United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R05-91/184
June 1991
EPA Superfund
Record of Decision:
Better Brite Plating Chrome &
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50272.101
REPORT DOCUMENTATION 1" REPORT NO. I~ 3. AeclpienI'8 Acceaion No.
PAGE EPA/ROD/R05-91/184
4. TIle end SWtItIe 5. Report 0818
SUPERFUND RECORD OF DECISION 06/28/91
Better Brite Plating Chrome & Zinc, WI
6.
First Remedial Action
7. Aulhor(8) 8. Perfonnlng Orgenlzatlon Repl No.
8. Perfonnlng Org8lnlzatlon NIl... end Add.... 10. Proj8ctfTuklWorIt Unit No.
11. Contrac:t(C) or Gr8tlt(G) No.
(C)
(G)
1~ ~ Org8nlz81lon ...... end Addntu 13. Type 01 Repor1 & Period Covered
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
washington, D.C. 20460 14.
15. Suppletrentery No-
18. Abetr8ct (Urnlt: 200 worde)
The 2-acre Better Brite Plating Chrome & Zinc site is composed of two plating
facilities in De Pere, Brown County, Wisconsin. The site includes the 1.5-acre
Chrome Shop and the 0.5-acre Zinc Shop, which are located approximately 0.5 miles
apart. Because of their proximity and related backgrounds, the two sites were
jointly nominated to the National Priority List and are addressed as a single site in
this Record of Decision (ROD). Land use in the area is predominantly residential and
commercial, with a wetlands located approximately one-quarter mile from the site.
The estimated 15,000 area residents use the municipal wells drawing from the deep
aquifer as a drinking water supply. A municipal well located approximately 250 feet
from the site is thought to influence the ground water flow in the contaminated
shallow aquifer, but impacts have not been observed in the municipal well onsite.
From 1963 to the early 1970's, the Zinc Shop primarily plated chrome switching later
to zinc. The Zinc Shop has a long history of improper operational procedures and
spills into the surrounding soil. Wastewater and/or plating solutions routinely
leaked between the floor and sill plate of the building. Reportedly underground
vertical plating tanks were used early on. The Chrome Shop began chrome plating
(See Attached Page)
17. Doc:um8nt AneIyei8 .. D8ecr1ptol8
Record of Decision - Better Brite Plating Chrome & Zinc, WI
First Remedial Action
Contaminated Media: gw, sw
Key Contaminants: VOCs (l,l-TCA, 1,1-DCE), other organics, metals (chromium, cyanide,
b. Id8ntlfl8r8l0pen0Ended T8I1I18 lead)
c. COSA" R8IdIG,oup
18. Av1l18b11ty SI8tem8nt 18. Security CI..8 (Thi8 Report) 21. No. 01 P8ge8
None 26
20. Security CI... (Thi8 Pege) 22. Price
Nnnp
-(7)
(See Af6.Z38.18)
SH/fllJlTUCbOll8 on ~VfI-
(FOI'ITI8I1y NTls.35)
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EPA/ROD/R05-91/184
Better Brite Plating Chrome & Zinc, WI
First Remedial Action
Abstract (Continued)
operations during the early 1970's using several above-ground tanks and four buried
vertical tanks in the plating process. In 1978 and 1979, the Chrome Shop was found to
be responsible for surface spills, which resulted in construction of a shallow ground
water extraction system around a portion of the site. Later, it was determined that the
underground plating tanks from the Chrome Shop had leaked an unknown amount of plating
solution and VOCs into the onsite ground water. Consequently, in 1985, the owner of the
Chrome Shop filed for bankruptcy and operations ceased in 1986. In 1987, the State
installed ground water monitoring wells at the site, which identified contamination by
metals and VOCs in soil and ground water. In 1989, the Zinc Shop closed, and a private
contractor removed the building that housed the Chrome Shop. The State constructed a
clay cap and fenced around the area of highest soil contamination. In 1990, the Zinc
Shop owner failed to comply with an Administrative Order to conduct clean-up activities.
Subsequently, EPA performed an emergency removal action, which included shipping
350 cubic yards of hazardous and solid waste offsite and constructing a ground water
collection sump. Ground water is collected, stored temporarily, and treated onsite.
