alternatives with
respect to the nine evaluation criteria. The cover system eliminates the
direct exposure pathway to contaminated surface soils and reduces the amount
of leachate generated within the site. The leachate extraction measures will
reduce the movement of contaminants away from the site. The existing slurry
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cut-off wall and clay berm will further restrict contaminant movement. The
active landfill gas extraction system provides for removal and treatment of
additional contaminants and will effectively control the migration of landfill
gases. Both leachate and gas will be treated.
E, Preference for Treatment as a Principal Element
By treating the waste mass with leachate and active gas extraction, the remedy
satisfies the statutory preference for remedies that employ treatment of the
principal contaminant threat to permanently and significantly reduce toxlclty,
mobility or volume through treatment.
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RESPONSIVENESS SUMMARY
This Responsiveness Summary has been prepared to ^eet the requirements of
Sections 113 (k) (2) (B) (iv) and 117(b) of the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA), as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA), which requires
the United States Environmental Protection Agency (EPA) or the state, for
state lead sites, to respond "... to each of the significant comments,
criticisms, and new data submitted in written or oral presentations" on a
proposed plan or draft Record of Decision for the remedial action. The
Responsiveness Summary addresses concerns by the public and potentially
responsible parties (PRPs) in written and oral comments received by the state
regarding the proposed remedy at the Boundary Road site.
A. Proposed Plan (PP) and Public Comment Period
The Proposed Plan for the site was made available for public comment in early
February, 1995. A public meeting to explain the Proposed Plan, and to receive
public comments was held on February 16, 1995. The public comment period was
originally between February 16 and March 16, 1995, and was extended twice at
the request of Waste Management of Wisconsin, Inc. (WMWI) for a total
extension of 60 days (2 30-day extensions). All comments which were received
by the Department prior to the end of the public comment period, including
those expressed verbally at the public meeting, were considered in making the
final decision and are addressed in this Responsiveness Summary.
B. Community Interest
Interest by residents near the site has not been high. However, significant
comments were prepared by WMWI, their consultant and a local politician. All
comments received by the Department, including those expressed verbally at the
public meeting, were in opposition to the selection of alternative 4A and •
favored the selection of alternative 3.
C. Summary of Significant Public Comments
Comments received during the public comment period are summarized below. Some
of the comments are paraphrased to effectively summarize them in this
document. The source of the comments are shown in brackets, preceding each
comment.
1. [WMWI, Rep. Lolita Schneiders, Wis. Manufacturers and Commerce, Montgomery
Watson, Melvin Mueller] Since Alternatives 3, 4 and 4A all meet the threshold
criteria for protectiveness, when considering the balancing criteria,
Alternatives 3 and 4A are similar except for cost. Therefore, any additional
cost associated with the implementation of Alternative 4A is unwarranted. The
design assumptions used in the PP for the cost estimates are inappropriate.
The cost estimates in the PP are inaccurate and the FS cost estimates should
be used.
Response: Alternatives 3 and 4A differ under other balancing criteria, such
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as effectiveness and implementability, as described in the Decision Summary.
WMWI used different cost estimates than the Department in the FS and their
comments, which showed a more significant cost difference between these 2
alternatives. Comments on the cost estimates are addressed below.
2. [WMWI] The PP should not have used a minimum slope specification for
Alternative 3 that exceeds the s. NR 506.08, Wis. Adm. Code, minimum
specification of 2% for the purposes of preparing the cost estimates.
Response: The Department approved the FS on the condition that a minimum
slope goal for the design be 5%, but the minimum slope allowed be 2%. The
subsequent PP contained some additional cost for placing additional soils to
meet this goal. The Department agrees that for the purposes of the Decision
Summary, the additional cost is not really necessary. As stated in the
Decision Summary, the minimum slope requirement will be determined during the
design.
3. [WMWI] The PP cost estimate for Alternative 3 should not include a
contingency for importing up to 20% more clay. There is already a sufficient
contingency volume at the site based on initial investigations.
Response: At the time the PP was prepared, the Department was concerned
about the ability to locate ^.sufficient volume of acceptable clay at the
site, accounting for the results of the preliminary soil investigation in the
Remedial Investigation (RI) and the s. NR 504.05 Wis. Adm. Code, minimum clay
specifications. Also, the preliminary investigation did not meet s. NR
512.18, Wis. Adm. Code, borrow source investigation requirements. Since that
time, it has been proposed to make the s. NR 504 clay specification less
stringent. The Department has now determined that any plan approval for the
design would likely use the less stringent specifications. Therefore, the
likelihood of finding a sufficient volume of clay has increased, so the
Department now agrees that the 2Q% volume contingency is no longer necessary.
However, an investigation meeting the goals of s. NR 512.18, Wis. Adm. Code,
borrow source investigation will still be necessary at the site.
4. [WMWI] The drainage blanket in alternative 4A should extend over the
entire cover area. The design described in the PP could have long-term
stability problems due to liquids accumulation and slope stability problems.
The placement of a frost protection/rooting layer directly over the
geomembrane may be a problem due to the risk of angular rock and other foreign
materials.
Response: The Department generally agrees with this comment and has
accounted for it in the Decision Summary. The Department now believes that
Alternative 4A would have implementability and reliability problems, as
discussed in section VII.B. of the Decision Summary.
5. [WMWI] The Department should not rely on the contingencies in the cost
estimates for specific items or activities, such as textured geomembrane on
side slopes.
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Response: The Department does not agree with this comment In this context.
When preparing the cost estimates for the PP, the Department used engineering
judgement to determine that a single cost per square foot estimate for plastic
geomembrane would oe generally accurate (In the correct: range), conservative
and would account for the relatively small additional cost for textured
plastic membrane on steeper slopes. It should also be noted that per U.S. EPA
guidance, cost estimates for this purpose have an error range of -30 to +50
percent. The Department still believes the estimate Is correct for these
purposes.
6. [WMWI] The unit cost for 40 mil VLDPE plastic geomembrane In the cost
estimates should be $0.50 per square foot rather than $0.35 per square foot.
based on vendor quotes and WMWI's experience. The actual type of membrane
used should be left to the design phase.
Response: The Department believes the figure It used Is correct In this
context. The figure Is based on estimates accepted for similar projects by
the Solid Waste Program and was confirmed by Information on bid prices for the
Holtz-Krause site. The figure has further validity given the additional
percentages used In the cost estimates for administration, engineering, a
contingency and mobilization/demobilization.
7. [WMWI] The difference In total present worth costs between Alternatives 3
and 4A are not presented properly In the PP, due to the differences between
the cost estimates used by the Department and WMWI, as described by the
previous comments on the cost estimates.
Response: See the response to the comments relating to the cost estimates- In
this responsiveness summary.
8. [WMWI] The cost estimates are Incomplete because they do not include
actual cost estimates for leachate extraction In the northeast portion of the
site, nor groundwater extraction south of the slurry wall, which are described
In the remedies In the PP.
Response: The Department agrees that normally, cost estimates would Include
these Items. However, given that all of Alternatives 2-4 and 4A would Include
the same dollar amount estimates for these systems, It doesn't make any
difference from a cost comparison basis whether the Items are there or not, as
the costs for all the alternatives would go up equally. Therefore, the cost
estimates may be used in the Proposed Plan and the Decision Summary for a
comparison basis.
9. [WMWI, Montgomery Watson] The Department should use a formal CERCLA waiver
for equivalent standard of performance for Alternative 4A, because It does not
meet state landfill standards under s. NR 504.07, WIs. Adm. Code.
Response: The Department disagrees. The design, as presented, meets the
requirements of s. NR 504.07, WIs. Adm. Code, because par. (4)(1ntro.) gives
the Department the ability to approve such alternative designs. No waiver Is
needed.
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10. [WMWI] The PP is inconsistent with U.S. EPA's Phased Implementation of
Remedies guidance, because Alternatives 3 and 4A are described differently
than the FS.
Response: The Department disagrees and believes the alternatives presented
in PP and the Decision Summary are consistent with the referenced guidance.
The Department-described alternatives are implemented in a phased approach,
with the implementation of several remedy elements being dependent on the
results of the initial elements. These include:
a. Groundwater extraction south of the slurry wall is conditional on
the results of source removal south of the wall and additional
investigations..
b. Actions to minimize leachate movement away to the west, north and
east and to minimize groundwater infiltration into the site at the
edges are conditioned on the effectiveness of the initial actions.
Additional studies will determine if these actions are necessary.
c. Actions to remediate groundwater to the north and east of the site
are also conditioned on the effectiveness of the initial actions.
Again, additional studies will determine if these actions are
necessary.
>
11. [WMWI] Repair of a geomembrane cover is more difficult and costly than a
soil cover, especially if significant settlement occurs, which is expected at
this site if leachate and landfill gas removal are to be implemented.
Response: The Department generally agrees with this comment and has
accounted for it in the Decision Summary. See section VII.B. of the Decision
Summary for a discussion of this.
12. [WMWI] The installation of additional leachate extraction measures in the
northern portion of the site is not necessary at this time and was not
justified in the PP.
Response: The Department believes the results of the remedial investigation
showed that this action is necessary, and documented the reasons in the
conditional FS approval letter. As stated in that letter, the action is
necessary to minimize the amount of leachate escaping through the base and
sides of the site, as there are downward gradients within the site,
contamination has already migrated away from the sides in some areas, and if
this migration continues, there continues to be the potential for additional
surface and/or groundwater contamination away from the edges of the site. The
Department does not believe that extracting leachate only from the southern
portion of the site from the existing leachate collection system would have a
significant enough effect on the leachate head levels in the northern portions
of the site to effectively minimize the migration of leachate away from the
site.
13. [WMWI] Groundwater extraction in.the TW-24 area is not warranted as an
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initial action. WMWI should be given the opportunity to investigate the
source(s) of this contamination first and remove it.
Response: The Department generally agrees that an investigation and
additional monitoring should be conducted before any groundwater extraction
system is installed. As described in the decision document, a 3-year effort
would be made to investigate this area. Groundwater extraction measures would
have to be installed after the 3-year investigation and monitoring period,
unless it is shown that there is a significant improvement in groundwater
quality in that area, showing a trend towards meeting ch. NR 140. Wis. Adm.
Code, PALs within a reasonable amount of time (as determined by applying the
criteria listed in s. NR 722.07(4)(a)4, Wis. Adm. Code).
14. [WMWI] The PP is misleading because it identifies "Current Exposures that
Could Cause Risk11. There are no current actual uses that would lead to the
exposure scenario described.
Response: The Department does not believe the title is misleading, once the
introduction to the section is considered. The section referred to in the PP
refers to risks from using contaminated groundwater from monitoring wells.
The introduction to this section states that the theoretical risk to people
was calculated, based on current and assumed future site use. One of the
current uses of the groundwater near the site is for drinking and showering.
A clearer title may have beeti "Current Theoretical Exposures that Could Cause
Risk".
15. [WMWI, Wis. Manufacturers and Commerce, Montgomery Watson] The
Department's statements in the PP alleging the increased reliability
associated with the cover in Alternative 4A, over Alternative 3 are not
supported by the FS. Soil covers have been consistently and routinely
implemented as remedial components at waste sites. It is unclear how the
Department could now question the reliability of such systems.
Response: The Department performed its own analysis in the PP and did not
rely only on the FS. The Department was not questioning the reliability of
soil cover systems in the PP, only indicating that composite systems are more
reliable at reducing infiltration. The Department indicated in the PP and
still believes that the composite cover alternatives are more reliable for
reducing infiltration into the site than the soil cover alternative,
Alternative 3.
