PB96-964105
                                EPA/ROD/R05-96/299
                                August 1996
EPA Superfund
      Record of Decision:
       Kohler Company Landfill,
       Kohler, WI
       6/26/1996

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                               RECORD OF DECISION
                            Kohler Company Landfill
                                   Kohler,  WI

                           GROUNDWATER OPERABLE UNIT
                                  FINAL  ACTION
 Site  Name  and Location
 Kohler  Company Landfill  is  located near  Kohler,  in  Sheboygan  County,  WI.  The
 40  acre industrial  landfill is  nearest the Village  of  Kohler  and  the  Kohler
 Company Plant,  and  is  bordered  by the Sheboygan  River, Highways A and PP  and
 undeveloped property which  is part of Kohler  Company's 800-acre River Wildlife
 Reserve.

 Statement  of  Basis  and Purpose

 This decision document represents the selected final remedial action  for  the
 site, and  addresses the  groundwater operable  unit by amending the source
 control ROD.   The ROD  for the source control  operable  unit was signed in  1992.
 This final action was  developed in accordance 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 to  the extent practicable,  the National Contingency Plan  (NCP).   The
 attached Summary of Remedial Alternatives identifies the information  contained
 in  the  administrative  record for  this site upon  which  the selection of the
 remedial action is  based.

 The EPA concurs with the selected final  action.  The 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 is Alternative  11,  base cap  and groundwater interceptor
 drain,   that addresses  groundwater  contamination  migrating from the landfill.
 This alternative includes:
            construction of the multilayer cap and institutional  controls
            selected under  the  1992 Source Control ROD, and
            the construction of a groundwater interceptor drain along the
            eastern and  southern downgradient edge of  the landfill, to an
            approximate  depth of  10',  approximately 2500'  long,  to intercept
            contaminated groundwater by  replacing the  toe drain identified in
            the 1992 Source Control ROD,
            natural  attenuation to  restore the contaminated groundwater which
            has already  migrated past the edge of waste,
            discharge  of collected  groundwater to a forcemain which passes
            near the landfill site  for eventual  discharge to the  Sheboygan
            Sewage  Treatment Plant, and
            long term monitoring to measure the  effectiveness of  the remedy.

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  that employ treatment that
reduces the toxicity, mobility or volume as a principal element because it
reduces toxicity,  mobility or volume.

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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 five years
after the commencement of this source control remedial action.

This groundwater operable unit is consistent with the source control ROD for
the site.
                  F
George Meyerv
Wisconsin Det
'ecretary
tment of Natu:
                              Date
Resources

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              UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                               REGION 5
                        77 WEST JACKSON BOULEVARD
                          CHICAGO, IL 60604-3590
                                  20 IMS
                                  L mu
                                             REPLY TO THE ATTENTION OF:
                                                    R-19J
Mr. George  E.  Meyer
Secretary
Wisconsin Department of Natural Resources
101 South Webster Street
P.O. Box 7921
Madison, Wisconsin 53707
Dear Mr. Meyer:

In accordance with 40 C.F.R. §300.515(e)(2)(I) and  (ii),  the
United States Environmental Protection Agency  ("U.S.EPA")  hereby
concurs with the alternative selected in the enclosed Decision
Document prepared by the Wisconsin Department of Natural
Resources  ("WDNR") for the Kohler Company Landfill Superfund Site
("the Site") .  U.S.EPA believes  that the selected remedy is the
most appropriate solution to remediate the contamination  at the
Site.  However,  U.S.EPA would not  have characterized the  remedy
selected as  a permanent solution,  given the nature  of the wastes
remaining  at the Site.

If you have  any  questions regarding this matter, please contact
Steve Padovani of my staff at  (312)  353-6755.  We look  forward to
continued  positive working relationship with the WDNR.
Sincerely yours,
Valdas V. Adamkus
Regional Administrator
         Recycled/Recyclable . Printed with/vegetable Oil Based Inks on 100% Recycled Paper (40% Postconsumer)

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                           RECORD OF DECISION SUMMARY
                            Kohler Company Landfill
                                   Kohler,  WI
 I.     SITE DESCRIPTION
 The  Kohler Company Landfill site was  listed on  the  National  Priorities  List
 (NPL)  by EPA in 1983,  and a remedial  investigation  and  feasibility study
 (RI/FS)  for the site was  conducted.   The  Source Control Operable  Unit  (SCOU)
 Record of Decision (ROD)  was signed in 1992.  This  ROD  describes  the selected
 final  remedy for the Groundwater Operable Unit  (GWOU).

 The  Kohler Company Landfill site is located in  the  NE 1/4  of the  SE 1/4 of
 Section 29,  T15N,  R23E within the corporate limits  of in the Village of
 Kohler,  Sheboygan County,  Wisconsin  (Figure 1).  The landfill is  situated on
 an 82-acre parcel of land which  is bounded on the south, east and far west by
 the  Sheboygan River,  to the west and  south by Hwy.  A and to  the north by
 County Highway PP,  formerly State Highway 28.   Approximately one-half of the
 permitted 82-acre parcel  has never been used for disposal  activities.

 The  landfill is situated  within  the corporate limits of the  Village of  Kohler.
 The  Village of Kohler,  the City  of Sheboygan Falls, and the  City  of Sheboygan
 are  located along the  Sheboygan  River within a  4 mile radius of Lake Michigan
 and  the Sheboygan River mouth.   In the immediate vicinity  of the  site,  the
 principal demographic  feature is the  Village of Kohler  and the Kohler Company
 plant  and facilities.   The plant in Kohler,  Wisconsin employs approximately
 4,500  persons.   Kohler Company owns the land surrounding the landfill  (except
 for  Highways A and PP)  which is  undeveloped and is  part of Kohler Company's
 800-acre  River Wildlife Reserve.   Access  to the River Wildlife Reserve  is
 limited to members  of  the  reserve.  The reserve is  located immediately
 adjacent  to the landfill  to the  east,  south, and west.   Highway PP  and  the
 Kohler Plant grounds are  located north of the landfill  (Figure 1).  County
 Highway PP is a principal  transportation  artery between the  Village of  Kohler
 and  City  of Sheboygan.  No proposals  for  additional transportation  routes or
 arteries  in the landfill vicinity are known to  exist.

 The  landfill  has been  in operation since  the 1950s, primarily for the disposal
 of foundry and manufacturing wastes (foundry sands, pottery  cull,  and clay
 slurry) produced by the Kohler Company manufacturing facilities.   It has been
 estimated,  based on knowledge  of prior operations and a  review of  current
 waste  disposal  records, that the majority of the volume  of waste  in the
 landfill  is  comprised  of foundry wastes including sand,   cores, dust collector
 waste,  and slag,  and pottery wastes including cull, clay,  molds,  and clarifier
 waste,  with foundry sand constituting the  overall majority.   Information
 obtained  during the completion of  borings  through the landfill indicates that
 the  waste  materials present  in the landfill  did not vary significantly with
 depth  or  laterally  across  the  landfill  nor  has  the composition of the wastes
 deposited  in  the landfill  varied significantly  during prior  operations.  These
 waste  streams  are considered to  be non-hazardous under  RCRA.   Very  little
 municipal  waste has been disposed  of  in the  landfill.   Therefore, there  is
 little potential  for waste  in  materials to  decompose and generate gas.

 Information  obtained from  the  Kohler  Company, Wisconsin  Geological and
National History Survey (WGNHS),  the  U.S.  Geological Survey,   and  local public
water  supply  departments was used  for  the residential well survey.  Public
 drinking water  in the vicinity of  the  site  is derived from Lake Michigan.
Residences within the corporate  limits  of the Village of Kohler,  Sheboygan
 Falls, and the  City of  Sheboygan are  on public water supplies derived from
Lake Michigan.   The Village  of Kohler  formerly used deep water supply wells,
which  are  no  longer in  use.


The geologic materials  at  the  landfill  consist of unconsolidated glacial and
alluvial sediments  underlain by  sedimentary dolomite bedrock.  The native
materials  which underlie the landfill  consist of approximately 20 to 100 ft of

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SOURCE: USGS 7.5 Minwe Topographic Map. SHEBOYGAN FALLS, WISCONSIN Quadrangle, 1973
          N
    1000   2000
           •
       SCALE IN FEET
4000
  ^GERAGHTY
     & MILLER, INC.
    EnriroitmtHtal Serrieet
                                                    FIGURE 1
                                         SITE LOCATION MAP
                                     KOHLER COMPANY LANDFILL
                                            KOHLER, WISCONSIN

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 glacial till of Wisconsin-age and younger alluvium deposited by the  Sheboygan
 River.   The till can be stratigraphically divided into  three units.   The  upper
 till  consists of clayey sandy silt with some  interbedded  clay and  sand  and
 averages 25 ft in thickness.   A silty clay layer  with occasional zones  of fine
 silty sand occurs below the  upper till unit.   This middle till averages
 approximately 20 ft thick.   The lower till unit is characterized by  a poorly
 sorted material consisting of clay,  silt,  sand, and dolomite gravel.  The
 lower unit averages approximately 15 ft thick.  Underlying the unconsolidated
 sediments is fractured Niagaran Dolomite bedrock  of Silurian-age.  Local
 weathering of the buried bedrock surface is evident, but  not prominent.   The
 dolomite underlying the region is approximately 700 ft  thick.


 II.    SITE HISTORY AND ENFORCEMENT ACTIVITIES

 The site is owned by Kohler  Company.   Kohler  Company has  operated  this  waste
 site  since the 1950s.   General landfill practices  between the  1950s  and mid-
 1970s consisted of the construction of cells  into  which wastes were  placed and
 other standard filling practices.   During this period,  practices also included
 the construction of waste disposal pits including  the Old Waste Pit,  two  burn
 pits  (the Northern and Southern Burn Pits), and a  nonflammable liquids
 disposal pit which was located in a portion of the Northern  Burn Pit.   A
 suspected pit was also identified by US EPA.  The  approximate  location  of the
 pits,  the approximate  limits  of the fill,  and the  approximate  82-area parcel
 on which the landfill  is  located are presented in  Figure  2.  Waste streams
 which were disposed of in select pits included hydraulic  oils,  solvents,  paint
 wastes,  enamel powder  (containing lead and cadmium), lint  from brass
 polishing,  and chrome  plating sludges.

 Beginning in 1975,  all hazardous waste liquids  (by current definition under
 RCRA)  were shipped off-site.   Disposal of  all solid hazardous  waste  (by
 current  definition under  RCRA)  in the landfill ceased prior  to 1980.  Since
 implementation of the  hazardous waste requirements  under  the RCRA in  November,
 1980,  all  RCRA-regulated  wastes (hazardous) have been shipped  off-site  for
 disposal.

 Other minor waste streams that had at one  time or  another been disposed of in
 the landfill  included  sediments from two  settling  lagoons constructed in  1972
 and operated by the Kohler Company pursuant to a WDNR permit to reduce  total
 suspended solids  content  of industrial  process water prior to  discharge and
 Sheboygan  River  sediments.  The two  lagoons were dredged of  sediment  in 1978,
 1982,  1985,  1988,  and  1989 and the  sediment was placed  into  the landfill.  The
 dredged  material  consisted primarily of  sand and clay,   and were found to  be
 non-hazardous  through  appropriate  testing.  In 1976, some foundry wastes  which
 could have  included floodplain soils  were  excavated and disposed in the
 landfill,  thereby introducing  PCBs  into  the landfill. In 1978, a Village  of
 Kohler sewer  construction project,  which crossed the Sheboygan River, produced
 approximately  75  to 85  cubic yards  of  sediment which were landfilled.   These
 sediments  were  tested  and contained  low  levels of polychlorinated biphenyls
 [range 1.3  to  37.5  mg/kg  (ppm)].   The Village of Kohler has also disposed of
municipal-related material in  the  landfill.

By mid-1971, a waste pit had been  constructed at the western boundary of  the
 landfilled  area  (referenced as  "Old Waste  Pit").  Waste liquids, including
oils,  solvents, and sludges were placed in the Old Waste Pit until mid-1974.
Abandonment of the  Old Waste Pit,  including the physical removal and  transport
off-site of all remaining waste  liquids, took place in  1976.  These liquids,
predominately  oil,  were recycled by Shell  Oil Company.

As the western half of the landfilled area reached appropriate elevation,  new
disposal cells were developed  to the  east.  By 1973, three cells had been
started  for the disposal of non-hazardous  solid waste and slurry.   A
triangular  area about  12 acres  in  size was employed for these wastes.  By May,
1984,  seven additional non-hazardous waste disposal cells were in various
stages of use.  These  seven cells were located over the original western half
of the landfilled area.  Non-hazardous solid wastes and slurries were the

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Kohler Company Landfill Site
          Kohler, Wisconsin
                                 /  A


                                 •'  ^
                        Non-Flammabla Pit / ^   , '

                                • A
                              ^Southern / '

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1 1
I \
x ' N Legend
^ \ -~*^tii&Kto~-^-
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                                           Figure 2

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 primary types  of wastes disposed in these  areas.   By May,  1989,  a  single
 disposal cell  was in use in the  northern portion  of  the  eastern  half  of the
 site.   Since  1990,  solid wastes  have been  placed  along the western slope  of
 the  landfill,  while waste slurries  have  been placed  in shallow trenches
 located in the northern portion  of  the eastern  half  of the site.

 Accurate records of the volume of waste  disposed  in  the  landfill are
 unavailable for most of its operating history.  However, Kohler  Company has
 prepared estimates  at various times.  Based  on  a  three week survey in October,
 1976,  it was  estimated that a yearly volume  of  90,111 yd3 of waste was
 generated.  Waste volume estimates  were  also prepared in October and  November,
 1981 which calculated that the annual volume of waste disposal in  the landfill
 was between 50,000  yd3 and  70,000 yd3. Another  estimate  made in  1990  which
 indicated that about 45,000 yd3 of solid waste were generated per year.  The
 1990 report also documents volume of waste from various  collection points.
 These  waste volume  figures are general estimates  due  to  the lack of
 information and assumed compaction  factors for  the various  waste types.   More
 precise estimates of the disposed volume have been maintained  since 1990.
 Annual waste volumes are 55,881  yd3 and 57,101 yd3 for 1990 and 1991,
 respectively.   These volumes have been confirmed  using annual  topographic
 survey techniques.

 The disposal of nonhazardous sludge  dredged  from  the  two settling  lagoons
 located southwest of the landfill occurs on  an  annual or semi-annual  basis.

 After  reviewing data from this site,  the WDNR recommended  to EPA that the  site
 be included on the  National Priorities List  (NPL).  The  site was listed on the
 NPL in 1983.   In 1985,  Kohler entered into an Administrative Order  by Consent
 (US EPA Docket Number V-W-85-C-018,  Sept.  30, 1985) to perform a remedial
 investigation  and feasibility study  (RI/FS)  under the Comprehensive Response,
 Compensation and Liability Act ("CERCLA).

 The RI/FS  for  the SCOU was  completed in  1991.   The EPA issued a proposed plan
 in October  1991.  The proposed plan  selected capping with an interceptor drain
 as the source  control remedy.  The SCOU  ROD  was finalized  in 1992.  The lead
 for the  site was  then passed to  the  State  to oversee  the SCOU design  and
 implementation,  and to finish RI/FS  activities  for the groundwater  operable
 unit (GWOU), and design  and implementation of a selected groundwater  remedy.
 These  activities  are being  conducted  under State  Solid Waste authorities.


 III.   COMMUNITY PARTICIPATION

 A Community Relations Plan  for the site was  finalized by US EPA in April 1987.
 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 and
 the administrative  record have been established and made available  to the
 public at the  Kohler Public  Library.

 In April, 1996,  WDNR released the GWOU Proposed Plan, identifying use of a
 groundwater interceptor  trench in addition to the base cap  selected in 1992 as
 the preferred  remedy as  well as descriptions of other alternatives evaluated.
 On May 2, 1996,  the  WDNR  and the Wisconsin Department of Health and Social
 Services  (WDHSS)  held a public informational meeting at the Kohler Village
Hall.  The meeting was held to discuss the site and to explain the cleanup
 alternatives.   Approximately 30 people attended this meeting.

A notice of availability  of the records used to select a remedy and of the
proposed plan was issued  on April 18, 1996.  Press releases were sent to The
 Sheboygan Press newspaper and to all  local media.   The public comment period
was from April  22,  1996  to May 21, 1996.   All comments which were received
 during that time  and at  the public meeting are addressed in the attached
Responsiveness  Summary.  A  transcript of  the meeting has been included in the
Administrative Record.

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Based upon comments  received during the public comment period, and other
information, WDNR has retained the selected alternative.  WDNR has selected
Alternative  11, Base Cap with Interceptor Trench as the best final,
groundwater  control  remedy.  This remedy provided the most effective means of
capturing contaminated groundwater and for allowing for restoration of the
aquifers in  a reasonable period of time, for the lowest cost.  Responses to
comments received during the public comment period are included in the
Responsiveness Summary attached to this ROD.

Local residents created the Sheboygan County Water Quality Task Force in 1984.
This group was active in the past with education/information activities.  The
Lake Michigan Federation  (LMF) has been active in Remedial Action Plan
activities for the Sheboygan River Area of Concern  (conducted under the Clean
Water Act/Great Lakes Water Quality Agreement), and in reviewing activities
conducted at both the Kohler Company Landfill and the Sheboygan River and
Harbor Superfund sites.  Others that have also participated in Superfund or
the Remedial Action  Plan process include local participants or chapters of the
Sierra Club  and the  Izaak Walton League.  The LMF received a Technical
Assistance Grant from EPA in March, 1994.  The purpose of the grant is to
allow persons affected by Superfund sites to retain their own technical staff
to explain the Superfund process and the data generated during the RI/FS.
WDNR attended a RAP  meeting in May 19, 1994 and a LMF-sponsored meeting on
August 24, 1995 to discuss progress at both the Kohler Co. Landfill and the
Sheboygan River and  Harbor Superfund sites.

A Public Health Assessment for the Kohler Company Landfill site was finalized
by the Division of Health, in January 1995.  A preliminary health assessment
had been sent out for public comment in 1989.  Recommendations from the Public
Health Assessment included to continue public education/awareness activities
regarding the state  health advisory on consuming sport-caught fish from the
area/Sheboygan River, monitoring groundwater quality in the dolomite on the
far side of  the Sheboygan River, and analysis of leachate and runoff waters
for PCBs.

The Proposed Plan for the SCOU  was made available for public comment in
October 1991.  Notices announcing the availability of the proposed plan were
published in the Sheboygan Press.   A public meeting to explain the Proposed
Plan,  and to receive public comments was held on October 15,  1991. The public
comment period was held between October 14, 1991 and December 14,  1991.   All
comments which were  received by EPA 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 were addressed in the
Responsiveness Summary,  which was part of the SCOU ROD.

The public participation requirements of the community relations requirements
in the National Contingency Plan at 40 CFR s. 300.430 (f) (3)  have been met in
this final remedy selection process.   All the documents listed above are
available in the Administrative Record maintained at the Kohler Public Library
and at GEF II,  Madison,  WI.


IV.   SCOPE AND ROLE OF THE RESPONSE ACTION

Contaminated groundwater at the site poses a potential threat to human health
and the environment because of the risks from possible ingestion of or dermal
contact with the groundwater should wells intercepting contamination be used.
The selected remedial action,  described as Alternative 11, Base Cap and
Groundwater Interceptor Trench,  addresses the principal threats posed by site
conditions by containing or controlling the groundwater contamination at the
site.

Remedial actions at the site were into two activities or "operable units".
The first operable unit,  the source control operable unit, involves remedial
actions taken to control the source of contamination to groundwater.   This ROD
addresses remedial actions necessary to control movement of contaminated
groundwater,  clean up groundwater and achieve compliance with established

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 groundwater quality standards.   WDNR has  determined that  this  groundwater
 control  remedy is  consistent  with the source  control operable  unit  remedy  for
 the  site.


 V.     SUMMARY OF SITE  CHARACTERISTICS

 A.     Topography

 The  original site  topography  has changed  considerably as  a  result of
 landfilling operations,  which are ongoing.  The original  topography of  the
 property,  as depicted  in a  1925  topographic map,  sloped gently toward the
 southeast.   Elevations ranged from approximately  630 feet (ft)  above mean  sea
 level  (msl)  along  the  western margin of the 82-acre  parcel  to  approximately
 590  ft msl  at the  eastern side near  the Sheboygan River.  Presently the
 surface  elevation  of the majority of the  eastern  portion  of the landfill is at
 approximately 660  ft msl.   The base  of the landfill  area  along the  eastern
 edge marks  the Sheboygan River 100-year flood plain.  The disposal  mound is
 generally  rectangular  in shape with  its major axis  trending north-northwest.
 The  surface terrain of the  landfill  slopes average  between  three and five
 percent, and side  slopes of the  waste disposal mound range  from a 3:1  (3
 horizontal  to 1 vertical or 33 percent slope) to  4:1 (4 horizontal  to 1
 vertical or 25 percent slope).

 B.     Geology/Hydrogeology

 The  geologic materials at the landfill consist of unconsolidated glacial and
 alluvial sediments  underlain  by  sedimentary dolomite bedrock.   The  native
 materials which underlie the  landfill consist of  approximately 20 to 100 ft of
 glacial till of Wisconsin-age and younger alluvium deposited by the Sheboygan
 River.  The till can be  stratigraphically divided into three units.  The upper
 till consists of clayey sandy silt with some interbedded  clay  and sand and
 averages 25  ft in  thickness.  A  silty clay layer with occasional zones of fine
 silty  sand  occurs below the upper till unit.  This middle till  averages
 approximately 20 ft thick.  The  lower till unit is characterized by a poorly
 sorted material consisting  of clay,  silt, sand,  and  dolomite gravel.  The
 lower  unit  averages approximately 15  ft thick.  Underlying the  unconsolidated
 sediments is fractured Niagaran  Dolomite bedrock of  Silurian-age.   Local
 weathering  of the buried bedrock surface is evident,  but  not prominent.  The
 dolomite underlying the  region is  approximately 700  ft thick.

 The  landfill is  underlain by  several  hydrostratigraphic units  including a
 relatively  permeable fill material,  alluvium, and the upper till unit.   The
 clay-rich middle till, which  constitutes a confining  layer to units beneath it
 underlies the above units.  The  lower till unit and  the dolomite bedrock exist
 below  the clay-rich middle  till  unit.  All of these units are at least
 partially saturated; however, in the  river valley the upper till unit and
 middle till  unit at Well Nest 2  have  been eroded away by  the Sheboygan River
 and are, therefore, not present  throughout the entire site.   Ground-water flow
 is directed  towards, and discharges  into,  the Sheboygan River that surrounds
 the site to  the  west,  south and  east.  The area investigated comprises a small
 ground-water watershed with recharge  derived locally.  Regional flow in the
 deep bedrock is  to the east and  discharges into Lake Michigan.   An important
 site feature  is  the middle  till  unit.  Evidence for the confining nature of
 the middle  till  is the low  horizontal and vertical hydraulic conductivities
 (approximately 10"6  cm/sec)  and that  pumping  (off-site and on-site) does not
 impact water  levels in monitoring wells screened above the middle unit.
Additionally,  samples  collected  from  the middle till consist of clay or silty
 clay.  Occasionally, individual  pieces of gravel within a clay matrix and thin
 layers of sand were observed  in  the middle till.  The middle till  unit impedes
 the downward  movement  of ground  water, however,  over the operational history
 of the landfill, chemical constituents have migrated through the middle till
 and into the  underlying geologic units.  Depth to the potentiometric surface
of ground water  in the glacial materials ranges from approximately less than 1
 foot to 75  feet  and from above the ground surface (flowing wells)  to 73 feet
below the ground surface in the  bedrock.

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Because  the  flux of  ground-water  from  the  site within  the unconsolidated
glacial  and  alluvial units  is  significant,  the upper aquifer  is most
susceptible  to  constituents migrating  from landfill materials.  However,  the
bedrock  in the  area  of  the  site is  the only hydrostratigraphic unit which
serves as a  viable aquifer.  The  yield of  water  from the bedrock  is primarily
from  fractures,  but  due to  the significant thickness of dolomite  in the
region,  large quantities (e.g., hundreds of gallons per minute) of water  can
be pumped.   The primary source of drinking water for the area is  generally
derived  from Lake Michigan.

