PB96-964107
EPA/ROD/R05-96/303
November 1996
EPA Superfund
Record of Decision:
Tomah Fairgrounds Landfill Site,
Monroe County, WI
9/26/1996
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Tomah Fairgrounds Landfill, Tomah, Monroe County, Wisconsin
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the Tomah Fairgrounds Landfill
(TFL) site in Tomah, Monroe County, Wisconsin, which was chosen 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 is
consistent with the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) to
the extent practicable. This decision is based upon the contents of the Administrative Record for
the site.
The State of Wisconsin has indicated a willingness to concur with this decision. A written
confirmation is expected by September 30,1996, and will be added to the administrative record
upon receipt.
DESCRIPTION OF THE SELECTED REMEDY
United States Environmental Protection Agency (U.S. EPA) has found that "No Further Action"
is appropriate due to properly implemented deed restrictions limiting land use and an agreement
between the City of Tomah and the Wisconsin Department of Natural Resources (WDNR)
implementing natural attenuation of ground water.
DECLARATION STATEMENT
U.S. EPA has found that no further remedial action is necessary at the TFL to ensure protection
of human health and the environment. A brief description of the basis for this finding is set forth
below.
U.S. EPA conducted a remedial investigation that identified contamination both in site soils and
in ground water at the TFL. U.S. EPA then completed a risk assessment that evaluated the risks
posed by these sources of contamination. Utilizing U.S. EPA's Office of Solid Waste and
Emergency Response Directive No. 9355.7-04 entitled "Land Use in the CERCLA Remedy
Selection Process," this assessment included a consideration of current and future land use,
including limitations imposed by existing institutional controls. In addition, to further .assess
conditions at the site, data collected during the remedial investigation was compared to Ch. NR
140, Groundwater Standards, Wisconsin Administrative Code, and Ch. NR 720, Soil Standards,
Wisconsin Administrative Code.
Based on the information collected to date on the site contamination, associated risks to human
health and the environment, and consideration of state soil standards, U.S. EPA concluded that
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remediation of soil is not warranted under the current or anticipated future land use. The City of
Tomah has implemented proper deed restrictions limiting the land use at the TFL to recreational
purposes. U.S. EPA believes that, given the degree of exposure associated with recreational use,
contaminated soil poses no significant risk to human health or the environment. Therefore U.S.
EPA is recommending that no further action be taken at this site for the landfill materials.
Based on the information collected to date on the site contamination, associated risks to human
health and the environment, and consideration of state groundwater standards, U.S. EPA is
recommending natural attenuation for the groundwater contamination identified at the TFL. This
recommendation is based on: 1) the existing City ordinance preventing groundwater use within
and around the TFL; and 2) the signing of an agreement between the City of Tomah and the
WDNR requiring maintenance of this ordinance and the implementation of groundwater
monitoring to evaluate natural attenuation. U.S. EPA concluded that as long as contaminated
ground water remains untapped in the vicinity of the Fairgrounds and attenuates before it reaches
an area where residents rely on private wells, groundwater contamination poses no significant
risk to human health or the environment
Although this decision is for "No Further Action", EPA will conduct five-year reviews in
accordance with CERCLA Section 121. The five-year reviews will be performed because
hazardous substances will remain at the site, and because the existing institutional controls to
prevent unacceptable exposures from these substances will remain over the long term.
U.S. EPA has determined that its response at this site is complete. Therefore, the site now
qualifies for inclusion on the Construction Completion List.
)ATE William E. Muno '
Superfund Division Director
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U.S. EPA Superfund
Record of Decision
Tomah Fairgrounds Landfill Site
Tomah, Monroe County, Wisconsin
September, 1996
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TABLE OF CONTENTS
I. Site Description 1
II. Site History and Enforcement Activities 1
III. Highlights of Community Participation 2
IV. Scope and Role of Operable Unit 2
V. Site Characteristics 3
VI. Summary of Site Risks 6
VII. Explanation of Significant Changes 7
VIII. State Concurrence 7
FIGURES
Figure 1 Tomah Fairgrounds Landfill Site Location Map
Figure 2 Tomah Fairgrounds Landfill Site Base Map
With Phase II Groundwater Sampling Locations
Figure 3 Tomah Fairgrounds Landfill Site Base Map
With Phase I Groundwater Sampling Locations
APPENDICES
Appendix A - Responsiveness Summary
Appendix B - Administrative Record
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DECISION SUMMARY
L Site Description
The Tomah Fairgrounds Landfill (TFL) is located in the southeastern portion of the City of
Tomah, Monroe County, Wisconsin (Figure 1). The TFL property covers roughly 37.5 acres,
with the landfill itself occupying about 15 acres within the boundaries of the Fairgrounds (Figure
2). The landfill area is a grass-covered, open field that is often used as a parking lot during
Fairground events. The site is bordered on the north by Grassman Street and a residential area.