16. [WMWI] The Department's statements in the PP alleging the increased
effectiveness associated with the cover Alternative 4A, over that provided by
the cover in Alternative 3, are not supported by the FS. Establishing and
maintaining inward gradients utilizing leachate extraction is the action that
will reduce the movement of leachate to groundwater. This is primarily a
function of the capabilities of the extraction network and the rate of
leachate extraction. The difference in time between Alternatives 3 and 4A to
achieve inward gradients is insignificant.
Response: The Department performed its own analysis in the PP and did not
- 49 -
-------
rely only on the FS. The Department generally agrees that if aggressive
leachate extraction is implemented and maintained for Alternative 3 that the
time to achieve inward gradients may be similar for the alternatives.
17. [WMWI] The Department's statements in the PP alleging increased
protect!veness associated with the cover Alternative 4A. over that provided by
the cover in Alternative 3,'are not supported by current research or the FS.
The infiltration rate is not inversely related to the ability or time required
to meet cleanup goals. Recent case studies and research show that additional
infiltration may help to accelerate cleanup by expediting stabilization of
landfill refuse (the landfill bioreactor theory). As described in the FS, as
long as containment is maintained, the remedies are equivalent in terms of
protectiveness.
Response: The Department performed its own analysis in the PP and did not
rely only on the FS. Again, the Department generally agrees that if
aggressive leachate extraction is implemented and maintained for Alternative 3
that the time to achieve inward gradients may be similar for the alternatives.
The Department agrees that maintaining additional refuse saturation in a
contained environment may accelerate anaerobic decomposition, but at the
increased risk of loosing containment effectiveness. Because of that
potential risk, new landfills that are completely lined must minimize the
amount of leachate ponding on the base of the site. Should a portion of the
base liner fail, higher leactfate head levels would cause more leachate to
escape from the site, because the higher levels would act as an additional
driving force. Allowing higher leachate head levels within this site, which
is unlined, increase the chances of migration away from the sides and bottom
of the site. Therefore, the selected remedy includes achieving and
maintaining "dry base" conditions.
18. [WMWI] The statements that alternative 4 and 4A are expected to meet
standards more quickly than Alternative 3 because they allow less water to
filter into the site are not correct. Stabilization of the waste would be
accomplished more quickly with additional infiltration into the site.
Compliance with ARARs is a threshold criteria; alternatives either comply or
they do not. The time until standards may be achieved as a result of remedial
actions should not be considered as part of the evaluation of ARARs criteria.
Response: As indicated above, the Department generally agrees that with
aggressive leachate extraction, Alternative 3 may achieve remedial goals in a
similar time frame to Alternatives 4 and 4A. The point on stabilization of
saturated waste is addressed in the previous comment. The Department
disagrees with the last point; ch. NR 140 requires that groundwater standards
be achieved in a reasonable amount of time (as determined by applying the
criteria listed in s. NR 722.07(4)(a)4, Wis. Adm. Code), when it is
technically and economically feasible. Alternatives that achieve standards
more quickly that are technically and economically feasible should be selected
to meet those requirements.
19. [WMWI] Statements in the PP identifying decreased soil and transportation
needs for Alternative 4A relative to Alternative 3 are not factual or
- 50 -
-------
supported by the FS. Additional material for a drainage layer would have to
be imported for Alternative 4A.
Response: The statements in the PP on importing soil are correct for the
alternatives evaluated in the PP. Alternative 3 in the PP assumed that
100,800 cubic yards of additional clay and rooting zone material would have to
be imported. Alternative 4A assumed that the only soil to be imported would
be 16,100 cubic yards of drainage material sand. The revised Alternative 3 in
the Decision Summary follows the volumes described in the FS, where 72,000
cubic yards of rooting zone material are imported.
20. [Melvin Mueller] It is difficult to understand why the existing
conditions at the site warrant a multi-million dollar cleanup effort. The
fact that the site has been closed for 25 years, the degree and extent of the
contamination is minimal, and there are no water supply wells impacted by the
landfill do not seem to justify the costs associated with either Alternative 3
or 4A.
Response: Based on the results of the RI, the site does pose an existing and
potential future risk to human health and the environment and state
groundwater standards are exceeded, as described in the Decision Summary.
Therefore, a cleanup action is warranted. Also, a goal of the remedial action
is to prevent future additional groundwater impacts, and potential future
impacts on private wells.. Given the size and nature of the site, all the
ARAR-compliant actions examined do have total present worth costs of several
million dollars (the "no-action" alternative does too, due to the O&M costs).
Soil covers, gas collection systems and monitoring costs at a site of this
nature have total present worth costs in the several million dollar range.
- 51 -
-------
Gravel Pits .,
o
OZ&tTKEE CO
north
2000
1 .
BASE MAP DEVELOPED FROM THE
MENOMONEE FALLS. WISCONSIN,
7.5 MINUTE U.S.G.S. TOPOGRAPHIC
QUADRANGLE MAP. DATED 1958.
PHOTOREVISED 1971 & 1976.
SCALE IN FEET
g
I
SITE LOCATION MAP
FEASIBILITY STUDY
BOUNDARY ROAD LANDFILL
WASTE MANAGEMENT OF WISCONSIN, INC.
VLLAGE Of MENOMONEE FALLS
WAUKESHA COUNTY. W1SCONSN
1S37101 A:
-------
LEQEND
*~ — GROUND CONTOUR
SURFACE WATER
WETLANDS
TEMPORARY CAS PROBE LOCATION AM)
PQOMETOC WELL LOCATON AND NUMBER
INDUSTRIAL
STAFF GAUGE LOCATION AND NLMBCR
PRNATE WELL LOCATION AND NUU3CT
TE
FORMER
PLAYING FIELDS
EMERGENT. NARROW-LEAF PCRSOTDCT. WTT
9OL. PALUS7WHC WETLAND
FORESTED. BROAD-LEAF DECIDUOUS, WET
SOL, PALUSTWNE NETLAMD
OfMNMZ SWM£ AND FLOW DMLO1ON
ACTIVE
DISPOSAL
COMPANY
RESIDENTIAL
NOTES
1. BASE MAP WAS PROVtOED BY WASTE
OF WBCOMSN. IMC ANO S AH AERW.
PERflMMCD BY AQU-UETWC EMCMC£R»4C. INCL.
SHEBOTCAN. WISCONSM, FLOWN APRM. 2B.
TOPOGRAPHY B BASED ON U-S.CLX. OATIAL
TOPOGMAPHC CONTOUR MTERVAL tS TWO fETT
CRD BASED ON WBCONSN STATE PLANE
COOftDMATE STSTDA,
AGRICULTURE
AGRICULTURE
h
i?i
Soil
ggujQ
Drawing Number
1537101 B20
-------
, v. |g l.
'
E
Us *
a *2
; «
$ E
jSfi &
58
537
B22
ant FEATURES AND MONITORING WELL LOCATION MAP
FEASIBILITY STUDY
BOUNDARY ROAD LANDFILL
WASTE MANAGEMENT OF WISCONSIN, INC.
VILLAGE OF MENOMONEE FALLS, WAUKESHA COUNTY. WISCONSIN
DJW
Drwn ^ TPB/LCL
Aoorw^d Br.
aZt
i^Z
Dot*:
REVISED NOTE NO. 5. DLF 8/9/93 DJW
-------
Figure 4 - Groundwater/Leachate Elevations on May 8,1992
*
1V• 765 —
. 1OT"
— 764'
/ /
/
&
TW2R
r.TWti
^MWt12
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COLLECTION SYSTEM ANO
WATER TABLE CONfOURS)
s\U^
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TW7
(I J3 2 4)
BUUNNO
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SUMTACC WATCH
WtTlANOS
roipoivary CAS p*c»c LOCATDW
NUMOCR
PCZOMCTWC WGI UXAHOH AM)
PMftTC WOL UKAnON ANO
APPMWJUATt PftOPCKTY Uh£
LIACHATC OOiiJtCDOH UNC
ClAY KM4
' WAIL
CftOUNOWATt* UONfTOMNO *fftLf£ff*M.
LCACHATC HCAO ANO CAS WOL LOCAOOK
NUMBEIL ANO U>£WTI/*VIDl UtU
Q£V(AT>ON
ITAfT QMJGC LOCATION. NUMKR AND
SUVACt WATHI OCVH010N
LCACHATt OOLLICnON fTTTDI MANHOU
LOCATION. NUUftdl ANO WATTO 1AJLC
HOTtt
1. B^C UA^ WAS FHQMOO) if WASTC UAJttCOCMT
Of WISCONSM. t<(X ANO « AN ACHM. fUf^tT
BY AflW-MOIIJC OONOMNQL M6,'
WOCONSIK HJOWN *f*L U. 1ttl.
CM) MSGD ON VWCOfflUH ITAll PIAHC
COOftCXNATt
i ANO MONnOANG POf
-------
Figure 5 - Groundwater Monitoring Well VOC Results
- -
\ \
\\
V 1 LHQ102,
i\ ^
MW109 P102\
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22 | 23 18 \ Ip"*^ ^ .
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TW3R TW2R
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236 372 764
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-4^. fTAfP CMUOC UXAHOH ANO HWKft
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noni
I. fttfC UM> Vt^S PHOVWCD *1 WASTC M^MCOOT
Or WOCONSK 1C. AHO 1) AM A£MAL SURVfY
POVWilCD tr ACHO-MCTftlC &OHW9H MCL.
ftoarcAK WMOONIH DATED ocrotc* 21. tHt.
S. GMO ±3& ON WSCONON SUII FIAMC
COOROHMf SYSTEM.
SCFTtMBCT 24* IMt TO OCTOOdi 31. IMt.
WCUJ MUM ANO MVIS WC INSTAUID ON
OCTOtOI 7. If 12 AHO OCTOfipl 27, lift
lOPfcnvdr. MRCMOU toos A/ID WOJL
OONSimiCIION ACfOftn AM UX^ItO M APf CN00C
A ANO ft. tOMIHOil LOOS AMO COKSTNUCIION
MDPOUTi FOR AtL^TW WHU AIC IDCATO M T>€
•MONCTORHO WOJL ONJUAHOM ^fcm* (NIPH»-
•CAUCK 1HI).
4. AtL tmtl VCMC fVtVCYtO 0V mnONM. tWJVCT
ON NOVDMOI 20-21. ItOI. AMO OCCSIiflOl 1
1N2. ML
-------
Well Parameter
TABLE 1
8u:Y!i!K!:''\' of Groundwater Monitoring Well
Data ExceeGiiiy Federal and/or Sta~e Regulations
Boundary Road Landfill Feasibility Study
BACKGROUND WELLS
Maximum NR 140(1)
Sampling Date Concentration T5(2) PALUT
MW109 Chloride (mg/L)
Manganese (ug/L)
MW110 Aluminum (ug/L)
Arsenic (ug/L)
Iron (ug/L)
Manganese (ug/L)
P102 Antimony (ug/L)
Arsenic (ug/L)
P103 Antimony (ug/L)
11/18/91
3/30/92
5/18/92
11/18/91
3/30/92
11/18/91
11/18/91
11/18/91
3/31/92
11/18/92
3/31/92
5/18/92
3/31/92
5/18/92
11/20/91
3/31/92
5/18/92 .