The residual chromium sludge from the ground water treatment is sent offsite for
recycling. Later in 1990, EPA performed an additional emergency response, and provided
for the construction of a wastewater pretreatment system and an extraction system to
collect and pretreat shallow ground water prior to discharge offsite to the De Pere
wastewater system. This ROD addresses Operable Unit 1, contaminated ground water and
surface water, as an interim action. Future RODs will address remaining soil and ground
water contamination. The primary contaminants of concern affecting the ground water and
surface water are VOCs including 1,1,1-TCA and 1,1-DCA; other organics; and metals
including chromium, cyanide, and lead.
The selected remedial action for this interim remedy includes continuing and expanding
the current operation of the ground water extraction system and pretreatment facility,
which will include pretreatment of the additional water collected by the surface water
and ground water collection systems, and the Chrome and Zinc shops, with discharge to
the De pere wastewater system; improving surface water drainage, and constructing berms
to control surface water runoff and to prevent contaminant migration; installing
monitoring wells; fencing both shops; and applying siding materials on the exterior of
the building at the Zinc Shop. The estimated present worth cost for this remedial
action is $500,000, which includes an annual O&M cost of $60,000.
PERFORMANCE STANDARDS OR GOALS:
site.
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Better Brite Plating Co. Chrome and Zinc Shops site
De Pere, wisconsin
STATEMENT OF BASIS AND PURPOSE
1
I
This decision document presents the selected interim remedial
action for the Better Brite Chrome and Zinc Plating Shop site, in
De Pere, wisconsin, which was chosen in accordance with the
requirements of 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 oil and Hazardous
Substances Pollution contingency Plan (NCP). This decision is
based on the administrative record for this site.
The State of wisconsin concurs with the selected interim remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action selected
in this ROD, may present an imminent and substantial endangerment
to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
This interim remedial action is the first of two or more operable
units for the site. This operable unit addresses contamination of
groundwater through treatment, engineering co~trols and limiting
site access. subsequent operable units will continue to address
contaminated soils and groundwater through the ongoing Remedial
Investigation/Feasibility Study (RIfFS).
The major components of the selected remedy include:
o
continued operation of the existing
extraction and pretreatment facility;
groundwater
o
Construction of berm(s) to divert the flow of surface
water;
o
Installation of an additional extraction system to help
alleviate ponding at the Chrome Shop;
Improvement of existing fences at the Chrome Shop and
installation of fences at the Zinc Shop;
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o
Application of siding and/or durable plastic to the
exterior of the building at the Zinc Shop; and
Installation of monitoring wells to provide information
concerning flow direction and chemistry of the
groundwater.
o
DECLARATION
This Interim Action is protective of human health and the
environment, complies with Federal and State requirements that are
legally applicable or relevant and appropriate to the Interim
Action and is cost effective. This action utilizes permanent
solutions and alternative treatment technologies to the maximum
extent practicable, given its limited scope. This action does not
constitute the final remedy for the Better Brite Plating Co. Chrome
and Zinc Shops site and the statutory preference for remedies that
employ treatment that reduces toxicity, mobility, or volume as a
principal element is addressed insofar as treatment is a principal
compo ent of this interim action. Subsequent actions are planned
to a dress full the principal threats posed by this sit~
JUlfe it ~ /c;fl
I .
Date
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DECISION SUMMARY
SITE NAME. LOCATION AND DESCRIPTION
The Better Brite Plating Co. Chrome and Zinc Shops site is located
in the city of De Pere, Brown County, Wisconsin, an urban area
southwest of the city of Green Bay. The site includes 1.5 acres
and .5 acres for the Chrome and Zinc Shops respectively, which are
both situated approximately one quarter mile west of the Fox River.
Both shops are in primarily residential areas and neither is
currently operating due to financial difficulties (See Figure 1).
The population of De pere is approximately 15,000. De pere has six
municipal wells located in the deepest aquifer, which are not
currently contaminated, all of which are within three miles of the
site, with the closest 250 feet west of the Zinc Shop. The
Chrome Shop is located less than one half mile southeast to the
Zinc Shop. The Better Brite Chrome and Zinc Shops have been
combined as one site because of their close proximity, related
background and joint nomination to the National Priorities List
(NPL) on August 28, 1990. Descriptions of each of the properties
are as follows:
A. Better Brite Chrome Shop,
Wisconsin
519 Lande Street, De Pere,
The Chrome Shop is located in a residential neighborhood and
abuts residential property on three sides with an active
railroad track to the east on the fourth side. The topography
is generally flat except on the west side and south side
property edges where it slopes downward to the adjacent
properties. Surface water flow off site is, therefore
generally to the south and west. Approximately 30 to 40 feet
of reddish brown clay overlays the dolomite bedrock surface.