C.    Hydrology

The Sheboygan River  is  located immediately east  of the landfill.  The
headwaters of the Sheboygan River occur in eastern Fond du Lac County
approximately 40  miles  west of Kohler, Wisconsin.  The river  flows 178 stream-
miles east through the  Sheboygan  Marsh and toward Lake Michigan while draining
a 432 square mile watershed.   Major tributaries  to the Sheboygan  River include
the Onion River and  Mullet  River  which join the  Sheboygan River 13 and 17
stream-miles upstream,  respectively, from  Lake Michigan.  The drainage of the
Sheboygan River is typical  for many streams in southeastern Wisconsin.  The
streams  that drain into Lake Michigan  flow down-slope, off the divide provided
by the Silurian cuesta.  Streams  usually flow through large marshes on the
back-slope of the cuesta.   These  marshes were once glacial lakes  that have
gradually drained and filled with vegetation.  The Sheboygan Marsh was a
glacial  lake covering approximately 16 square miles to a depth of
approximately 45  ft.  Nearby Elkhart Lake  is a remnant of that extinct water
body.  The Sheboygan River  flows  over  a series of bedrock outcrops forming the
falls and rapids  at  Sheboygan  Falls, Wisconsin.   Three low dams (Sheboygan
Falls Dam, River  Bend Dam,  and the Waelderhaus Dam) cross the river as it
flows between Sheboygan Falls  and the  landfill.   Near the landfill the river
flows in a series of  incised meanders  and  several oxbow lakes are present.
Additional information  on the  morphology and discharge of the Sheboygan River
is provided  in  Section  3.4.4 and  Appendix  L of the Final RI report (Geraghty &
Miller,  1991) .

To address the  presence of  wetlands near the site, a preliminary wetlands
assessment was  completed by a  USEPA ecologist during a June 4, 1991 site visit
(Geraghty & Miller,  1991) .  Stands of  hydrophilic vegetation  (e.g. cattails)
totalling less  than  two acres  were observed north of the landfill and around
the eastern,  southern,  and  western part of  the landfill.  Evaluation of
shallow  test pits dug by the USEPA ecologist indicated that hydric soils were
present  north and northeast of the landfill.

E.    Groundwater Contamination

Groundwater beneath  and adjacent  to the site is contaminated with the same
chemical constituents found in landfill wastes and vapors,  including VOCs,
PAHs, heavy metals and  some inorganics.  The contaminants of concern are
listed in the following section titled "Constituent Characterization".   A list
of contaminants,  including VOCs,   PCBs and  inorganics,  some showing exceedances
of state groundwater  enforcement  standards, are included as Tables 1,  2,  3,  4,
5 and 6.   Contamination is generally to the east and south,  towards the
Sheboygan River.

The Wisconsin Geological and Natural History Survey (WGNHS)  files  indicate
that there are approximately 38 wells present in the immediate vicinity of the
site.  There are no wells within  1200 feet of the limits of the waste filling.
The well nearest  to  the  landfill  is situated approximately 1,500 ft.  southeast
of the landfill.  These  38 wells  are located within a zone which includes an
area approximately one-half mile  up-gradient of the site and one mile down-
gradient of the site.   Private wells monitored indicated no contamination due
to the landfill.

F.    Nature and Extent  of Contamination

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                                                                                                                                        Page 1 of 5
Table 1.  Summary of Organic Constituents Detected in Phase I and II Ground Water Samples
           Kohler, Wisconsin.
                                                                                                (a)
                                                                 , Kohler Company Landfill,
Parameters
MCL
ES
Well No.:
Phase (b)
IB
II
1C
II
ID
II
2
I
2
I(RE)
2D
I
2D
I(RE)
2D
II
3
I
3
KRE)
VOCs (tig/L)
Vinyl Chloride
Chloroe thane
1,1 -Dichloroethane
1,2-Dichloroethene
1,1,1-Trichloroethane
Trichloroethene
Toluene
1,1-Dichloroethene
Benzene
Chlorobenzene
Xylenes
Tetrachloroethene

SEMI-VOLATILES (ttg/L)
Phenol
2-Methylphenol
4-Methylphenol
2,4-Dimethylphenol
Pyrene
 1,2-Dichlorobenzene
 Acenapthene
 Benzyl Alcohol
 Napthalene
0.2

850
100
200
  5
343
  7
  5

620
  1
                                                      340
                                                                         52
                                                                       71 J
                                                                         74
380
280
                           6J
 75
                   3 J
                   3 J
                   3 J
 (a) - Inorganic constituents detected in all of the samples, the Phase I results are summarized in Table 6-4 (Weston, 1988), and the Phase II
      results are summarized on Tables 3-5 and 3-12 (Radian, 1989).
 (b) - Samples from Phase I (I), Phase I resampling [I(RE), Phase II (II), and Phase II resampling [(II(RE)].
I     I  Value exceeds Safe Drinking Water Act (42 U.S.C. 300(f) et seq.)  Maximum Contaminant Levels (MCL) or Enforcement Standards (ES) (s. NR 140.10,
	  Wis. Adm. Code).
 A summary of data qualifiers is provided in Appendix Q, Final RI report, Geraghty & Miller, 1991.
 — Constituent was not detected at, or above, the given quantitation limit.
 1404kohlerVH/orgcon.wkl
                                                                                                           GERAGHTY & MILLHR, INC.

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                                                                                                                                     Page 2 of 5
Table 1.  Summary of Organic Constituents Detected in Phase I and II Ground Water Samples
           Kohler, Wisconsin.
                                                                                               (a)
Kohler Company Landfill,
Parameters
VOCs (ng/L)
Vinyl Chloride
Chloroethane
1 , 1 -Dichloroethane
1 ,2-Dichloroethene
1,1, 1-Trichloroethane
Trichloroethene
Toluene
1 , 1-Dichloroethene
Benzene
Chlorobenzene
Xylenes
Tetrachloroethene
SEMI-VOLATILES (ue/U
Phenol
2-Methylphenol
4-Methylphenol
2 ,4-Dimethylphenol
Pyrene
1 ,2-Dichlorobenzene
Acenapthene
Benzyl Alcohol
Napthalene
MCL 3 3D 3D 3D 3R 3R 4
ES II I I(RE) II II II(RE) I(RE)

0.2 - - | 75 | | 58 | |340E | | 160 | | 13 |
5J
850 - - - - 55J
100 |120 J | - 32 37 | 200 | | 190 |
200 170 J 12 JB
5 - - | 7 |
343 -
7----1J--
5 - - - - - - | 6 |
_ _
620 -
1 - - - - -

11 JD - - - - -
_ _
_ _
_ _

75 - - - - ___
_ _
3J -
— — — _ _ _ _
4 4D 4D 5
II I I(RE) I

| 17 | - - | 130 |
-
- - - -
77 4 J 1 J 52
- - - -
| 16 | - | 5 J |
_
_
4J - | 5 J |
_
- - - -
- - - -

_ _ _ _
_
_
_
_
_
-
- - - -
- - - -
 (a) - Inorganic constituents detected in all of the samples, the Phase I results are summarized in Table 6-4 (Weston, 1988), and the Phase II
     results are summarized on Tables 3-5 and 3-12 (Radian, 1989).

 (b) - Samples from Phase I (I), Phase I resampling [I(RE), Phase II (II), and Phase II resampling [(II(RE)].

|    |   Value exceeds Safe Drinking Water Act (42 U.S.C. 300(f) et seq.)  Maximum Contaminant Levels (MCL) or Enforcement Standards (ES) (s. NR 140.10,
       Wis. Adm. Code).

 A summary of data qualifiers is provided in Appendix Q, Final RI report, Geraghty & Miller, 1991.
 — Constituent was not detected at, or above,  the given quantitation limit.

                   k]                                                                                    GKRAGHTY»MII.I.I-:R,INC.

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                                                                                                                                          Page 3 of 5
Table 1.  Summary of Organic Constituents Detected in Phase I and II Ground Water Samples
            Kohler, Wisconsin.
                                                                                                  (a)
                                                                    , Kohler Company Landfill,
Parameters
VOCs (ue/U
Vinyl Chloride
Chloroe thane
1 , 1 -Dichloroethane
1 ,2-Dichloroethene
1,1, 1-Trichloroethane
Trichloroethene
Toluene
1 , 1-Dichloroethene
Benzene
Chlorobenzene
Xylenes
Tetrachloroethene
MCL 5
ES I(RE)

0.2 | 2J |
-
850
100 4J
200
5 1 J
343
7
5
-
620
i r~nn
5D 5D
I I(RE)


2,200 | | 1,200 |
10 J
79 J 47 J
880 | | 640 |
-
| 12J |
-
-
-
-
-
-
5D 8 8D 8R 8R 9
II I(RE) II II II(RE) I

pnol - - | — 69~| EJS] [TTJ
- - - -
38 J - - 6
| 520 | - - |240E | r420~| 47
16 J 1 JB - - - 1 J
- - - | 460 | | 710 |
14 J - - - 1 J
_ _
- -
_ _
- - - -
_ _
9D 9D
I I(RE)

II ~
2 J
-
46 18
4 J
1 J 1 J
-
-
2 J
-
-
-
SEMI-VOLATILES
Phenol
2-Methylphenol
4-Methylphenol
2,4-Dimethylphenol
Pyrene
 1,2-Dichlorobenzene
Acenapthene
Benzyl Alcohol
Napthalene
                                                            14
75
 (a) - Inorganic constituents detected in all of the samples, the Phase I results are summarized in Table 6-4 (Weston, 1988), and the Phase II
      results are summarized on Tables 3-5 and 3-12 (Radian, 1989).
 (b) - Samples from Phase I (I), Phase I resampling [I(RE), Phase II (II), and Phase II resampling [(II(RE)].

[    |    Value exceeds Safe Drinking Water Act (42 U.S.C. 300(f) et seq.) Maximum Contaminant Levels (MCL) or Enforcement Standards (ES) (s. NR 140.10,
         Wis. Adm. Code).
 A summary of data qualifiers is provided in Appendix Q, Final RJ report, Geraghty & Miller, 1991.
 — Constituent was not detected at, or above, the given quantitation limit.

 1404kohlcrVII/orgcon.wkl                                                                                       GERAGHTY & MILLER, INC.

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                                                                                                                                          Page 4 of 5
Table 1.  Summary of Organic Constituents Detected in Phase I and II Ground Water Samples
            Kohler, Wisconsin.
                                                                                                 (a)
                                                            Kohler Company Landfill,
Parameters
MCL
ES
9D
II
10
I
10
II
11
I
11
I(RE)
11
II
11D
I
11D
I(RE)
11D
II
VOCs (ue/L)
Vinyl Chloride                0.2
Chloroethane
1,1-Dichloroethane            850
1,2-Dichloroethene            100
1,1,1 -Trichloroethane         200
Trichloroethene                 5
Toluene                      343
1,1 -Dichloroethene              7
Benzene                        5
Chlorobenzene
Xylenes                      620
Tetrachloroethene               1
23
         1 J
                             710 J
                                                           240
4,000
710 J
   31
1,300
9,300
 100 J
                                                                                                 6J
SEMI-VOLATILES (ue/L)
Phenol
2-Methylphenol
4-Methylphenol
2,4-Dimethylphenol
Pyrene
1 ,2-Dichlorobenzene
Acenapthene
Benzyl Alcohol
Napthalene
61
3 J
16
12

75 _


-
33 890
4,800
7,600
29,000
_



-

440 JD
5,700 D
45,000 D

18


-

24
21
660




-

52
78





1 4 J
 (a) - Inorganic constituents detected in all of the samples, the Phase I results are summarized in Table 6-4 (Weston, 1988), and the Phase II
      results are summarized on Tables 3-5 and 3-12 (Radian, 1989).
 (b) - Samples from Phase I (I), Phase I resampling [I(RE), Phase II (II), and Phase II resampling [(II(RE)].
 I    I    Value exceeds Safe Drinking Water Act (42 U.S.C. 300(f) et seq.) Maximum Contaminant Levels (MCL) or Enforcement Standards (ES) (s. NR 140.10,
 	    Wis. Adm. Code).
 A summary of data qualifiers is provided in Appendix Q, Final RI report, Geraghty & Miller, 1991.
 — Constituent was not detected at, or above, the given quantitation limit.
 1404kohlerVII/orgcon.wkl
                                                                                                           GERAGHTY & MILL,ER, INC.

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                                                                                                                                       Page 5 of 5
Table 1.  Summary of Organic Constituents Detected in Phase I and II Ground Water Samples8  , Kohler Company Landfill,
            Kohler, Wisconsin.


                            MCL          12           12D          13R          13R
Parameters     '              ES            II            II            II          II(RE)

VOCs
Vinyl Chloride                 0.2            -            -         |  5 J |        |  7 J
Chloroethane                                 -
1,1-Dichloroethane             850            -
1 ,2-Dichloroethene             100            -            -            31            30
1,1,1-Trichloroethane          200
Trichloroethene                  5            -            -             -           2 J
Toluene                       343
1,1-Dichloroethene               7
Benzene                         5         •   -
Chlorobenzene                                -
Xylenes                       620
Tetrachloroethene                1

SEMI-VOLATILES (ue/L)
Phenol                                       -
2-Methylphenol                               -
4-Methylphenol                              4 J
2,4-Dimethylphenol                           16           7J
Pyrene                                       -
 1 ,2-Dichlorobenzene            75
Acenapthene                                 -            -             -             -
Benzyl Alcohol                               -
Napthalene                                   -
 (a) - Inorganic constituents detected in all of the samples, the Phase I results are summarized in Table 6-4 (Weston, 1988), and the Phase II
      results are summarized on Tables 3-5 and 3-12 (Radian, 1989).
 (b) - Samples from Phase I (I), Phase I resampling [I(RE), Phase II (II), and Phase II resampling [(II(RE)].
|    | Value exceeds Safe Drinking Water Act (42 U.S.C. 300(f) et seq.) Maximum Contaminant Levels (MCL) or Enforcement Standards (ES) (s. NR 140.10,
       Wis. Adm. Code).
 A summary of data qualifiers is provided in Appendix Q, Final RI report, Geraghty & Miller, 1991.
 — Constituent was not detected at, or above, the given quantitation limit.
 1404kohlerVH/orgcon.wkl
                                                                                                        GERAGHTY #MILLFR, INC.

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                                                                                                                                                  Page 1 of 7
Table 2.  Summary of Organic Constituents Detected in Phase III Ground-Water Samples, Kohler Company Landfill, Kohler, Wisconsin.
Sample ID
VOCs («£/L)
Vinyl Chloride
Chloroethane
Carbon Disulfide
1 , 1-Dichloroethene
1 , 1-Dichloroethane
1 ,2-Dichloroethene (total)
Chloroform
1 ,2-Dichloroethane
1,1,1 -Trichloroethane
Bromodichloromethane
Trichloroethene
Benzene
4-Methyl-2-Pentanone
Toluene
Chlorobenzene
Ethylbenzene
Xylene (total)
SEMI-VOLATILES (us/L)
Phenol
Bis(2-Chloroethyl)Ether
2-Methylphenol
Bis(2-Chloroisopropyl)Ether
4-Methylphenol
2 ,4-Dimethylphenol
Napthalene
Fluoranthene
Pyrene
Benzo(a) Anthracene
Chrysene
Bis(2-Ethylhexyl)Phthalate
PHENOLS (UE/L)
4-Chloro-3-Methylphenol
2 ,4-Dichlorophenol
2,4-Dimethyphenol
Phenol
2,4, 6-Trichlorophenol
MCL
ES

0.2


7
850
100
6
5
200
179
5
5

343

1360
620


1C-01

<10
<10
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<10
<5
<5
<5
<5

<10
1D-01 OW1SR-01 OW1DR-01

<10 <1(
<10 <1(

) <10
) <10
<5 <5 <5
<5 <5 <5
<5 <5 <5
 J <5
J J <5
<5 <5 <5
<5 <5 <5
<5 1
<5  <5
<5 <5 <5
<10 <1(
3 <10
<5 <5 <5
<5 <5 <5
<5 <5 <5
<5 <5 <5

<10 <1

3 <13
2-01

<10
<10
<5
<5
<5
| 15 1
<5
<5
<5
<5
[~~T~J~]
<5
<10
<5
<5
<5
<5

<10
2-02

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

<10
2D-01

Hip

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                                                                                                                                             Page 2 of 7
Table 2. Summary of Organic Constituents Detected in Phase III Ground-Water Samples, Kohler Company Landfill, Kohler, Wisconsin.
Sample ID
MCL
 ES
2DR-01
2DR-02
OW2-01
3-01
3-02
3D-01
3R-O1
VOCs (ue/U
Vinyl Chloride
Chloroethane
Carbon Disulfide
1 , 1-Dichloroethene
1,1-Dichloroethane
1,2-Dichloroethene (total)
Chloroform
1 ,2-Dichloroethane
1,1, 1-Trichloroethane
Bromodichloromethane
Trichloroethene
Benzene
4-Methyl-2-Pentanone
Toluene
Chlorobenzene
Ethylbenzene
Xylene (total)
SEMI-VOLATILES (ng/L)
Phenol
Bis(2-Chloroethyl)Ether
2-Methylphenol
Bis(2-Chloroisopropyl)Ether
4-Methylphenol
2,4-Dimethylphenol
Napthalene
Fluoranthene
Pyrene
Benzo(a) Anthracene
Chrysene
Bis(2-Ethylhexyl)Phthalate
PHENOLS (tig/L)
4-Chloro-3-Methylphenol
2 ,4-Dichlorophenol
2 ,4-Dimethyphenol
Phenol
2,4,6-Trichlorophenol

0.2


7
850
100
6
S
200
179
5
5

343

1360
620




















liiiiil

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                                                                                                                                                  Page 3 of 7
Table 2.  Summary of Organic Constituents Detected in Phase III Ground-Water Samples, Kohler Company Landfill, Kohler, Wisconsin.
Sample ID
VOCs (/ig/L)
Vinyl Chloride
Chloroethane
Carbon Disulfide
1 , 1-Dichloroethene
1 , 1-Dichloroethane
1,2-Dichloroethene (total)
Chloroform
1 ,2-Dichloroethane
1,1,1 -Trichloroethane
Bromodichloromethane
Trichloroethene
Benzene
4-Methyl-2-Pentanone
Toluene
Chlorobenzene
Ethylbenzene
Xylene (total)
SEMI-VOLATILES (qg/L)
Phenol
Bis(2-Chloroethyl)Ether
2-Methylphenol
Bis(2-Chloroisopropyl)Ether
4-Methylphenol
2,4-Dimethylphenol
Napthalene
Fluoranthene
Pyrene
Benzo(a) Anthracene
Chrysene
Bis(2-Ethylhexyl)Phthalate
PHENOLS ((ig/L)
4-Chloro-3-Methylphenol
2 ,4-Dichlorophenol
2,4-Dimethyphenol
Phenol
2,4, 6-Trichlorophenol
MCL
ES 3SR-01 3DR-01

0.2
<

7
850
loo m
6
5
200
179
5
5

m, » | iw.wU
                                                                                                                  GKRAOHTY S MIU.IiR, INC.
o

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                                                                                                                                                  Page 4 of 7
Table 2.  Summary of Organic Constituents Detected in Phase III Ground-Water Samples, Kohler Company Landfill, Kohler, Wisconsin.
Sample ID
VOCs («e/U
Vinyl Chloride
Chloroethane
Carbon Disulfide
1 , 1-Dichloroethene
1 , 1 -Dichloroethane
1,2-Dichloroethene (total)
Chloroform
1 ,2-Dichloroethane
1,1,1 -Trichloroethane
Bromodichloromethane
Trichloroethene
Benzene
4-Methyl-2-Pentanone
Toluene
Chlorobenzene
Ethylbenzene
Xylene (total)
SEMI-VOLATILES (wE/L)
Phenol
Bis(2-Chloroethyl)Ether
2-Methylphenol
Bis(2-Chloroisopropyl)Ether
4-Methylphenol
2 ,4-Dimethylphenol
Napthalene
Fluoranthene
Pyrene
Benzo(a) Anthracene
Chrysene
Bis(2-Ethylhexyl)Phthalate
PHENOLS (ng/L)
4-Chloro-3-Methylphenol
2,4-Dichlorophenol
2 ,4-Dimethyphenol
Phenol
2,4,6-Trichlorophenol
MCL
ES
0.2
7
850
100
6
5
200
179
5
5
343
1360
620
6SR-01 6DR-01 8(RE)-01
<10 <10
<10 <10
<5 <5
<5 <5
<5 <5
<5 [~Z
<5 <5
<5 <5
<5 <5
<5 <5
<5 2
<5 1
<10
<10
<5
<5
<5
3 <55
<5
<5
<5
J <5
J <5
<10 <10 <10 J
<5 <5 | T]
<5 <5 <5
<5 <5 <5
<5 <5 J <5 J
<10 <10 <10
<10 <10 <10
<10 <10 <10
<10 J <10 J <10
<10 <10 <10
<10 <10 <10
<10 <10 <10
<10 <10 <10
<10 <10 <10
<10 10 <10
<10 10 <10
<10 <10 <10
<3.6 <3.6 J <3.6
<3.9 <3.9 J <3.9
<3.2 <3.2 J <3.2
<1.4 <1.4 J <1.4
<6.4 <6.4 J <6.4
8D-01
<5
<5
<5
<5
<5
<5
8DR-01 8R-01
<10 J <10
<5 <5
<5 2
<5 13
| 5| 1,400'
<5 <5
<5 J <5
<5 J <5
<5 J <5
8SR-01
<5
rj <5
2-J]
Dj ' 170'}
<5
<5
<5
<5
1' ' 7 | <5
<10
<5
<5
<5
<5
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<3.6
<3.9
<3.2
<1.4
<6.4
<5 <5
<10 J <10
<5 <5
<5 | 2
<5 <5
<5 <5
<10 <10
<10 <10
<10 <10
<10 | <10
<10 <10
<10 <10
<10 <10
<10 <10
<10 | 3
<10 <10
<10 <10
<10 <10
<3.6 <3.6
<3.9 <3.9
<3.2 <3.2
<1.4 <1.4
<6.4 <6.4
<5
J <10 J
J <5 J
T] <5 J
~T <5 J
J <5 J
<10
<10
<10
Tj <10
<10
<10
<10
<10
T] <10
<10
<10
<10
J <3.6
J <3.9
J <3.2
     NA - No analysis.
 |   |Constituent was detected at designated concentration.