4/1/92
160
138
127
170
85
379
6.1
402
710
96.5
37
49
5.5
11.4
7.5
5.8
6.9
5.3
250
250
250
50
50
50
300
300
50
50
50
6
6
50
50
50
6
125
125
125
25
25
--
5
150
150
25
25
25
1.2
1.2
5
5
5
1.2
-------
TW7
Antimony (ug/L)
3/31/92
6.8
1.2
Well
WELLS OUTSIDE WASTE MANAGEMENT AREA
(Not Including Background Wells)
Parameter
Sampling Date
Maximum
Concentration
NR 140(1)
~T5(2) PALU7
MW111 Arsenic (ug/L)
Barium (ug/L)
Benzene (ug/L)
Chloride (mg/L)
Iron (ug/L)
Manganese (ug/L)
Nickel (ug/L)
1,1,2.2-Tetra-
chloroethane (/L/g/1)
THF (ug/L)
11/19/91
4/1/92
5/19/92
11/19/91
4/1/92
5/19/92
11/19/91
4/1/92
5/19/92
11/19/91
4/1/92
5/19/92
11/19/91
4/1/92
5/19/92
11/19/91
4/1/92
5/19/92
11/19/91
4/1/92
4/1/92
5/19/92
16.7
9.2
9.1
706
658
637
15
7
7
462
374
389
1.770
2,240
2,460
456
814
975
29.5
24
2
78
50
50
50
2.000
2.000
2.000
5
5
5
250
250
250
300
300
300
50
50
50
100
100
0.2
50
5
5
5
400
400
400
0.5
0.5
0.5
125
125
125
150
150
150
25
25
25
20
20
0.02
10
-------
MW112 Chloride (mg/L)
MW114
MW115
P103
Iron (ug/L)
Manganese (ug/L)
Sulfate (mg/L)
THF (ug/L)
Antimony (ug/L)
Benzene (ug/L)
Chloride (mg/L)
Manganese (ug/L)
Cadmium (ug/L)
Manganese (ug/L)
Arsenic (ug/L)
Chloride (mg/L)
11/19/91
4/1/92
5/18/92
11/19/91
4/1/92
5/18/92
11/19/91
4/1/92
5/18/92
11/19/91
4/1/92
5/18/92
5/18/92
12/4/92
11/2/92
11/2/92
12/4/92
11/2/92
12/4/92
12/4/92
11/2/92
12/4/92
4/1/92
11/19/91
4/1/92
5/19/92
350
296
322
1.260
453
901
299
399
340
151
138
140
25
6.2
2
238
255
65
26
2.9
2,300
2,360
5.3
159
157
219
250
250
250
300
300
300
50
50
50
250
250
250
50
6
5
250
250
50
50
5
50
50
50
250
250
250
125
125
125
150
150
150
25
25
25
125
125
125
10
1.2
0.5
125
125
25
25
0.5
25
25
5
125
125
125
-------
Manganese Cug/L).
TW5R Antimony (ug/L)
Barium (ug/L)
Chloride (mg/L)
Manganese (ug/L)
Nickel (ug/L)
TW6R Antimony (ug/L)
Arsenic (ug/L)
Benzene (ug/L)
Manganese (ug/L)
TW7 Antimony (ug/L)
TW8 Antimony (ug/L)
TW11 Antimony (ug/L)
Sulfate (mg/L)
11/19/91
4/1/92
5/19/92
3/31/92
5/19/92
11/20/91
11/20/91
3/31/92
5/19/92
11/20/91
3/31/92
' 5/19/92
3/31/92
5/19/92
3/31/92
11/19/91
11/19/91
11/19/91
3/31/92
3/31/92
5/20/92
11/20/91
4/1/92
5/20/92
28.7
68
134
5.5
6.8
413
377
265
219
1,350
1,200
572
30/29 (dup)
26
5.5
7.6
1
41.6
6.8
15.1
18.3
258
287
448
50
50
50
6
6
2,000
250
250
250
50
50
50
100
100
6
50
5
50
6
6
6
250
250
250
25
25
9£
Zo
1.2
1.2
400
125
125
125
25
25
25
20
20'
1.2
5
0.5
25
1.2
1.2
1.2
125
125
125
-------
TW24
Manganese (ug/L)
Nickel (/;g/l)
Sulfate (mg/L)
THF (ug/L)
Arsenic (ug/L)
Benzene (ug/L)
Chloride (mg/L)
Iron (ug/L)
Mercury (ug/L)
Nitrate+Nitrit*
Nickel (jLvg/1)
4/1/92
5/19/92
11/21/91
4/1/92
5/19/92
4/1/92
5/19/92
11/21/91
4/1/92
5/19/92
5/19/92
11/20/91
3/31/92
5/20/92
11/20/91
3/31/92
5/20/92
11/20/91
3/31/92
5/20/92
11/20/91
3/31/92
5/20/92
5/20/92
11/20/91
11/20/91
6,790
5.830
136
138
126
64/62 (dup)
79
605
182
156
43
25.3
13.1
13.5
77
86
140
432
348
289
4.860
2,570
4,790
0.21
5.22
41.1
300
Q n H
50
50
50
100
100
250
250
250
50
50
50
50
5
5
5
250
250
250
300
300
300
2
10
100
150
~! ^ M
— -...' '~J
25
25
25
20
20
125
125
125
10
5
5
5
0.5
0.5
0.5
125
125
125
150
150
150
0.2
2
20
-------
TW13
TW16
TW22
Chloride (mg/L)
Iron (ug/L)
Manganese (ug/L)
Sulfate (mg/L)
Iron (ug/L)
Manganese (ug/L)
Mercury (ug/L)
Antimony (ug/L)
Benzene (ug/L)
Chloride (mg/L)
Iron (ug/L)
11/20/91
11/20/91
4/3/92
5/18/92
11/20/91
4/3/92
5/18/92
11/20/91
4/3/92
5/18/92
11/18/91
4/1/92
5/19/92
11/18/91
4/1/92
5/19/92
11/18/91
5/19/92
11/21/91
4/1/92
5/19/92
11/21/91
4/1/92
5/19/92
11/21/91
132
586
2.060
3,400
186
262
311
214
184
197
558
857
1,220
151
240
270
0.41
15.6
1
2
. 2
140
728
889
5,480
250
300
300
300
50
50
50
250
250
250
300
300
300
50
50
50
2
6
5
5
5
250
250
250
300
125
150
150
150
25
25
25
125
125
125
150
150
150
25
25
25
0.2
1.2
0.5
0.5
0.5
125
125
125
150
-------
PW7
PW8
PW9
PW10
Key:
Iron (ug/L)
Manganese (ug/L)
Arsenic (ug/L)
Iron (ug/L)
Arsenic (ug/L)
Iron (ug/L)
Arsenic (ug/L)
Iron (ug/L)
Manganese (ug/L)
Arsenic (ug/L)
Iron (ug/L)
5/21/92
12/5/91
5/21/92
12/5/91
12/5/91
4/9/92
12/5/91
4/9/92
12/5/91
4/9/92
12/5/91
4/9/92
12/5/91
4/9/92
12/5/91
4/9/92
12/5/91
12/5/91
4/9/92
12/5/91
4/9/92
6.2
1.480
678
26
7
7.2
955
837
6.8
7.2
440
346
8.2
7.9
297
230
35
5.9
5.5
359
336
50
300
300
50
50
50
300
300
50
50
300
300
50
50
300
300
50
50
50
300
300
5
150
150
25
5
5
150
150
5
5
150
150
5
5'
150
150
25
5
5
150
150
MW, TW = Monitoring Wells
P = Piezometer
PW = Private Well
General Notes:
-------
Sulfate (mg/L)
THF (ug/L)
PW1 Arsenic (ug/L)
Iron (ug/L)
PW2 Arsenic (ug/L)
Iron (ug/L)
PW4 Arsenic (ug/L)
Iron (ug/L)
PW5 Arsenic (ug/L)
Iron (ug/L)
3/31/92
5/20/92
11/20/91
3/31/92
5/20/92
3/31/92
5/20/92
12/5/91
4/9/92
12/5/91
4/9/92
12/5/91
4/10/92
12/5/91
4/10/92
12/5/91
4/10/92
12/5/91
4/10/92
12/5/91
4/10/92
12/5/91
4/10/92
45.2
35.1
1.000
1,150
984
17
37
7
7.2
1,050
1,800
7.5
5.7
1,260
1,040
5.3
6.5
570
1,070
6.3
6.8
537
964
100
100
250
250
250
50
50
50
50
300
300
50
50
300
300
50
50
300
300
50
50
300
300
20
20
125
125
125
10
10
5
5
150
150
5
5
150
150
5
5
150
150
5
5
150
150
PW6
Arsenic (ug/L)
12/5/91
7.8
50
-------
TABLE 2
Cumulative Risks Associated with Current or Potential Future
Land-Use Conditions at the Boundary Road Landfill Sitec)
Exposure Pathway
Child/Teenager Trespasser
Ingestion of Soil
Dermal Contact with Soil
Ingestion of Surface Water
Dermal Contact with Surface Water
Ingestion of Sediment
Dermal Contact with Sediment
TOTAL RISK:
Adult Residents
Off-Site Northern Monitoring Wells
Ingestion of Groundwater
Inhalation of VOC's in Groundwater
TOTAL RISK: *
Off-Site Eastern Monitoring Wells
Ingestion of Groundwater
Inhalation of VOC's in Groundwater
TOTAL RISK:
Upper Bound Excess
Lifetime Cancer Risk(2)
1E-06
1E-06
3E-08
6E-08
3E-07
2E-Q8
2E-06
4E-07
4E-Q7
7E-07
6E-06
4E-Q6
1E-05
Hazard Index for
Noncarcinogenic Effects(3)
1E-03
1E-02
2E-02
3E-02
1E-04
3E-Q4
6E-02
9E-02
5E-03
1E-01
1E-01
4E-04
1E-01
Off-Site Southern Monitoring Wells
Ingestion of Groundwater NA
Inhalation of VOC's in Groundwater NA
TOTAL RISK: NA
Private Wells
Ingestion of Groundwater NA
Inhalation of VOC's in Groundwater NA
TOTAL RISK: NA
1E+00
NE
1E+00
4E-01
4E-Q5
4E-01
General Notes:
NA = Not applicable. No carcinogenic chemicals were selected as chemicals of
potential concern.
NE = Not evaluated.
-------
1. Data for leachate and groundwater-monitoring wells located within the
waste management area (within the limits of refuse and slurry cutoff
wall) are not included in this table.
2. Total dissolved solids (IDS) data was not included in this table.
3. THF = Tetrahydrofuran
Footnotes:
(1) Chapter NR 140, Wisconsin Administrative Code.
(2) Enforcement Standard
(3) Preventive Action Limit
-------
TABLES
Cumulative Risks Associated with Future Land-Use Conditions
at the Boundary Road Landfill Site
Exposure Pathway
Hypothetical On-Site
Child/Teenager Resident
Ingestion of Soil
Dermal Contact with Soil
Ingestion of Surface Water
Dermal Contact with Surface Water
Ingestion of Sediment
Dermal Contact with Sediment
TOTAL RISK:
Upper Bound Excess
Lifetime Cancer Risk(1)
3E-05
2E-06
2E-07
2E-07
2E-06
4E-Q8
3E-05
Hazard Index for
Noncarcinogenic Effects(2)
3E-02
4E-02
1E-01
1E-01
7E-04
6E-04
3E-01
Hypothetical On-Site
Adult Resident
Ingestion .of Soil(3)
Dermal Contact with Soil(3)
I
On-Site Northern Perimeter Monitoring Wells
Ingestion of Groundwater
Inhalation of VOC's in Groundwater
TOTAL RISK(3):
On-Site Monitoring Wells South of Slurry Wall
Ingestion of Groundwater
Inhalation of VOC's in Groundwater
TOTAL RISK(3):
On-Site Monitoring Wells South of Site Pond
Ingestion of Groundwater
Inhalation of VOC's in Groundwater
TOTAL RISK(3):
Footnotes:
IE-OS
3E-06
5E-05
4E-05
1E-04
4E-05
2E-05
7E-05
2E-07
2E-07
IE-OS
4E-03
1E-02
1E+00
2E-Q2
1E+00
!E-hOO(4)
3E-Q3
1E+03(4)
7E-02
9E-Q5
8E-02
(1) The upper bound individual excess lifetime cancer risk represents the additional probability that an
individual may develop cancer over a 70-yr lifetime as a result of the exposure conditions evaluated.