Fair Street runs along the eastern border, angles across the southeast corner and borders the
Fairgrounds along the south. Further east lies a commercial/industrial area. To the south and
southwest are seven homes with private drinking water wells and open fields. To the west is an
open field. Besides the seven homes to the south and southwest, the remaining residences
around the Fairgrounds are supplied drinking water by the City of Tomah municipal service.
IL Site History and Enforcement Activities
The TFL was used and operated by the City of Tomah as a disposal site before the Tomah
Municipal Sanitary Landfill was developed. Landfilling occurred at the site from 1955 until the
site was closed in 1960. Upon its closure, waste disposal was transferred to the municipal
sanitary landfill.
Waste disposal methods consisted of excavating 6 to 8 feet of soil, landfilling, placement of a
cover consisting of previously excavated soils, and a final grading process. Some material
disposed of in the landfill may have been burned before it was buried. No disposal records
regarding the types (residential, commercial, or industrial) or quantities of material buried were
maintained.
Representatives of the Wisconsin Department of Natural Resources (WDNR) and the U.S. EPA's
Field Investigation Team (FIT) investigated the site in 1984 to gain information for a preliminary
assessment. A site inspection report was prepared, and the site was scored using the Hazard
Ranking System (HRS). The site was placed on the National Priorities List (NPL) on July 21,
1987. The possible effects of disposal directly into an aquifer and the potential for direct contact
with hazardous substances because of erosion of the landfill cap were the concerns raised during
the preliminary assessment.
In January, 1988, the Agency for Toxic Substances and Disease Registry (ATSDR) prepared a
preliminary health assessment for the site. The assessment lists a number of potential exposure
routes including ingestion and dermal contact with ground water, surface water, and soils and
inhalation of contaminated dusts or volatile compounds. The assessment was completed before
the collection of any samples at the site and thus recommended environmental characterization
and sampling of the site to address the environmental and human health exposure pathways.
In August, 1991, WDNR collected groundwater from three residential wells south of the
Fairgrounds. The samples were analyzed for volatile organic compounds (VOCs). VOCs were
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not detected in any of the residential well samples.
In February, 1992, U.S. EPA sampled ground water in three residential wells near the TFL to
confirm WDNR's results. Analyses of the samples revealed no chemicals above state or federal
standards.
In July, 1993, U.S. EPA, in cooperation with WDNR and the United States Geological Survey
(USGS), conducted a Phase I remedial investigation (RI) at the TFL. The purpose of the Phase I
RI was to collect groundwater and soil samples to characterize the nature and extent of
contamination and associated exposure risks. This characterization would provide a basis for
deciding whether further action was necessary at the site. Results of the Phase I RI indicated that
additional groundwater and soil sampling was needed to adequately characterize the site.
Research to identify parties responsible for conditions at the TFL was completed in December,
1994. U.S. EPA named the City of Tomah as a potentially responsible party (PRP), based on the
City's ownership and operation of the site. U.S. EPA sent a special notice letter to the City in
January, 1995, requesting a "good faith" proposal to continue the Phase II remedial
investigation/feasibility study (RI/FS). In February, 1995, the City declined the offer to perform
the response action. U.S. EPA initiated a fund-lead Phase II RI/FS in March, 1995.
Ill, Highlights of C^Qmrn^nity Participation
In July, 1993, U.S. EPA hosted a "kick-off' public meeting at the Tomah City Hall Council
Chambers . The purpose of the meeting was to inform local residents of the Superfund process
and the work to be performed under the RI.
An information repository has been established at the Tomah Public Library, 716 Superior
Avenue, Tomah, Wisconsin. U.S. EPA maintains a copy of the administrative record for the site
in the information repository. The RI was released to the public in July, 1996. A Proposed Plan
was made available on July 26, 1996. A public meeting was held on August 7, 1996, to discuss
the RI and Proposed Plan. Advertisements were placed in local newspapers to announce the
public meeting and comment period. A public comment period for the Proposed Plan was
established from July 29, 1996, to August 29, 1996. The public generally supports the selected
remedy. The responsiveness summary is contained in Appendix A.
The public participation requirements of CERCLA Sections 113 (k)(2)(B) (i-v) and 1 17 of
CERCLA have been met in the remedy selection process. This decision document presents the
selected remedy for the Tomah Fairgrounds Landfill Superfund site, chosen in accordance with
CERCLA, as amended by SARA, and to the extent practicable, the NCP. The decision for this
site is based on the Administrative Record.