 \4^jValue exceedes Safe Drinking Water Act [42 U.S.C. 300(1) et. seq.] Maximum Contaminant Levels (MCL) or Enforcement Standards (ES) (s. NR 140.10, Wis. Adm. Code)
     Data qualifiers are provided in Appendix Q, Final RI report, Geraghty & Miller, 1991.
     < - Constituent was not detected at, or above, given quantitation limit.
 1404KOHLEJRVlI/chcmcn8w.wk!
                                                                                                                  GERAGHTY & MILLER, INC.
O

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                                                                                                                                                   Page 5 of 7
Table 2.  Summary of Organic Constituents Detected in Phase III Ground-Water Samples, Kohler Company Landfill, Kohler, Wisconsin.
Sample ID
VOCs («g/L)
Vinyl Chloride
Chlorocthanc
Carbon Disulfide
1 , 1-Dichloroethene
1 , 1-Dichloroethane
1,2-Dichloroethene (total)
Chloroform
1 ,2-Dichloroethane
1,1,1 -Trichloroethane
Bromodichloromethane
Trichloroethene
Benzene
4-Methyl-2-Pentanone
Toluene
Chlorobenzene
Ethylbenzene
Xylene (total)
SEMI-VOLATILES (we/L)
Phenol
Bis(2-Chloroethyl)Ether
2-Methylphenol
Bis(2-Chloroisopropyl)Ether
4-Methylphenol
2 ,4-Dimethylphenol
Napthalene
Fluoranthene
Pyrene
Benzo(a) Anthracene
Chrysene
Bis(2-Ethylhexyl)Phthalate
PHENOLS (ug/L)
4-Chloro-3-Methylphenol
2 ,4-Dichlorophenol
2 ,4-Dimethyphenol
Phenol
2 ,4 , 6-Trichlorophenol
MCL
ES
0.2
7
850
100
6
5
200
179
5
5
343
1360
620
8SR-01RE 11-01
<5
<5
<5
<5 J
<5 J
<5 J
<10 J
<5
<5
<5
<5
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA



23 i
38b
<25

14 I
MPQ V
i,!iQ# i>
<25
17& 1
200;;
<2$

14,000- J>
' $&\
45
340'
120
44
190
<20
230
<20
J

180
14,000
D
<20
<20
<20
<20
<20
8
J
NA
NA
NA
NA
NA
11D-01



~~wi
--jjjy-
' tO-'l'
140
• 370
<25
19 'J
280; |
<25
2QC
4t
34 J
210 |
14 J
56

6 J
<10
110
<10 J
230 D
3,200 D
<10
<10
<10
50 D
<39 J
2,000 D
<14 J
<64 J
12-01
<5
3 <5
<5
<5
<5
<5
<5
<5
n 
-------
                                                                                                                                                  Page 6 of 7
Table 2.  Summary of Organic Constituents Detected in Phase III Ground-Water Samples, Kohler Company Landfill, Kohler, Wisconsin.
Sample ID
                                        MCL
                                          ES
13SR-01RE
                                                                      13DR-01
                                              14-01
                                                                                                     14SR-01
15-01
15SR-01
15DR-01
VOCs (ug/L)
   Vinyl Chloride
   Chloroethane
   Carbon Disulfide
    1,1-Dichloroethene
    1,1 -Dichlorocthanc
    1,2-Dichloroethene (total)
   Chloroform
    1,2-Dichloroethane
    1,1,1 -Trichloroethane
   Bromodichloromethane
   Trichloroethene
   Benzene
   4-Methyl-2-Pentanone
   Toluene
   Chlorobenzene
    Ethylbenzene
   Xylene (total)

SEMI-VOLATILES (ttg/L)
   Phenol
    Bis(2-Chloroethyl)Ether
    2-Methylphenol
    Bis(2-Chloroisopropyl)Ether
    4-Methylphenol
    2,4-Dimethylphenol
    Napthalene
    Fluoranthene
    Pyrene
    Benzo(a) Anthracene
    Chrysene
    Bis(2-Ethylhexyl)Phthalate
                                         0.2
 7
850
100
 6
 5
200
179
 5
 5

343

1360
620
                                  iipilj
                                                                                          <5
                                                                                          <5
                                                            3
                                                          <5
                                                         <10
                                                          <5
                                                          <5
                                                          <5
                                                          
-------
                                                                                                                                                  Page 7 of 7
Table 2.  Summary of Organic Constituents Detected in Phase III Ground-Water Samples, Kohler Company Landfill, Kohler, Wisconsin.
Sample ID
VOCs (ng/L)
Vinyl Chloride
Chloroethane
Carbon Disulfide
1 , 1-Dichloroefhene
1 , 1 -Dichloroethane
1,2-Dichloroethene (total)
Chloroform
1 ,2-Dichloroethane
1 , 1 , 1-Trichloroethane
Bromodichloromethane
Trichloroethene
Benzene
4-Methyl-2-Pentanone
Toluene
Chlorobenzene
Ethylbenzene
Xylene (total)
SEMI-VOLATILES (tig/L)
Phenol
Bis(2-Chloroethyl)Ether
2-Methylphenol
Bis(2-Chloroisopropyl)Ether
4-Methylphenol
2,4-Dimcthylphenol
Napthalene
Fluoranthene
Pyrene
Benzo(a) Anthracene
Chrysene
Bis(2-Ethylhexyl)Phthalatc
PHENOLS («g/L)
4-Chloro-3-Methylphenol
2 ,4-Dichlorophenol
2 ,4-Dimethyphenol
Phenol
2,4,6-Trichlorophenol
MCL
ES

0.2


7
850
100
6
5
200
179
5
5

343

1360
620


16-01

<10
<10 J
<5
<5
<5
<5
| 1 ~J~[
<5 J
<5 J
<5 J
<5
<5
<10 J
<5
<5
<5
<5

<10
16SR-01 16SR-01DUP 17SR-01

<10 <1(
<10 <1

D <10
3 <10



<5 <5 <5
<5 <5 <5
<5 <5 <5
<5 <5 <5
1 2"~3 |
3 J | 2
n
<5 <5 <5
<5 <5 <5
<5 <5 <5
<5 <5 <5
<5 <5 <5
<10 <1
0 <10

<5 <5 <5
<5 <5 <5
<5 <5 <5
<5 <5 <5

<10 <1

0 <10
<10 <10 <10 190




<10
<10
<10
<10
<10 <1
<10 <1
<10 <1
<10 <1
0 <10
0 <10
0 <10
0 <10
<10 <10 <10 | I




<10
<10
<10
<10
<10
<10
<10
<10
2 J <10
3 J <10
2 J <10
3 j 
-------
                                                                                                                 Page 1 of 15
Table 3.  Organic Constituents Analyzed in Post-RI Ground-Water Verification Sampling, June and December 1991 and January 1992,
          Kohler Company Landfill, Kohler, Wisconsin.
Kohler Sample ID
Laboratory Sample ID
Date Collected
VOCs (/ig/L)
Chloromethane
Bromomethane
Vinyl Chloride
Chloroe thane
Methylene Chloride
Acetone
Carbon Disulfide
1 , 1-Dichloroethene
1 , 1 -Dichloroe thane
1,2-Dichloroethene (total)
Chloroform
1 ,2-Dichloroethane
2-Butanone
1,1,1 -Trichloroethane
Carbon Tetrachloride
Vinyl Acetate
Bromodichloromethane
1 ,2-Dichloropropane
Cis-1 ,3-Dichloropropene
Trichloroethene
Dibromochloromethane
1 , 1 ,2-Trichloroethane
Benzene
Trans- 1 ,3-Dichloropropene
Bromoform
4-Methyl-2-Pentanone
2-Hexanone
Tetrachloroethene
6SR
HYU001
12/4/91

i
<10
<6 B
<10
<5
<5
<5
<5
<5
<5
<10
<5
<5
<10
<5
<5
<5
<5
<5
<5
<5
<5
<5
<10
<10
<5
15
HXX004
12/3/91

i
<10
<14 B
<10
<5
<5
<5
<5
<5
<5
<10
<5
<5
<10
<5
<5
<5
<5
<5
<5
| 15~|
<5
<5
<10
<10
<5
Duplicate 15
15 QA003
IHV001 IHV003
1/17/92 1/17/92

<10
<10
<12 B
<10
<5
<5
<5
<5
<5
<5
<10
<5
<5
<10
<5
<5
<5
<5
<5
<5
[ 17~]
<5
<5
<10
<10
<5

<10
<10
<7 B
<10
<5
<5
<5
<5
<5
<5
<10
<5
<5
<10
<5
<5
<5
<5
<5
<5
| 14"1
<5
<5
<10
<10
<5
15SR
HXX005
12/3/91

i
<10
<6 B
<10
<5
<5
<5
<5
<5 (b)
<5
<10
<5
<5
<10
<5
<5
<5
<5
<5
<5
<5
<5
<5
<10
<10
<5
15DR
HXX006
12/3/91

i
<10
<14 B
5 J|
5I
<5
<5
<5
<5
<5
<10
<5
<5
<10
<5
<5
<5
<5
<5
<5
<5
<5
<5
<10
<10
<5
16
HXX002
12/2/91

s
<10
<12 B
<10
<5
<5
<5
<5
<5
<5
<10
<5
<5
<10
<5
<5
<5
<5
<5
<5
<5
<5
<5
<10
<10
<5
                                                                                        GERAGHTY & MIU..HR, INC.

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                                                                                                                 Page 2 of 15
Table 3.  Organic Constituents Analyzed in Post-RI Ground-Water Verification Sampling, June and December 1991 and January 1992,
          Kohler Company Landfill, Kohler, Wisconsin.
Kohler Sample ID ' 6SR 15 15
Laboratory Sample ID HYU001 HXX004 IHV001
Date Collected 12/4/91 12/3/91 1/17/92
VOCs (qg/L) (Con'O
1,1 ,2,2-Tetrachloroethane <5 <5 <5
Toluene <5 | 1 J | 3 J |
Chlorobenzene <5 <5 <5
Ethylbenzene <5 | 1 J | 1 J |
Styrene <5 <5 <5
Xylene (total) <5 | 4 J | 5 |
SEMI-VOLATILES (qg/L)
Phenol <10 <10 NA
Bis(2-Chloroethyl)Ether <10 <10 NA
2-Chlorophenol <10 <10 NA
1 ,3-Dichlorobenzene <10 <10 NA
1 ,4-Dichlorobenzene <10 <10 NA
Benzyl Alcohol <10 <10 NA
1,2-Dichlorobenzene <10 <10 NA
2-Methylphenol <10 <10 NA
Bis(2-Chloroisopropyl)Ether <10 <10 NA
4-Methylphenol <10 <10 NA
N-Nitroso-Di-n-Propylamine <10 <10 NA
Hexachloroethane <10 <10 NA
Nitrobenzene <10 <10 NA
Isophorone <10 <10 NA
2-Nitrophenol <10 <10 NA
2,4-Dimethylphenol <10 <10 NA
Benzoic Acid <50 <50 NA
Bis-(2-Chloroethoxy)Methane <10 <10 NA
2,4-Dichlorophenol <10 <10 NA
Duplicate 15
QA003 15SR 15DR 16
IHV003 HXX005 HXX006 HXX002
1/17/92 12/3/91 12/3/91 12/2/91

<5 <5 <5 <5
| 	 1 J <5 [ 1 J | <5
<5 <5 <5 <5
| 1 J <5 <5 <5
<5 <5 <5 <5
| 4 J <5 <5 <5

NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA <10 <10 <10
NA <50 <50 <50
NA <10 <10 <10
NA <10 <10 <10
                                                                                         GERAGHTY & MILLER, INC.

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                                                                                                                 Page 3 of 15
Table 3.  Organic Constituents Analyzed in Post-RI Ground-Water Verification Sampling, June and December 1991 and January 1992,
          Kohler Company Landfill, Kohler, Wisconsin.
Kohler Sample ID • 6SR
Laboratory Sample ID HYU001
Date Collected 12/4/91
SEMI-VOLATILES (jig/L) (Con't)
1 ,2,4-Trichlorobenzene <10
Napthalene <10
4-Chloroaniline <10
Hexachlorobutadiene <10
4-Chloro-3-Methylphenol <10
2-Methylnaphthalene <10
Hexachlorocyclopentadiene <10
2,4,6-Trichlorophenol <10
2,4,5-Trichlorophenol <50
2- Chloronaphthalene < 1 0
2-Nitroaniline <50
Dimethyl Phthalate <10
Acenaphthylene <10
2,6-Dinitrotoluene <10
3-Nitroaniline <50
Acenaphthene <10
2,4-Dinitrophenol <50
4-Nitrophenol <50
Dibenzofuran <10
2,4-Dinitrotoluene <10
Diethylphthalate <10
4-Chlorophenyl-Phenylether <10
Flourene <10
4-Nitroaniline <50
4,6-Dinitro-2-Methylphenol <50
N-Nitrosodiphenylamine (1) <10
4-Bromophenyl-Phenylether <10
15
HXX004
12/3/91

<10
<10
<10
<10
<10
<10
<10
<10
<50
<10
<50
<10
<10
<10
<50
<10
<50
<50
<10
<10
<10
<10
<10
<50
<50
<10
<10
15
IHV001
1/17/92

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Duplicate 15
QA003
IHV003
1/17/92

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
15SR
HXX005
12/3/91

<10
<10
<10
<10
<10
<10
<10
<10
<50
<10
<50
<10
<10
<10
<50
<10
<50
<50
<10
<10
<10
<10
<10
<50
<50
<10
<10
15DR
HXX006
12/3/91

<10
<10
<10
<10
<10
<10
<10
<10
<50
<10
<50
<10
<10
<10
<50
<10
<50
<50
<10
<10
<10
<10
<10
<50
<50
<10
<10
16
HXX002
12/2/91

<10
<10
<10
<10
<10
<10
<10
<10
<50
<10
<50
<10
<10
<10
<50
<10
<50
<50
<10
<10
<10
<10
<10
<50
<50
<10
<10
                                                                                        GERAGHTY & MILLER, INC.

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                                                                                                                Page 4 of 15
Table 3.  Organic Constituents Analyzed in Post-RI Ground-Water Verification Sampling, June and December 1991 and January 1992,
          Kohler Company Landfill, Kohler, Wisconsin.
Kohler Sample ID '
Laboratory Sample ID
Date Collected
SEMI-VOLATILES (/ig/L) (Con't)
Hexachlorobenzene
Pentachlorophenol
Phenanthrene
Anthracene
Di-n-Butylphthalate
Fluoranthene
Pyrene
Butylbenzylphthalate
3,3' -Dichlorobenzidine
Benzo(a)Anthracene
Chrysene
Bis(2-Ethylhexyl)Phthalate
Di-n-Octyl Phthalate
Benzo(b)Fluoranthene
Benzo(k)Fluoranthene
Benzo(a)Pyrene
Indeno(l ,2,3-cd)Pyrene
Dibenz(a ,h) Anthracene
Benzo(g,h,i)Perylene
PHENOLS fug/U)
4-Chloro-3-Methylphenol
2- Chlorophenol
2,4-Dichlorophenol
2,4-Dimethyphenol
2,4-Dinitrophenol
6SR 15
HYU001 HXX004
12/4/91 12/3/91
<50 <50
<10 <10
<10 <10
<10 <10
<10 <10
<20 <20
<10 B | 36 B
<10 <10
<10 <10
<10 <10
<2.0 <2.0
<2.0 <2.0
<2.0 <2.0
<2.0 <2.0
<5.0 <5.0
15
IHV001
1/17/92
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Duplicate 15
QA003
IHV003
1/17/92
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
15SR
HXX005
12/3/91
<50
<10
<10
<10
<20
| 32 B|
<2.0
<2.0
<2.0
<2.0
<5.0
15DR
HXX006
12/3/91
<50
<20
<14 B
<2.0
<2.0
<2.0
<2.0
<5.0
16
HXX002
12/2/91
<50
<10
<10
<20
<10 B
<2.0
<2.0
<2.0
<2.0
<5.0
                                                                                       GERAGHTY & MILLER, INC.

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                                                                                                                                   Page 5 of 15
Table 3.   Organic Constituents Analyzed in Post-RI Ground-Water Verification Sampling, June and December 1991 and January 1992,
            Kohler Company Landfill, Kohler, Wisconsin.
Kohler Sample ID '
Laboratory Sample ID
Date Collected
PHENOLS (U.S./L) (Con't)
2-Methyl-4,6-Dinitrophenol
2-Nitrophenol
4-Nitrophenol
Pentachlorophenol
Phenol
2,4,6-Trichlorophenol
6SR
HYU001
12/4/91
<5.0
<2.0
<5.0
<5.0
<2.0
<2.0
15
HXX004
12/3/91
<5.0
<2.0
<5.0
<5.0
<2.0
<2.0
15
IHV001
1/17/92
NA
NA
NA
NA
NA
NA
Duplicate 15
QA003
1HV003
1/17/92
NA
NA
NA
NA
NA
NA
15SR
HXX005
12/3/91
<5.0
<2.0
<5.0
<5.0
<2.0
<2.0
15DR
HXX006
12/3/91
<5.0
<2.0
<5.0
<5.0
<2.0
<2.0
16
HXX002
12/2/91
<5.0
<2.0
<5.0
<5.0
<2.0
<2.0
|   [  Analyte was detected.
NA - Sample was not analyzed for indicated parameters.
B - Chemical constituent was detected in the associated method blank.
J - Constituent is estimated.
< - Constituent was not detected at, or above, the given quantitation limits.
(b) - Chemical constituent was detected in the field blank.
A summary of data qualifiers is provided in Appendix Q, Final RI report, Geraghty & Miller, 1991.
 1404KOHLERVH/GWDATA.WK1
                                                                                                       GERAGHTY & MILLER, INC.
o

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                                                                                                                Page 6 of 15
Table 3.  Organic Constituents Analyzed in Post-RI Ground-Water Verification Sampling, June and December 1991 and January 1992,
          Kohler Company Landfill, Kohler, Wisconsin.
Kohler Sample ID ' 16SR
Laboratory Sample ID HXX003
Date Collected 12/2/91
VOCs (ug/U)
Chloromethane <10
Bromomethane <10
Vinyl Chloride <10
Chloroethane <10
Methylene Chloride <14 B
Acetone 3 J |
Carbon Disulfide <5
1 , 1 -Dichloroethene <5
1 , 1 -Dichloroethane <5
1,2-Dichloroethene (total) <5
Chloroform <5 (b)
1,2-Dichloroethane <5
2-Butanone <10
1,1,1 -Trichloroethane <5
Carbon Tetrachloride <5
Vinyl Acetate <10
Bromodichloromethane <5
1,2-Dichloropropane <5
Cis-l,3-Dichloropropene <5
Trichloroethene <5
Dibromochloromethane <5
1,1,2-Trichloroethane <5
Benzene <5
Trans- 1,3-Dichloropropene <5
Bromoform <5
4-Methyl-2-Pentanone <10
2-Hexanone <10
Tetrachloroethene <5
17 17SR 18SR
HXX007 HXX008 GRQ01
12/3/91 12/3/91 6/27/91

<10 <10 <10
<10 <10 <10
<10 <10 <10
<10 <10 <10
<15 B <6 B <5
6 J | <10 <10
10 <5 <5
<5 <5 <5
<5 <5 <5
<5 <5 | 4 J |
<5 <5 <5
<5 <5 <5
<10 <10 <10
<5 <5 <5
<5 <5 <5
<10 <10 <10
<5 <5 <5
<5 <5 <5
<5 <5 <5
<5 <5 <5
<5 <5 <5
<5 <5 <5
<5 <5 <5
<5 <5 <5
<5 <5 <5
<10 <10 <10
<10 <10 <10
<5 <5 <5
18SR 18DR
HXX001 GRQ02
12/2/91 6/27/91

<10 <10
<10 <10
<10 <10
<10 <10
<11 B <5
<10 <10
<5 <5
<5 <5
<5 <5
L 2 J | [ 4 J
<5 <5
<5 <5
<10 <10
<5 <5
<5 <5
<10 <10
<5 <5
<5 <5
<5 <5
<5 <5
<5 <5
<5 <5
<5 <5
<5 <5
<5 <5
<10 <10
<10 <10
<5 <5
18DR
HYU002
12/4/91

<10
<10
<10
<10
<8 B
<10
<5
<5
<5
| 3 J |
<5
<5
<10
<5
<5
<10
<5
<5
<5
<5
<5
<5
<5
<5
<5
<10
<10
<5
                                                                                        GERAGHTY & MILLER, INC.

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                                                                                                                               Page 7 of 15
Table 3.  Organic Constituents Analyzed in Post-RI Ground-Water Verification Sampling, June and December 1991 and January 1992,
           Kohler Company Landfill, Kohler, Wisconsin.
Kohler Sample ID •
Laboratory Sample ID
Date Collected
16SR
HXX003
12/2/91
17
HXX007
12/3/91
17SR
HXX008
12/3/91
18SR
GRQ01
6/27/91
18SR
HXX001
12/2/91
18DR
GRQ02
6/27/91
18DR
HYU002
12/4/91
VQCs (ug/L) (Con't)
    1,1,2,2-Tetrachloroethane               <5            <5            <5             <5            <5           <5              <5
    Toluene                              <5            <5            <5             <5            <5           <5              <5
    Chlorobenzene                        <5            <5            <5             <5            <5           <5              <5
    Ethylbenzene                          <5            <5            <5             <5            <5           <5              <5
    Styrene                              <5            <5            <5             <5            <5           <5              <5
    Xylene (total)                         <5            <5            <5             <5            <5           <5              <5

SEMI-VOLATILES (ug/L)
    Phenol
    Bis(2-Chloroethyl)Ether
    2-Chlorophenol
    1,3-Dichlorobenzene
    1,4-Dichlorobenzene
    Benzyl Alcohol
    1,2-Dichlorobenzene
    2-Methylphenol
    Bis(2-Chloroisopropyl)Ether
    4-Methylphenol
    N-Nitroso-Di-n-Propylamine
    Hexachloroethane
    Nitrobenzene
    Isophorone
    2-Nitrophenol
    2,4-Dimethylphenol
    BenzoicAcid                         <50          <50            <50            <50           <50          <50             <50
    Bis-(2-Chloroethoxy)Methane
    2,4-Dichlorophenol	



                                                                                                    GERAGHTY & MILLER, INC.

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                                                                                                                                  Page 8 of 15
Table 3.  Organic Constituents Analyzed in Post-RI Ground-Water Verification Sampling, June and December 1991 and January 1992,
           Kohler Company Landfill, Kohler, Wisconsin.
Kohler Sample ID -
Laboratory Sample ID
Date Collected
16SR
HXX003
12/2/91
17
HXX007
12/3/91
17SR
HXX008
12/3/91
18SR
GRQ01
6/27/91
18SR
HXX001
12/2/91
18DR
GRQ02
6/27/91
18DR
HYU002
12/4/91
SEMI-VOLATILES (ug/U (Con'f)

    1,2,4-Trichlorobenzene
    Napthalene
    4-Chloroaniline
    Hexachlorobutadiene
    4-Chloro-3-Methylphenol
    2-Methylnaphthalene
    Hexachlorocyclopentadiene
    2,4,6-Trichlorophenol
    2,4,5-Trichlorophenol
    2-Chloronaphthalene
    2-Nitroaniline
    Dimethyl Phthalate
    Acenaphthylene
    2,6-Dinitrotoluene
    3-Nitroaniline
    Acenaphthene
    2,4-Dinitrophenol
    4-Nitrophenol
    Dibenzofuran
    2,4-Dinitrotoluene
    Diethylphthalate
    4-Chlorophenyl-Phenylether
    Flourene
    4-Nitroaniline
    4,6-Dinitro-2-Methylphenol
    N-Nitrosodiphenylamine (1)
    4-Bromophenyl-Phenylether
<50
<10
<50
<50
<10
<50
<50
<10
<50
<50
<10
<50
<50
<10
<50
<50
<10
<50
<50
<10
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
                                                                                                      GERAGHTY & MILLER, INC.

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                                                                                                                                 Page 9 of 15
Table 3.  Organic Constituents Analyzed in Post-RI Ground-Water Verification Sampling, June and December 1991 and January 1992,
           Kohler Company Landfill, Kohler, Wisconsin.
Kohler Sample ID -
Laboratory Sample ID
Date Collected
16SR
HXX003
12/2/91
17
HXX007
12/3/91
17SR
HXX008
12/3/91
18SR
GRQ01
6/27/91
18SR
HXX001
12/2/91
18DR
GRQ02
6/27/91
18DR
HYU002
12/4/91
SEMI-VOLATILES (ug/L) (Con'O

   Hexachlorobenzene
   Pentachlorophenol
   Phenanthrene
   Anthracene
   Di-n-Butylphthalate
   Fluoranthene
   Pyrene
   Butylbenzylphtlialate
   3,3' -Dichlorobenzidine
   Benzo{a)Anthracene
   Chrysene
   Bis(2-Ethylhexyl)Phthalate
   Di-n-Octyl Phthalate
   Benzo(b)Fluoranthene
   Benzo(k)Fluoranthene
   Benzo(a)Pyrene
   Indeno(l ,2,3-cd)Pyrene
   Dibenz(a ,h) Anthracene
   Benzo(g,h,i)Perylene
                                        <50
<50
<50
<50
<50
<50
<50
                                        <20
<20
<20
<20
<20
<20
<20
                                        <13  B
     B
<10  B
             |  27  B
                             <10 B
PHENOLS (uzIL)
4-Chloro-3 -Methylphenol
2-Chlorophenol
2,4-Dichlorophenol
2,4-Dimethyphenol
2,4-Dinitrophenol

<2.0
<2.0
<2.0
<2.0
<5.0

<2.0
<2.0
<2.0
<2.0
<5.0

<2.0
<2.0
<2.0
<2.0
<5.0

<3.6
<3.1
<3.9
<3.2
<130

<2.0
<2.0
<2.0
<2.0
<5.0

<3.6
<3.1
<3.9
<3.2
<130

<2.0
<2.0
<2.0
<2.0
<5.0
                                                                                                      GERAGHTY & MILLER, INC.
                                                                                   VJ

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                                                                                                                                  Page 10 of 15
Table 3.   Organic Constituents Analyzed in Post-RI Ground-Water Verification Sampling, June and December 1991 and January 1992,
            Kohler Company Landfill, Kohler, Wisconsin.
Kohler Sample ID '
Laboratory Sample ID
Date Collected
16SR
HXX003
12/2/91
17
HXX007
12/3/91
17SR
HXX008
12/3/91
18SR
GRQ01
6/27/91
18SR
HXX001
12/2/91
18DR
GRQ02
6/27/91
18DR
HYU002
12/4/91
PHENOLS (qg/U (Con'O
2-Methyl-4,6-Dinitrophenol
2-Nitrophenol
4-Nitrophenol
Pentachlorophenol
Phenol
2,4,6-Trichlorophenol

<5.0
<2.0
<5.0
<5.0
<2.0
<2.0

<5.0
<2.0
<5.0
<5.0
<2.0
<2.0

<5.0
<2.0
<5.0
<5.0
<2.0
<2.0

<160
<4.5
<28
<74
<1.4
<6.4

<5.0
<2.0
<5.0
<5.0
<2.0
<2.0

<160
<4.5
<28
<74
<1.4
<6.4

<5.0
<2.0
<5.0
<5.0
<2.0
<2.0
|   I  Analyte was detected.
NA - Sample was not analyzed for indicated parameters.
8 - Chemical constituent was detected in the associated method blank.
J - Constituent is estimated.
< - Constituent was not detected at, or above, the given quantitation limits.
(b) - Chemical constituent was detected in the field blank.
A summary of data qualifiers is provided in Appendix Q, Final RI report, Geraghty & Miller, 1991.
 1404KOHLERVn/OWDATA.WKl
                                                                                                       GERAGHTY & MILLER, INC.