(2) The hazard index indicates whether or not exposure to mixtures of noncarcinogenic chemicals may
result in adverse effects.
(3) Risks from soil exposure pathways were added into the cumulative risk for each ground water well
grouping.
(4) The hazard index summed for each target organ/critical effect is less than one for this exposure
pathway.
-------
Footnotes:
(1) Although ingestion of ground water
from off-site monitoring wells by
nearby residents is evaluated under the
current land-use condition in the risk
assessment, it may be more appropriate
under hypothetical future land-use
conditions at the site. This is true
since off-site monitoring wells, which
are currently not used for consumption,
are screened in the surficial aquifer
while all private wells which are used
in the vicinity of the landfill are
screened in the lower bedrock aquifer.
(2) The upper bound individual excess
lifetime cancer risk represents the
additional probability that an individual
may develop cancer over a 70-yr
lifetime as a result of the exposure
conditions evaluated.
t-
(3) The hazard index indicates whether or
not exposure to mixtures of
noncarcinogenic chemicals may result
in adverse effects.
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 5
77 WEST JACKSON BOULEVARD
CHICAGO, IL 60604-3590
MAR I 81996
MAR } f t99ir -••'••i'---"- - ^^D!AL RESPONSE SECTION I
REPLY TO THEJ^ZgatgaifiESc HAZRQ WASTE •
R-19J
Mr. George E. Meyer
Secretary
Wisconsin Department of Natural Resources
101 South Webster Street
Madison, Wisconsin 53707
Dear Mr. Meyer:
The United States Environmental Protection Agency ("U.S. EPA")
hereby concurs with the selected remedy in the Record of Decision
("ROD")'completed by the Wisconsin Department of Natural
Resources ("WDNR") for the Boundary Road Landfill Superfund Site
(the "Site"). This concurrence is in accordance with 40 CFR
Section 300.515(e) (2) (i) and (ii) .
U.S. EPA understands that this ROD identifies the final remedy
and/or decision for the Site. The final remedy for this Site
includes the construction of a new soil cover system,
establishment of new vegetation, installation of an active
landfill gas extraction system and continued leachate extraction
in the northern and southern portions of the Site, with a new
leachate extraction system in the north central portion of the
Site to control the source of groundwater contamination.
Extraction of contaminated groundwater at 'the southeast edge of
the Site, construction of new fencing and continuous monitoring
of groundwater, leachate, and the environment are also included
in the final remedy.
U.S. EPA understands that a 3-year groundwater quality evaluation
and potential contaminant source removal in the area of
monitoring well TW24 will begin during the design phase and
Recyclad/RecydabU • Printed with Vegetable Oil Based Inks on 100% Recyded Paper (40% Postconsumer)
-------
unless the results of this evaluation show a significant
improvement in groundwater quality in that area, additional
groundwater extraction measures shall be implemented. The
mcnicoring of che grounawacer will be evaluated aft
years to determine the remedy's compliance with the legal
requirements and the terms set forth in this ROD.
U.S. EPA congratulates the State of Wisconsin for using a common
sense presumptive remedy approach in an expedited time frame, for
the Boundary Road Landfill site.
Sincerely yours,
Valdas V. Adamkus
Regional Administrator
-------
March, 1996
Administrative Record Index
WMI/Boundary Road Landfill, Menomonee Falls
FID# 268152390
Page 1
D
0
c
*
Date
ThJ«
Pages
Author
Recipient
Document Typ«
REPORTS AND STUDIES
1
2
3
4
5
6
7
8
9
1
0
1
1
2/91
4/91
8/91
8/92
12/92
1/93
2/93
4/93
7/93
2/94
9/94
Boundary Road Landfill,
Superfund Site Community
Relations Plan
Monitor Well Evaluation Report
Work Plan: (including the
following documents)
Sampling and Analysis Plan
Quality Assurance Project Plan
Health and Safety Plan
Data Management Plan
t
Remedial
Investigation/Feasibility Study,
Investigative Results and
Analysis Report (Vol. Mil)
Technical Workplan for the
Boundary Road Landfill Baseline
Risk Assessment
Boundary Road Landfill RI/FS
Phase 4 Report
Groundwater Quality Results
Alternatives Array Document
Remedial Investigation Report
(Vol. I-V)
Baseline Risk Assessment
Feasibility Study
25
WDNR
Jim Leverance
Hydro-Search
Robert
Karnauskas
Warzyn & HSI
Warzyn
Clement
International
Corp.
Warzyn
Thomas
Karwoski
Alan Schmidt
Warzyn
John
Hurtenbach
Alan J. Schmidt
Warzyn
Warzyn
Clement Risk
Assessment
Division of ICF
Kaiser Engineers
Warzyn
Gary
Edelstein
Gary
Edelstein
Gary
Edelstein
Gary
Edelstein
Report/Study
Report/Study
Report/Study
Technical
Memorandu
m
Report/Study
Report/Study
Report/Study
Report/Study
Report/Study
Report/Study
Report/Study
-------
March, 1996
Administrative Record Index
WMI/Boundary Road Landfill, Menomonee Falls
FID# 268152390
Page 2
D
0
C
••#'•
1
2
D«t»
7/94
Tltte
Plan Modification Proposal for
the Boundary Road Landfill
(F/K/A Lauer 1 Landfill)
Menominee Falls, Wisconsin
Pag**
Author
RUST
Environment &
Infrastructure
R«cip4«nt
Document Typ«
Report/Study
Request for
modification
GENERAL CORRESPONDENCE
1
2
a
1
3
1
4
1
4
a
1
4
b
1
4
c
1
5
1
6
1
7
1
8
1
9
6/9/81
7/17/90
8/1/90
7/16/90
5/4/90
5/23/90
8/22/90
9/10/90
9/10/90
9/10/90
9/14/90
US EPA CERCLA Section
103(c) Notification of
Hazardous Waste Site Form for
the Lauer Landfill (aka Lauer I)
Lab Report
Env. Repair Contract #SF-90-
01
f
Statement of Work for
Conducting the Remedial
Activities
Clarification of the Application
of NR 1 40 to the Lauer I
Landfill Superfund Site
Application of NR 1 40 to the
Lauer I Landfill Superfund Site
Renaming of site
Letter to attendee of kick-off
meeting
Review of existing conditions
report
History of site
Request to rename site to
Boundary Road Landfill
2
2
33
66
2
2
1
1
1
1
1
Completed by
Waste
Management,
Inc.
N/A
Hydro-Search,
Inc.
Suzanne
Bangert, WDNR
Dave Lindorff,
WDNR
Stewart, David -
WMI
Leverance, Jim -
DNR
Edelstein, Gary
Leverance, Jim -
DNR
Cheely, Susan -
WMI
US EPA
N/A
N/A
Dave
Lindorff,
WDNR
Suzanne
Bangert,
WDNR
Didier, Paul -
DNR
Pittman,
Gene -
Citizen
Hamblin,
Gerald - WMI
Biedrzycki,
Paul-
Division of
Environment
al Health &
Technology
Meyer, Linda
- DNR
US EPA
Form
Report
Contract
Attachment
A to ER
Contract
Internal
Memorandu
m, Attach. B
toER
Contract
Internal
Memorandu
m, Attach. C
toER
Contract
Letter
Letter
Letter
Letter
Letter
-------
March, 1996
Administrative Record Index
WMI/Boundary Road Landfill, Menomonee Falls
FID# 268152390
Page 3
D
O
C
*
2
0
2
1
2
2
2
3
2
4
2
5
2
6
2
7
2
8
2
9
3
0
3
1
3
2
3
3
D«t«
9/17/90
9/25/90
10/15/90
10/30/90
10/3/90
12/13/90
1 2/30/90
1/2/91
1/10/91
1/15/91
1/18/91
1/18/91
2/28/91
3/3/91
Tltk
Health Concerns
Request to rename site to
Boundary Road Landfill
Comments on Task 1 review
Response to DNR's comments
on Task 1
Comments on existing
conditions report
Conditional approval of Task 1
Submittal of draft community
relations plan
Community relation plan
submittal
Administrative record file and
public information record files
Administrative Record File
Letter regarding phone
conversation
Existing monitor well integrity
evaluation
Use of site by soccer club
Letter explaining oversight
services, problems, etc.