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IV, Scope and Role of Response Action
U.S. EPA has determined that "no further action" is necessary at the TFL. This decision is based
on an analysis of site risks, described in detail below. The decision relies on legal assurances
that contaminated land will not be used in a way that could pose significant risks, and that
groundwater monitoring will continue until it is clear that groundwater contamination has
attenuated. Because hazardous substances will remain at the site, U.S. EPA will conduct a five-
year review in accordance with Section 121 of CERCLA to assess whether any other response is
necessary.
Yi Site Characteristics
The Phase I and IIRI involved sampling and analysis of ground water, air, subsurface soil, and
surface soil to determine site conditions. Groundwater samples were collected from residential
and monitoring wells around the site. Subsurface and surface soils were collected from within
the landfilled area to determine if contamination is present as well as outside the landfilled area
to determine background conditions. A geophysical investigation consisting of a magnetic survey
and an electromagnetic survey was conducted to determine the approximate boundaries of the
landfilled area.
Based on the results of the RI, U.S. EPA examined the threats to human health and the
environment through exposure by ingestion and/or direct contact with contaminants in ground
water, and in subsurface and surface soils.
Site Conditions
Physical Features
1. Soils
Data from soil borings indicate that the Fairgrounds is underlain predominantly by tan, brown,
and gray fine-grained soils. These deposits are alluvial and lacustrine in origin. Clayey sands,
with the characteristics of wetland soils, were encountered in borings outside of the landfill area
at depths of about 4 to 6 feet. These shallow clayey sand lenses may be associated with wetlands
that are numerous in the area and occur near the site.
2. Hydrology
There are no surface water bodies onsite. The Fairgrounds is covered with buildings; paved and
dirt roadways; and gravel, paved, and grass parking areas. The landfill is grass-covered and used
as a parking lot for some Fairground events. Overland flow of water during storms occurs
primarily in the paved and gravel parking areas. The area is drained by storm sewers within the
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Fairgrounds boundaries and along roads outside the Fairgrounds fence line. In the vicinity of the
landfill area, surface runoff follows the site topography and flows toward the north and west.
3. Hydrogeology
Ground water at the Fairgrounds was encountered between 1 to 9 feet below ground surface,
depending on the topography. During July and September, 1995, ground water was determined
to flow to the northwest toward Lake Tomah and its surrounding wetlands. Hydraulic
conductivities were not measured as part of the RI. However, an average horizontal flow
velocity of 28 ft/yr was calculated, based upon data collected from monitoring wells screened in
similar materials at the Tomah Municipal Sanitary Landfill Superfund site, which is located on
the northwest side of Tomah.
The main regional and local aquifer in the area are the sandstone formations of Late Cambrian
age. The Cambrian sandstones also contain lenses of dolomite, siltstone, and shale. The aquifer
varies in thickness from 50 to 2,500 feet across the region.
Virtually all drinking water within the Tomah city limits is provided by municipal services.
There are five municipal wells sunk into the sandstone aquifer. Three of the wells are currently
in use at depths ranging from 280 to 325 feet. Two wells are not currently used. All of the wells
are within 1 to 3 miles of the site. Data collected as part of the RI indicate that the municipal
wells are unaffected by contamination at the TFL.
4. Ecology
The Fairgrounds is characterized by buildings, barns, paved and dirt roads, mowed lawns, and
two areas of mature trees. Wildlife habitat at the Fairgrounds is limited due to lack of vegetative
cover.
Land surrounding the Fairgrounds includes wetlands, woodlands, grassy fields, and agricultural,
residential, and commercial land.
WDNR's Bureau of Endangered Resources reports no known occurrences of threatened or
endangered species, or natural areas in the vicinity of the site. The U.S. Fish and Wildlife
Service does report that endangered and threatened species occur in Monroe County. However,
the U.S. Fish and Wildlife Service believes that these species are not being adversely affected by
conditions at the site.
5. Contamination
Phase I RI
In July, 1993, U.S. EPA, in cooperation with WDNR and the United States Geological Survey
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(USGS), collected groundwater and subsurface soil samples and had them analyzed for volatile
organic compounds (VOCs), semi-volatile organic compounds (SVOCs), and metals as part of a
Phase IRI. The Phase I groundwater sampling locations are shown on Figure 3. Sampling
results indicated that contaminants within the landfill boundary are present in concentrations
above state and/or federal standards. The primary contaminants of concern in ground water are
lead and vinyl chloride, found primarily within the boundaries of the landfill. Three upgradient
residential wells were also sampled for VOCs, SVOCs, and metals as part of the Phase I RI. The
upgradient residential wells are not affected by the groundwater contamination from the site. The
Phase I RI concluded that the presence of vinyl chloride and lead in the ground water at levels
that exceed health standards along with the cumulative effect of the other chemicals, merited
additional groundwater monitoring.
The evaluation of the nature and extent of contamination in the subsurface soils indicated that,
although some contamination occurs at depth, the concentrations detected do not warrant further
investigation. However, the Phase I RI concluded the surface soils needed to be characterized to
evaluate risks associated with direct contact at the landfill area through unrestricted access and
use as a parking lot for Fairground events.