The clay unit represents the area's shallow aquifer, which is
contaminated at both facilities. The deep aquifers of the
area consist of dolomite bedrock and an underlying sandstone
unit, from which drinking water is obtained (See Figure 2).
B. Better Brite Zinc Shop, 315 South 6th Street, De Pere,
Wisconsin
The site has residences located on three sides and a trucking
company on the fourth side. The surface topography is
generally flat. Surface water leaves the property to the
north and east via natural contours. Soils near the site
consist of 30 feet of lacustrine silty clay with lenses and
seams of more permeable silts and sands above the dolomite
bedrock. The groundwater flow direction in the aquifer is to
the northwest and exhibits a strong downward gradient flow.
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Setter Brite sites location map
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There is a municipal well located approximately 250 feet to
the northwest which is thought to influence the groundwater
flow in the shallow aquifer.
It is also thought that other municipal wells in the area may
also influence the groundwater flow in the shallow aquifer
(See Figure 3). These drinking water wells are located in the
deeper bedrock aquifer of the area.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Wisconsin Department of Natural Resources (WDNR) and the United
States Environmental Protection Agency (U.S. EPA) are currently
developing further remedial and enforcement activities to
investigate and clean up the site, in addition to the action
proposed by the Declaration. The history and enforcement
activities relating to each of the shops are as follows:
A. Better Brite Chrome Shop
The Chrome Shop began chrome plating in the early 1970s and
ceased in 1986. It used four vertical tanks buried 18 to 22
feet in the ground and several above-ground tanks in the
plating process. Documented surface spills in 1978 and 1979
resulted in the construction of a shallow (15 feet deep)
groundwater extraction system around a small portion of the
site. It was later found that the underground plating tanks
had leaked an unknown amount of plating solution and volatile
organic compounds (VOCs) directly into the groundwater. U.S.
EPA's Emergency Response section removed some of the
accumulated waste materials and contaminated soils. In Fall
1987, WDNR, utilizing their Environmental Fund, installed
groundwater monitoring wells at the site to investigate the
extent of contamination. High levels of chromium and VOCs
were found in soil borings and in the groundwater samples
taken both on and off site. In 1989, the building housing the
Chrome Shop, was removed by a private cont.ractor. WDNR,
utilizing their Environmental Fund, constructed a clay cap and
erected a fence around the area of highest soil contamination.
U.S. EPA's Emergency Response section constructed a wastewater
pretreatment system and extraction system to collect and
pretreat shallow groundwater prior to its discharge to the De
pere wastewater system. This groundwater collection system is
still in operation and pumps approximately 5,000 gallons a day
during the wettest times of the year. The system has been
operating since October 1990. The Better Brite Plating Co.
Chrome and Zinc Shops and its owners and operators have been
referred to the Wisconsin State Department of Justice several
times since 1979 for spills and hazardous waste violations.
Legal efforts remain in progress.
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SITE MAP
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B. Better Brite Zinc Shop
The Zinc Shop operated from 1963 to 1989. Prior to moving the
chrome plating operation to the Lande Street location, this
facility plated chrome in deep, vertical plating tanks similar
to those used at the Chrome Shop. File information indicates
that these tanks were never properly decommissioned.
Consequently, they continue to be a source of contamination.
Since the early 1970s, after the chrome plating operations
moved to Lande Street, the facility primarily plated zinc.
The facility has a long history of poor operation and spills
onto the surrounding soils. wastewater and/or plating
solutions routinely leaked between the floor and sill plate of
the building along the south and east walls. In 1987, WDNR,
utilizing the Environmental Fund, installed wells to monitor
groundwater quality. Sample results obtained from these wells
showed the soil and groundwater around the building to be
contaminated with heavy metals, cyanide and VOCs. Chrome was
found in the basement of an adj oining residence located
directly south of the facility.
On May 7, 1990, John Zenner and the Zinc Shop, Inc., were
issued a proposed Administrative Order by Consent to conduct
cleanup at the Zinc Shop, but the parties did not respond to
the proposal in a timely manner. Therefore, on June 4, 1990,
a Unilateral Administrative Order was issued to John Zenner
and the Zinc Shop, Inc. ordering the parties to conduct
cleanup activities at the Zinc Shop. The Respondents failed
to comply with the Unilateral Administrative Order.