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                                                                                                                 Page 11 of 15
Table 3.  Organic Constituents Analyzed in Post-RI Ground-Water Verification Sampling, June and December 1991 and January 1992,
          Kohler Company Landfill, Kohler, Wisconsin.
Kohler Sample ID •
Laboratory Sample ID
Date Collected
VOCs («g/D
Chloromethane
Bromomethane
Vinyl Chloride
Chloroethane
Methylene Chloride
Acetone
Carbon Disulfide
1 , 1 -Dichloroethene
1 , 1 -Dichloroethane
1,2-Dichloroethene (total)
Chloroform
1 ,2-Dichloroethane
2-Butanone
1,1,1 -Trichloroethane
Carbon Tetrachloride
Vinyl Acetate
Bromodichloromethane
1 ,2-Dichloropropane
Cis-1 ,3-Dichloropropene
Trichloroethene
Dibromochloromethane
1 , 1 ,2-Trichloroethane
Benzene
Trans-1 ,3-Dichloropropene
Bromoform
4-Methyl-2-Pentanone
2-Hexanone
Tetrachloroethene
Trip Blank
HXX012
12/3/91
<10
<10
<10
<15 B
<5
<5
<5
<5
<5
<5
<10
<5
<5
<10
<5
<5
<5
<5
<5
<5
<5
<5
<5
<10
<10
<5
Trip Blank
HYU006
12/5/91
<10
<10
<10
<10
| 23 B|

<5
<5
<5
<5
<5
<10
<5
<5
<10
<5
<5
<5
<5
<5
<5
<5
<5
<5
<10
<10
<5
Trip Blank
IHV002
1/17/92
<10
<10
<10
<10
<7 B
<5
<5
<5
<5
<5
<5
<10
<5
<5
<10
<5
<5
<5
<5
<5
<5
<5
<5
<5
<10
<10
<5
Duplicate 17SR
QA-1
HXX011
12/3/91
<10
<10
<10
<10
<5
<5
<5
<5
<5
<5
<5
<10
<5
<5
<10
<5
<5
<5
<5
<5
<5
<5
<5
<5
<10
<10
<5
Duplicate 18DR
QA-2
HYU004
12/4/91
<10
<10
<10
<7 B
<5
<5
<5
2 J|
<5
<5
<10
<5
<5
<10
<5
<5
<5
<5
<5
<5
<5
<5
<5
<10
<10
<5
Field Blank
QA-3
HYU005
12/4/91
<10
<10
<10
<8 B
<5
<5
<5
<5
1 4 J|
<5
<10
<5
<5
<10
<5
<5
<5
<5
<5
<5
<5
<5
<5
<10
<10
<5
Equipment Blank
QA01EB
HIV004
1/17/92
<10
<10
<10
<15 B
<5
<5
<5
<5
<5
<5
<10
<5
<5
<10
<5
<5
<5
<5
<5
<5
<5
<5
<5
<10
<10
<5
                                                                                         GERAGHTY 8 MILLER, INC.

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                                                                                                                 Page 12 of 15
Table 3.  Organic Constituents Analyzed in Post-RI Ground-Water Verification Sampling, June and December 1991 and January 1992,
          Kohler Company Landfill, Kohler, Wisconsin.
Kohler Sample ID '
Laboratory Sample ID
Date Collected
VOCs (us/D (Con't)
1 , 1 ,2,2-Tetrachloroethane
Toluene
Chlorobenzene
Ethylbenzene
Styrene
Xylene (total)
SEMI-VOLATILES (ug/L)
Phenol
Bis(2-Chloroethyl)Ether
2-Chlorophenol
1 ,3-Dichlorobenzene
1 ,4-Dichlorobenzene
Benzyl Alcohol
1 ,2-Dichlorobenzene
2-Methylphenol
Bis(2-Chloroisopropyl)Ether
4-Methylphenol
N-Nitroso-Di-n-Propylamine
Hexachloroe thane
Nitrobenzene
Isophorone
2-Nitrophenol
2,4-Dimethylphenol
Benzoic Acid
Bis-(2-Chloroethoxy)Methane
2,4-Dichlorophenol
Trip Blank
HXX012
12/3/91

<5
<5
<5
<5
<5
<5

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Trip Blank
HYU006
12/5/91

<5
<5
<5
<5
<5
<5

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Trip Blank
IHV002
1/17/92

<5
<5
<5
<5
<5
<5

NA
NA
NA
NA
NA
NA
NA
NA
NA
.NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Duplicate 17SR
QA-1
HXX011
12/3/91

<5
<5
<5
<5
<5
<5

<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<50
<10
<10
Duplicate 18DR
QA-2
HYU004
12/4/91

<5
<5
<5
<5
<5
<5

<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<50
<10
<10
Field Blank
QA-3
HYU005
12/4/91

<5
<5
<5
<5
<5
<5

<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<50
<10
<10
Equipment Blank
QA01EB
HIV004
1/17/92

<5
<5
<5
<5
<5
<5

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
                                                                                          GERAGHTY & MILLER, INC.
W

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                                                                                                              Page 13 of 15
Table 3.  Organic Constituents Analyzed in Post-RI Ground-Water Verification Sampling, June and December 1991 and January 1992,
          Kohler Company Landfill, Kohler, Wisconsin.
Kohler Sample ID '
Laboratory Sample ID
Date Collected
SEMI-VOLATILES (ue/L) (Con't)
1 ,2,4-Trichlorobenzene
Napthalene
4-Chloroaniline
Hexachlorobutadiene
4-Chloro-3-Methylphenol
2-Methylnaphthalene
Hexachlorocyclopentadiene
2,4,6-Trichlorophenol
2,4,5-Trichlorophenol
2-Chloronaphthalene
2-Nitroaniline
Dimethyl Phthalate
Acenaphthylene
2,6-Dinitrotoluene
3-Nitroaniline
Acenaphthene
2,4-Dinitrophenol
4-Nitrophenol
Dibenzofuran
2,4-Dinitrotoluene
Diethylphthalate
4-Chlorophenyl-Phenylether
Flourene
4-Nitroaniline
4 , 6-Dinitro-2-Methylphenol
N-Nitrosodiphenylamine (1)
4-Bromophenyl-Phenylether
Trip Blank
HXX012
12/3/91

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Trip Blank
HYU006
12/5/91

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Trip Blank
IHV002
1/17/92

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Duplicate 17SR
QA-1
HXX011
12/3/91

<10
<10
<10
<10
<10
<10
<10
<10
<50
<10
<50
<10
<10
<10
<50
<10
<50
<50
<10
<10
<10
<10
<10
<50
<50
<10
<10
Duplicate 18DR
QA-2
HYU004
12/4/91

<10
<10
<10
<10
<10
<10
<10
<10
<50
<10
<50
<10
<10
<10
<50
<10
<50
<50
<10
<10
<10
<10
<10
<50
<50
<10
<10
Field Blank
QA-3
HYU005
12/4/91

<10
<10
<10
<10
<10
<10
<10
<10
<50
<10
<50
<10
<10
<10
<50
<10
<50
<50
<10
<10
<10
<10
<10
<50
<50
<10
<10
Equipment Blank
QA01EB
HIV004
1/17/92

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
                                                                                       GERAGHTY & MILLER, INC,

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                                                                                                                Page 14 of 15
Table 3.  Organic Constituents Analyzed in Post-RI Ground-Water Verification Sampling, June and December 1991 and January 1992,
          Kohler Company Landfill, Kohler, Wisconsin.
Kohler Sample ID '
Laboratory Sample ID
Date Collected
SEMI-VOLATILES (ttg/Lt (Con'O
Hexachlorobenzene
Pentachlorophenol
Phenanthrene
Anthracene
Di-n-Butylphthalate
Fluoranthene
Pyrene
Butylbenzylphthalate
3,3' -Dichlorobenzidine
Benzo(a)Anthracene
Chrysene
Bis(2-Ethylhexyl)Phthalate
Di-n-Octyl Phthalate
Benzo(b)Fluoranthene
Benzo(k)Fluoranthene
Benzo(a)Pyrene
Indeno(l ,2,3-cd)Pyrene
Dibenz(a ,h) Anthracene
Benzo(g,h,i)Perylene
PHENOLS (ue./Vi
4-Chloro-3-Methylphenol
2-Chlorophenol
2,4-Dichlorophenol
2,4-Dimethyphenol
2,4-Dinitrophenol
Trip Blank
HXX012
12/3/91

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
Trip Blank
HYU006
12/5/91

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
Trip Blank
IHV002
1/17/92

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
Duplicate 17SR
QA-1
HXX011
12/3/91

<10
<50
<10
<10
<10
<10
<10
<10
<20
<10
<10
<15 B
<10
<10
<10
<10
<10
<10
<10

<2.0
<2.0
<2.0
<2.0
<5.0
Duplicate 18DR
QA-2
HYU004
12/4/91

<10
<50
<10
<10
<10
<10
<10
<10
<20
<10
<10
<10 B
<10
<10
<10
<10
<10
<10
<10

<2.0
<2.0
<2.0
<2.0
<5.0
Field Blank
QA-3
HYU005
12/4/91

<10
<50
<10
<10
<10
<10
<10
<10
<20
<10
<10
<10 B
<10
<10
<10
<10
<10
<10
<10

<2.0
<2.0
<2.0
<2.0
<5.0
Equipment Blank
QA01EB
HIV004
1/17/92

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
                                                                                         GERAGHTY & MILLER, INC.

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                                                                                                                                  Page 15 of 15
Table 3.   Organic Constituents Analyzed in Post-RI Ground-Water Verification Sampling, June and December 1991 and January  1992,
            Kohler Company Landfill, Kohler, Wisconsin.

Kohler Sample ID '
Laboratory Sample ID
Date Collected
PHENOLS (ug/U (Con'O
2-Methyl-4,6-Dinitrophenol
2-Nitrophenol
4-Nitrophenol
Pentachlorophenol
Phenol
2,4, 6-Trichlorophenol

Trip Blank
HXX012
12/3/91

NA
NA
NA
NA
NA
NA

Trip Blank
HYU006
12/5/91

NA
NA
NA
NA
NA
NA

Trip Blank
IHV002
1/17/92

NA
NA
NA
NA
NA
NA
Duplicate 17SR
QA-1
HXX011
12/3/91

<5.0
<2.0
<5.0
<5.0
<2.0
<2.0
Duplicate 18DR
QA-2
HYU004
12/4/91

<5.0
<2.0
<5.0
<5.0
<2.0
<2.0
Field Blank
QA-3
HYU005
12/4/91

<5.0
<2.0
<5.0
<5.0
<2.0
<2.0
Equipment Blank
QA01EB
HIV004
1/17/92

NA
NA
NA
NA
NA
NA
|   j Analyte was detected.
NA - Sample was not analyzed for indicated parame
B - Chemical constituent was detected in the associated method blank.
J - Constituent is estimated.
< - Constituent was not detected at, or above, the given quantitation limits.
(b) - Chemical constituent was detected in the field blank.
A summary of data qualifiers is provided in Appendix Q, Final RI report, Geraghty & Miller, 1991.
 1404KOHLERVII/OWDATA.WK1
                                                                                                       GERAGHTY & MILLER, INC.

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                                                                                                                                     Page 1 of 4
Table 4.   Low-Level PCBs Analyzed in Post-RI Ground-Water Verification Sampling, December 1991 and January 1992,
            Kohler Company Landfill,  Kohler, Wisconsin.
Kohler Sample ID
Laboratory Sample ID
Date Collected
PCBs (ue.IV)
Aroclor 1016
Aroclor 1221
Aroclor 1232
Aroclor 1242
Aroclor 1248
Aroclor 1254
Aroclor 1260
SB2
SX05B2
12/5/91
Unfiltered

<0.10
<0.20
<0.10
<0.10
<0.10
<0.10
<0.10
SB2 dilution*
SX05B2
12/5/91
Unfiltered

<1.0 DJ
<2.0 DJ
<1.0 DJ
<1.0 DJ
<1.0 DJ
<1.0 DJ
<1.0 DJ
SB-4
SX05B4
12/5/91
Unfiltered

<0.10 J
<0.20 J
<0.10 J
<0.10 J
<0.10 J
<0.10 J
<0.10 J
SB-4 dilution* OW-2 OW-2
SX05B4 SXOOW2 IHV-05
12/5/91 12/5/91 01/17/92
Unfiltered Unfiltered Unfiltered

<1.0 DJ <0.
<2.0 DJ <0.
<1.0 DJ 0.
<1.0 DJ <0.

10 <0.10
20 <0.20
15 <0.10
10 <0.10
<1.0 DJ <0.10 <0.10
<1.0 DJ <0.
<1.0 DJ <0.
10 <0.10
10 <0.10
OW-2
IHV-06
01/17/92
Filtered

<0.10
<0.20
<0.10
<0.10
<0.10
<0.10
<0.10
 Polychlorinated Biphenols (PCBs) analyzed by USEPA-approved Standard Operating Procedure to acheive lower than contract required detection limits
 (Gulf South, May, 1991).
 J - Concentration is estimated.
 D - Sample was diluted and reanalyzed due to significant matrix interferences.
 < - Constituent was not detected at, or above, given quantitation limit.
 * Due to significant levels of matrix interferences present in the sample, lower detection limits were not attained.
      Analyte was detected.
 1404KOHLERVm/pcbuni.wkl
                                                                                                        GERAGHTY & MILLER, INC,

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                                                                                                                                    Page 2 of 4
Table 4.   Low-Level PCBs Analyzed in Post-RI Ground-Water Verification Sampling, December 1991 and January 1992,
            Kohler Company Landfill, Kohler, Wisconsin.
Kohler Sample ID
Laboratory Sample ID
Date Collected
PCBs (qg/L)
Aroclor 1016
Aroclor 1221
Aroclor 1232
Aroclor 1242
Aroclor 1248
Aroclor 1254
Aroclor 1260
4
IHV-11
01/17/92
Unfiltered

<0.10
<0.20
<0.10
<0.10
<0.10
<0.10
<0.10
4D
SX04D
12/5/91
Unfiltered

<0.10
<0.20
<0.10
<0.10
<0.10
<0.10
<0.10
05
SX0005
12/5/91
Unfiltered

<0.10
<0.20
<0.10
<0.10
<0.10
<0.10
<0.10
5D
SX005D
12/5/91
Unfiltered

<0.10
<0.20
<0.10
<0.10
<0.10
<0.10
<0.10
6RE 11 11
SX06RE IHV-09 IHV-12
12/5/91 01/17/92 01/17/92
Unfiltered Unfiltered Filtered

<0.10 <0
<0.20 <0
<0.10 <0
<0.10 0
<0.10 <0
<0.10 <0
<0.10 <0

10 J <0.10
20 J <0.20
10 J <0.10
67 J <0.23
.10 J <0.10
.10 J <0.10
.10 J <0.10
 Polychlorinated Biphenols (PCBs) analyzed by USEPA-approved Standard Operating Procedure to acheive lower than contract required detection limits
 (Gulf South, May, 1991).
 J - Concentration is estimated.
 D - Sample was diluted and reanalyzed due to significant matrix interferences.
 < - Constituent was not detected at, or above, given quantitation limit.
 * Due to significant levels of matrix interferences present in the sample, lower detection limits were not attained.
      Analyte was detected.
 1404KOHLERVm/pcb8«m.wkl
                                                                                                       GERAGHTY & MILLER, INC.

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                                                                                                                                      Page 3 of 4
Table 4.   Low-Level PCBs Analyzed in Post-RI Ground-Water Verification Sampling, December 1991 and January 1992,
            Kohler Company Landfill, Kohler, Wisconsin.
Kohler Sample ID
Laboratory Sample ID
Date Collected
11D 1 ID dilution* 11D 11D 13
SX011D SX011D IHV-08 IHV-10 SX0013
12/5/91 12/5/91 01/17/92 01/17/92 12/5/91
Unfiltered Unfiltered Unfiltered Filtered Unfiltered
PCBs (ug/U
Aroclor 1016
Aroclor 1221
Aroclor 1232
Aroclor 1242
Aroclor 1248
Aroclor 1254
Aroclor 1260

<0.10 J <1.0 J <0
<0.20 J <2.0 J <0
<0.38 J* <1.0 J <0
<0.28 J* <1.0 J 0

10 <0.10 <0.10
20 <0.20 <0.20
10 <0.10 <0.10
27 J <0.10 <0.10
<0.10 J <1.0 J <0.10 <0.10 <0.10
<0.10 J <1.0 J <0
<0.10 J <1.0 J <0
.10 <0.10 <0.10
.10 <0.10 <0.10
18SR
SX18SR
12/4/91
Unfiltered

<0.10
<0.20
<0.10
<0.10
<0.10
<0.10
<0.10
18DR
SX18DR
12/4/91
Unfiltered

<0.10
<0.20
<0.10
<0.10
<0.10
<0.10
<0.10
 Polychlorinated Biphenols (PCBs) analyzed by USEPA-approved Standard Operating Procedure to acheive lower than contract required detection limits
 (Gulf South, May, 1991).
 J - Concentration is estimated.
 D - Sample was diluted and reanalyzed due to significant matrix interferences.
 < - Constituent was not detected at, or above, given quantitation limit.
 * Due to significant levels of matrix interferences present in the sample, lower detection limits were not attained.
       Analyte was detected.
 1404KOHLERVm/pcbum.wkl
                                                                                                        GERAGHTY & MILLER, INC.

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                                                                                                                                  Page 4 of 4
Table 4.   Low-Level PCBs Analyzed in Post-RI Ground-Water Verification Sampling, December 1991 and January 1992,
            Kohler Company Landfill, Kohler, Wisconsin.
Kohler Sample ID
Laboratory Sample ID
Date Collected
PCBs (ue/L)
Aroclor 1016
Aroclor 1221
Aroclor 1232
Aroclor 1242
Aroclor 1248
Aroclor 1254
Aroclor 1260
Equipment
Blank
QA-1EB
IHV-04
01/17/92
Unfiltered

<0.10
<0.20
<0.10
<0.10
<0.10
<0.10
<0.10
Equipment
Blank
QA-1EB
IHV-07
01/17/92
Filtered

<0.10
<0.20
<0.10
<0.10
<0.10
<0.10
<0.10
Duplicate
18DR
QA-2
SXOQA2
12/4/91
Unfiltered

<0.10
<0.20
<0.10
<0.10
<0.10
<0.10
<0.10
Duplicate
OW2
QA-2
IHV-13
01/17/92
Unfiltered

<0.10
<0.20
<0.10
<0.10
<0.10
<0.10
<0.10
Duplicate
OW2
QA-2
IHV-14
01/17/92
Filtered

<0.10
<0.20
<0.10
<0.10
<0.10
<0.10
<0.10
Duplicate
13
QA-4
SXOQA4
12/5/91
Unfiltered

<0.10
<0.20
<0.10
<0.10
<0.10
<0.10
<0.10
 Polychlorinated Biphenols (PCBs) analyzed by USEPA-approved Standard Operating Procedure to acheive lower than contract required detection limits
 (Gulf South, May, 1991).
 J - Concentration is estimated.
 D - Sample was diluted and reanalyzed due to significant matrix interferences.
 < - Constituent was not detected at, or above, given quantitation limit.
 * Due to significant levels of matrix interferences present in the sample, lower detection limits were not attained.
      Analyte was detected.
 1404KOHLERVffl/pcbsam.wkl
                                                                                                     GERAGHTY & MILLER, INC.

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                                                                                                                                                                       Page 1 of 2
  Table 5.  Summary of Inorganic Constituents Detected in Till Wells, Phase III RI, Kohler Company Landfill, Kohler, Wisconsin.
   Sample ID
Background
(Maximum)
                                MCL
                                 ES
2D
OW2
3D
4D
                                                                                                                                         5D
                                                                    8(RE)
                                                                    8D
Antimony          96

Arsenic            7.3           50

Barium            361          1,000

Cadmium          5.7           10

Chromium        12.2*          50

Copper            68.7

Iron              223

Lead              <1           50

Silver             7.9           50

Zinc              32.3

Flouride (Dist)     1.04          4

Flouride (Elect)   0.367          4

Nitrate-Nitrite    0.509          10
                                                                         70.6 UJ

                                                                         <2.0 J

                                                                         48.2 J

                                                                         <2.0

                                                                          7.2 J

                                                                         84.6 |

                                                                          176

                                                                          1.0 J

                                                                          9.1 UJ

                                                                       |  59.6 [

                                                                         0.439

                                                                         0.271

                                                                         0.299
   109  UJ|

 <2.0  J

  39.4  J

   2.5  J

  47.9  J   |

  53.2

   195

 <1.0

   7.5  UJ

| 44.4  |

| 2.21  |

| 2.17  |

 0.101
 NA

 NA

 NA

 NA

 NA

 NA

 NA

 NA

 NA

 NA

 NA

 NA

0.073
                                                                                            59.9  UJ

                                                                                            <2.0

                                                                                            24.7  J

                                                                                             2.6  UJ

                                                                                             9.6  J

                                                                                           |  118 |

                                                                                            75.3  J

                                                                                            <1.0

                                                                                             6.0  UJ

                                                                                           1150   |

                                                                                            0.832

                                                                                           | 0.474 |

                                                                                            0.174
                                                               <32.0 J

                                                                <3.0 J

                                                                55.2 J

                                                                <2.0

                                                                <5.4 UJ

                                                               | 75.7 R|

                                                                41.5 UJ

                                                                <1.0 J

                                                                 5.8 J

                                                               | 82.6 J  |

                                                                 NA

                                                                0.225

                                                                0.146
                                                                 <32.0  J

                                                                  <3.0

                                                                   80.6  J

                                                                 I   7-8  U  I
                                                                 |  17.4  UJ|

                                                                   60.7  R

                                                                    127  UJ

                                                                  <1.0  J

                                                                    4.3  J

                                                                 |  60.1  J  |

                                                                    NA

                                                                  0.195

                                                                  0.350
                                                                   68.9  J

                                                                  <3.0  R

                                                                   48.8

                                                                  <2.0  J

                                                                  <4.0

                                                                    6.3  U

                                                                   24.8  U

                                                                  <1.0

                                                                  <2.0

                                                                  <3.0

                                                                    NA

                                                                 | 0.447  |

                                                                  0.093
                                                         49.7  UJ

                                                          5.5  J

                                                         54.1  J

                                                          3.5  UJ

                                                         13.1  J  |

                                                         74.7  U|

                                                         73.9  J
                                                         <2.0

                                                        |  37.7  U|

                                                         0.418

                                                         0.334

                                                         0.267
   Concentrations are /ig/L, except Flouride and Nitrate-Nitrite at mg/L.
   NS - No sample collected.
   NA - No analysis.
   Data qualifiers are provided in Appendix Q, Final RI report, Geraghty & Miller, 1991
   |    [   Value is above background concentration.
'   [    |   Value exceeds Safe Drinking Water Act [42 USC 300(f) et seq.] Maximum Contaminant Levels (MCLs) or Enforcement Standards (NR140.10 Wisconsin Administration Code).
   * - Chromium concentration from Well OW1 was not included in the calculation for the background chromium concentration.
   < - Constituent was not detected at, or above, the given quantition limits.