Phase II RI
Field investigations for the Phase II RI included sampling of surface soils on and off the landfill
and the installation of monitoring wells for sampling ground water. The location of the
monitoring wells are shown on Figure 2. Groundwater flow is to the north-northwest, putting
MW-2, MW-3, MW-4S, and MW-4D downgradient.
The results of the surface soil sampling indicated the presence of contaminants at levels
exceeding background. In particular, a number of heavy metals including cadmium, chromium,
lead, mercury, and selenium were detected in the surface soils. Only one surface soil sample
exceeded the State soil standard for lead. All other concentrations were either at or below State
soil standards.
Results of the groundwater analysis indicated the presence of vinyl chloride and cis-1,2-
dichloroethene (cis-l,2-DCE) in a deep well located downgradient of the TFL, MW-4D on
Figure 2. Vinyl chloride was detected at a concentration of 6 parts per billion (ppb). The cis-
1,2-DCE was detected at a concentration of 2 ppb. A second round of samples was taken in the
same well to confirm the presence of the vinyl chloride and cis-l,2-DCE. Concentrations
detected in the second round were 9 ppb for vinyl chloride and 3 ppb for cis-l,2-DCE. The
federal groundwater standards for vinyl chloride and cis-l,2-DCE are 2 ppb and 70 ppb,
respectively. Volatile organic compounds (VOCs) were not detected in any other monitoring
wells at the site, including a shallower well (MW-4S) located at the same location as the
downgradient deep well. In addition, a number of metals were detected, including arsenic,
barium, cadmium, chromium, lead, and mercury. Downgradient concentrations of these
inorganic analytes are higher than upgradient concentrations. The downgradient concentrations
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of barium, cadmium, and mercury are still below their respective federal groundwater standards
and therefore were not considered significant. The remaining concentrations of arsenic,
chromium, and lead did exceed their respective federal groundwater standards. However,
observations during the groundwater sampling indicated that the water samples collected from
the monitoring wells were turbid. Thus, samples were also analyzed for dissolved metals to
determine if the high metals concentrations were on the suspended solid fraction rather than
dissolved in the water. The analyses of the dissolved metals did not detect any arsenic,
chromium, or lead in any of the filtered samples.
VI, Summary of Site Risks
U.S. EPA used the data collected during the RI to assess human health and ecological risks. This
assessment compared contamination levels at the site with U.S. EPA standards. In addition,
further assessment of conditions at the site compared contamination levels at the site with Ch.
NR 140, Groundwater Standards, Wisconsin Administrative Code, and Ch. NR 720, Soil
Standards, Wisconsin Administrative Code. The assessment considered ways in which people
and wildlife could be exposed to site-related contaminants and whether such exposure could
increase the incidence of cancer and noncarcinogenic (noncancer related) diseases above the
levels that normally occur in the study area.
The screening assumed that people could be exposed to site-related contaminants by a number of
different pathways (e.g., - ingestion, inhalation, dermal contact). Exposure to surface and
subsurface soils, landfill gases, and ground water were evaluated under current and future land
use conditions.
Current land use and reasonably anticipated future use of the land at NPL sites are important
considerations in determining current risks, future potential risks, and the appropriate extent of
remediation. (See "Land Use in the CERCLA Remedy Selection Process," OSWER Directive
No. 9355.7-04, May 25,1995). Land use assumptions affect the exposure pathways that are
evaluated in the risk assessment. The results of the risk assessment aid in determining the degree
of remediation necessary to ensure current and long-term protection at the site. The risk
assessment considers present use of the site to determine current risks. It may restrict its analysis
of future risks to the reasonably anticipated future land use.
In the case of the TFL risk assessment, U.S. EPA assumed that the future use of the site would be
the same as the current use, i.e., recreational, and not residential in nature. EPA based that
assumption on land use restrictions currently in effect, including deed restrictions and a city
ordinance. (Copies of these restrictions are included in the Administrative Record). Consistent
with a recreational use of the site, EPA focused on the risks to recreational users and utility
workers. However, in addition, EPA went further than was strictly necessary by calculating
some risks associated with residential land use, i.e., risks arising from regular use of ground
water for drinking and bathing. Due to the institutional controls already in place, these activities
are unlikely. EPA therefore considers the risks calculated for them as conservative estimates
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associated with a potential, but unlikely use of the site, rather than as realistic estimates
associated with the reasonably anticipated future use of the site. As such, they point to the
importance of maintaining land use controls so that the risks associated with residential use never
arise.
Potential risks to public health for cancer are expressed numerically, i.e., IxlO"4 or IxlO"6.