In July 1990, U.S. EPA's Emergency and Enforcement Response
Branch (ERRB) shipped 350 cubic yards of hazardous and solid
waste off site. A groundwater collection sump was constructed
along the east side of the building. The sump began operation
in August 1990. So far, approximately 12,000 gallons of
contaminated groundwater have been pump"ed out. Additional
groundwater is pumped as the collection sump recharges.
After the groundwater is extracted it is sent to the
pretreatment system where it is held in temporary storage
until 5000 gallons is available for batch treatment.
Several steps are involved, first hydroxide and polymer are
added, then acid to balance the ph. This precipitates the
chrome and zinc from the groundwater. The chromium sludge is
dewatered and sent off site for recycling at a RCRA licensed
facility.
The waste is a RCRA D007 characteristic waste. U.S. EPA
believes that the water generated from the pretreatment system
originated from the electroplating baths; therefore, the
contaminated soil and groundwater is not considered to be a
RCRA F006 waste, which is designated as a wastewater treatment
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sludge from an electroplating operation. Since this is merely
characteristic waste, actions at the site can proceed under
the Soil and Debri exemption of the Land Disposal Restrictions
until that exemption expires.
COMMUNITY PARTICIPATION
A Community Relations Plan for the Better Brite Plating Co. Chrome
and Zinc Shops site was finalized in September 1990. This document
lists contacts and interested parties throughout government and the
local community. It also established communication pathways to
ensure timely dissemination of pertinent information.
Subsequently, a fact sheet outlining the emergency removal
activities was distributed in April 1990, in conjunction with an
April 19, 1990 availability session. A tour of the pretreatment
facility was held February 19, 1991. A fact sheet was also
distributed in February 1991. The Proposed Plan for this Interim
Action for the Better Brite Plating Co. Chrome and Zinc Shops site
was sent to the Information Repository April 26, 1991. All site
related documents were made available in the Administrative Record
and the information repository maintained at the Brown county
Public Library De pere Branch, 380 Main Avenue, De Pere, Wisconsin.
An index of the Administrative Record is found in Appendix C. The
notice of availability of these documents was published in both The
Green Bav Press Gazette and De Pere Journal on April 25, 1991.
A public comment period for this Interim Action was held from May
1, 1991 through May 31, 1991. In addition, a pUblic meeting was
held on May 9, 1991, to present the preferred alternative as
presented in the Proposed Plan for this Interim Action. A court
reporter was present at the meeting. A transcript is available and
is part of the Administrative Record. All comments received by
u.S. EPA prior to the end of the public comment period, including
those expressed verbally at the public meeting, are addressed in
the . Responsiveness Summary which is attached to this ROD as
Appendix A.
The provisions of Sections 113 (K) (2) (B) (i-v) and 117 of the
Comprehensive Environmental Response Compensation and Liability Act
(CERCLA) have been satisfied.
SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION WITHIN SITE
STRATEGY
U. S. EPA has currently organized this project into two or more
operable units. The first operable unit is an Interim Action to
address contamination of the groundwater by chromium by-products
and other constituents. Subsequent operable units will constitute
the final response action at the site and will address the
remaining groundwater and soil contamination.
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The contamination problems at the site are complex, as is the case
with many Superfund sites. The contaminated areas at each shop
represent a potential threat to residents in the immediate area who
use the groundwater for drinking. Direct contact with
contamination at the site also poses a potential threat. Since
the Remedial Investigation components for aquifer and soil
remediation will take an extended period of time to complete, u.S.
EPA and WDNR are proposing this Interim Action. This Interim
Action will continue and expand the ongoing activities to reduce
the contamination source, to help protect the municipal drinking
water supply through installation of additional monitoring wells,
to reduce ponding by control of surface water runoff, and limit
direct contact threats to neighboring residents and trespassers by
securing the site. Current funding for the groundwater pumping and
operation of the pretreatment facility will expire in October 1991.
This ROD is necessary for u.S. EPA to continue these activities.
Limited additional actions will also be taken to minimize direct
contact with contamination. u.S. EPA believes that contamination
has migrated off-site, but does not know the extent of
contamination at this time. This action will not address the
principal threat at the site. Subsequent operable units will
address the principal threat. This Interim Action is considered
consistent with the final site remediation.