   1404KOHLERVm/tillwcll.wkl
                                                                                                                                GERAGHTY & MILLER, INC.

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                                                                                                                                                        Page 2 of 2
Table 5.  Summary of Inorganic Constituents Detected in Till Wells, Phase III RI, Kohler Company Landfill, Kohler, Wisconsin.
Background MCL
Sample ID (Maximum) ES 1 1

Antimony 96 , 657 J

Arsenic 7.3 50 18.4 J
Barium 361 1000 14.2 U
Cadmium 5.7 10 4.2 U
Chromium 12.2+ 50 7&Q if

Copper 68.7 92.3 R

Iron 223 320 UJ
Lead <1 50 | 100 |
Silver 7.9 50 4.2 J
Zinc 32.3 87.0 J
Flouride (Dist) 1.04 4 NA
Houride (Elect) 0.367 4 NA
Nitrate-Nitrite 0.509 10 NA
11D 12 12D 13 14

] 46.3 J 53.4 UJ 40.8 UJ <640 J 42.7

| 7.7 J | <2.0 <2.0 J <3.0 <3.0
30.7 U 56.9 J 35.7 J 186 J 41.6
<2.0 2.8 UJ <2.0 4.2

j | 40.2 J 5.2 J | 35.3 j| <80.0 | 14.4

66.1 R | 83.0] 64.8 <40.0 J 31.0

| 328 UJ 55.6 J | 264 | <100 389
<1.0 J <1.0 <1.0 | 5.6 | <1.0
4.1 J 2.5 J 6.4 UJ 9.1

| | 47.0 J | 78.9 | | 47.0 | <60.0 | 61.7
NA 0.223 0.555 NA NA
I'ljO"! <0-1 1 0.677 | 1 0.407 | 0.346
0.267 0.292 0.203 0.232 0.041
15 16
J 32.1 U 1 854 J|
J 5.8 J 3.6 J
U 91.6 J 126 J
U <2.0 <40.0
UJ 9.1 UJ <80.0
R 38.0 UJ <40.0 J
UJ 1 2,510 | <100

J | 1.1 J | <1.0

J 2.9 UJ | 40.0 j|

J | 29.0 U <60.0
NA NA
| 0.413 | [ 0.589 |
0.092 0.445
Concentrations are /ig/L, except Flouride and Nitrate-Nitrite at mg/L.
NS - No sample collected.
NA - No analysis.
Data qualifiers are provided in Appendix Q, Final RI report, Geraghty & Miller, 1991
| | Value is above background concentration.
| j Value exceeds Safe Drinking Water Act [42 USC 300(f) et seq.] Maximum Contaminant Levels (MCLs) or Enforcement Standards (NR140. 10 Wisconsin Administration Code).
* - Chromium concentration from Well OW1 was not included in the calculation for the background chromium concentration.
< - Constituent was not detected at, or above, the given quantition limits.
1404KOHLERVIII/tillwcll.wkl
GERAGHTY & MILLER, INC.
17
<32.0 J
5.2 J
76.8 J
<2.0
16.2 UJ
36.4 R
64.1 UJ
3.2 UJ
3.3 J
45.4 J
NA
0.503 |
0.149
o

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                                                                                                                                         Page 1 of 2
Table 6. Summary of Inorganic Constituents Detected in Bedrock Wells, Phase III RI, Kohler Company Landfill, Kohler, Wisconsin.
Background MCL
Sample ID (Maximum) ES 2SR
2DR 3R 3SR 3DR 8R 8SR SDR 13R

Antimony ,61.4 <32 J [
Arsenic 6.3 50 <3.0
Barium 60.1 1,000 43.7 J
Cadmium 3.3 10 | 3.6 UJ

Chromium 15.9 50 &J J | |

Copper 47.9 97.2 R|
Iron 253 172 UJ
Lead 1.5 50 <1.0
Silver 9.7 50 2.7 J
Zinc 66.7 53.6 J
Flouride (Dist) 0.533 4 NA
Flouride (Elect) 0.514 4 1 0.580 1
Nitrate-Nitrite 0.187 10
78.3 UJ| <640 J <32 J <640 J 40.4 J <640 J | 778 J | | 902 J |
NR 4.4 J <3.0 R <3.0 5.5 J <3.0 <3.0 J <3.0
56.8 J 130 J | | 121 J | | 174 J ] | 84.6 J | 288

<2.0 ["30,e J \ 3.3 UJ <40.0 3.2 U <40

16.3 UJ| <80 <4.0 <80.0 | 16.0 UJ | <80
48.5 <40.0 J 5.5 U <40.0 J 43.3 R <40
J | t,m J 1 | 168 J |
.0 <40.0 <40.0
.0 <80.0
.0 J <40.0 J <40.0 J
178 520 J| 23.4 U <100 75.7 UJ <100 1 5,370 1 <100

<1.0 J <1.0 <1.0 <1.0 | 2.8 U | <1.

8.3 UJ <40.0 J <2.0 <2.0 J S4.I
37.7 <60.0 5.5 J <60.0 62.6 J <60
0 <1.0 <1.0 J
) J i m J | [ flfli J |

.0 | 154 J | <60.0
NA NA NA NA NA NA NA NA
NS 0.391 0.373 0.456 0.326 0.442 0.416 0.446
0.018 0.067 0.093 0.074 1 0.324 | |0.194| 1 0.289 1 0.181
Concentrations are /Jg/L, except Flouride and Nitrate-Nitrite at mg/L.
NS - No sample collected.
NA - No analysis.
NR - Not reported.
Data qualifiers are provided in Appendix Q, Final RI report, Geraghty & Miller, 1991.
Value is above background concentrations.

Value exceeds Safe Drinking Water Act [42 U.S.C. 300(0 «* set}-] Maximum Containment Levels (MCLs) or Enforcement Standards (s. NR 140.10 Wise. Admin. Code).
 1404KOHLERVIII/bedrock.wkl
                                                                                                        GERAGHTY & MILLER, INC.

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                                                                                                                                   Page 2 of 2
Table 6. Summary of Inorganic Constituents Detected in Bedrock Wells, Phase HI RI, Kohler Company Landfill, Kohler, Wisconsin.
Background MCL
Sample ID (Maximum) ES 13SR 13DR 14SR 15SR 15DR 16SR


Antimony 61.4 <640 J <3.2 <32.0 <640 J 53.7 U | 740
Arsenic 6.3 50 <3.0 <0.30 <3.0 J <3.0 <3.0 J <3.0
Barium 60.1 1,000 | 108 j| <0.30 96.2 J | | 228 J | | 76.6 j| 160


Cadmium 3.3 10 <40.0 <0.20 <2.0 <2.0 <40.0
Chromium 15.9 50 <80.0 <0.40 4.4 UJ <80.0 6.8 UJ <80.0
Copper 47.9 <40.0 J 0.97 UJ 23.8 UJ <40.0 J 24.5 UJ <40.0
Iron 253 <100 <0.50 J | 1,110 1 <100 26.1 UJ <100
Lead 1.5 50 <1.0 <0.10 J <1.0 J <1.0 J <1.0 J 1.3
Silver 9.7 50 | V» j] 0.26 UJ 6.4 UJ <70.0 J 3.5 UJ 7&0
Zinc 66.7 <60.0 0.94 UJ 8.9 UJ <60.0 6.6 UJ <60.0
Flouride (Dist) 0.533 4 NA NA NA NA NA NA
Flouride (Elect) 0.514 4 0.449 0.416 [ 0.648 | 1 0.533 1 0.450 0.498
Nitrate-Nitrite 0.187 10 0.200 0.022 | 1.56 | 0.075 0.076 0.09
16SR DUP 17SR

J | 652 | 83.5 UJ
<3.0 <2.0 J
J | 148 | 102 J
<40 3.5 J
<80 10.7 UJ
J <40 | 49.4 |
| 268 | 45.9 UJ
J <1.0 <1.0
J illHil 5.7 UJ
<60.0 40.4
NA 0.456
0.413 0.394
| 0.20 | 0.098
Concentrations are ngfL, except Flouride and Nitrate-Nitrite at mg/L.
NS - No sample collected.
NA - No analysis.
NR - Not reported.
Data qualifiers are provided in Appendix Q, Final RI report, Geraghty & Miller, 1991.

11
Value is above background concentrations.

Value exceeds Safe Drinking Water Act [42 U.S.C. 300(f) et seq.] Maximum Containment Levels (MCLs) or Enforcement Standards (». NR 140. 10 Wise. Admin. Code).
 1404KOHLERVIII/bedrock.wkl
                                                                                                   GERAGHTY & MILLER, INC.
o

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                               Table 7                               Page I of 2
Federal and Wisconsin Water Quality Criteria for the Constituents of Concern
      And Comparison to Estimated Sheboygan River Concentrations
              Kohler Company Landfill, Kohler, Wisconsin
                            Units in mg/L

1
Constituent
]-
VOC's
Acetone
1 Benzene
2-Butanone (MEK)
Cartoon disulfide
IChlorobenzenc
Chloroe thane
Chloroform
11.1-DichJoroethane
1,2-Dichloroethane
1.1-Dichioroethene
11,2-Dichloroethene (total)
Ethylbenzene
4-Methyl-2-pentanone
1 Methylene chloride
1 Toluene
1,1,1 -Trichloroethane
_ Trichlorocthenc
1 Vinyl chloride
Xylene
| Semi- VOC's
1 Bis(2-chloroethyl)ether
Bis(2-chloroisopropyl)ether
1Bis(2:ethylhexyl)phihalatc
Butylbenzylphthalate
4-Chloro-3-methylphenol
12,4-Dichlorophenol
2,4-Dimethylphenol
Di-n-ocryl phthalate
_ Fluoranthene
1 2-MethylpbCTol
4-Methylpbenol
N-nitrosodiphenylamine
I Phenanthrene
• Phenol
Pyrene
IPCB's

Taken from Figure 4 of
I
1
Federal Criteria Other Wisconsin Criteria
Fresh Water Toxldty wild/Demotic
Acute Chrook Values Acute Chronic Animal

.
5.3* ....
-
-
0.25" 0.05" ....
.
28.9* 124* -
.....
118* 20*
11.6** -
11. 6« - - - -
32*
.
11*4 ....
17.5* - - - - -
18**.
45* 21.9* ....
-
13.9C7)

238* - . .
238* ....
0.94** 0.003*s ....
0.94** 0.003*1 ....
0.03* ....
2".02* 0.365* ....
2.12* ....
0.94*5 0.003*J ....
3.98* ....
15.8W
21.1<8>
5.85*6 ....
0.03 (p) 0.0063 (p) ....
10.2* 2.56* ....
0.09 «>'
0.002* 0.000014* - - - 0.000003

Preliminary Ecological Assessment (WWES, 1993).


wds - (M005.04 |:\n«Vkohl«^COMOOEL.XLS
1

Most
Stringent
Criteria

-
5.3
-
-
0.05
-
1.24
.
20
11.6
11.6
32
-
11
17.5
18
21.9
-
13.9

238
238
0.003
0.003
0.03
0.365
2.12
0.003
3.98
15.8
21.1
5.85
0.0063
2.56
0.09
0.000003




Estimated
River
Concentrator

0.0094
0.000032
ND
0.000028
0.000053
0.00015
0.0000059
0.0029
0.00007
0.000013
0.0017
0.000024
0.000035
0.001
0.00024
0.00015
0.005
0.00059
0.000085

0.00019
0.000012
0.000038
0.000027
0.000044
0.00005
0.0059
0.000021
0.0000059
0.00012
0.00014
0.000012
ND
0.000044
0.0000088
0.0032




Pnnttd: 11/10^1

*».

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 1
 1
 1
 I
 I
 I
 I
 I
 I
                                                                                               \
                                                        Table  7                                    Page 2 of Z
                    Federal and Wisconsin Water Quality Criteria for the Constituents of Concern
                            And Comparison to Estimated Sheboygan River Concentrations
                                     Kohier Company Landfill, Kohler, Wisconsin
                                                     Units in m#/L
Constituent
Inorganics
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chloride
Chromium
Cobalt
Copper
Fluoride
Iron .
Lead
Magnesium
Manganese
Nickel
Nitrate-nitrite
Potassium
Selenium
Silver
Sodium
Suifate
Vanadium
Zinc
Federal
Fresh
Acute

0.75 (pH)
0.088 (p)
0.36
-
0.13*
0.0158**
-
860
0.016
-
0.0566**
-
-
OJ92**
-
-
4.71**
-
-
0.02
0.0009 (p)
-
-
-
0.333**
Criteria Other Wisconsin Criteria Most
Water Toxicity Wild/Domestic Stringent
Chronic Values Acute Chronic Animal Criteria

0.087 (pH)
0.03 (p)
0.19
-
0.0053*
0.00299**
-
230
0.011
-
0.0339**
-
1
0.0153**
-
-
0244**
-
-
0.005
0.00012
-
-
-
0.301**

-
-
0.3638
-
-
0.116**
.
-
0.0142
-
0.0529**
-
-
0.812**
-
-
3.06**
-
-
0.058
0.00841**
-
-
-
0293**

-
-
0.153
-
-
0.00189**
.
'- -
0.00974
-
0.0368**
-
-
0.0484**
-
-
0.188**
-
-
0.00707
0.00841**
-
.
-
0.141**

0.087
0.03
0.153
-
0.0053
0.00189
.
230
0.00974
-
0.0339
-
1
0.0153
-
-
0.188
-
-
0.005
0.00012
-
-
-
0.141
Estirnatec
River
Concentrati

0.0041
0.0021
0.002
0.0041
0.000007
0.00007
4.4
0.23
0.003
0.00097
0.0042
0.0094
0.013
0.000044
1.6
0.011
0.001
0.27
0.2
0.0000059
0.00038
0.67
1.1
0.0016
0.023
                  * This value is the Lowest Observed Effea Level (LOEL) due to insufficient data to develop criterion.
                  ** Hardness-dependant criterion (343 mg/L CaCO3 equivalent from Blasland & Bouck, 1990 was use.
                  (p) This criterion is proposed
                  (pH) This criterion is pH-dependant (7.8 from U.S.G.S., 1991 for Manitowoc River at
                      Manitowoc, WI, March 1991).
                  1 This value is for chlorinated benzenes.      2 This value is for dichloroethylenes.
                  1 This value is for phthalate esters.          * This value is for halomethanes.
                  5 This value is for trichlorinated ethanes.     6 This value is for nitrosamines.
                  7 EC50 (immobilization) for mosquito larvae (Berry and Brummer, 1977).
                  1 EC50 (immobilization) for Daphnin mapna (Koppennan, et al, 1974).
                  ' EC50 (immobilization) for Daphnin mapna (Abemathy, et al.  1986).
                  - No criterion available.
                  Shaded concentrations exceed the most stringent water quality criteria
  iFaken from Figure 4  of Preliminary Ecological Assessment  (WWES,  1993).
I

I
- 04005.04 j:V3MVkohler^COMODEL.XLS
                             GERAGHTY & MILLER.HNC.
                                                                                     Pnnied:

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 The  majority of  the  groundwater contamination  in  found  in  the upper
 till/alluvium unit.   Enforcement standard  exceedances are  also  found  in  the
 upper  bedrock unit.   Figures  3,  4,  5  and 6 provide  a summary of VOC compounds
 and  concentrations in the  surficial till,  lower till, shallow bedrock and
 deeper bedrock wells.   Contamination  is generally found beneath and
 downgradient of  the  landfill,  to the  Sheboygan River.   Contamination  due to
 the  landfill has not been  found in  monitoring  wells across  the  river.
 Contamination in the upper bedrock  unit is believed to  have been due  to  the
 disposal  of  solvents in the old waste pit, which  may have  created a large
 enough hydraulic head to force  contamination through the middle till  unit  into
 the  bedrock  aquifer.

 Leachate  seeps are also found along the edge of the landfill, between the
 river  and landfill.   Compounds  found  in the seeps are primarily VOCs  and
 inorganics.   Table 2 of the Source  Control ROD summarizes  these compounds  and
 their  concentrations.

 VI.    SUMMARY OF SITE RISKS

 A baseline risk  assessment was  completed pursuant to the NCP to determine
 whether the  contaminants of concern identified at the site  pose a current  or
 potential  risk to human health  and  the environment in the absence of  any
 remedial  action.  It provides information  used in determining whether  action
 is necessary and is  one justification for  performing remedial actions.   The
 baseline  risk assessment includes an  exposure  assessment and a  toxicity
 assessment,  the  results of which are  combined  to develop an overall
 characterization of  risk.

 The  baseline risk assessment  for the  Kohler site was completed  to evaluate
 public  health and environmental  risks associated with the chemical
 constituents detected  in groundwater,  leachate and surface  water.   A number of
 scenarios were evaluated and  estimated risks calculated.  Two of the  scenarios
 exceeded U.S.  EPA's  health-based guidelines of 1 x 10-4 to  1 x  10-6 for  excess
 lifetime  cancer  risk and 1.0  for the  hazard index (HI).   Potable use of
 groundwater  by hypothetical future  residents (both adults and children)
 resulted  in  risk estimates  that  exceed the guidelines.   Exposure to VOCs while
 showering by hypothetical  future adults using water drawn from  the
 unconsolidated unit  resulted  in  an  HI exceeding 10.   While  the  risk assessment
 covered a variety of potential  scenarios,   the  selected  source control  remedy
 will eliminate certain  direct contact exposure scenarios,  and the groundwater
 remedy  selected  will  further reduce both human and environmental exposure from
 other pathways.

 Excess  lifetime  cancer  risks are determined by multiplying  the  intake  level
 with a  cancer potency factor.   These  risks are probabilities that are
 generally expressed  in  scientific notation (e.g.,  1 x 10-6 means that an
 individual has an additional one in one million chance of developing cancer as
 a result of  site-related exposure to  a carcinogen over a 70-year lifetime
under the specific exposure conditions at a site).

 Potential concern for noncarcinogenic effects of a single contaminant in a
 single medium  is  expressed as the hazard quotient (HQ)   (or the ratio of the
estimated intake  derived from the contaminant concentration in a given medium
by the  contaminants's reference  dose).  By adding the HQs for all  contaminants
within a medium  or across all media to which a given population may reasonably
be exposed,  the  HI can be generated.  The HI provides a  useful reference point
 for gauging  the  potential significance of multiple contaminant exposures
within a single  medium or across media.

Constituent  Characterization

Based on the occurrence of specific constituents and a comparison of the
constituent  concentrations to standards  and criteria,  a  listing of chemicals
of concern (COCs) was developed.  The  COCs are as follows:

      benzene                       aluminum

-------
                                                         OW1-SR
                                                         OW1-DR
                                                                                U-Otchlorwhw
                                                                                Total VOC*
                                                           OW2
                                                         NoraOaMdcd
                                     11
                             14,000 Tridibr(Mh«w
                              8,100 1,1-OcManMChan*
                              1.200 U-ddilonwUwm
                               540 TokMM
                               380 CtUoreMham
                               200 i.i.t-TffcMarnihaM
                               190 XytoM
                               170
                               120 Chkmbwinm
                               50 B«n»n«
                               45 4-M«hyl-2-P»manoo«
                               44 EthytMnnm
                               28 VlnylChlarid*
                               14 1.1-OcMaroelhan*
                         110 Vinyl Chkxld*
                         62
                                4 1.2-OlcnoroettMiw
                                2 TMilaroMtww
                                   40
                              2  12-ddikxaothens
                                     50
                               770 VlnyHCWorid*
                               680 1.2-OlcNoraMlMn*
                               43 1,1-0chl
-------
                                         8D
                                    77  1^-Dchloroelhene
                                     7  Trichloroatnen*
                                     6  Vinyt Chkxid*
\
  I  I
I   I
i   I
\   t
\  \
 \  \
  \
   \  \
'< ' LEGEND
                                                i i
                                                          EXISTING WELLS
                N
          200_   400

            SCALE IN FEET
                           800
          (^MILLER, INC.
          Environmental Services
                                     FIGURE 4
  PHASE III VOCs (ug/L) IN LOWER TILL WELLS
                       KOHLER COMPANY LANDFILL
                             KOHLER, WISCONSIN
                                      WM6413- 0764.31

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                                    \
                                                               OR
                                                                                  14SR
                                                                             700 ' .2-Oicnkw o«n»n«
                                                                             430 Vinyl Chbrue
                                                                              •6 1.1-Ochkxoetharw
                                                                              3 1.1-Dichloro«h«ne
                                                                              2 Chtoroathane
                                                                              2 Tncftloroethene
                                                                                           120

                                                                                            12
                                                                                                  2SR
                                                                                                1.2-OictilcxoMherw
                                                                            1.153 TotalVOCt
\
  /  '
 /  i

 /   i
/   i
i    i
 \  \
  \   \
  \  •>
   \ \
      • OW2
                                                                           3R
                                                                      130
                                                                      120  Vinyl Chlonda
                                                                       3  1.1-Dichloro0tnan«

                                                                      253  TotalVOCt
>6
V*
^1
S*«SD
8R
1.400 1,2-OWiloroethene
370 Trichloroethene
140 Vinyl Chloride
13 1.1-Dichkxoethane
2 1.1-DJcnkxoeihena
2 Chkxobenzene
1.927 TotalVOCt
17SR |17S3»
3 Chloroform J-"^
^
8D-
/'
/ /

10
3SR k^3SR I '
40 Vinyl Chloride 1 J"^35)H /
20 1.2-Dichloroethene MS^ ' 1
5 1.1-DichlonMhane f ' /
** ™™* 1 sim* ' ;

13SR
97 1.2-Dichloroethene
11 Vinyl Chloride
5 Trichkuoethsne
113 TolalVOCt
r*^
WISHES^. 	 —
8SR
170 1,2-Olchkxoethene
38 Trichloroethene
26 Vinyl Chloride
2 1.1-Oichloroetnane
236 TotalVOCt
40»«4

— ^^
13 A*
13C*>.
w
13DR


	
|WP /'/
S^ /.'
13R
100 1^-Oichloroethene
9 Vinyl Chkxide
5 Trichlenethene
114 TotalVOCt
^C' 1|
>^v>s^ •
' 7^^ 15SR.V
^.' ^.SDR*
15SR
2 Chloroform
                                                                         16SR
                                                                      2 Chloroform
                                         16SR
        ' ,' LEGEND
                                                                 EXISTING WELLS
                 N
           200    400
                 " •
             SCALE IN FEET
                               800
            & MILLER, INC.
           Environmental Services
                                                 FIGURE 5

PHASE ill VOCs (ug/L) IN SHALLOW BEDROCK WELLS
                                 KOHLER COMPANY LANDFILL
                                        KOHLER, WISCONSIN
                                                  WI16413 - 0764.32

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                                                  13DR
                                               2 1.2-0tetiloro«hene
                                               1 Chbfotofrn
                                            EXISTING WELLS
200   400
      •
  SCALE IN FEET
  GERAGHTY
 '& MILLER, INC
Environmental Serricei
                                   FIGURES
PHASE III VOCs (ug/L) IN DEEP BEDROCK WELLS
                      KOHLER COMPANY LANDFILL
                            KOHLER, WISCONSIN
                                    WI16413- 0764.33

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       2-butanone                    antimony
       chlorobenzene                 arsenic
       chloroethane                  beryllium
       1,1-dichloroethane             cadmium
       1,2-dichloroethane             chromium
       1,1-dichloroethene             cobalt
       1,2-dichloroethene(total)      copper
       ethylbenzene                  fluoride
       4-methyl-2-pentanone           iron
       toluene                        lead
       1,1,1-trichloroethane          magnesium
       trichloroethene                manganese
       vinyl  chloride                 nickel
       xylene                        nitrate-nitrite
       butylbenzylphthalate           selenium
       4-chloro-3-methylphenol        silver
       2.4-dimethylphenol             sulfate
       di-n-octyl phthalate           vanadium
       2-methylphenol                 zinc
       4-methylphenol
       phenol
       pyrene

Table  1  of the  Source Control ROD provides a summary of the concentration of
the COCs detected  in groundwater at  the site and highlights those which exceed
either the MCLs or ESs, whichever is most stringent for each constituent.  As
shown  in this table, the levels of contaminants in site wells far exceed
federal  and  state  standards.  The data clearly indicate that the landfill
materials are acting as a source of  groundwater contamination.  With the
discharge of the contaminated groundwater into the Sheboygan River, additional
loading of persistent toxic chemicals into Lake Michigan lend toward the
potential for toxic effects to be felt by the aquatic environment.  This
source will  continue to load contaminants to the groundwater and the Sheboygan
River  unless addressed by a remedial action.

