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
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•' ^
Non-Flammabla Pit / ^ , '
• A
^Southern / '
' Bum Pit '
1 1
I \
x ' N Legend
^ \ -~*^tii&Kto~-^-
\ \ ^•Wr^ A Existing Wells
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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
-------
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
-------
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
-------
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
-------
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.
-------
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.
-------
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.
-------
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
-------
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,
-------
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.
-------
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.
-------
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,
-------
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.
-------
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.
-------
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.
-------
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
-------
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
*».
-------
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:
-------
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
-------
\
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
-------
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
-------
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
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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
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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
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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.
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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.
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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.
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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.
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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.
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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
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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
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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
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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.
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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
-------
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
-------
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
-------
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
-------
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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