Carcinogenic risk expressed as 1x1O"4 means that of 10,000 people exposed to contamination
over a 70-year lifetime one individual could potentially develop cancer as a result of the
exposure. A carcinogenic risk of IxlO"6 means that of 1,000,000 people exposed over a 70-year
lifetime one individual could potentially develop cancer as a result of the exposure. U.S. EPA
has established a carcinogenic risk range from IxlO"4 to IxlO"6 in an attempt to set standards for
remediation and protectiveness. The measure of noncarcinogenic risk is termed a hazard index
(HI) and is also expressed numerically. When the HI exceeds 1, there is a potential for adverse
health effects.
In general, low levels of contamination have been observed in the surface and subsurface soil
throughout the landfilled area and there do not appear to be any hot spots. Methane and organic
vapors were not detected during the sampling of surface soil indicating that volatization of
landfill gases to the atmosphere is limited under existing conditions. In addition, based on site
specific conditions, including the size and depth of the landfill, the distance of the surrounding
residential areas from the landfill, and current deed restrictions that eliminate possible exposures,
U.S. EPA concluded that migration of subsurface landfill gas was not a significant or completed
pathway of concern. The potential for release of contaminated dust to the atmosphere is limited
based on the relatively heavy vegetative or gravel covers over most of the contaminated areas.
Moreover, activities such as excavation or grading that might release contaminants to the air
require WDNR approval under existing property restrictions.
Although downgradient concentrations of metals are up to an order of magnitude higher than
upgradient metals concentrations, groundwater contamination appears limited . This has been
confirmed from the results of the filtered, dissolved metals analyses which indicated no
exceedances in the downgradient monitoring wells. The existence of low levels of vinyl chloride
in the groundwater downgradient of the landfill was also confirmed, but is limited to one
downgradient well. Discharge of contaminated groundwater to private wells is not considered a
viable pathway. With the exception of three upgradient private wells that have not shown any
impact, there is no known use of groundwater at the site or in the surrounding areas. In addition,
the City of Tomah has filed a deed restriction and has implemented a zoning ordinance that
prohibits permits for well operation on the Tomah Fairgrounds property and within a zone that
extends 400 feet beyond the northern boundary of the Fairgrounds. Municipal water is being
supplied to this area, eliminating the need to tap potentially contaminated ground water.
Currently, it is possible that attendees of public events and utility workers employed to maintain
the Fairgrounds could be exposed to contaminants in the surface soil. Potential excess lifetime
cancer risks due to surface soil exposure estimated for recreational adults were 3x10"9. Potential
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excess lifetime cancer risks due to surface soil exposure for recreational children were 2xlO"9.
For an adult utility worker the cancer risks for exposure to surface soils were estimated at IxlO"7.
All these estimates were below the federal risk standard of IxlO"6. Hazard indices calculated for
surface soil exposures were .005 for the adult recreational user, .01 for the child recreational user,
and .2 for the adult utility worker. All these values are below the federal standard of 1.0.
Subsurface soil exposure to those in attendance during events is unlikely; however, utility
workers could be exposed if excavation activities within the landfill are necessary. The potential
excess lifetime cancer risk due to subsurface soil exposures for utility workers was TxlO"6. This
cancer estimate is within the acceptable federal risk range of 1x10"4 to 1x10"6. The hazard index
calculated for subsurface soil exposure was .4 for the adult utility worker. This value is below
the federal risk standard of 1.0.
Future contact with site surface and subsurface soil will be the same that exists under current
land use conditions assuming the status of the TFL and all controls (institutional and zoning)
remain intact. However, if controls are eliminated, it is possible that residential exposures to
surface soil, subsurface soil, and groundwater could occur and potential risks to future residential
users could exceed acceptable U.S. EPA risk standards. Based on a recent, binding agreement
between WDNR and the City of Tomah that requires maintenance of deed restrictions, etc.,, U.S.
EPA believes that any weakening of the existing institutional controls is unlikely.
An ecological risk assessment was conducted to estimate the risks to terrestrial organisms at the
site and qualitative measure impacts on areas surrounding the TFL. Except for potential risks
associated with the target receptor, the American robin, which were based on conservative
assumptions, selected receptors were not considered at risk based on benchmark values in the
literature. No adverse impact or actual damage associated with the TFL to the aquatic
ecosystem, adjacent wetlands, and a nearby lake, was observed.
Based on the information collected to date on the site contamination and associated risks to
human health and the environment, remediation of both soil and groundwater is not warranted
under current land use. The City of Tomah has implemented institutional controls and deed
restrictions to limit future land use to current land use conditions and restrict use of the ground
water on the site and 400 feet north (downgradient) of the TFL. In addition, the City of Tomah
and the WDNR reached an agreement in which the City will perform natural attenuation
monitoring and will maintain permanent institutional controls and deed restrictions at the site.