Toxicity Assessment

Cancer potency  factors  (CPFs) have been developed by U.S. EPA's Carcinogenic
Assessment Group for estimating excess lifetime cancer risks associated with
exposure to  potentially noncarcinogenic chemicals.  CPFs, which are expressed
in units of  (mg/kg.day)-1, are multiplied by the estimated intake of a
potential carcinogen, in mg/kg/day,  to provide an upper-bound estimate of the
excess lifetime  cancer risk associated with  exposure at that intake level.
The term "upper  bound" reflects the conservative estimate of the risks
calculated from  the CPF.  Use of this approach makes underestimation of the
actual cancer risk highly unlikely.   CPFs are derived from the results of
human  epidemiological studies or chronic animal bioassays t which animal-to-
human  extrapolation and uncertainty factors  have been applied (e.g., to
account for  the  use of animal data to predict effects on humans).

Reference doses  (RfDs)  have been developed by U.S. EPA for indicating the
potential for adverse health effects from exposure to chemicals exhibiting
non-carcinogenic effects.   RfDs, which are expressed in units of mg/kg-day are
estimates of the lifetime daily exposure levels for humans, including
sensitive individuals,  below which no adverse non-carcinogenic effects will be
suffered.  Estimated intakes of chemicals from environmental media  (e.g.,  the
amount of a  chemical ingested from contaminated drinking water)  can be
compared to  the RfD by dividing the estimated dose by the Reference Dose to
obtain the Hazard Index (HI).  RfDs are derived from human epidemiological
studies to which uncertainty factors have been applied (e.g.,  to account for
the use of animal data to predict effects upon humans).   These uncertainty
factors help ensure that the RfDs will not underestimate the potential for
adverse non-carcinogenic effects to occur.

Based on the list of COCs,  the physical and  chemical properties as they relate
to fate and  transport in the environment were developed.   The following

                                      10

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 properties  were considered:   molecular weight,  water  solubility,  specific
 gravity,  vapor pressure,  Henry's  Law constant,  organic  carbon  partition
 coefficient,  octanol-water coefficient,  fish bioconcentration  factor,  and
 half-life in  water.   A summary of toxicological properties  was also  developed
 for  the  COCs.   This  included RfDs for non-carcinogenic  effects and cancer
 classification and cancer slope factors  (CSFs)  for  carcinogenic effects.

 Constituents  were  also classified according  to  their  carcinogenic and  non-
 carcinogenic  toxicity effects.  For  carcinogenic  compounds,  the excess
 lifetime  cancer risk provides an  estimate of the  increased  risk of cancer
 which  results  from lifetime  exposure,  at specified  average  daily  dosages, to
 constituents  detected in  media at the site.   For  non-carcinogenic compounds,
 the HQ is used to  define  the ratio of the estimated exposure dose to the
 reference dose (based upon a dose which  elicits no  effect when evaluating the
 most sensitive response).   Because of these  differing approaches  to
 calculating risk,  the risks  associated with  carcinogenic effects  are generally
 much higher than those associated with non-carcinogenic effects, particularly
 at the low-dose levels associated with environmental  exposures.  Table 3 of
 the Source  Control ROD summarized the recognized  toxic  responses associated
 with the  site-specific COCs.

 Exposure  Characterization

 The exposure  characterization completed  in the  Risk Assessment  included a
 release/source analysis,  an  evaluation of exposure  pathways, exposure  points
 and receptors;  and calculation of exposure point  levels and  exposure doses for
 groundwater leachate and  surface  water.  The  landfill material  constitutes the
 source are  for VOCs,  SVOCs,  and inorganic compounds.  Leaching  of the  source
 are is the  primary release mechanism.  Leachate seeps and groundwater
 discharged  to  Sheboygan River are also release  mechanisms.   There is no
 evidence  that  on-going erosional  runoff  is an important release source from
 the landfill.

 Exposure  scenarios were developed to  describe potential human  exposures via
 these  pathways  under current  site conditions and potential site uses.
 Potential effects  on the  environment  were also  evaluated in  a qualitative
 manner.

 Risk Characterization

 The risk  characterization  for the  Kohler Company landfill site provides a
 quantitative risk  estimate for  human  exposure to groundwater, leachate  and
 surface water.   The  estimated risks were quantified by calculating an  excess
 lifetime  cancer  risk and HI  for each  reasonable maximum exposure scenario.
 Excess lifetime  cancer  risks  are  determined by  multiplying the  intake  level
 with the  CPF.   These risks are probabilities that are generally expressed in
 scientific  notation  (e.g.  1 x 10-6).   An excess lifetime cancer risk of 1 x
 10-6 indicated that  as  a plausible upper bound,  an  individual has a  one in one
 million chance of  developing  cancer as a result of  site-related exposure to a
 carcinogen  over  a  70-year  lifetime under the specific exposure conditions at a
 site.

 Three hypothetical future  groundwater exposures (equipment washing by  a future
worker, and potable  use by a  future resident at the site,  via ingestion and
via showering);  two  potentially existing leachate exposures  (site worker and
 trespasser); two hypothetical future  leachate exposures (adult and child
 residents);  and  two  potentially existing surface water exposures  (swimming and
 fish consumption)  were  evaluated.   Table 4 of the Source Control ROD provides
 a summary of these risks.

 Equipment Washing  by Future Worker:

A hypothetical future scenario  involving workers using site groundwater for
 equipment washing  activities  over a 25-year period was developed.   These risks
were calculated  for  hypothetical non-potable water supply wells in each of the
 three water units.    Excess lifetime cancer risks ranged from 1 x 10-7  for

                                      11

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 wells  completed in the deep bedrock to 6  x 10-6  for wells  in  the
 unconsolidated deposits and shallow bedrock unit.  The His ranged  from 0.030
 for  the  deep bedrock and shallow bedrock  units to  0.10 for the  unconsolidated
 unit.  These values are below or within the range  of  acceptable health
 guidelines.

 Potable  Use  by a Future Resident

 Risks  for a  reasonable maximum exposure scenario  (30  year  residence period)
 for  a  hypothetical future adult resident  using potable water  from  a well
 completed at the site were calculated  in  the Baseline Risk Assessment.  Excess
 lifetime cancer risk estimates ranged  from 1 x 10-4 for a  well  completed  in
 the  deep bedrock to 5 x 10-3  for a  well completed  in  the shallow bedrock.  The
 His  ranged from 30 for the unconsolidated deposits to 60 for  the deep  bedrock.
 Risks  from ingestion of groundwater by a  future child resident  (age 0-6
 years) were  evaluated.   The excess  lifetime cancer risks ranged from 6  x  10-5
 in the deep  bedrock unit to 2  x 10-3 in the shall ow  bedrock  and
 unconsolidated units.   The His ranged  from 60 for the unconsolidated deposit
 to 100 for the deep bedrock.

 Risks  to a hypothetical future adult resident from inhalation of vapors
 released during showering were also calculated separately  for each of  the
 three  hydrogeological units.   Excess lifetime cancer  risk  estimates range for
 3 x  10-6 for the deep bedrock  unit  to  1 x 10-4 for the unconsolidated  and
 shallow  bedrock units.   The His range  from 0.020 for  the deep bedrock  to  2.0
 for  the  unconsolidated unit.

 Values for both ingestion and  showering are shown to  exceed the acceptable
 health guidelines.

 Leachate Exposure  by Site Worker  or Trespasser

 Leachate seeps occur at the site  and exposure to this medium  was evaluated for
 the  potentially existing pathways (site worker and trespasser) and for  the
 hypothetical  future pathways  (adult and child residents).    The excess  lifetime
 cancer risk  was  2  x 10-6 for a current  worker and 3 x 10-6  for a trespasser.
 The  His were  0.0060 and 0.20 for  the current worker and the trespasser,
 respectively.   The excess lifetime  cancer  risk for the future resident
 exposure to  leachate was 6  x 10-6 for an  adult and 2 x 10-5 for a  child.  The
 His  were 0.020  for an adult and 0.20 for  a  child.  These values lie within the
 acceptable health  guidelines.

 Surface Water  Exposures  (Swimming and Fish  Ingestion)

 Estimates of potential  constituent  concentrations in the Sheboygan River based
 on levels observed in the groundwater were  evaluated  in lieu  of river water
 data.  The highest  95  percent  upper confidence limit  (UCL)  on the arithmetic
 average concentrations  for  COCs from the three groundwater units were used to
 estimate a surface  water exposure point concentration.  Several simplifying
 assumptions were made:   (1) the aquifer is  homogenous and  isotropic; (2) the
 constituents are distributed equally over the entire site as  95 percent UCL
 concentrations  of  each  constituent;   (3) the groundwater acts  as a continuous
 source; and  (4) no  dispersion, biodegradation,  or adsorption occurs along the
 flow path from  the  site  to  the  river.

The excess lifetime  cancer  risk for adults  swimming in the Sheboygan River
 (for this site  alone) was  1 x  10-12  and the HI was 0.0020.   Consuming fish
caught in the  Sheboygan  River  (for this site alone) was calculated to produce
an excess lifetime  cancer risk  in adults of 2 x 10-11 and an HI of 0.30.
Risks  for children  engaged  in  these activities were calculated,  and were
similar to the values  for adults.  These values for potential recreational use
of the Sheboygan River under these assumptions are below or within health-
based guidelines.

Cumulative Site Risk
                                      12

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A cumulative  site risk  can be derived by the summation of excess lifetime
cancer risks  and His across exposure routes for all media at the site.
Current total  site  risk was estimated by assuming that a site worker could, in
addition to leachate exposure, be exposed to constituents estimated in the
Sheboygan River during  recreational activities.  the combined risk for the on-
site leachate  exposure  pathway and the surface water pathways results in an
excess lifetime cancer  risk of 4 x 10-6 and an HI of 0.30.

The hypothetical future total site risk values are based upon a future
resident living on  site, using the groundwater for drinking and showering,
swimming in the river,  and eating fish caught from the river.  These values
are 5 x 10-3  and 60 for the excess lifetime cancer risk and HI values,
respectively.  The  total site risk for a future child resident results in an
excess lifetime cancer  risk and HI of 2 x 10-3 and 100, respectively.  These
two scenarios  are outside of U.S. EPA's health based guidelines.

Chemical constituents contained in the landfill materials have affected
groundwater in the  vicinity of the site.  Data obtained from on-site
groundwater monitoring  wells indicate that substantial amounts of chemical
constituents have been  and continue to be released from the landfill materials
to the groundwater.  Potential future risks from use of the groundwater are
unacceptable.  The  levels of the COCs in the groundwater exceed Federal and
State standards.  Continued leaching of these COCs from the landfill materials
to the groundwater  will result in continued unacceptable risks.  Should these
COCs migrate under  the  Sheboygan River to existing private wells,  or in the
event of future site development involving the installation of a water supply
well, contaminant exposure via groundwater use and consumption may occur.

Based on the Baseline Risk Assessment and Remedial Investigation/Environmental
Contamination  Assessment, it is concluded that actual and/or threatened
releases of hazardous substances from the site, if not addressed by
implementing the response action selected in the 1992 Source Control ROD and
in this ROD, may present an imminent and substantial endangerment to public
health, welfare or  the  environment.

Environmental  Assessment

The potential  environmental risks of affected groundwater on the aquatic and
terrestrial ecosystems around the site were assessed qualitatively.   The
calculated constituent concentrations in the Sheboygan River are at least one
order of magnitude below the Wisconsin surface water criteria or the Federal
Ambient Water  Quality Criteria.   Table 7 provides a comparison of the COCs
estimated in the Sheboygan River water to the applicable or relevant and
appropriate water quality criteria.

The bioaccumulation potential for the majority of the COCs by aquatic
organisms is relatively low,  based on a comparison of fish bioaccumulation
factors (BCFs) with the value of 1,000 L/kg which was used in the Baseline
Risk Assessment.  The BCF relates the concentration of a chemical in plant and
animal tissues to the concentration of the chemical in the water in which they
live.  Fish BCFs greater than 1,000 L/kg are believed to bioaccumulate
significantly.  Two COCs have BCFs exceeding 1,000 L/kg:   silver and di-n-
octyl phthalate.

The presence of PCBs in the landfill has been documented through chemical
analyses of samples of the landfill materials during the final phase of
investigative  activities.  The extent of any PCB contamination in the
groundwater was investigated as part of the groundwater operable unit.   This
investigation  also addressed whether PCBs were migrating from the landfill via
the groundwater and discharging into the Sheboygan River.   PCBs have a high
BCF and numerous studies have documented their toxic impacts on both aquatic
life and human health.   The concentrations and extent of PCB contamination in
the Sheboygan  River fish and water fowl has been well documented in the
Remedial Investigation/Enhanced Screening Report and Alternative Specific
Remedial Investigation under the ongoing Sheboygan River and Harbor RI/FS.


                                      13

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 Subsequent  to  the  Phase  III  investigation,  the U.S.  EPA  and WDNR  requested
 that  selected  wells  located  throughout  the  landfill  and  along  the perimeter  be
 sampled  for PCBs during  December  1991 and January  1992.  The samples were
 submitted as both  unfiltered and  filtered samples  for  PCB analysis.

 Unfiltered  groundwater samples  collected in December 1991 from monitoring
 wells OW2 and  11D  contained  detectable  levels of PCBs; PCB concentrations in
 11D were subsequently qualified as undetected during the data  validation
 process.  Field records  indicate  that these samples  contained  high levels of
 suspended sediments, which may  have  caused  matrix  interference during  the
 analyses.   Several wells were resampled in  January 1992  and both  filtered and
 unfiltered  samples were  collected for analysis.  Low levels of PCBs were
 detected in unfiltered samples  collected from monitoring wells 11 and  11D; PCB
 levels were qualified as estimated by the laboratory.  However, PCBs were not
 detected in the field filtered  samples  from either well.  PCBs were also not
 detected in either sample collected  from monitoring  well OW2 in January 1992.

 U.S. EPA resampled selected  monitoring  wells at the  landfill for  PCBs  with
 lower detection limits again in September 1992.  Kohler  Company split  samples
 with EPA.   Analyses  were run using the  same operating procedures  as those in
 December 1991  and  January 1992.   Results indicate  that PCBs were  not present
 in either filtered or unfiltered  groundwater samples.

 A comparison of the  95 percent  UCL groundwater concentrations  to  the
 appropriate water  quality criteria was  conducted to  evaluate the potential
 groundwater discharge might  have  on  benthic dwelling organisms.  This
 comparison  is  presented  in Table  OC.  This  qualitative evaluation suggests
 that the potential exists for the groundwater to affect  sediment dwelling
 organisms.   Subsequent analyses of silver levels in  groundwater were
 considered  to  not  pose a concern  to  sediment dwelling organisms.

 Risks to terrestrial organisms  associated with the site were not
 quantitatively evaluated.  The  site  has not been identified as a critical
 habitat  for any species,  and no state or federal endangered species that have
 been reported  as migrating through the  Wildlife Reserves are known to  reside
 in the immediate vicinity of  the  site.  Terrestrial  animals could be exposed
 via ingestion  of surface water  or aquatic life.  The level of  exposure to
 constituents in the  leachate  is unknown and difficult to quantify.

 Although an ecological assessment was planned, it was later decided to be
 unnecessary by EPA,  and  was not completed.


 VIII. DESCRIPTION  OF THE REMEDIAL ALTERNATIVES

 A.    Remedial Action Objectives

 The ECA/RAA report (November  1992) identified four remedial action objectives
 for the  groundwater  operable  unit.   These objectives were formulated based on
 information gathered during the Remedial Investigation (RI)  (September 1991)
 and potential  exposure routes and risks identified in the Baseline Risk
Assessment  (September 1991).   The remedial  response objectives for groundwater
 at the site are:

      •     Prevent contact or ingestion of groundwater which exceeds
            appropriate  regulatory and risk-based criteria.

      •     Prevent degradation of surface water resources resulting from
            groundwater  releases.

      •     Prevent  further migration of contaminants to currently unaffected
            portions of  the aquifer.

      •     Minimize long term site management and maintenance.
                                      14

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 These  objectives  protect  human health  and  the  environment by preventing
 exposure  to  contaminated  groundwater and surface water, and preventing further
 degradation  of  the  environment.

 The purpose  of  the  groundwater portion of  the  final  remedy is  to  control  the
 main source  of  groundwater  contamination and 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 the groundwater
 cleanup standards found in  NR 140, Wis. Adm. Code.   The groundwater cleanup
 standards are the Preventive Action Limits (PALs).   The groundwater cleanup
 standards are applicable  requirements  for  the  groundwater cleanup.  These
 groundwater  standards are listed  in Tables 1 and 2 of ch. NR 140, Wis. Adm.
 Code.

 The location of the point of compliance for the groundwater cleanup standards
 is the waste boundary and the outer edge of the interceptor drain.
 Groundwater  cleanup standards shall be attained throughout the contaminated
 plume  (excluding  the  area directly underneath  the landfilled waste), within a
 reasonable period of  time.

 The remedial alternatives were assembled from  applicable remedial technology
 options.  The alternatives  surviving the initial screening were evaluated and
 compared with respect to  the nine criteria set forth in the NCP.  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.

 Groundwater  Alternatives:

 Alternative  1:    No  Action

 This action  serves  as a baseline for comparing all other options.  This remedy
 consists of  no  extraction or treatment  beyond  the remedy selected in the
 Source Control  ROD.   That remedy included  closure of the landfill, placement
 of a solid waste  cap,  collection, treatment and discharge of leachate via  a
 toe drain, access and use restrictions  and operational and surface controls
 for the remaining period  of  landfill operation.

 Capitol costs for this  option are $0.

Alternative  6:    Base  Cap,   Accelerated Fill Dewatering and Focused
                  Groundwater Extraction

This alternative  includes the  following major components:

       - Source  control  measures as described under Alternative 1 and in the
       source control ROD.

       - Sixteen extraction wells to accelerate dewatering of the fill.

       - Two  focused groundwater extraction wells to recover contaminated
       groundwater above the middle till near the Old Waste Pit.

       - Treatment and discharge or direct discharge of extracted groundwater .

       - Long term monitoring.

In addition  to  the source control ROD this alternative includes groundwater
remedial action using extraction wells to dewater the fill material and
thereby limit future releases from the fill material to groundwater at the
site.   This alternative also  includes  capture of impacted groundwater at  the
Old Waste Pit area.   The installation of a cap alone will  result in
significant dewatering  of the fill through the effects of  reduced local
infiltration.  This alternative serves to accelerate and increase the fill
dewatering,  and provides additional focused collection of  groundwater.

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 Collection,  and discharge of the  recovered groundwater  would be  included as
 part  of  this alternative.   The dewatering  well  network  and  the focused
 groundwater  extraction wells would continue to  operate  for  the 30-year design
 life  of  the  remedy.

 Capital  costs are $5.9 million, with annual operation and maintenance  costs  of
 $176,000.  Present worth cost is  $8.6 million.

 Present  worth costs  includes the  capital costs  -  the money  needed  to build the
 remedy - plus thirty years of operation and maintenance in  today's  dollars.

 Alternative  7:     Base Cap and Downgradient Extraction  Wells

 This  alternative includes  the following major components:

       -  Multilayer cap,  toe drain,  and institutional controls as required in
       the  source control ROD.

       -  Six  to  eighteen groundwater extraction  wells located along  the
       downgradient perimeter of the fill installed down to  the middle  till.

       -  Treatment and discharge or direct  discharge of  extracted groundwater.

       -  Long term monitoring.

 The base cap would be a multilayer cap as  required in the source control  ROD.
 Refer  to the Plan of  Operation Modification, Source Control  Remedial Design
 document (December 1992) and subsequent addenda for detailed design
 specifications.   In  addition to the base cap this alternative includes  a
 series of  wells  installed  to the  top of the middle till  (or  the base of the
 alluvium deposits if  the middle till is absent)  along the downgradient
 perimeter  of the fill.   This line  of wells  is intended  to capture groundwater
 flowing  toward  the Sheboygan River.   Capturing  the groundwater at this
 location reduces discharge  to  the  river, and limits the potential for  long
 term exceedance  of state groundwater quality standards  in shallow groundwater
 beyond the fill  limits.  Collection and discharge of recovered groundwater
 would be included as  part  of this  alternative.  Costs are determined   for the
 downgradient well network  extraction to operate for a 30-year design life.

 Capital  costs are $5.7  million, with annual operation and maintenance  costs  of
 $186,000.  Present worth cost  is  $8.6  million.

 Alternative   8:    Base  Cap,  Downgradient Recovery Wells and  Downgradient
                   Slurry Wall

 Alternative  8 consists  of  the  base  cap, downgradient recovery wells, and a
 downgradient slurry wall.  Again,   a  series  of wells would be used to extract
 contaminated groundwater.   In  addition, a slurry wall would be constructed
 between  the  landfill  and the Sheboygan River to reduce water coming from the
 river into the extraction  system.

 The capital  costs  for this option are  $9.6 million,  with annual operation and
 maintenance  costs  of  $236,000.  Present worth cost is $13.3 million.

Alternative  9:     Base  Cap,  Upgradient Slurry Wall,  Downgradient Recovery
                   Wells  and  Downgradient Slurry Wall

Alternative  9 consists  of the  base  cap, upgradient slurry wall,  downgradient
 recovery wells and a downgradient slurry wall.  This option would be similar
 to alternative 8,  with  the addition  of a slurry/cutoff wall upgradient of the
 landfill to  direct uncontaminated water around,  rather than through the site.

 Capital  costs are  $13.4 million, with annual operation and maintenance costs
 of $236,000.   Present worth  cost is  $17.1 million.

Alternative  10:    Deep Aquifer Analysis

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Alternative  10  consists  of  an extraction  system  for  addressing  contaminated
groundwater  in  the  deeper aquifer.   This  option  would be used in  conjunction
with  any  of  options 6-9  and 11 in order to  address contamination  in both  the
upper and lower aquifer  systems.  Effectiveness  was  evaluated based on  a
system of 90 extraction  wells across the  entire  landfill, with  a.  20 year
operation life.

Capital costs are $1.9 million, with annual operation and maintenance costs of
$187,000.  Present  worth cost is $5.0 million.

Alternative  11:   Base Cap  and Groundwater  Interceptor Drain

Alternative  11  consists  of  the base  cap and an interceptor drain  downgradient
of the landfill.  This option would  be similar to the existing  remedy selected
for capping  the  landfill, which called for  construction of a toe  drain
downgradient of  the landfill  to intercept shallow groundwater contamination.
Instead of the  toe  drain, an  interceptor  trench  would be constructed along the
downgradient edge of  the landfill, to intercept  most of the contaminated
groundwater  in  the  upper aquifer, above the middle till unit.   This would also
cut off flow to  the Sheboygan River,  and  reduce  contaminant movement to the
lower bedrock aquifer, and  is expected to induce additional flow  from the
lower bedrock aquifer towards the drain.  Groundwater and leachate collected
by the drain would  flow  to  collection sumps.  From there, it would be pumped
to a  force main, treated if necessary, and  discharged.

Capital costs are $5.6 million, with annual operation and maintenance at
$139,000.  Present  worth cost is $7.8 million.

Discharge Options

Five  options were also evaluated for discharge of leachate and  groundwater.
Those five options  included:
       1.     discharge of untreated groundwater to the nearest publically  owned
             treatment works (POTW) (Kohler  sewer system to Sheboygan POTW)
       2.     discharge of pretreated  water to nearest POTW
       3.     pretreatment of groundwater at  the Kohler Company wastewater
             treatment plant prior to POTW discharge
       4.     pretreatment of groundwater prior to discharge to Sheboygan River
       5.     direct  discharge  of untreated water  to the Sheboygan River

Estimated costs  for these options are:

             Capital     O&M         Present Worth

       1.     $165,000     $15,400      $401,730
       2.     Not  Estimated
       3.     Not  Estimated
       4.     $187,000     $53,000      $1,001,720
       5.     $109,000     $20,000      $416,840


IX.    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
practicable,  and to 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 NCP at 40  CFR 300.430(e)(9)(iii)  as the basis of
comparison.  These nine criteria are summarized as follows:


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 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  - A
       remedy must meet all applicable or relevant and requirements of
       federal/state laws.  If  not,  a waiver  may apply.