Pas**
2
2
5
4
3
2
1
1
1
4
1
4
2
2
Author
Williams, Robert
- US Dept. of
Health and
Human Service
Meyer, Linda •
DNR
Edelstein, Gary
Ales, Steven
Wong, Gene
Karnauskas,
Robert - HSI
Ales, Steve -
DNR
Edelstein, Gary
Ales, Steve -
DNR
Leverance, Jim -
DNR
Leverance, Jim -
DNR
Leverance, Jim -
DNR
Leverance, Jim -
DNR
Ales, Steve -
DNR
Wong, Gene •
HSI
Smith, March -
WMI
Didier, Paul -
DNR
Barker, Francis
Baghat, Snehal
Camp Dresser &
McKee
fUcipi«nt
Edeistein,
Gary
Cheely,
Susan - WMI
Smith, March
-WMI
Edelstein,
Gary
Edelstein,
Gary
Smith, March
-WMI
Pastor, Sue -
EPA
Nelson, John
Schmidt, Jim
-DNR
Edelstein,
Gary
Reid, Ann -
Maude
Shunk Public
Library
Edelstein,
Gary
Ales, Steve
Edelstein,
Gary
Smith, March
-WMI
Edelstein,
Gary
Document Typ«
Letter
Letter
Letter
Letter
Memo
Letter
Letter
Memo
Memo
Letter
Letter
Letter
Letter
Letter
-------
March, 1996
Administrative Record Index
WMI/Boundary Road Landfill, Menomonee Falls
FID# 268152390
Page 4
o
0
c
*
3
4
3
5
3
6
3
7
3
8
3
9
4
0
4
1
4
2
4
3
4
4
4
5
4
6
4
7
4
8
Oaf*
3/6/91
3/7/91
3/19/91
3/19/91
3/20/91
3/21/91
3/26/91
3/28/91
4/2/91
4/3/91
4/9/91
4/10/91
4/10/91
4/11/91
4/19/91
Titi«
Review of project plan
Schedule or approval of work
plan
Comments on work plans
Comments on work plans
First draft review of PRP QAPP
Comments on QAPP
Request for Environmental
Fund Monies for oversight
contract
Handwritten conference call
notes
Conference call notes -
handwritten
SAS Analysis for QAPP
Comments on Risk Assessment
plan handwritten
Comments on Risk Assessment
Plan
Comments on Risk Assessment
Plan
Review of Task 2 RI/FS
Follow up to SOP request
Pag«*
1
2
3
5
8
10
1
3
3
1
3
2
2
6
1
Author
Edelstein, Gary
Edelstein, Gary
Ales, Steve -
DNR
Edelstein, Gary
Schupp, George
-EPA
Edelstein, Gary
Bangert, Susan
Edelstein, Gary
Edelstein, Gary
Novy, Mary Beth
-EPA
Podowski,
Andrew - EPA
Novy, Mary Beth
-EPA
Novy, Mary Beth
Edelstein, Gary
Novy, Mary Beth
• EPA
Rdctpitnt
Smith, March
- WMI
Bangert, Sue
Giesfeldt,
Mark
Schmidt, Jim
-SED
Edelstein,
Gary
Smith, March
- WMI
Novy, Mary
Beth - EPA
Dikinis,
Jonas - EPA
Smith, March
-WMI
Tierney, Ray
Giesfeldt,
Mark
Karnauskas,
Robert -
Hydro-Search
Novy, Mary
Beth
Edelstein,
Gary
Edelstein,
Gary
Smith, March
-WMI
Wong, Gene
- Hydro-
Search
Document Type
Letter
Memo
Memo
Fax
Memo
Fax
Memo
Meeting
Notes
Meeting
Notes
Letter
Memo
Letter
Letter
Letter
Letter
-------
March, 1996
Administrative Record Index
WMI/Boundary Road Landfill, Menomonee Falls
FID# 268152390
Page 5
D
O
C
*
4
9
5
0
5
1
5
2
5
3
5
4
5
5
5
6
5
7
5
8
5
9
6
0
6
1
6
2
Date
5/7/91
5/28/91
5/31/91
6/12/91
6/18/91
6/19/91
6/20/91
6/20/91
6/24/91
6/26/91
7/3/91
7/10/91
7/15/91
7/18/91
Titte
Submittal letter of Task 2 work
plan and Monitor Well
Evaluation Reports
DNR will review revised Task 2
WMI lab choice
Work plan comments
EPA's comments on QAPP
Draft response to work plans
Consultant Change
Completion of Task 2 and
DNR's non-approval
Nomination of Boundary Road
Landfill as an enforcement pilot
program
Planned response to comments
on work plan
A thank you and clarification
on 5/30/91 meeting
Comments from EPA & DNR
regarding revision 1 of work
plan
Handwritten letter with a
summary of what took place
during a phone conversation
Letter giving estimated days
required to perform field
activities
Pag««
1
1
39
2
1
6
1
5
2
8
2
2
1
1
Author
Wong, Gene
Karnauskas,
Robert - Hydro-
Search
Edelstein, Gary
Novy, Mary Beth
-EPA
Ales, Steve -
DNR
Edelstein, Gary
Smith, March -
WMI
Karnauskas,
Robert - Hydro-
Search
Smith, March -
WMI
Edelstein, Gary
Ales, Steven
Giesfeldt, Mark
Asbury, Gregory
Schubert,
William - WMI
Asbury, Greg -
Warzyn
Ales, Steve -
DNR
Karwoskj,
Thomas
Asbury, Greg -
Warzyn
Racipiant
Novy, Mary
Beth - EPA
Smith, March
-WMI
Edelstein,
Gary
Edelstein,
Gary
Smith, March
-WMI
Edelstein,
Gary
Edelstein,
Gary
Smith, March
-WMI
Priddy,
Lynda - EPA
Edelstein,
Gary
Sridharan,
Lakshmi -
DNR
Edelstein,
Gary
Novy, Mary
Beth - EPA
Edelstein,
Gary
Edelstein,
Gary
Document Type
Letter
Letter
Letter
Memo
Fax
Fax
Letter
Letter
Letter
Letter
Letter
Letter
Letter
Letter
-------
March, 1996
Administrative Record Index
WMI/Boundary Road Landfill, Menomonee Falls
FID# 268152390
Page 6
0
0
c
*
6
3
6
4
6
5
6
6
6
7
6
9
7
1
7
2
7
3
7
4
7
5
7
6
7
7
7
8
Date
7/18/91
7/18/91
7/24/91
7/24/91
7/24/91
7/29/91
8/8/91
8/9/91
8/12/91
8/13/91
8/23/91
8/28/91
9/5/91
9/5/91
Titi*
Letter with Lab reports for
private wells
Comments on ecological
assessment
Review of work plan findings
Review of 2nd revision of Task
2 RI/FS
Comments on Task 2 revisions
t
Public Informational Meeting on
Boundary Road Superfund Site
Agenda for Superfund meeting
EPA comments on QAPP
Memo to file regarding the first
public meeting minutes
Letter FYI and use of latest
copy of work plans
Letter giving approval of Task
2 RI/FD project plans
Fax regarding the revised pages
to the work plan
Letter indicating proposed well
movement
Letter transmitting 1 copy of
Decontamination Pad Design
Sketch
Pag**
20
3
1
3
1
1
2
3
1
4
2
1
2
2
Author
Asbury, Gregory
• Warzyn
Edelstein, Gary
Edelstein, Gary
Edelstein, Gary
Felix, Binyoti •
DNR
Edelstein, Gary
Edelstein, Gary
Edelstein, Gary
Edelstein, Gary
Edelstein, Gary
Karwoski,
Thomas
Asbury, Gregory
Warzyn
Asbury, Gregory
- Warzyn
Recipient
Edelstein,
Gary
Smith, March
-WMI
Asbury, Greg
- Warzyn
Smith, March
-WMI
Asbury, Greg
- Warzyn
Smith, March
-WMI
Edelstein,
Gary
Smith, March
-WMI
Asbury, Greg
Karwoski,
Tom -
Warzyn
File
Buss, Dan -
COM
Smith, March
-WMI
Buss, Dan -
COM
Edelstein,
Gary
Edelstein,
Gary
Document Type
Letter
Fax
Fax
Letter
Memo
Press
Release
Meeting
Agenda
Fax
Memo
Letter
Letter
Fax
Letter
Letter
-------
March, 1996
Administrative Record Index
WMI/Boundary Road Landfill, Menomonee Falls
FID# 268152390
Page 7
D
O
C
*
7
9
8
0
8
1
,8
3
8
4
8
5
8
6
8
7
8
8
8
9
9
0
9
1
9
2
9
3
9
4
9
5
D«t«
9/5/91
9/5/91
9/6/91
9/23/91
9/24/91
9/30/91
10/7/91
10/16/91
10/16/91
10/21/91
10/22/91
10/22/91
10/30/91
11/1/91
11/5/91
11/7/91
Titto
Fax regarding landfill
investigative liquids
management
Letter giving EPA approval if
QAPP
Letter correcting DOT
classification
Fax confirming conference call
minutes
Fax confirming conference call
minutes
Fax confirming conference call
minutes t
Fax confirming conference call
minutes
Fax on well depths
Fax on oversight
Fax providing direction on
oversight activities
Letter regarding oversight
activities
Memo on a cover inspection
which was conducted on
10/18/91
Letter regarding the analytical
results and the chain of
custody for the samples
Letter regarding the completed
installation of leachate/gas
wells
Letter regarding a summary of
oversight activities.
Fax regarding Leachate Wells
and proposed parameters
Pag«s
3
3
1
2
1
1
1
10
1
1
2
3
7
1
2
2
Author
Edelstein, Gary
Edelstein, Gary
Smith, March -
WMI
Edelstein, Gary
Edelstein, Gary
Edelstein, Gary
Edelstein, Gary
Karwoski, Tom -
Warzyn
Edelstein, Gary
Edelstein, Gary
Buss, Daniel
Bhagat, Snehal -
COM
Edelstein, Gary
Wayne, Janet -
Warzyn
Smith, March
Buss, Daniel
Bhagat, Snehal -
COM
Karwoski,
Thomas
R*cipi«nt
Ebersohl,
Walt - DNR
Smith, March
-WMI
Edelstein,
Gary
Buss, Dan -
COM
Buss, Dan -
COM
Buss, Dan -
COM
Buss, Dan -
COM
Edelstein,
Gary
Buss, Dan -
COM
Buss, Dan
Edelstein,
Gary
File
Smith, March
-WMI
Morsan,
James - WMI
Edelstein,
Gary
Edelstein,
Gary
Document Typ«
Fax
Letter
Letter
Fax
Fax
Fax
Fax
fax
fax
letter
memo
letter
letter
letter
fax
-------
March, 1996
Administrative Record Index
WMI/Boundary Road Landfill, Menomonee Falls
FID# 268152390
Page 8
D
O
C
*
9
6
9
7
9
8
9
9
1
0
0
1
0
1
1
0
2
1
0
3
1
0
5
Data
11/12/91
11/13/91
11/15/91
11/25/91
12/12/91
12/2/91
12/26/91
1/7/92
1/31/92
Title
Letters requesting permission
to sample private wells in the
area.
\
Letter documenting several
phone conversations regarding
changes or additions to the
work scope.
Letter listing monitoring points
for Round 1 Groundwater
Sampling
Fax regarding oversight
activities
Fax regarding oversight
activities
Letter with enclosures of
copies of all access
agreements.
Response letter to recent
correspondence regarding
sampling activities
Fax regarding oversight
activities
Boundary Rd. Field Sampling
Activities
Page*
20
2
1
1
1
10
2
1
1
Author
Straw, Ann -
WMI
Edelstein, Gary
Asbury, Greg
Karwoski,
Thomas
Warzyn
Edelstein, Gary
Edelstein, Gary
Smith, March -
WMI
Edelstein, Gary
Edelstein, Gary
Asbury, Gregory
- Warzyn
Recipient
Sanders, Ron
Schwartz,
Thomas
Fisher, Brian
Schwartz,
Henry
Magestro,
Joseph
Brill, William
Strauss,
Gerhardt
Liebherr,
Lester
Arthur,
Douglas
Rowe Sand
& Gravel
Karwoski.