Under the agreement, groundwater standards set forth in Chapter NR 140, Groundwater Quality,
Wisconsin Administrative Codes, need to be achieved within a reasonable timeframe. The
WDNR has determined that ten years is a reasonable timeframe for trends to be established that
show the natural reduction of the contaminants of concern in groundwater. If after ten years
additional monitoring is necessary the timeframe can be extended. The agreement also includes
provisions that will maintain institutional controls and deed restrictions at the TFL on a
permanent basis. However, a future remedial action might be warranted if the Fairgrounds
became residential, if private well use was allowed on or near the site, or if natural attenuation
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has not effectively remediated groundwater.
VII. Explanation of Significant Changes
There are no significant changes from the recommended alternative described in the proposed
plan.
VTIL State Concurrence
The State of Wisconsin has indicated a willingness to concur with this decision. A written
confirmation is expected by September 30,1996 and will be added to the administrative record
upon receipt.
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FIGURES
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SCALE IN FEET
from Tomah Quadrangle 7.5' series
(topographic) 1983
FIGURE 1
Site Location Map fW>///'//!
Tomah Fairgrounds Landfill
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GRASSMAN STREET
Estimated
Fill Area
Fence
Building
Monitoring Well Locations
SCALE IN FEET
FIGURE 2
Site Base Map
Tomah Fairgrounds Landfil
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TOMAH FAIRGROUNDS
GRASSMAN STREET
FENCE
BUILDING
LEGEND
W-1 X GEOPROBE GW SAMPLE
RESIDENTIAL SAMPLE
SCALE IN FEET
TOO 200 300 400 500
FIGURE 3
PHASE I GROUNDWATEB
SAMPLE
LOCATIONS
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APPENDIX A
Responsiveness Summary
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RESPONSIVENESS SUMMARY
TOMAH FAIRGROUNDS LANDFILL
TOMAH, MONROE COUNTY, WISCONSIN
PURPOSE
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 1986 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), which requires the United States Environmental
Protection Agency (U.S. EPA) to respond to each of the significant comments, criticisms, and
new data submitted in written and oral presentations on a proposed plan for remedial action. The
responsiveness summary provides a summary of citizen's comments and concerns identified and
received during the public comment period, and U.S. EPA's responses to those comments and
concerns. All comments received by U.S. EPA during the public comment period were
considered in the selection of the remedial alternative for the TFL. The responsiveness summary
serves two purposes: it summarizes community preferences and concerns regarding the remedial
alternatives, and it shows members of the community how their comments were incorporated
into the decision-making process.
This document summarizes written and oral comments received during the public comment
period of July 29,1996 to August 28,1996. The comments have been paraphrased to efficiently
summarize them in this document. The public meeting was held at 7:00 p.m. on August 7,1996
at the Tomah City Hall Council Chambers, Tomah, Wisconsin. A full transcript of the public
meeting, as well as all site related documents, are available for review at the Information
Repository, located at the Tomah Public Library, 716 Superior Avenue, Tomah, Wisconsin.
Comments and questions were received during the public meeting from several residents and/or
city officials. No comments were mailed to U.S. EPA.
OVERVIEW
The proposed remedial alternative for the Tomah Fairgrounds Landfill was announced to the
public just prior to the beginning of the public comment period. U.S. EPA proposed no further
action.
Community Comments
1. Comment: What determines the length of time for groundwater monitoring?
Response: The timeframe for monitoring of ground water is dependent on the effects of
natural attenuation in reducing levels of contamination currently present in ground water.
WDNR and U.S. EPA have established five year reviews that allow an opportunity to
review groundwater monitoring data collected over subsequent five years to determine if
natural attenuation is resulting in reduction of contaminants in the ground water.
However, if after five years the effects of natural attenuation are not discernible, the
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timeframe for monitoring may need to be extended to allow more time for contamination
to diminish.
2. Comment: What is the frequency of the groundwater monitoring, i.e. annually,
semiannually, etc...?
Response: Semiannually (twice a year) for wells downgradient of the TFL, and once a
year for the upgradient well. In addition, private drinking water wells will be sampled
every five years, as part of the mandatory five-year review, to ensure that they are not
impacted and the decision remains protective..
3. Comment: Is it reasonable to assume, based upon the U.S. EPA recommended
alternative, that there was not a great deal of contamination at the TFL?
Response: While there is certainly less contamination at TFL than at many municipal
landfills, there is enough limited contamination present in ground water and soils to raise
levels above federal and state standards. EPA's determination that no further action is
necessary is not based on a single factor such as the amount of contamination, but on a
variety of factors. These include the presence of institutional controls to preclude
residential land use and a binding agreement requiring groundwater monitoring. EPA
believes that, given the current land use controls, contamination does not pose a
significant risk onsite, and that ground water contamination will attenuate before it can
pose any significant risk offsite. EPA will review regular groundwater monitoring results
to confirm this.