 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 Toxicity, Mobility or Volume Through Treatment -  The
       purpose  of this criteria 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  criteria 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 Acceptance - After review of  the Feasibility  Study/Remedial Action
       Analysis  and the Proposed Plan,  support  agency's  concurrence or
       objections  are  taken into consideration.

    9.  Community Acceptance - This  criteria summarizes the public's response to
       the alternative  remedies  after the  public comment period.

 B.  Comparative  Analysis of Alternatives

 The following is  a summary of  the  comparative analysis highlighting  each
 alternative's strength and weakness  with  respect  to  the nine  evaluation
 criteria.  An alternative providing  the best balance with respect to the nine
 criteria  is determined from this  evaluation.

 1,  Overall Protection of Human Health and the  Environment

 Overall protection of  human health and the environment is a threshold
 criterion that  must be met by  the alternative being  analyzed,  or else the
 alternative is  dropped from further  consideration.   This  threshold criterion
 addresses whether a remedy eliminates, reduces, or controls threats  to human
 health and to the environment.   The  major exposure pathways of concern at the
 Kohler Company  Landfill are the potential ingestion  of,  or inhalation of
 vapors from contaminated groundwater.  These pathways have been  shown to
generate the highest risk.

All of the remedial alternatives  considered  for the  Kohler Company Landfill
 site are protective of human health  and the  environment by eliminating,
 reducing, or controlling risks  at the site with the  exception of the no action
 alternative.  As Alternative 1, the no action alternative does not provide

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 protection of  human health and the  environment,  it  is  not  eligible  for
 selection and  will  not  be  discussed further  in  this  document.

 All  remaining  alternatives have a capping  component  as part  of  the  specific
 alternative.   The capping  component was  fully discussed  in the  March  1992
 Source  Control Operable Unit  ROD and will  not be further addressed  in this
 Groundwater Control Operable  Unit ROD.

 Alternative 10 is an extraction system for the  deeper  aquifer,  and  is to be
 considered an  additional step to be used in  conjunction  with the previously
 described alternatives.

 Alternatives 11, 9,  8,  7,  and 6 (with or without alternative 10) address the
 potential risks posed by contaminated groundwater by reducing and controlling
 the  threat to  human health and the  environment.   These alternatives do not
 immediately eliminate the  threat to human  health and the environment.
 Groundwater contamination  is  a complex problem  and no  technology exists today
 that would immediately  eliminate the contamination in  a  groundwater aquifer.
 Alternatives 11, 9,  8,  7,  and 6 (with or without alternative 10) provide
 overall protection  of human health  and the environment and are  retained for
 further consideration.

 2.  Compliance with Applicable or Relevant and  Appropriate Requirements

 Compliance with applicable or relevant and appropriate requirements  (ARARs) is
 a threshold criterion that must be  met by  the alternative  being analyzed, or
 else the  alternative is  dropped from further  consideration.  This threshold
 criterion evaluates  whether an alternative meets  ARARs set forth in Federal,
 or more stringent State, environmental standards  pertaining  to  contaminants
 found at  the site (chemical specific), siting requirements itself (location
 specific)  or proposed actions at the site  (action specific).   Section XI,
 Statutory Determination, will discuss the  potential  ARARs  for the site.  This
 section only notes  those ARARs  with which  a particular alternative does not
 comply.

 Alternatives 11, 9,   8,  7,  and 6  (with or without  alternative 10) can  comply
 with the  chemical specific, location specific,  and action  specific ARARs.
 Each alternative is  an  appropriate  response to  the State regulation ch. NR
 140, Groundwater Quality,  Wis.  Adm.  Code.  A  waiver  from any of the ARARs can
 not at this time be  justified.

 The alternatives were also viewed in terms of treatment/discharge options for
 the collected  contaminated groundwater.  While  it may  be possible for surface
 water quality  criteria  to  be  met with a  direct  discharge of  the collected
 contaminated water  to the  Sheboygan  River,  a  direct  discharge would not comply
 with State  requirements  in ch.  NR 220, Wis. Adm.  Code,  entitled Categories and
 Classes of  Point Sources and  Effluent Limitations.   Specifically,  subchapter
 III - Effluent  Limitations  for Uncategorized  Point Sources would apply.  This
 subchapter  states effluent  limitations "...shall be  those which the department
 determines are  achievable  by  the application  of the best practicable  control
 technology currently available,  or,   where  appropriate,  the best available
 control technology  economically  achievable".   A direct discharge to the
 Sheboygan River without use of  a control technology does not comply with this
ARAR and will not meet this threshold criterion.  Therefore,  discharge option
 5, - direct discharge of untreated water to the Sheboygan River is not
 eligible  for selection and is not discussed further  in this document.

 3. Long-term Effectiveness  and Permanence

All alternatives offer a permanent  solution to groundwater contamination by
 extracting, collecting,  transporting and treating the groundwater prior to
discharge.  All of the alternatives would  require a long period of operation
 time to achieve restoration of the groundwater.   Long term groundwater
monitoring is required,  as  is a  five year  review of the  remedy,  for all
options.


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All alternatives use  conventional technologies requiring standard maintenance.
The selected  remedy should be  constructed of materials compatible with the
contaminated  groundwater.  Compatibility of materials would reduce possible
excessive maintenance or early replacement of the extraction, collection and
transport system.

The alternatives have the following levels of long term effectiveness based on
reduction of  the horizontal  flux of groundwater in the upper aquifer over a
ten year period  (the  most contaminated zone):

   Alternative          % Reduction in Flux
   6                    61%
   7                    91%
   8                    93%
   9                    94%
   11                   95%  in one year,  (95.6% over 10 years)

The alternatives also have the following levels of effectiveness based on fill
dewatering efficiencies, as  compared to use of a cap alone.  These options are
being compared to dewatering by use of a cap alone; direct comparisons between
alternatives  is not done as  factors for determining efficiencies vary between
alternatives:

   Alternative          % of Fill Dewatered     % Dewater by Cap Alone
      6                 86%                     80%
      7                 83%                     80%
      8                 83%                     80%
      9                 84%                     80%
      11                78%                     77%

Based on these efficiencies, Alternative 11 provides the most efficient method
of reducing contamination migration to the Sheboygan River.  The level of
effectiveness of capture is expected to remain fairly constant over time,
although the  short term effectiveness is expected to be greater for
alternative 11 than for alternatives 6-9.  The timeframe for restoration of
the groundwater is expected to  be more than 10 years for all alternatives,  but
is expected to be shorter for  those options with greater removal efficiencies.

Any option used in conjunction  with alternative 10 would provide the greater
removal efficiency, and would  have a shorter restoration timeframe.   Maximum
capture of the contaminated groundwater cannot be assured since groundwater
movement through cracks and fissures could bypass the extraction points.

Alternative 11 will be more effective than the other alternatives because the
proposed extraction/collection  method,  a continuous trench, acts like a long
sump system and its efficiency  is not affected by changes in soil type in the
vertical direction to the degree that a well system would be affected.

Alternatives  9 and 8 use downgradient extraction wells and slurry wall(s).
While the use of slurry wall(s) can improve capture efficiency over a series
of wells, construction difficulty increases.  Alternative 7 uses downgradient
extraction wells without slurry walls.   The change of location of the wells
when compared to alternative 6  improves capture efficiency by providing an
active hydraulic barrier.   Complete capture of contaminated groundwater
between the extraction points  cannot be fully assured.

Alternative 6 uses wells to collect contaminated groundwater/leachate from
under the landfill.  While this action assumes removal of the most highly
contaminated water at the point of generation,  removal efficiencies will  vary
depending on soil/fill materials intercepted.  Lack of good capture results in
some residual groundwater risk.

4.  Reduction of Toxicity,  Mobility or Volume Through Treatment

This balancing criterion addresses the statutory preference for selecting
remedial actions that employ treatment technologies which permanently and

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 significantly reduce toxicity,  mobility,  or  volume  of  the  hazardous
 substances.   This  preference is satisfied when  treatment is  used  to  reduce  the
 principle threats  at a site through destruction of  toxic contaminants,
 irreversible reduction of contaminant  mobility,  or  reduction of total  volume
 of  contaminated media.

 All the  alternatives provide extraction,  collection, transport and treatment
 of  the contaminated groundwater.

 Alternative  11 would provide the  highest  potential  for reduction  of  toxicity,
 mobility and volume due to the  type of extraction/collection system  it
 provides.  A continuous backfilled trench will  be constructed for passive
 extraction and collection of the  contaminated groundwater.   Extraction  and
 collection potential are improved because of the sudden increase  in  the
 permeability due to the backfill  material employed.

 Alternatives 9 and 8,  with their  use of the  slurry  wall(s),  have  the potential
 to  reduce the volume of contaminated water generated,  or needed to be treated
 by  either diverting clean water away from the existing area  of contamination
 (upgradient  slurry wall)  or by  limiting the  amount  of  clean  groundwater
 extracted (downgradient slurry  wall).

 Alternatives 7,  6,  and 10 also  provide a  reduction  of  toxicity, mobility or
 volume but with lesser overall  efficiency.   Of  these three alternatives 7 has
 the best  efficiency.

 The preference for treatment of the contaminated groundwater  can  be  satisfied
 by  implementing one of  the remaining four discharge options,  as each option
 has a treatment element proposed.

 5.   Short-term Effectiveness

 This balancing criterion addresses:  the time to  achieve the  remedial response
 objectives;  the risk to,  and degree of protection needed for  site workers and
 the community nearby;  and environmental impacts.  All  of the  alternatives have
 varying degrees of contaminated media  exposure  risk associated with them.

 Alternatives  7  and 10 would probably have  the least exposure  risk since their
 associated extraction wells  are installed  downgradient  of the landfill.  The
 area of installation would most likely expose workers  to contaminated
 groundwater  and soils saturated with contaminated groundwater.  A relatively
 low volume of  contaminated water  and soil  would  be generated under alternative
 7 and a larger  volume under  alternative 10.

 Alternative  11  will  have  to  address  a  much greater volume of the media  than
 alternatives  7,  8,   and  9.   This increase  in volume means that the time period
 for exposure   risk increases.  Alternatives  8 and 9 have the same exposure
 potential as  alternative  7 but have  additional contaminated groundwater
 exposure potential  due  to  installation of  the downgradient slurry wall.
 Alternative  6 will  have  the  highest  concentrations of contaminated media,
 since wells would  be installed  through the landfill waste mass.

 Onsite workers  will  take  adequate standard protection measures to reduce or
 prevent direct  contact  exposure with contaminated media and to reduce or
 prevent inhalation of airborne vapors  which may be present form time to time.
 With site access being  controlled,  the community at large should not have a
 direct contact  exposure problem,  and,  inhalation of airborne vapors should be
monitored for,  but  should not be  a  significant problem.  The landfill is
 currently in operation  and the day-to-day  fill activities are not impacting
 the community air  quality.

 6.  Implementability

 This balancing  criterion  requires consideration of the technical and
 administrative  feasibility of a remedy, including whether needed services and
materials are available.  All of  the alternatives meet the requirements of

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 this  criterion.   The  installation of the slurry walls for alternatives  8 and
 9  may present additional construction challenges, but installation is still
 feasible.   Restrictions on building in or near the floodplain may necessitate
 a  change  in location of a treatment building if onsite treatment or
 pretreatment of  contaminated groundwater is included as part of the current
 remedy.

 7.  Cost

 Under this  balancing criterion capital (CAP),  operation and maintenance  (O&M),
 and 30 year present worth (PW)  costs are addressed.

        Alt  #6       Alt #7       Alt #8       Alt #9       Alt #10       Alt #11

 CAP    $5,900,000    $5,700,000    $ 9,600,000    $13,400,000   $1,900,000    $5,600,000

 O&M    $  176,000    $ 186,000    $   236,000    $  236,000   $ 187,000    $ 139,000

 PW     $8,600,000    $8,600,000    $13,300,000    $17,100,000   $5,000,000    $7,800,000

 The extraction alternatives  6 and 7 have identical present worth costs.   The
 slurry wall alternatives are more expensive but have comparable present worth
 costs.  Alternative 10 present worth cost would be an add on cost to the
 selected  remedy.   While alternative 10 is technically feasible its
 effectiveness is  questionable.  Alternative 10 appears to be less viable an
 alternative based upon its low effectiveness  for the money spent.

 The proposed discharge options present worth ranged from a low of $402,000 to
 $1,002,000  and would be an add on cost to the  remedy selected.

 8. Support  Agency Acceptance

 The United  States Environmental Protection Agency (EPA)  is the support agency
 for this action.    EPA concurs with the  selected remedy.   The concurrence
 letter is attached to this ROD.

 9. Community Acceptance

 In general,  the comments were supportive  of implementing  a remedy soon,
 although some commentors wanted either more or less action to be taken.
 Comments submitted addressed several topics.   These included the desire to
 have  a more aggressive remedy implemented now,  instead of  waiting to see the
 effectiveness of  the  proposed measures, by adding a soil  vapor extraction
 system, deep bedrock  extraction wells in  combination with the interceptor
 trench; no  action;  quick closure  of the  landfill and implementation of the
 remedy; deepening of  the interceptor trench; concern over the effects  of
pumping groundwater/leachate through the  Village of Kohler;  and replacement of
 the current ecosystem via the purchase of additional areas along the Sheboygan
River  to limit other  types of pollution  from affecting the Sheboygan River.

The specific community comments received  and the Department's responses  are
 included in the attached Responsiveness Summary.


X.      THE SELECTED  REMEDY

Based upon  consideration of  the requirements of CERCLA, as amended by  SARA,
and the NCP,  the  detailed analysis  of the alternatives and public  comments,
the Wisconsin Department of  Natural Resources,  (in consultation with EPA),
believes that Alternative 11,  the  selected remedy,  will be the  most
appropriate remedy  for this  site/operable unit.  The selected remedy for  the
site includes the following:

       - Multilayer  cap and institutional  controls  as required in the 1992
       Source  Control  Record  of Decision
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       -  Groundwater Interceptor Drain located along  the  eastern  and  southern
       perimeter of  the  landfill,  to  an approximate depth of  10 feet,
       approximately 2500  feet  long,  to replace the toe drain identified  in  the
       1992  Source Control ROD

       -  Natural attenuation  of the contaminated groundwater  which has  already
       passed beyond the edge of the  waste

       -  Discharge of Captured  Water  to the  Sheboygan STP

       -  Long Term Monitoring to measure the effectiveness of the remedy

This measure is believed  to  have the best potential  to capture the majority of
contaminant  migration both laterally towards  the Sheboygan River, and
vertically,  to  the  deeper, bedrock aquifer,  with the fewest  implementation
problems, at the most reasonable cost.   By  doing so, it  should thereby allow
natural  attenuation processes  to reduce the remaining contamination  in between
the interceptor trench  and the Sheboygan River over  time.  At a total  present
worth  cost of $7.8  million,  the DNR  believes  these measures  will adequately
address  site contamination within a  reasonable time  frame and cost.

The cost associated with  option 10 in addition to option 11  was not  considered
cost effective.  The source  control  measures  (capping and interceptor  trench)
and natural  attenuation of the contaminated groundwater  which has already
moved  past the  edge of  waste will be addressed by option 11.  Groundwater
quality  is expected to  meet  standards  within  a reasonable timeframe  for  this
site,  considering current  and  potential  future land  uses and institutional
controls required in the  1992  Source Control  ROD, using  option 11.   Also, the
problems with implementing option 10,  i.e.  limited chances of intersecting
fractures within the bedrock,  make this  option less  effective in reducing risk
at depth, for the associated additional  cost.

XI.  STATUTORY  DETERMINATION

The selected remedy must  satisfy  the requirements of Section 121 of  CERCLA  to:

       a.     protect human  health  and the environment,
       b.     comply  with ARARs,
       c.     be  cost effective,
       d.     use permanent  solutions  and  alternate treatment  technologies to
             the maximum extent  practicable,  and
       e.     satisfy the preference for  treatment as  a principal element  of  the
             remedy  or document  in the  ROD why  the preference for treatment was
             not satisfied.

The implementation  of Alternative 11  satisfies the requirements of CERCLA as
detailed below:

A.  Protection  of Human Health  and the Environment

The selected remedy provides protection of human health and the environment
through  interception of groundwater  at the downgradient waste boundary,
treatment as necessary,  and  discharge of contaminated groundwater.
Interception of  the  majority of future contaminated groundwater will also
allow  for natural attenuation processes to address the contamination between
the landfill and the river, within a reasonable period of time for site
circumstances.

B.  Attainment  of ARARs

The selected remedy will be designed to meet all applicable,  and relevant and
appropriate requirements under  federal and state environmental laws.   Since
the Kohler Company  Landfill  is  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:

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NR  140,  Groundwater  Quality.  NR  140  is  applicable, as  it provides numeric
standards  and  responses  for  sites where  contamination exceeds such standards.

NR  141,  Groundwater  Monitoring Well Construction.  NR 141 is applicable  for
construction of  additional wells  and  abandonment of existing wells.

NR  700  - 736   These  codes are applicable to the  (investigation and)
remediation of environmental contamination.  Signage according to NR 714  is
needed.  The Department  will be responsible for responding to information
inquiries  as per s.  NR 714.07(4).  This  has been requested specifically  for
providing  the  public information  on the  results of the  long term or
effectiveness  monitoring for the  selected remedy.

Other ARARs were covered by  the Source Control ROD.  These ARARs include:

      1.    Discharge of collected groundwater: chs. NR 102, 104, 105, 106 and
            207,  Wis. Adm. Code.

      2.    Solid Waste  Management requirements:  chs. NR 500-520, Wis. Adm.
            Code.

      3.    Closure  Plan/Long Term Care:  s. 514.07,  Wis. Adm. Code.

      4.    Final Use Compatibility with Cover:  s. 504.07,  Wis. Adm. Code

      5.    Placement of Water Supply Wells within 1200 Feet:  ch. 812, Wis.
            Adm.  Code (formerly NR 112).

      6.    Air  Quality  Requirements: chs. 400-484, Wis. Adm. Code.

C.  Cost Effectiveness

The selected remedy  provides for  overall cost effectiveness.  Based on the
comparison of  effectiveness achieved per cost,  this remedy provides the most
efficient means  of complying with groundwater standards within a reasonable
period of time,  at the lowest cost.

D.  Use of Permanent Solutions and Alternative Treatment Technologies

The remedy selected will rely on  standard treatment technologies for VOC or
heavy metal removal,  if  needed for the discharge.  The remedy is permanent,
and O&M will be  required for the  life of the remedy.

E.  Preference for Treatment as a Principal Element

The selected response action does not satisfy the statutory preference for
remedies that  employ treatment as a principal element.  Treatment of the waste
mass to permanently and  significantly reduce toxicity, of the contaminants was
not found to be practicable nor cost effective for this operable unit.
Mobility and volume will be decreased by extraction of the contaminated
groundwater,  allowing existing contamination to undergo natural attenuation
processes to meet groundwater standards within a reasonable  period of time.
Treatment of the extracted groundwater/leachate will be a part of the
discharge option selected.
                                      24

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                             RESPONSIVENESS  SUMMARY

 This  Responsiveness  Summary has  been  prepared  to meet  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 on 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
 groundwater remedy at the Kohler Company  Landfill Superfund site.

 A.    PUBLIC COMMENT  PERIOD

            A  public  comment period was held from April 22, 1996 to May 21,
            1996 to allow interested  parties to comment on the Proposed Plan
            in accordance with Section 117  of  CERCLA.  In  addition, a public
            meeting was  held on  May 2, 1996  at the Kohler  Village Hall.  The
            WDNR presented  the Proposed Plan,  answered questions and accepted
            comments  from the  public.  During  the public comment period, WDNR
            received  written and verbal comments concerning the  Proposed Plan.
            These  comments  focused primarily on the discharge option and the
            contamination present  in  the  bedrock aquifer.

 B.    COMMUNITY INVOLVEMENT

 Local residents created  the Sheboygan County Water Quality Task  Force in 1984 .
 This  group was active in the past  with education/information activities.
 Others that have also participated in Superfund or the Remedial Action  Plan
 process include local participants  or chapters of the  Sierra Club and the
 Izaak Walton League.   The Lake Michigan Federation (LMF)  has been active in
 Remedial  Action Plan  activities  for the Sheboygan River Area of Concern
 (conducted under the  Clean  Water Act/Great Lakes Water Quality Agreement),  and
 in reviewing activities  conducted  at  both the Kohler Company Landfill and  the
 Sheboygan River and Harbor  Superfund  sites.   The LMF received a Technical
Assistance  Grant from EPA in March, 1994.  The purpose of  the grant is  to
 allow persons affected by Superfund sites to retain their  own technical  staff
 to explain the Superfund process and  the  data generated during the  RI/FS.
WDNR attended a RAP meeting in May  19, 1994  and a LMF-sponsored meeting  on
August 24,  1995 to discuss  progress at both  the Kohler Co.   Landfill and  the
 Sheboygan  River and Harbor  Superfund  sites.

Both oral  and written  comments were submitted on the proposed plan,  at and
after the public meeting.   In general, the comments were supportive of
 implementing a remedy  soon,   although  some commentors wanted either more or
 less action to be  taken.  Comments submitted addressed several topics.   These
included the desire to have  a more aggressive remedy implemented now,  instead
of waiting  to see  the  effectiveness of the proposed measures,  by adding a soil
vapor extraction system, deep bedrock extraction wells in combination with the
interceptor trench; no action;  quick  closure of the landfill and
implementation of  the  remedy; deepening of the interceptor trench;  concern
over the effects of pumping groundwater/leachate through the Village of
Kohler;  and replacement of  the current ecosystem via the purchase of
additional  areas along the  Sheboygan River to limit other types of pollution
from affecting the Sheboygan River.
                                      25

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                               COMMENT RESPONSES


 A/e  strongly concur  with Mark  Tusler  of BT2,  Inc. that the biggest  limitation
 of  the proposed remedy is  its focus  on cleaning up contamination after the
 fact  instead of preventing further contamination.  The active source control
 methods  recommended by Mr.  Tusler: a landfill  venting system to evaporate
 VOCs, along with installation of horizontal  wells to dewater the waste, will
 work  to  prevent further ground water contamination.

 See below  for specific responses to  Mark Tusler's comments.


 The major  limitation  I see on the proposed remedy is the lack of active source
 control.   Under the proposed  remedy,  concentrations will decline to an
 asymptotic levels that are probably  above NR 140 standards.  At that time,
 Kohler can request  permission to close the system based on practicability.  It
 would seem prudent  to look further at  what could be done now to reduce that
 future asymptotic level.

 The proposed  remedy consists  of a ground water collection trench that extends
 around the downgradient perimeter of the landfill.   It will function by
 inducing shallow and  some  deep groundwater to discharge into the drain system,
 intercepting  the contaminants  in the water before they can migrate beyond the
 waste limits.   While  this  system would operate in a more "passive" manner,
 i.e., relying on the  natural  differences in  ground water gradients to induce
 flow  into  the drains,  the  collected  liquid will be actively pumped out to a
 force main for  treatment.   The system will be actively managed to insure
 inward gradients towards the  drain are maintained and the contaminant source
 is  contained.

 Groundwater modelling  results presented by Geraghty & Miller,  Inc.  in their
 February 14,  1996 Addendum Response  report,  indicate that all  VOC compounds of
 concern will  be  in  compliance with ch. NR 140,  Wis.  Adm.  Code water quality
 standards  within 3.5 years  of the installation of the perimeter drain system
 with  the possible exception of vinyl chloride.   Vinyl  chloride is the only VOC
 of  concern that  is  projected to possibly need an alternate concentration limit
 (ACL) established in the future due  to nonattainment of the NR 140 standards.
 If  vinyl chloride does reach  an asymptotic level above the standards,  the
 Department will  evaluate the system  at that time and determine if an ACL is
 warranted  or  if  additional  remedial  actions could be implemented to reduce the
 levels further.  This  system would intercept inorganic and semi-volatile as
well  and those contaminant  levels would also be expected  to fall  below our
 groundwater quality standards.  In any case,  the Kohler Company will  be
 required to evaluate the effectiveness of the remedial  action  on a periodic
 basis to ensure  that progress is being made towards  NR 140 compliance.