SUMMARY OF SITE CHARACTERISTICS
To date, a number of contaminants have been detected in the
groundwater, surface water and soil near the site. contaminants
found during past site investigations are as follows:
contaminants of Concern
Carcinoqens
Non-Carcinoqens
Tetrachloroethylene
Benzene
1,1-Dichloroethane
DDT
1,1,1 -Trichloroethane
Cadmium
Chromium
Barium
Lead
cyanide
Zinc
Table 1 shows the levels of contaminants found in the groundwater
and the respective Federal and State groundwater standards for the
contaminants. The results presented in Table 1 are from sampling
performed by the WDNR on October 16, 1989. Figure 4 shows the
locations of the wells sampled. The maximum contaminant levels
(MCLs) as set by the Federal Safe Drinking Water Act are identified
in the Table. The Enforcement Standards and the Preventative
Action Limits (PALs), as set by the Wisconsin Administrative Code
of NR 140, are also listed. If no remedial action is taken at the
Better Brite site, the contamination could eventually affect
drinking water supplies.
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Table 1:
Groundwater Sample Results (ppb)
WDNR
October 16, 1989
Chrome Shop
We 11 I
Chromium
Cadium
Lead
Zinc
1,1,1
-Trich1oro
ethane
1, 1
-DichIara
ethane
Cyanide
1018 <100 <20 <100 <20 ND ND NA
101A <100 <20 <100 <20 15 1.2 -
1028 <100 <20 <100 <20 ND ND -
102A <100 <20 <100 410 ND ND -
1038 1000 <20 <100 <20 500 27 -
104A <100 <20 <100 <20 53 16 -
105A 30,000 <20 <100 <20 69 7 -
Zinc Shop
Well I
Chromium
Cadium
Lead
Zinc
1,1,1
-Trichloro
ethane
1,1
-DichIara
ethane
Cyanide
18 160 <20 <100 <20 21 2.2 100
1A 570 <20 <100 <20 4 1.6 160
28 38000 <20 <100 <20 ND ND 80
2A 48000 <20 <100 24 5.3 ND 230
38 6600 <20 <100 <20 100 9.8 90
3A 35000 <20 <100 <20 400 35 170
MCL
ES
PAL
100
50
5
5
10
1
50
50
5
5000**
2500**
200
200
40
850
85
200
200
40
MCL - Federal Safe Drinking Water Act, Maximum Contaminant Level
ES - WAC NR140 Enforcement Standard (Public Health Standard)
PAL - WAC NR140 Preventative Action Level (Public Health Standard)
A and B Indicates Welle Locations
ND - Not Detected
NA - Not Analyzed
** Stated Limit for Zinc is Public Welfare standard
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SUMMARY OF SITE RISKS
A baseline risk assessment will be part of the Remedial
Investigation/Feasibility Study (RI/FS) which will be completed
later. However, current site risks can be estimated from the
following available information.
Currently, monitoring of the municipal wells has not shown site
related contaminants in the municipal water supply. However,
investigations conducted at the Chrome and Zinc Shops do indicate
that chromium contamination increases with depth in the monitoring
wells installed within the shallow aquifer. The shallow aquifer
beneath the site recharges or leaks into the deeper aquifer, which
is the source of drinking water for De Pere and some of the
surrounding communities. If the levels of chromium and other
contaminants increase and are allowed to spread, contamination will
eventually degrade the deeper aquifers and potentially reach
municipal water supplies which utilize the sandstone aquifer. The
deep aquifer and municipal wells are vulnerable to contamination
from the Chrome and Zinc Shops because the deep aquifer is
geologically open to infiltration from the shallow aquifer above.
There are reportedly private wells in the dolomite aquifer, which
are located near the sources of contamination.
Based on the information supplied to u.s. EPA, the Agency has
determined that a person using water supplied by private wells in
the dolomite aquifer is at a possible future risk of exposure to
drinking water contaminated with VOCs and metals. This possible
risk of exposure is assumed, based on levels of contamination
present within the shallow aquifer. This discussion is also based
on the site's current condition. It is possible that contaminants
may reach the sandstone aquifer and introduce potential risks to
the municipal drinking water supply. In addition, there is
potential for the public to come into contact with contaminated
water that may be ponding on the surface or seeping into nearby
residents' basements. In either of these situations, there is a
potential for the public to come into contact with contaminated
drinking water, surface water or soil. Fencing at the shops is
required to reduce the potential for the public to come into direct
contact with on-site contaminants. Surface water drainage control
is necessary to avoid contact with ponding of contaminated water
and runoff to the nearby river. Actual or threatened releases of
hazardous substances from this site, if not addressed by
implementing the response action selected in this ROD, may present
an imminent and substantial endangerment to public health, welfare,
or the environment.