4. Comment: How far north of the Fairgrounds was ground water sampled?
Response: A monitoring well nest, containing a deep water well (approximately 25 feet
deep), and a shallow well (approximately 12 feet deep or at the water table), was installed
in a vacant lot approximately 50 to 75 feet north of the Fairgrounds boundary. The deep
water well showed limited contamination. Regional groundwater flow is to the north-
northwest. An area of 400 feet from the northern boundary of the Fairgrounds was
established to help define an area covered by the city ordinance which restricts
installation of drinking water wells and also provides a buffer zone for the natural
attenuation of the groundwater.
5. Comment: One commenter wanted clarification on the negotiation process for the long-
term groundwater monitoring. The same commenter wondered what would happen if the
city did not sign a consent order to perform the long-term groundwater monitoring?
Another commenter asked if the City of Tomah could contract to do the long-term
groundwater monitoring more cheaply than allowing the Agencies to conduct the
sampling and analysis.
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Response: EPA's determination that no further action is warranted assumes that a long-
term groundwater monitoring program will take place, pursuant to a binding agreement
between the City of Tomah and WDNR. To monitor the effects of natural attenuation of
the ground water, monitoring wells on and around the Fairgrounds property will be
sampled and analyzed. In many cases, U.S. EPA or WDNR would perform the sampling
and analysis. However, because the Agencies and the City of Tomah believe that it may
be more cost effective for the city to contract the long-term monitoring itself, WDNR
developed a consent agreement which specifies long-term groundwater monitoring
requirements the City must meet. The City of Tomah signed the agreement on September
17,1996. U.S. EPA and WDNR will track the monitoring results as they come in and
will conduct a formal review at five-year intervals to determine the efficacy of natural
attenuation. If the Agencies agree that natural attenuation has reduced the levels of
contamination in groundwater to a point where the monitoring is no longer needed, the
City of Tomah may petition WDNR to terminate the monitoring requirements. Because
the guaranteed monitoring is one of the bases for the overall remedial decision at the site,
reaching a decision on the long-term groundwater monitoring was essential to avoid
significant delays in the remedial-decision making process.
6. Comment: What will happen to the monitoring wells after the long-term monitoring is
completed? If they are removed, who pays to close them?
Response: The monitoring wells would need to be properly abandoned at the City of
Tomah's expense.
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APPENDIX B
Administrative Record
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U.S. EPA ADMINISTRATIVE RECORD
REMEDIAL ACTION
TOMAH FAIRGROUNDS SITE
TOMAH, WISCONSIN
UPDATE #2
09/26/96
DOCt DATE
srss srss
AUTHOR
1 05/20/96 Kuhliann, H.,
Boardian, Suhr,
Curry & Field
2 07/00/96 U.S. EPA
RECIPIENT
Meyer, I,, HDNR
Public
3 08/07/96 Southwest Reporters, U.S. EPA
Inc.
TITLE/DESCRIPTION PASES
Letter Forwarding Attached (1) Certified 7
Change to the Ordinance on Hell Abandonment
and (2) Duly Filed Deed Restriction re: the
Jonah Fairgrounds NPL Site
Fact Sheet: Proposed Plan for the Toiah 5
Fairgrounds Site and Announcement of August
7, 1996 Public Meeting and July 29- August
28, 1996 Public Conent Period
Transcript of August 7, 1996 Public Heeting 29
re: the Proposed Plan
4 00/00/99 Heyer, 6., HDNR
5 00/01/99 HDNR
6 00/02/99 U.S. EPA
fluno, H., U.S. EPA Letter re: HDNR's Concurrence with the
Selected Remedy for the Toiah Fairgrounds
Superfund Site
Respondents
Consent Order Between HDNR and the City of
Toiah (PENDING)
Record of Decision for the Toiah Fairgrounds
Site (PENDING)
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U.S. EPA ADMINISTRATIVE RECORD
REMEDIAL ACTION
TOMAH FAIRGROUNDS SITE
TOMAH, WISCONSIN
UPDATE *2
09/18/96
AR
DOCI DATE AUTHOR
ssss srss ssssss
RECIPIENT
srsssssss
TITLE/DESCRIPTION
PAGES
1 05/20/96 Kuhliann, Ğ.,
Boardian, Suhr,
Curry I Field
2 07/00/96 U.S. EPA
Heyer, L, UDNR
Public
3 08/07/96 Southwest Reporters, U.S. EPA
Inc.