Thomas
Asbury,
Gregory
Warzyn
Edelstein,
Gary
Barker,
Francis •
COM
Barker,
Francis
Edelstein,
Gary
Asbury, Greg
- Warzyn
Barker,
Francis -
COM
Edelstein,
Gary
Document Typo
letter
letter
letter
Fax
fax
Letter
Letter
Fax
Letter
-------
March, 1996
Administrative Record Index
WMl/Boundary Road Landfill, Menomonee Falls
FID# 268152390
Page 9
o
o
c
*
1
0
7
1
0
8
1
0
•9
1
1
0
1
1
1
1
1
2
1
1
3
1
1
4
1
1
6
1
1
7
1
1
9
1
2
0
D«t«
3/1 8/92
3/19/92
3/24/92
3/25/92
4/2/92
4/7/92
4/15/92
4/1 6/92
4/23/92
4/24/92
5/5/92
5/26/92
Titta
Letter regarding endangered
resources near project site
Submittal Letter of the Target
Compounds Short List and Well
Location Summary
First Round Private Well
Sampling Results, Boundary
Rd. Landfill Superfund Site
Private Well Results, Target
Compound Short List (TCSL)
and Point of Standards
Application
Sampling of well nests P105
and P106
Expansion of United Waste
Container Storage Area
Boundary Road RI/FS Schedule
Confirmation of Recent
Telephone Conversations
Boundary Road Master
Schedule
Boundary Road Landfill,
Postponement of LCS Tests
RI/FS Work Plan Addendum
Work Plan Amendment and
Revision to Approved Schedule
Pag«*
2
6
52
2
1
3
1
3
6
2
3
2
Author
Weisensel,
Wendy - DNR
Smith, March -
DNR
Edelstein, Gary
Edelstein, Gary
Edelstein, Gary
March, Thomas -
WMI
Asbury, Greg -
Warzyn
Edelstein, Gary
Smith, March -
WMI
Smith, March -
WMI
Asbury, Greg -
Warzyn
Edelstein, Gary
Recipient
Kelly, Jerry -
Warzyn
Edelstein,
Gary
Schmidt,
Jim- SED
Pilarski, Greg
-SED
Smith, March
-WMI
Smith, March
-WMI
Asbury,
Greg/
Karowski,
Tom -
Warzyn
Klett, Roger -
DNR
Edelstein,
Gary
Smith, March
-WMI
Edelstein,
Gary
Edelstein,
Gary
Edelstein,
Gary
Smith, March
-WMI
Document Typ«
Letter
Letter
Memo
Letter
Fax
Letter
Letter
Letter
Letter
Letter
Letter
Letter
-------
March, 1996
Administrative Record Index
WMI/Boundary Road Landfill, Menomonee Falls
FlD# 268152390
Page 10
D
O
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1
2
1
1
2
2
1
2
•3
1
2
4
1
2
5
1
2
6
1
2
7
1
2
8
1
2
9
1
3
0
1
3
1
1
3
2
1
3
3
Daw
7/8/92
8/20/92
8/24/92
9/4/92
9/1 8/92
9/23/92
9/24/92
9/24/92
9/30/92
10/2/92
10/8/92
10/15/92
10/21/92
Titte
Guidelines for Groundwater
Point of Standards Application
at Superfund Sites
Recommendation Acceptance
and Initial Comments,
Technical Memorandum #1
First Round Private Well
Sampling Results, Boundary
Rd. Landfill Superfund Site
Comments on Technical
Memorandum #1
Handwritten Meeting Notes
WMWI Responses to DNR
Comments on Technical Memo
#1
Work Plan Addendum
Fax on Work Plan Addendum
Ron Sanders Property
Denial for Well on Property
Revised Schedule/Revised
Health and Safety Plan
Revised Schedule
Submittal of Work Plan
Addendum
Page*
6
2
1
4
2
8
4
1
1
1
8
3
4
Author
Giesfeldt, Mark -
DNR
Edelstein, Gary
Edelstein, Gary
Edelstein, Gary
Edelstein, Gary
Karwoski,
Thomas/Schmidt
, Alan - Warzyn
Karwoski,
Thomas/Schmidt
, Alan - Warzyn
Edelstein, Gary
Otter, Donald -
WMI
Smith, March -
WMI
Karwoski,
Thomas/Schmidt
, Alan - Warzyn
Schmidt, Alan -
Warzyn
Karwoski,
Thomas/Schmidt
, Alan - Warzyn
Recip4»m
DNR
Personnel
Smith, March
•WMI
Schmidt,
Jim- SED
Pilarski, Greg
-SED
Smith, March
Edelstein,
Gary
Edelstein,
Gary
Schmidt,
Alan/Karwos
ki, Thomas -
Warzyn
McLario,
John,
Attorney
Edelstein,
Gary
Edelstein,
Gary
Edelstein,
Gary
Edelstein,
Gary
Document Typ*
Memo
Letter
Memo
Letter
Meeting
Notes
Letter
Letter
Fax
Letter
Letter
Letter
Fax
Letter
-------
March, 1996
Administrative Record Index
WMl/Boundary Road Landfill, Menomonee Falls
FID# 268152390
Page 11
D
O
C
1
3
4
1
3
5
1
3
6
1
3
7
1
3
8
1
3
9
1
4
0
1
4
1
1
4
2
1
4
3
1
4
4
Oat*
10/21/92
10/22/92
1 0/27/92
1 2/24/92
1/25/93
1/26/93
2/2/93
2/2/93
2/3/93
2/9/93
2/1 5/93
Titi*
Well Location Acceptance
Work Plan Amendment
Summary of Well Data
Submittal of Technical
Workplan
Risk Assessment Technical WP
Comments
Handwritten Conference Call
Notes
Work Plan Addendum for Cone
Penetrometer Tests
Comments on Phase 4
Handwritten Conference Call
Notes
Draft Response to Phase 4
Comments on Phase 4 Report
Pag«*
1
2
34
2
9
2
1
1
1
5
3
Author
Karwoski,
Thomas/Schmidt
, Alan - Warzyn
Smith, March -
WMI
Edelstein, Gary
Karwoski,
Thomas/Schmidt
, Alan - Warzyn
Smith, March -
WMI
Edelstein, Gary
Edelstein, Gary
Edelstein, Gary
Felix, Binyoti -
DNR
Edelstein, Gary
Edelstein, Gary
Edelstein, Gary
Recipient
Edelstein,
Gary
Smith, March
-WMI
Pilarski, Greg
-DNR
Edelstein,
Gary
Smith, March
-WMI
Novy, Mary
Beth - EPA
Karwoski,
Thomas/Sch
midt, Alan -
Warzyn
Smith, March
-WMI
Edelstein,
Gary
Karwoski,
Thomas/Sch
midt, Alan -
Warzyn
Smith, March
-WMI
Smith, March
-WMI
Document Typ*
Fax
Letter
Letter
Letter
Fax
Conference
Call Notes
Fax
Memo
Handwritten
Conference
Call Notes
Fax
Letter
-------
March, 1996
Administrative Record Index
WMI/Boundary Road Landfill, Menomonee Falls
FID# 268152390
Page 12
D
O
C
>
1
4
5
1
4
6
1
4
'7
1
4
8
1
4
9
1
5
0
1
5
1
1
5
2
1
5
3
1
5
4
1
5
5
1
5
6
1
5
7
D*W
2/15/93
2/22/93
2/25/93
2/25/93
2/25/93
4/13/93
4/15/93
5/4/93
5/10/93
5/14/93
5/20/93
5/24/93
5/25/93
Tltfc
RI/FS & bis(2-
Ethylhexy)phthalate (BEHP)
Boundary Road Landfill RI/FS
BEHP Letter of 2/1/93
Comments on Baseline RA
WMWI Responses to DNR*
Comments on Phase 4 Report
Boundary Road Landfill Rl
Report
Comments on RI/FS
Boundary Rd. "HELP" Model
Information
Remedial Investigation Report
Comments on Draft Remedial
Investigation
Review of Alternatives Array
Review of Alternatives Array
Review of Alternatives Array
Pig««
1
1
1
7
2
3
1
16
4
6
3
1
3
Author
Khazae, Charlene
- DNR
Schmidt, Alan -
Warzyn
Smith, March -
WMI
Schmidt, Alan -
Warzyn
Pearsall, Lorraine
- Clement
Karwoski,
Thomas/Schmidt
, Alan - Warzyn
Khazae, Charlene
-DNR
Amungwafor,
Binyoti - DNR
Karwoski, Tom -
Warzyn
Sharp, Rauland -
US EPA
Edelstein, Gary
Morrow, William
- EPA
Sharp, Rauland -
EPA
Bandemehr,
Angela - EPA
Recipient
Edelstein,
Gary
Edelstein,
Gary
Edelstein,
Gary
Edelstein,
Gary
Edelstein,
Gary
Edelstein,
Gary
Edelstein,
Gary
Edelstein,
Gary
Edelstein,
Gary
Smith, March
-WMI
Sharp,
Rauland -
EPA
Edelstein,
Gary
Sharp,
Rauland -
EPA
Document Tvcn)
Memo
Letter
Fax
Letter
Letter
Memo
Memo
Fax
Letter
Letter
Memo
Memo
Memo
-------
March, 1996
Administrative Record Index
WMI/Boundary Road Landfill, Menomonee Falls
FID# 268152390
Page 13
D
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*
1
5
8
1
5
9
1
6
'0
1
6
1
1
6
2
1
6
3
1
6
4
1
6
5
1
6
6
1
6
7
1
6
8
1
6
9
Oat*
5/25/93
5/26/93
5/27/93
5/27/93
5/28/93
6/7/93
6/8/93
6/9/93
6/10/93
6/11/93
6/14/93
6/16/93
ThU
Alternatives Array
Handwritten Notes on
Discussion of Rl Letter
Draft Comments from EPA
Comments on Alternatives
Array
Boundary Rd. Risk Assessment
(RA) Comments *
Additional EPA Geologist
Comments
Comments on Alternatives
Array Document
Submittal letter for RI/RA
Remedial Investigation Report
Response to EPA Comments on
Rl Report
Change Name of Site to
Boundary Road Letter
Fax Changing Estimate
P*g«*
1
2
4
1
2
4
6
1
3
31
1
3
Author
Kleiman, Judy -
EPA
Edelstein, Gary
Sharp, Rauland -
EPA
Amungwafor,
Binyoti - DNR
Edelstein, Gary
Edelstein, Gary
Smith, March -
WMI
Schmidt, Alan -
Warzyn
Schmidt, Alan -
Warzyn
Karwoski,
Thomas/Schmidt
, Alan - Warzyn
Smith, March -
WMI
Wessley, Joe -
Warzyn
R*cipi*nt
Sharp,
Rauland -
EPA
Edelstein,
Gary
Edelstein,
Gary
Smith, March
-WMI
Karwoski,
Thomas/Sch
midt, Alan -
Warzyn
Smith, March
•WMI
Edelstein,
Gary
Edelstein,
Gary
Edelstein,
Gary
Edelstein,
Gary
Sharp,
Rauland -
EPA
Edelstein,
Gary
Document Typ«
Fax
Handwritten
Discussion
Notes
Fax
Memo
Fax
Fax
Letter
Letter
Letter
Letter
Letter
Fax
-------
March, 1996
Administrative Record Index
WMl/Boundary Road Landfill, Menomonee Falls
FID# 268152390
Page 14
D
O
c
*
1
7
0
1
7
1
1
7
2
1
7
3
1
7
4
1
7
5
1
7
6
D*t«
6/1 6/93
6/25/93
6/30/93
7/2/93
7/7/93
7/14/93
7/15/93
Tltk
Fax Responding to Comments
on Draft Baseline RA
Review Memo Attached to
Feasibility Study
*
Response to DNR/EPA
Comments on Alternatives
Array Document
Submittal of Final Rl
w/attachments
Update on Boundary Rd. and
Agency Reviews
Conference Call notes re:
Alternative Array (handwritten)
Geological Comments on Final
Rl
Pages
9
2
14
49
1
1
3
Author
Bailey, Lisa -
Clement
Longest II, Henry
L. - EPA
Wessley,
Joe/Schmidt,
Alan - Warzyn
Schmidt Alan
Karwoski,
Thomas -
Warzyn
Edelstein, Gary
Edelstein, Gary
Sharp, Rauland -
EPA
RdcipUnt
Edelstein,
Gary
Waste
Management
Division
Directors
Regions I, IV,
V, VII;
Emergency
and Remedial
Response
Division
Director
Region II;
Hazardous
Waste
Management
Division
Directors
Region III, VI,
VIII, IX;
Hazardous
Waste
Division
Director
Region X
Edelstein,
Gary
Edelstein,
Gary
Smith, March
- WMI
Edelstein,
Gary
Document Typ*
Fax
Memo
Letter
Letter
w/attachmen
ts
Fax
Meeting
Notes
Fax
-------
March, 1996
Administrative Record Index
WMI/Boundary Road Landfill, Menomonee Falls
FID# 268152390
Page 15
0
0
c
1
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7
1
7
8
1
7
9
1
8
0
1
8
1
1
8
2
1
8
3
1
8
4
1
8
5
Oat*
7/20/93
7/20/93
8/2/93
8/4/93
8/5/93
8/10/93
8/24/93
8/25/93
9/3/93
Titi*
Request for Surface Water
Discharge Limits
Meeting Minutes
Private Well Sample Results
Private Well Sample Results
'
Agenda for 8/10 Meeting
Conference Call Notes • Rl
Issues (handwritten)
Public Meeting Set to Discuss