Groundwater systems are notoriously  ineffective in  removing contaminants.   The
mass  removal  rates are generally much greater in soil  venting systems than in
groundwater extraction systems.  -  A  venting system should be installed to
allow the  VOCs to evaporate before they reach the ground water or the River.

                                      26

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 The efficiency of a  groundwater  remedial system varies considerably depending
 upon a  variety of factors  Including site geology, contaminant types, and the
 design  and  construction  of the system.  Soil venting systems are, generally,
 more effective at contaminant removal if the contamination consists of highly
 volatile  orgamcs, Is  In a fairly porous geologic unit (I.e. sand), and Is
 confined  to the vadose (unsaturated) zone.  While some of these conditions are
 undoubtedly met within certain areas of the landfill, the area with the
 highest level  of contamination,  the Old Waste Pit, doesn't meet any of the
 criteria.   There are high  levels of volatile organic compounds in the pit, but
 not all of  them are  easily volatilized and air stripping would do little or
 nothing to  the elevated  levels of metals, inorganics and semi-volatile.  The
 pit area  is saturated  to within  2 to 4 feet of the surface and not easily
 drained (see below).   Most of the waste is fairly fine-grained and not very
 transmissive for either  liquids  or gases.


 Phil  raised the concern  that much of the waste will remain saturated and thus
 unaffected  by  a venting  system.  Horizontal wells draining into the collection
 trench  would help dewater  the waste.

 The use of  horizontal  wells would be relatively expensive and would still  fail
 to  address  some fundamental problems with VOC removal from within the Old
 Waste Pit.   Horizontal wells can be extremely useful  in certain applications,
 such  as situations where the contamination is beneath an existing structure or
 where contaminants are migrating downward from an unlined waste area or spill.
 However,  in this  particular case, horizontal wells would be of limited
 usefulness  for  the same  reasons that vertical  wells were found to be of
 limited use:   the waste  mass consists,  in large part, of fine-grained
 materials,  including clay  slurries,  that do not transmit liquids in quantities
 that make it efficient to  dewater the area within a reasonable amount of time.
 The radius  of  influence  to a vertical  or horizontal  well  would be very limited
 because of  the  nature  of these fine-grained wastes and the well(s) may not
 have any effect  on liquid  even 5 feet or so away from the well  screen.

 Also, horizontal  wells placed in the Old Waste Pit area would only affect
 contaminants at  that particular location.   Elevated levels of VOCs were
 detected in many  places  throughout the landfill  and horizontal  wells at the
 Old Waste Pit would have no effect on VOC concentrations  in those other areas.
 It would be prohibitively  expensive to install  horizontal  wells at all  VOC
 "hotspots"  and  it would  probably be pushing the limits of the technology to
 try to  extend wells beneath the entire site.


 The bedrock contains substantial levels of VOCs.   The effectiveness of the
perimeter drainage system on the bedrock contamination depends where the
 trench  is located in relation to the edge of the till and the river.   If the
 till extends to a short distance downgradient  of the  trench,  the bedrock
groundwater will  flow  into the trench.   If the till extends to the river,  the
 trench will not be effective in removing the bedrock  groundwater.

This is basically true.  The proposed perimeter drain system will  not be as
 effective at collecting deeper groundwater flow in those  areas  where the

                                      27

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 middle  till  aqultard  extends,  unbroken, to the edge of the riverbed.  From the
 borings that have  been  completed during the remedial Investigations, It
 appears that the middle till extends to the riverbed along the southeastern
 corner  of  the landfill, but  Is generally absent north of that corner.
 Unfortunately,  the exact extent of the middle till east of the toe of the
 landfill Is  unknown.  The top  of the middle till unit Is an eroslonal surface
 and  subject  to a great  deal  of variability In It's extent and thickness.
 Consistent with the modelling  results, any deep groundwater that Is not
 captured by  the perimeter drain will discharge Into the river.


 Mr.  Bob Jones suggested boreholes into bedrock that would drain into the
 collection trench.  These wells would exploit the upward gradient and no pumps
 would be needed.   Check valves could be added if there is a concern over
 gradient reversals.   These wells would cost substantially less than the $5
 million cost of Alternative  10.  -  I believe that in addition to the items of
 remedial action in Option 11,  a system of vertical wells located along a line
 parallel to  the 2400  feet of drain trench should be included in the clean up
 plan.   -   LMF would like to  see more effort to address the contaminated ground
 water in the deep  aquifer such as drilling boreholes into the bedrock to drain
 to the  interceptor trench.

 Installing boreholes  Into the bedrock to collect deeper groundwater would
 encounter  the same difficulties deep groundwater extraction wells would
 encounter  under Alternative #10:  most of the groundwater flow In the deeper
 bedrock  system  flows  preferentially along fractures and other zones of
 enhanced permeability.  These preferential  flow pathways are extremely
 difficult  to locate,  but unless the boreholes suggested above are completed
 within  these zones, they will intercept very little groundwater.   Geraghty &
 Miller  attempted to locate and characterize these preferential  flow paths,  but
 were unsuccessful.   Even when they had a monitoring well  that happened to be
 completed within one  of these zones, they could not intercept the fracture a
 second  time  to  determine it's extent or orientation.

 A second problem would be determining just  where one of these borings would be
 needed  and where the  existing upward gradients are already directing deep flow
 into the drain  system.  As mentioned earlier,  the exact extent of the middle
 till  erosional  surface has not been fully defined in the area between the
 landfill and  the river.   Conducting such an investigation would necessarily
 delay implementation  of the chosen remedial  action.

There are still legitimate concerns regarding opening potential  contaminant
pathways between the  highly contaminated upper aquifer and the less
contaminated  lower aquifer.   A check valve  would,  as long as  it was functional
and not clogged by iron or carbonate precipitates,  prevent downward migration
of shallower water if the gradients reverse within the pipe,  but contaminant
migration via the  annular space between the borehole and  the  well  casing would
be more difficult to  control.


 I think the drainage ditch should be as deep as the bottom of the river.
 including silt.  -   The collection system should be constructed at a level

                                      28

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 that  is proximate with  the River.   The placement of the system at this  level
 should enhance  the chances of collecting  the  leachate before  it enters  the
 deeper ground water.   - A drain depth of 10  feet  is fully penetrating  of the
 upper aquifer system  in the hydraulic sense,  so a  drain deeper than 10  feet
 below land surface would be no more effective at intercepting ground water
 flow  away from  the landfill than the proposed drain.

 The Kohler Company ran  a series of  groundwater models based on existing
 groundwater monitoring  data as part of their  Environmental Contamination
 Assessment and  Groundwater Remedial Action Alternatives Report Addendum dated
 November  30,  1995.  The groundwater modelers  progressively deepened the
 perimeter trench  until  they reached a point,  at approximately 10 feet below
 the current land  surface, where nearly all groundwater within the upper,
 shallow aquifer would be effectively captured by the drain system and the
 drain would remain beneath the water table even during dry spells.   At a ten
 foot  depth,  the drain would be lower than the alluvial  (upper aquifer)  layer
 in many areas and only  1 to 2  feet  above the  base  of the alluvium in most
 other areas due to the  very uneven  erosional  surface of the middle till unit
 near  the  river.   Placing the drain  system at  a lower elevation would not
 increase  it's effectiveness.


 I think Kohler  Co.  should be responsible for  the cleaning landfill,  until no
more  leaching is  detected on either side of the river.

 Kohler Co.  is responsible for  addressing contamination at the Kohler Co.
 Landfill.   This responsibility includes operation  of any extraction systems,
 and long  term monitoring of the effectiveness of any actions taken.
 Monitoring  will address groundwater quality on both sides of the Sheboygan
 River, and  will be addressed during design of the  remedy,  to be included in a
 plan  modification  to Kohler's  existing plan of operation for the landfill.
The thirty  years  used to compare remedy costs in the proposed plan  was based
 on two factors; one is  the state requirement that Kohler Co.  provide financial
 assurance  for a 30 year time frame, and the (use of the) equation for
determining  present net worth  does  not provide a reliable estimate  for times
greater than 30 years.  Kohler Co.   is responsible for greater than  30 years.


 - Kohler has a new water treatment plant that should be used for cleaning the
 leachate  rather than pumping the leachate to the City of Sheboygan 's POTW.
 -  Nothing  should  leave Kohler as far as any contaminants or untreated water.
 -  I  think  that leachate should be  treated before  it is disposed of in any
water  or  in any other sewage system.  They have a plant here at Kohler that
could maybe  treat  that  (leachate).   -  The Village (of Kohler) needs to know
the following:  A)  Is  the village obligated to receive the waste flows?  B)
How will these  flows affect the present rate structure?  C)  Is there a
provision  for sampling and testing of discharge to determine the flow and
strength of the discharge prior to entry into the Village's system?  D)  Why
doesn't the Company run the discharge through their existing treatment plant
facility  first,  thereby paying treatment costs directly for the wastes created
by the company?  E)  What safeguards are planned to prevent any residential


                                      29

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 users  from absorbing any additional sewage conveying or treatment costs due to
 the implementation  of this proposed settlement?

 The discharge  option ultimately  used  Is dependant on negotiations between
 Kohler Co.,  the  Village  of Kohler  and the Sheboygan POTW, or any other party
 Involved  In  a  discharge  option.  Although discussions are ongoing between
 Kohler Co.  and the  Village and the POTW, If an agreement is not reached, use
 of  the Kohler  Co. treatment  plant  remains an option.  Initial estimates of
 leachate/groundwater concentrations are expected to not require the need for
 pretreatment prior  to discharge  to a  POTW, but will be included in any
 negotiations on  acceptance of such leachate/groundwater.  The Village of
 Kohler, and  the  Sheboygan POTW are not obligated to accept the discharge
 waters.   Cost, pretreatment, monitoring and any other conditions the
 POTW/Village might  want  to include can be discussed during negotiations with
 Kohler.   Long  term  costs due to  use of capacity can also be considered during
 negotiations.


 Close  the landfill  immediately.  -  I suggest the clean up plan specify that
 the Company  take steps to secure a site in 1997 and construct the landfill in
 1998,  with plans to begin using  the site by April 1999.   -  I would like to
 see the use  of the  landfill  by the Kohler Company terminate at the earliest
 date possible.

 As  part of the Plan of Operation Addendum for the Source Control Remedial
 Design submitted to the  DNR  on November 29,  1995, the Kohler Company has
 agreed to close  and place final  cover on about 50% of the landfill
 (approximately 27 acres) by  the  end of 1996,  provided construction of the
 ground water remedial system does  not delay placement of the final  cover along
 the eastern  and  southern side slopes.   The DNR also approved an alternative
 final  cover  configuration for the  remaining,  open portion of the landfill  that
 would  allow  additional filling of  about 400,000 cubic yards of nonhazardous
 industrial waste.   This would extend the life of the landfill to approximately
 December  of  1999 at  present  fill rates.

 The Kohler Company  is actively working towards obtaining the necessary permits
 for  a new engineered  landfill at a site in the Town of Wilson,  three miles
 south of  the existing disposal facility.   The DNR issued a feasibility
 determination  for the proposed site on April  15,  1996.


 / suggest that testing of the ground water be continued using wells  located
between the  landfill and the river.  Also some testing of the ground water
 across the river from the landfill.  -  Nested monitoring wells should be
 installed in sufficient number to show how the interceptor drain affects the
 ground water gradient and the contaminants present in the shallow bedrock.
 -   Long-term contaminant monitoring should continue below and on the other
 side of the  trench  and river in order to evaluate the system's  effectiveness.
    k/e further concur with Mr.  Tusler's recommendation that nitrates/ammonia
be  included  in the monitoring plan.  -   All  testing wells should remain in
place and checked every so often to insure that the river will  stay  clean.


                                      30

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The quality of the groundwater In both the shallow and deep aquifers will be
tested  In  accordance with a sampling schedule approved by the DNR, for the
life of the remedial action and as long as needed to assure compliance with
Wisconsin  groundwater quality standards.  Groundwater monitoring wells will be
located between the proposed perimeter collection trench and the river In both
the shallow and deeper aquifers to determine the effectiveness of the remedial
action.  Existing deep aquifer wells located to the east and south of the
Sheboygan  River will continue to be monitored to determine whether or not
contaminants are migrating past the river's discharge zone.   Currently,  the
monitoring wells surrounding the landfill are monitored four times a year for
various Indicator parameters and once a year for all  the constituents of
concern.  The deep wells east and south of the Sheboygan River are monitored
twice a year for volatile organic chemicals.


When the monitoring system has been developed,  a public information session
should  be held in the area to describe the system,  and this initial session
should  be  followed by periodic reporting to the public.

Such followup can be provided,  In the form of public  meetings,  press releases
letters and factsheets, as desired.


There should be an emergency plan ready if it appears that the remedy is not
working as projected.

The five year reviews required under the Superfund  rules provide for mandatory
periodic reviews of system effectiveness.   Review Is  likely to take place more
frequently, as groundwater monitoring results are obtained,  and disseminated
to the  public.  If additional  action appears  to be  necessary,  It would be
dependant on a review at that time of what actions  would be practicable.


The Kohler Company landfill's cap should include a  synthetic layer which would
greatly reduce the amount of water that would infiltrate the landfill and
cause l/OCs and other contaminants to migrate  out of the landfill.

A composite landfill  cover system,  consisting of clay,  a synthetic geomembrane
and a drainage layer,  would reduce Infiltration Into  the waste.   However,
direct Infiltration through the waste mass from precipitation  is not the only
means of contaminant migration  at this site.   There is  considerable flow
through of groundwater originating from areas upgradient of  the landfill
within the upper aquifer.   There is  also,  especially  near the  toe of the
eastern and southern side slopes,  a  component of upward  groundwater flow from
the deeper aquifer that enhances contaminant  migration.   The addition of a
geomembrane to the landfill  cap will  not affect either  of these transport
mechanisms and would,  therefore,  only add a small measure of additional
protection.
                                      31

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 I  feel  that  the Kohler Company should purchase property along the Sheboygan
 River and  it's tributaries and create vegetation buffer zones which would
 reduce  the amount  of non-point source pollution entering the Sheboygan River.


 While the  concern  for reducing pollution along the length of the Sheboygan
 River is understandable, and has been clearly expressed by many over the
 years,  this  process  can only address this site, at this time.  The concern
 over the overall river quality is also considered in other cleanup activities
 being planned along  the Sheboygan River.  However, creation of additional
 "buffer zones" was not included in the evaluation of alternatives for this
 site, as it  would  not directly address the contamination from this particular
 site.


 Based on the analyses conducted,  Kohler Co. believes that the proposed remedy
 is the  best  alternative and will meet remediation objectives without
 alteration.

 The Record of Decision, in selecting the proposed remedy,  identifies
 Alternative  11 as the most effective and cost efficient alternative to meet
 the goals  of compliance with groundwater quality standards in a reasonable
 period  of time.


 It seems to me that  there's no health hazard right now.  I think Option 1 (No
Action Alternative)  is the best option to take.

Although there may be no current exposure to the contaminated groundwater,  the
 possibility  exists for the future,  without taking some action to prevent
 exposure and to reduce contaminant levels.


 Take these actions to collect the pollutants but keep the site open so more of
 this pollution could be forced thru (sic) the fill for collection.   Rather
than try to  cover and capsulate the mess,  let's force as much as possible for
a faster and more complete cleanup of the site.

With the horizontal flow-through  of shallow groundwater and the upward
movement of deeper groundwater into certain areas of the fill,  contaminants
will  continue to be flushed out of the fill  area even after the site has been
completely closed.   While leaving the landfill  area  uncapped would  increase
Infiltration and accelerate contaminant  leaching,  the landfill  cap  also serves
other functions besides keeping the waste mass  dry.   One of the major benefits
of a cap system is it's value in  limiting human contact with the waste and
eliminating the potential  for accidental  dermal or inhalation exposure.   The
cap system will  also act to further stabilize the waste mass and control
precipitation runoff, thereby limiting the potential  for erosion of the side
slopes and continued exposure of the waste.
                                      32

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                                    Administrative Record Index
                                Kohler Company Landfill, Kohler WI
                                          FID# 460015380
No.  Date

1    12/28/90

2    3/27/91
3
4
5
6
7
11/22/91
3/20/92
3/30/92
4/7/92
4/7/92
*12/91
*8/28/90
8    4/9/92

8A   4/9/92

9    7/8/92

10   7/13/92

10A  7/24/92

11   7/31/92

12   11/9/92

13   12/16/92

14   2/4/93
     2/26/93
Title/Regarding

Alternatives Array

Responses to Alt.  Array
- 3/22/91 Eleder to Becker, 4 pg.
- 2/22/91 Ales to Eleder, 13 pg.
- 3/15/91 Ales to Eleder, 10 pg.
- 1/23/91 WW Engin. to Eleder, 9 pg.

SVE/GW ACLs

SCOU ROD Summary

SCOU ROD (see Source Control Adm. Rec.

Concurrence Letter

Notice of Ecological Assessment
ECO Update  (attached to 4/7/92 letter)
OSWER Directive No. 9835.15
 (attached to 4/7/92 letter)

Data Validation Report

Evaluation of Use of ACLs

Guidelines for GW POSA

Briefing Meeting

Ecological Assessment Workplan

Meeting Summary

ECA/RAA Report

Source Control Plan of Op. Modif.

Ecol. Ass't., Analytical Results
PSU
42
36
11
3
100 +
2
2
8
2
40
100 +
3
25
100 +
3
100 +
100 +
16
36
Author
Kohler
Eleder
Rothschild
Grefe
EPA
Besadny
Eleder
EPA
EPA
Duchac
Franks
Giesfeldt
Geraghty
WW Engin.
Duchac
Geraghty
Geraghty
Duchac
ii
Recipient
Ales
Becker
Eleder
Giesfeldt
-
Adamkus
Becker
Kohler
Eleder
Program
Kohler
Eleder
Sridharan
Sridharan
Kohler
Kohler
ii
Doc . Type
report
letters
letter
memo
ROD
letter
letter
bulletin
directive
report
report
memo
report
report
letter
report
report
report
11

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15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
2/19/93
2/19/93
7/22/93
7/27/93
8/5/93
8/30/93
10/12/93
. 10/12/93
11/22/93
11/22/93
12/3/93
1/5/94
2/2/94
2/8/94
2/14/94
3/4/94
3/22/94
4/25/94
5/19/94
6/1/94
Meeting Summary re. ECA/RAA Review

Comments on Draft Ecological Ass't.

Water Balance Evaluation for EGA

Progress on SRH and Kohler Sites

Review of Plan Modification

RAP Meetings/Public Involvement

Final GW Sampling Tech Memo

Preliminary Ecological Ass't.

WDNR Comments on Plan of Oper. Modif.

Interim GW Monitoring Plan

Notice of Intent to Modify a Plan App.

Water Quality Discharge Limits
- 7/30/91 Effluent Limits/BAT
- 8/6/91  Discharge Limits
- 7/15/91 Projected Effluent Limits
- NR 207
- General Permit

Review of Discharge Limits  (w/o App.B
from Source Control FS)

Meeting Summary

Public Partic. Prior to Remedy Select.

Effluent Limits

Cover Memo for Effluent Limits

Response to WDNR Comments on ECA/RAA

SCWQTF Concerns

Summary of NR 140  ES Exceedances
3
3
47
2
6
3
48
30 +
11
10
18
1
3
2
10
19
1
2
2
3
3
21
3
4
Pf arrer
Talbot
Grefe
Lemcke
Grefe
Eleder
WW Engineer.
WW Engineer.
Stinson
Sridharan
Pf arrer
Lemcke
Hantz
Ales
Schuettpelz

Duchac
Pf arrer
Eleder
Hantz
Sridharan
Pf arrer
Sebald
Fauble
Sridharan
Eleder
file
Eleder
Pf arrer
Lemcke
EPA
EPA
Sridharan
Duchac
Sridharan
Pf arrer
Ales
Becker
Giesfeldt

Hantz
Sridharan
Giesfeldt
Fauble
Pf arrer
Sridharan
Jones
file
letter
letter
memo
letter

letter
report
report
letter
•P
letter
letter
memo
letter
memo
permit
letter
letter
letter
memo
letter
letter
letter
list

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X
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
6/7/94
6/9/94
7/8/94
7/27/94
8/4/94
8/23/94
10/7/94
12/5/94
12/13/94
12/14/94
1/20/95
1/30/95
2/17/95
2/17/95
2/24/95
2/24/95
3/9/95
3/16/95
3/20/95
3/24/95
3/30/95
4/5/1995
4/13/95
Citizen Letter re. Landfill Cap

Key Activities

Meeting Summary for 7/7/94

PCB Contamination

PCB Contamination

Press Contact

GW Remedy Analysis                 35/98

Recommendations re. Alt's. Development  2

LMF Concerns

Meeting Summary

GW RA response

Notice of Intent to Modify Plan Approv. 24

CERCLA ACLs at the Kohler Landfill

Communication with LMF

Meeting Summary
Meeting Summary                    10/23

Public Health Assessment           39

Notice of Intent to Modify Plan of Op.  18

Potential Surface Water Quality Impacts 1

Meeting Summary

Comments on 1/30/95 Proposed Plan Mod.  41

Eval. of Potential for GW to Impact

Response to 2/24/95 and 3/16/95 Letters 2
3
2
5
1
4
1

2
4
6
10
24
6
2
2
!

18
1
2
41
41
2
Breckheimer
Sridharan
Pf arrer
Gehl
Pf arrer
Fauble
Pf arrer
Fauble
Tusler
Fauble
Sridharan
Sridharan
Sridharan
Skavroneck
Sridharan
Connelly
WI DHSS
Sridharan
Tusler
Connelly
Duchac
Geraghty
Pf arrer
Pastor
Didier
Gehl
Earl
Gehl
Meyer
Sridharan
Sridharan
Gehl
Sridharan
Pf arrer
Pf arrer
Edelstein
Kohler
Pf arrer
file
-
Pf arrer
Fauble
file
Sridharan
Kohler
Sridharan
letter
memo
memo
letter
memo
memo
report
memo
letter
memo
letter
letter
memo
letter
letter
memo
report
letter
letter
memo
letter
report
letter

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57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
4/20/95
4/25/95
4/26/95
4/26/95
4/28/95
5/17/95
5/18/95
5/30/95
6/6/95
8/1/95
8/31/95
9/6/95
9/6/95
10/12/95
10/13/95
11/30/95
1/10/96
1/16/96
2/15/96
4/96
5/2/96
6/96
PCB Contamination

Surface Water Impacts/Reply to Schaeffer3

ECA/RAA Addendum

Extension Request/GW Impacts

Silver Concentration in GW

Evaluation of Potential Impacts to S.W. 7
Surface Water Concerns

Intent to Modify Plan Approval

SOW for GW/Silver Analyses

Silver Sampling Results

Evaluation of Silver Tests

Review of ECA/RAA

Plan Modification

Meeting Summary

Phone Summaries

ECA/RA Report Addendum

Review of ECA/RAA

Status Report

ECA/RAA Addendum Response

Proposed Plan

Transcript of Public Meeting

GWOU ROD and Responsiveness Summary
4
•3
28
2
4
7
2
6
3
38
1
14
7
4
3
100 +
2
3
26
9
80
32
Fauble
Kessler
Geraghty+
Sridharan
Jones
Shuettpelz
Sridharan
Pf arrer
Duchac
Duchac
Schmidt
Sridharan
Sridharan
Connelly
Connelly
Geraghty
Sridharan
Connelly
Pf arrer
WDNR

WDNR
Kazmierczak memo
Kazmierczak memo
Kohler
Pfarrer
Schmidt
Sridharan
Pfarrer
Sridharan
Sridharan
Schmidt
Connelly
Pfarrer
Kohler
file
file
Kohler
Pfarrer
Didier
Sridharan
-
Mallman/Bastyr
_
report
letter
letter
memo
letter
letter
letter
report
memo
letter
letter
memo
memo
report
letter
memo
report
f actsheet
transcript
ROD

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