4 00/00/00 WDNR
5 00/00/00 U.S. EPA
U.S. EPA
Letter Forwarding Attached (1) Certified
Change to the Ordinance on Well Abandonment
and (2) Duly Filed Deed Restriction re: the
Toiah Fairgrounds NPl Site
Fact Sheet: Proposed Plan for the Tciah
Fairgrounds Site and Announcement of August
7, 1996 Public Meeting and July 29- August
28, 1996 Public Couent Period
Transcript of August 7, 1996 Public Meeting
re: the Proposed Plan
Letter re: NDNR's Concurrence with the Record
of Decision for the Toiah Fairgrounds Site
(PENDING)
Record of Decision for the Toiah Fairgrounds
Site (PENDIN6)
29
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U.S. EPA ADMINISTRATIVE RECORD
REMEDIAL ACTION
TOMAH FAIRGROUNDS SITE
TOMAH, WISCONSIN
UPDATE 4*1
07/23/96
AR
DOCI DATE
AUTHOR
ssssss
i 01/10/95 u.s. EPA
RECIPIENT
Respondents
2 01/19/95 HayU, J., U.S. EPA City of Toiah
3 02/21/95
4 03/07/95
5 03/22/95
& 04/13/95
7 04/2B/95
PolUrd, F., City of
Toiih
Feinqold, R., U.S.
Senate
Adukus, V., U.S.
EPA
Feinqold, R., U.S.
Senate
Adukus, V., U.S.
EPA
Nayka, J., U.S. EPA
8 04/28/95
9 05/25/95
Petri, T., U.S.
Congress
Adukus, V., U.S.
EPA
10 05/25/95 U.S. EPA/OSHEB
11 07/00/96 CH2B Hill
TITLE/DESCRIPTION
SS3K33SSSSSSS2S2S
Administrative Order on Consent re: Reiedial
Investigation/Feasibility Study for the Toiah
Fairgrounds Landfill Site (UNSIGNED)
a/Attached Statement of Work
Litter re! Notification of Potential
Liability
Letter re: City of Toiah's Response to U.S.
EPA's Letter of January 199 1993 Concerning
Notification of Potential Liability
PAGES
Collui, I., U.S. EPA Letter re: Status of City of Toiah's
Supcrfund Sites
Feinqold, R., U.S.
Senate
Letter re: U.S. EPA's Response to Senator
Feingoid's March 7, 199S Letter Concerning
tht Status of the Toiah Superfund Sites
Collui, T,, U.S. EPA Letter re: City of Toiah Superfund Sites
(ATTACHMENT CONSISTS OF ATTORNEY/CLIENT
PRIVILEGE]} INFORMATION AND HAS NOT BEEN
COPIED FOR PHYSICAL INCLUSION INTO THE AR)
Feinqold, R., U.S.
Senate
Adaikus, V.9 U.S.
EPA
Petri, T,, U.S.
Congress
U.S. EPA
U.S. EPA
Letter re: EPA's Evaluation of City of
Toiah's Report Concerning the Hazard Ranking
Systei Site Score and Placement of the Toiah
Ariory and Fairgrounds Sites on the National
Priorities List
Letter re: Status of TMO Landfills in the
City of Toiah Considered Superfund Sites
(ATTACHMENT CONSISTS OF ATTORNEY/CLIENT
PRIVILEGED INFORMATION AND HAS NOT BEEN
COPIED FOR PHYSICAL INCLUSION INTO THE AR)
Letter re: U.S. EPA's Response to Congressman
Petri's April 28, 1993 Letter Concerning
Superfund Sites in Toiah
Metorandui re: Land Use in the CERCLA Reiedy
Seltction Process (OSKR Directive 9355.7-04)
Final Reiedial Investigation Report for the
Toiah Fairgrounds Landfill Site
23
11
301
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U.S. EPA ADMINISTRATIVE RECORD
REMEDIAL ACTION
TQMAH FAIRGROUNDS
TOMAH, WISCONSIN
ORIGINAL
08/30/95
A*
DOCI DATE AUTHOR RECIPIENT
rsss zsss ===::: rssssssss
TITLE/DESCRIPTION
sssssssssrrrzssss
PASES
i 03/01/84 Eigenbrodt, V., WDNR U.S. EPA
2 09/10/84 Sause, A., Ecology File
and Environment,
Inc.
3 06/00/93 Evans, L., U.S. EPA
4 06/00/93 U.S. EPA
5 06/00/93 U.S. EPA
6 12/00/94 U.S. EPA
Prelitinary Assessient 5
August 28, 1934 Site Inspection Report 16
^/Attached Cover fleiorandui
Health and Safety Plan for the Toiah 80
Fairgrounds Site
Quality Assurance Project Plan for the Toiiah 71
Ariory and Toiah Fairgrounds Superfund Sites
Vork Plan for the Toiah Ariory and Toiah 203
Fairgrounds Superfund Sites
Phast I Remedial Investigation Report for the 181
Totih Ariory and Toiah Fairgrounds Landfills
(Revision 2)
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