Boundary Road Landfill
Investigation Results
Remedial Investigation (Rl)
Report Approval, Remedial
Investigation/Feasibility Study
(RI/FS), Boundary Road LF
(F/K/A Lauer I LF)
Revised Risk Assessment
Comments from US EPA
Page*
1
5
1
2
2
1
3
Author
Wessley, Joseph
Schmidt, Alan -
Warzyn
Schmidt, Alan -
Warzyn
Payne, Nancy
Payne, Nancy -
DNR
Edelstein, Gary
Edelstein, Gary
DNR
Edelstein, Gary
Edelstein, Gary
FUcip**nt
Edelstein,
Gary
Edelstein,
Gary
MacArthur,
Douglas and
Mary
Schwartz,
Thomas
Schwartz,
Henry
Brill, William
Fisher, Brian
Magestro,
Joseph
Liebherr,
Lester
Rowe Sand
& Gravel
Sanders, Ron
Smith, March
Karwoski,
Tom/Schmidt
, Al
Felix, Binyoti,
Felix
News Media
Smith, March
-WMI
Forney, Jim -
WMI
Document Typo
Letter
Letter
w/Attachme
nts
Speed Memo
Letters
Fax
Meeting
Notes
News
Release
Letter
Fax
-------
March, 1996
Administrative Record Index
WMI/Boundary Road Landfill, Menomonee Falls
FID# 268152390
Page 16
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1
8
6
1
8
7
'1
8
8
1
8
9
1
9
0
1
9
1
1
9
2
1
9
3
1
9
4
1
9
5
1
9
6
D«u
9/9/93
9/14/93
10/1/93
10/7/93
10/27/93
10/28/93
11/15/93
12/9/93
12/14/93
12/15/93
1 2/23/93
Title
Public Meeting Agenda
Re: Response to U.S. EPA
Second Set of Comments on Rl
Report Boundary Road Landfill
RI/FS
ICF Kaiser's responses to
second round of comments
Conference Call Notes on
Boundary Landfill Risk
Assessment Letter and Points
from I.C.F. 10/1/93 Letter
(handwritten)
Conference Call Notes, Risk
Assessment Comments
(handwritten)
Comments on the Draft
Feasibility Study (FS), Remedial
Investigation/Feasibility Study
(RI/FS), Boundary Road LF
Superfund Site (F/K/A Lauer I
LF)
Boundary Road Landfill Remedy
Selection
Boundary Rd. FS and Technical
Impracticality Waivers
Meeting Notes (handwritten)
Meeting Correspondence
Lauer 1 Superfund Site Final
Feasibility Study
Pages
1
4
1
1
2
8
14
1
1
2
2
Author
Schmidt, Alan -
Warzyn
Karwoski,
Thomas -
Warzyn
Bailey, Lisa
Edelstein, Gary
Edelstein, Gary
Edelstein, Gary
Edelstein, Gary
Edelstein, Gary
Edelstein, Gary
Edelstein, Gary
Hantz, Dave -
DNR
Hadpient
Edelstein,
Gary
Clarke,
Rosita
Edelstein,
Gary
Kuyawa,
Lydia - WMI
Kuyawa,
Lydia - WMI
Kuyawa,
Lydia - WMI
Kuyawa,
Lydia
Edelstein,
Gary
Document Type
Public
Meeting
Agenda
Letter
Letter
Meeting
Notes
Meeting
Notes
Letter
Fax
Fax
Meeting
Notes
Fax
Memo
-------
March, 1996
Administrative Record Index
WMI/Boundary Road Landfill, Menomonee Falls
FID# 268152390
Page 17
D
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*
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7
1
9
8
1
'9
9
2
0
0
2
0
1
2
0
2
2
0
3
2
0
4
2
0
5
2
0
6
2
0
7
Dat*
1/6/94
1 /6/94
1/12/94
1/19/94
1 /1 9/94
1/20/94
2/1/94
2/7/94
2/22/94
2/22/94
3/2/94
Titl*
Boundary Road Landfill
Feasibility Study Comments
Supplemental Response on the
Boundary Road Baseline Risk
Assessment
Boundary Road Landfill Baseline
Risk Assessment
Meeting Notes
Meeting Agenda
Revised Cost estimates By DNR
Submittal of Final Baseline Risk
Assessment for the Boundary
Road Landfill Site
Re: Meeting Minutes, WMI
Response to fax, Conceptual
Proposal, Proposed Plan
Conceptual Cover Layout
Drawing
Conference Call Notes on
Selection Issues and FS
Revisions (handwritten)
Re: Boundary Road Landfill
Risk Assessment Review
Page*
1
32
1
4
4
6
4
3
2
1
1
Author
Clarke, Rosita
Bailey, Lisa -
I.C.F. Kaiser
Clarke, Rosita
Edelstein, Gary
Kuyawa, Lydia -
WMI
Edelstein, Gary
Bailey, Lisa - I.C.
F. Kaiser
Forney, James -
WMI
Kuyawa, Lydia -
WMI
Kuyawa, Lydia -
WMI
Edelstein, Gary
Moran, Erin -
EPA
Recipient
Edelstein,
Gary
Clarke,
Rosita
Edelstein,
Gary
Edelstein,
Gary
Edelstein,
Gary
Lemcke,
Jane
Clarke,
Rosita
Quinn, Ken
Conner, Gary
Forney, Jim
Kuyawa,
Lydia - WMI
Edelstein,
Gary
Clarka,
Rosita - EPA
Edelstein,
Gary
Edelstein,
Gary
Clarke,
Rosita, EPA
Document Typ«
Letter
Letter with
Attachments
Letter
Meeting
Notes
Meeting
Agenda and
Handout
Fax
Letter
Letter
Fax
Meeting
Notes
Memo
-------
March, 1996
Administrative Record Index
WMI/Boundary Road Landfill, Menomonee Falls
FID# 268152390
Page 18
D
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C
*
2
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8
2
0
9
2
1
0
2
1
1
2
1
2
2
1
3
2
1
4
2
1
5
2
1
6
2
1
7
Bat*
3/3/94
3/30/94
4/11/94
5/24/94
6/15/94
7/1/94
7/11/94
8/9/94
8/21/94
8/22/94
TitJ*
Letter of transmittal including a
prelim, cover design calcs. and
bid summary - drainage letter
Re: Boundary Rd. Risk
Assessment
Re: Boundary Road Landfill
Baseline Risk Assessment
Re: Risk Assessment (RA)
Portion of the Remedial
Investigation (Rl) Report
Approval, Remedial
Investigation/Feasibility Stjjdy
(RI/FS), Boundary Road LF
(F/K/A Lauer I LF)
Re: Conditional Approval for
the Revised Feasibility Study
(FS), Remedial
Investigation/Feasibility Study
(RO/FS), Boundary Road LF
Superfund Site (F/K/A Lauer I
LF)
Handwritten notes on
conference call
Notes form Meeting w/WMI
(handwritten)
Boundary Road Landfill (F/K/A
Lauer I Landfill) - Plan
Modification Proposal
Private Well Sampling Results
Boundary Road Landfill -
Review of the Plan
Modification Proposal
Pages
9
2
1
1
9
3
1
1
15
1
Author
Wessley, Joe -
Warzyn
Edelstein, Gary
Clarke, Rosita -
EPA
Edelstein, Gary
Edelstein, Gary
Edelstein, Gary
Edelstein, Gary
Kuyawa, Lydia -
WMI
Schmidt, Alan -
Warzyn
Clarke, Rosita
fUcipfont
Edelstein.
Gary
Lydia
Kuyawa -
WMI
Edelstein,
Gary
Kuyawa,
Lydia - WMI
Kuyawa,
Lydia - WMI
Sridharan,
Lakshmi
Edelstein,
Gary
Edelstein,
Gary
Document Typ*
Letter of
transmittal
Fax
Letter
*
Letter
Letter
meeting
notes
Meeting
Notes
Letter
Letter
Letter
-------
March, 1996
Administrative Record Index
WMI/Boundary Road Landfill, Menomonee Falls
FID# 268152390
Page 19
o
o
c
»
2
1
8
2
1
9
2
2
0
2
2
1
2
2
2
2
2
3
2
2
4
2
2
5
Date
8/25/94
8/29/94
9/16/94
9/20/94
10/26/94
10/28/94
11/3/94
1 1 /23/94
Titte
Your Response to the
Conditional Approval for the
Revised Feasibility Study (FS),
Remedial
Investigation/Feasibility Study
(RI/FS), Boundary Road LF
Superfund Site (F/K/A Lauer I
LF)
WMWI Response to the WDNR
June 1 5, 1 994 Letter Granting
Conditional Approval for the
Revised Feasibility Study (FS),
Boundary Road Landfill
Superfund Site (F/K/A Lauer I
Landfill)
»
Oversight Cost Reimbursement,
Boundary Road LF Superfund
Site (F/K/A Lauer I LF)
Environmental Repair Contract
#SF-90-01
Final Revised Feasibility Study
Report Boundary Road Landfill
Oversight Cost Reimbursement
Boundary Road Landfill
Superfund Site Environmental
Repair Contract #SF-90-01
Boundary Road Landfill -
Feasibility Study Comments
Oversight Cost Reimbursement,
Boundary Road LF Superfund
Site (F/K/A Lauer I LF)
Environmental Repair Contract
#SF-90-01 ("Contract")
Conditional Approval for the
Final Revised Feasibility Study
(FS), Remedial
Investigation/Feasibility Study
(RI/FS), Boundary Road LF
Superfund Site (F/K/A Lauer I
LF)
Pages
3
5
1
1
2
1
1
5
Author
Edelstein, Gary
Kuyawa, Lydia -
WMI
Edelstein, Gary
Quinn, Kenneth
Prattke, Michael
Clarke, Rosita
Edelstein, Gary
Edelstein, Gary
Recipient
Kuyawa,
Lydia
Edelstein,
Gary
Kuyawa,
Lydia
Edelstein,
Gary
Edelstein,
Gary
Edelstein,
Gary
Prattke,
Michael
Prattke, Mike
Document Type
Letter
Letter
Letter
Letter
Letter
Letter
Letter
Letter
-------
March, 1996
Administrative Record Index
WMI/Boundary Road Landfill, Menomonee Falls
FID# 268152390
Page 20
D
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2
3
2
2
3
3
2
3
4
2
3
5
2
3
6
2
3
7
Oat*
11/28/94
1 1 /2S/94
1/9/95
1 /1 9/95
1/20/95
1/27/95
1/30/95
1/31/95
2/3/95
2/3/95
2/3/95
2/16/95
Till*
Boundary Rd. Alternative
Revisions
Revisions to the FS Cost
Estimates for the Preparation of
the Proposed Plan
Comments on Draft Proposed
Plan for the Boundary Road
Landfill Site
Revision to the FS Cost
Estimates for the Preparation of
the Proposed Plan
Boundary Rd. Proposed Plan
Cost Estimates
Public Commentary
Letter Sending Out a Copy of
the Final Feasibility Study
Comments from Air Toxics &
Radiation Branch for Draft
Proposed Plan
Boundary Rd. Plan Modification
Boundary Rd. Plan Modification
Notice of Intent to Modify a
Plan Approval for the Waste
Management of Wisconsin
Boundary Road Landfill (f/k/a
Lauer I Landfill), Lie. No. 001 1
Boundary Road Landfill
Superfund Site Public Meeting
Agenda
Page*
1
6
2
2
1
1
1
2
1
1
10
1
Author
Edelstein, Gary
Edelstein, Gary
Clarke, Rosita
Edelstein, Gary
Edelstein, Gary
Mueller, Melvin
Edelstein, Gary
Clarke, Rosita
Edelstein, Gary
Edelstein, Gary
Sridharan,
Lakshmi - DNR
DNR
Rtciptent
Prattke, Mike
File
Edelstein,
Gary
File
Prattke, Mike
Edelstein,
Gary
Anthony,
Susan -
Milw.
Metropolitan
Sewage
District
Edelstein,
Gary
Prattke, Mike
Clarke,
Rosita
Prattke,
Michael -
WMI
Public
Document Typ«
Fax Cover
Sheet
Letter
w/attachmen
ts
Letter
Memo
Fax Cover
Sheet
Letter
Letter
Fax
Fax Cover
Sheet
Fax Cover
Sheet
Letter
w/Attachme
nts
Meeting
Agenda
-------
March, 1996
Administrative Record Index
WMI/Boundary Road Landfill, Menomonee Falls
FID# 268152390
Page 21
D
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2
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4
2
4
5
2
4
6
2
4
7
2
4
8
2
4
9
Date
2/16/95
2/23/95
2/25/95
2/27/95
3/3/95
4/4/95
4/12/95
4/13/95
4/14/95
4/17/95
4/25/95
5/15/95
TitU
Boundary Rd. Plan Mod.
Meeting Notes (handwritten)
Request for Extension to the
Public Comment Period
Target Compound Short List
Boundary Rd. Proposed Plan
Comment Period Extension
Response to the Notice of v
Intent to Modify a Plan
Approval for the Boundary
Road Landfill (f/k/a Lauer I
Landfill), Lie. No. 001 1 - dated
February 3, 1995
Citizen Letter Regarding Site
Remedy
Request for Extension to Public
Comment Period 0 Boundary
Rd. Landfill Site
Responses to your questions
Request for Extension to Public
Comment Period - Boundary
Road Landfill Site
Boundary Rd. Proposed Plan
Comment Period Extension
April 27 Meeting to Discuss
DRAFT Comments on the
Boundary Rd. Landfill Proposed
Plan
Submittal Letter of Comments
to Proposed Plan, with
attachments
Pag**
2
1
120
1
9
2
1
2
1
1
1
3
Author
Edelstein, Gary
Prattke, Michael
Asbury, Gregory
- Warzyn
Edelstein, Gary
Prattke, Michael
- WMI
Mueller, Melvin
Prattke, Michael
-WMI
Clarke, Rosita
Prattke, Michael
-WMI
Edelstein, Gary
Lemcke, Jane -
DNR
Prattke, Michael
-WMI
Recipient
Edelstein,
Gary
Edelstein,
Gary
Prattke, Mike
-WMI
Edelstein,
Gary
Edelstein,
Gary
Edelstein,
Gary
Edelstein,
Gary
Edelstein,
Gary
Prattke, Mike
Prattke, Mike
-WMI
Edelstein,
Gary
Document Typ«
Meeting
Notes
Letter
Letter w/
attachments
Fax
Letter
Letter
Letter
e-mail
Letter
Fax Cover
Letter
Letter
Letter
-------
March, 1996
Administrative Record Index
WMI/Boundary Road Landfill, Menomonee Falls
FID# 268152390
Page 22
D
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9
a
2
4
9
b
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5
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2
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5
3
2
5
4
2
5
5
D*u
5/15/95
5/15/95
5/16/95
5/17/95
5/17/95
5/19/95
6/5/95
9/8/95
Thte
Attachment A to Mike
Prattke's Cover letter
commenting on the Proposed
Plan
Attachments B-E to Mike
Prattke's letter commenting on
the Proposed Plan
Briefing Memo on the Proposed
Remedy for the Boundary Road
Landfill (Formerly known as
Luer 1) Superfund Site,
Menominee Falls, Wl
•r
Response to DNR Proposed
Plan
Boundary Corp. Landfill
Concern for DNR's
Recommendations for
Boundary Rd. Site
Boundary Rd. Landfill
Boundary Road Landfill
Project Status
Pag«*
12
6
2
2
1
1
4
Author
WMI
WMI
Giesfeldt, Mark -
DNR
Wessley,
Joe/Quinn,
Kenneth -
Montgomery
Watson
Stevens, Pat -
Wisconsin
Manufacturers
and Commerce
Schneiders,
Lolita -
Representative
Wisconsin
Assembly
Edelstein, Gary
Prattke, Michael
-WMI
ffedptant
Meyer,
George
Sylvester,
Susan
Didier, Paul
McCutcheon,
Gloria
Kazmierczak,
Ron
Edelstein,
Gary
Edelstein,
Gary
Edelstein,
Gary
Schneiders,
Lolita -
Representati
ve Wisconsin
Assembly
Edelstein,
Gary
Document Typ«
Detailed
comments
Support
documents
for detailed
comments
Memo
Letter
Letter
Letter
Letter
Letter
-------
March, 1996
Administrative Record Index
WMI/Boundary Road Landfill, Menomonee Falls
FID# 268152390
Page 23
D
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2
5
6
Data
12/19/95
Title
Conversation with Mike Prattke
Regarding Cost Estimates
Pag«*
1
Author
Edelstein, Gary
Recipient
File
Document Type
Memo
FACT SHEETS AND TAPES
7
0
2
5
7
2
5
8
2
5
9
2
5
9
a
8/91
8/93
9/93
2/95
2/1 6/95
Superfund Investigation to
begin at Boundary Road Landfill
Investigation Complete at
Boundary Road Landfill
Boundary Road Landfill
(formerly Lauer Landfill)
DNR Recommends Cleanup
Action
February 16, 1995 Proposed
Plan Meeting Audio Tape
7
10
4
11
DNR
Department of
Health and Social
Services
DNR
Fact Sheet
Fact Sheet
Fact Sheet
Fact Sheet
Cassette
Audio Tape
GUIDANCE AND REFERENCE DOCUMENTS
2
6
0
2
6
1
2
6
2
2
6
3
2
6
4
2
6
5
8/25/93
2/91
2/92
9/90
9/93
9/93
Region 5 Standard Operating
Procedure for Validation of CLP
Organic Data,
Conducting Remedial
Investigations/Feasibility
Studies for CERCLA Municipal
Landfill Sites
Guidance on Remedial Actions
for Contaminated Groundwater
at Superfund Sites
Streamlining the RI/FS for
CERCLA Municipal Landfill
Sites
Presumptive Remedies: Policy
& Procedures, EPA 540-F-93-
047
Presumptive Remedy for
CERCLA Municipal Landfills,
EPA 540-F-93-035
307
9
5
8
14
EPA OSWER
EPA
EPA OSWER
EPA OSWER
EPA OSWER
U.S. EPA
Region 5 CRL
Guidance
Document
Guidance
Document
Guidance
Document
Guidance
Document
Quick
Reference
Fact Sheet
Quick
Reference
Fact Sheet
-------
March, 1996
Administrative Record Index
WMI/Boundary Road Landfill, Menomonee Falls
FID# 268152390
Page 24
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7
2
2
7
3
2
7
4
2
7
5
2
7
6
2
7
7
2
7
8
Oat*
10/18/89
2/92
1/92
11/89
11/89
4/90
1/81
4/13/87
4/19/88
6/1/85
7/23/87
6/1/86
12/1/86
Titl*
Considerations in Groundwater
Remediation at Superfund Sites
In-Situ Bioremediation of
Contaminated Groundwater
Chemical Enhancements to
Pump and Treat Remediation
Groundwater Issue
Guide to Developing Superfund
Proposed Plans
Feasibility Studies:
Development and Screening of
Remedial Action Alternatives
Guide to Selecting Superfund
Remedial Actions
Costs of Remedial Response
Actions at Uncontrolled
Hazardous Waste Sites,
Environmental Review
Requirements for Remedial
Actions
Information on Drinking Water
Action Levels
EPA Guide for Minimizing the
Adverse Environmental Effects
of Cleanup of Uncontrolled
Hazardous Waste Sites,
RI/FS Improvements
Superfund Remedial Design and
Remedial Action Guidance
Superfund State Lead Remedial
Project Management Handbook
Pag««
10
13
22
6
7
9
164
6
17
250
11
100
120
Author
EPA OERR
EPA OSWER
EPA OERR
EPA OERR
EPA OERR
EPA OERR
Rishel et al.
EPA OERR
EPA OSWER
EPA
Environmental
Research
Laboratory
EPA OERR
EPA OERR
EPA OERR
Rscjf4@nt.
Document Typ«
Guidance
Document
Guidance
Document
Guidance
Document
Guidance
Document
Guidance
Document
Guidance
Document
Guidance
Document
Guidance
Document
Guidance
Document
Guidance
Document
Guidance
Document
Guidance
Document
Guidance
Document
-------
March, 1996
Administrative Record Index
WMI/Boundary Road Landfill, Menomonee Falls
RD# 268152390
Page 25
D
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8
0
2
8
1
2
8
2
2
8
3
2
8
4
2
8
5
2
8
6
2
8
7
2
8
8
2
8
9
2
9
0
2
9
1
D«t«
3/1/87
7/1/88
2/1/88
9/1/82
8/1/78
7/1/82
11/1/85
8/1/84
12/1/86
8/88
8/89
12/19/86
in/87
Till*
Data Quality Objectives for
Remedial Response Activities:
Development Process
Laboratory Data Validation
Functional Guidelines for
Evaluating Inorganics Analyses
Laboratory Data Validation
Functional Guidelines for
Evaluating Organics Analyses
Evaluating Cover Systems for
Solid and Hazardous Waste
Guidance Manual for
Minimizing Pollution From *
Waste Disposal Sites
RCRA Guidance Document:
Landfill Design Liner Systems
and Final Cover,
Leachate Plume Management,
Ground-Water Protection
Strategy
Guidelines for Ground- Water
Classification Under the EPA
Ground-Water Protection
Strategy
CERCLA Compliance with
Other Laws Manual
CERCLA Compliance with
Other Laws Manual: Part II
Final RCRA Comprehensive
Ground-Water Monitoring
Evaluation Guidance Document
Alternative Concentration Limit
Guidance Part 1 , ACL Policy
Information Requirements,
P*3«*
150
20
45
58
83
30
590
65
600
appr
ox.
250
appr
ox.
150
55
124
Author
EPA OERR
EPA
EPA
Lutton, et al.
Tolman, et al.
EPA
Repo, et al.
EPA, Off. of GW
Protection
EPA Off. of GW
Protection
EPA OERR
EPA OSWER
Lucero, EPA
EPA OSW/WMD
Recipient
Document Typ«
Guidance
Document
Guidance
Document
Guidance
Document
Guidance
Document
Guidance
Document
Guidance
Document
Guidance
Document
Guidance
Document
Guidance
Document
Guidance
Document
Guidance
Document
Guidance
Document
Guidance
Document
-------
March, 1996
Administrative Record Index
WMI/Boundary Road Landfill, Menomonee Falls
FID# 268152390
Page 26
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2
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7
2
9
8
2
9
9
3
0
0
3
0
1
3
0
2
3
0
3
D«t«
2/1/88
5/1/87
4/19/88
11/25/85
5/16/88
1 2/24/86
6/24/85
6/1 /88
8/1/85
10/1/86
2/89
4/1/86
Titl«
Guidance Document for
Providing Alternate Water
Supplies
Quality Criteria for Water 1986
Information on Drinking Water
Action Levels,
Endangerment Assessment
Guidance
Interim Guidance on Poterftially
Responsible Party Participation
in Remedial Investigations and
Feasibility Studies
Interim Guidance on Superfund
Selection of Remedy,
RCRA/CERCLA Decisions Made
on Remedy Selection
Community Relations in
Superfund: A Handbook
Toxicology Handbook
Superfund Public Health
Evaluation Manual,
Methods & Method Detection
Limits for Chapter NR 219
Superfund Exposure
Assessment Manual
Pag«*
64
325
17
11
37
10
3
188
126
500
21
160
Author
EPA OERR
EPA Off. of
Water
Regulations and
Stds.
Fields EPA
Porter
EPA/OSWER
Porter
EPA/OSWER
Porter
EPA/OSWER
Kilpatrick
EPA/OWPE
EPA OERR
Life Systems Inc.
EPA OSWER
EPA OERR
Recipient
Document Typ«
Guidance
Document
Guidance
Document
Guidance
Document
Guidance
Document
Guidance
Document
Guidance
Document
Guidance
Document
Guidance
Document
Guidance
Document
Guidance
Document
Technical
Guidance
Guidance
Document
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