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DESCRIPTION OF ALTERNATIVES
Pursuant to CERCLA and the NCP, u.S. EPA must follow a series of
steps for choosing a plan to protect human health and the
environment from an actual or potential threat of contamination.
u.S. EPA is required to consider a number of possible alternatives
and then evaluate them according to certain standards or criteria
(See Summary of comparative Analysis of Alternatives).
In order to continue to minimize an actual or potential imminent
threat to human health and the environment in the Better Brite site
area, u.S. EPA is proposing to continue the ongoing removal actions
and take additional limited action for the period that the RIfFS is
being conducted and until actions of the alternative chosen for the
second operable unit begin. The proposed Interim Action
alternative includes pretreatment of the groundwater and added site
security as described below. This proposed cleanup alternative is
evaluated against a "no-action" alternative to determine whether
this interim cleanup action is necessary or appropriate to prevent
public exposure to contamination; to ensure that it will not
increase contamination problems around the shops; and to ensure
that the Interim Action is consistent with any final cleanup plan
for the site. Alternatives for the site are as follows:
Alternative 1 - No Action: u.S. EPA would not take any action.
The pretreatment facility presently controlling the source of
contamination would cease operating as it does currently, in
October 1991. Untreated, contaminated groundwater would enter the
City of De Pere' s wastewater system and possibly pond at the
surface. site security would continue to be inadequate to properly
deter trespassers. There is no cost associated with this
alternative. Applicable or relevant and appropriate requirements
(ARARs) would not be addressed by this alternative.
Alternative 2 - Pretreatment Facilitv Operation: This alternative
will work in tandem with subsequent source control and aquifer
remediation measures. with this alternative, groundwater at the
Chrome and Zinc Shops will continue to be collected, treated and
modified before being discharged into the City of De Pere's
wastewater system. Surface water runoff at the Chrome Shop will be
controlled with additional ground contouring and berming. This
will reduce the possibility for ponding of contaminated water off
site. The operation and maintenance of the pretreatment plant will
continue until a final remedy is implemented. Any residual created
by this Interim Action will be managed according to State and
Federal ARARs including Resource Conservation and Recovery Act
(RCRA) Land Disposal Restrictions (LDRs).
Because of possible direct contact exposure at the Zinc Shop, U.S.
EPA plans to secure the area with fencing and apply more durable
materials on the Zinc Shop building's exterior. Groundwater
monitoring wells will also be installed near a municipal well to
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monitor the aquifers and serve as an early detection system for
potential contamination of the municipal well. In addition,
miscellaneous site restoration may be conducted on an as needed
basis.
At this point, it is not known how long this Interim Action will be
necessary. It is anticipated that this Interim Action will last at
least five (5) years or until the final cleanup plan regarding
restoration of the contaminated aquifer and contaminated soils has
been selected and completely implemented.
The implementation of this alternative will continue to intercept
contaminated groundwater and pretreat it prior to discharge to the
city of De pere' s wastewater system, and will increase site
security to discourage trespassing. By doing so, any actual or
potential imminent threats will be minimized.
Certain ARARs will be met given the limited scope of the Interim
Action. These include ARARs regarding wastewater pretreatment
standards, well installation requirements, Wisconsin waste
management guidelines, and waste management requirements for any
pretreatment residuals including hazardous waste regulations. It
is expected that subsequent remedial actions for the site will meet
all ARARs.
Approximate associated costs for this alternative are as follows:
Estimated Construction Cost: $440,000
Estimated Annual Operation and Maintenance Cost:
Estimated Present Worth: $500,000
$60,000
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
To evaluate the alternatives presented in this ROD, U.S. EPA uses
the following nine criteria. The first seven criteria are used in
evaluating all the alternatives, with more emphasis on the
Threshold criteria. The Threshold Criteria need to be met by any
final remedial action chosen, while the Primary Balancing criteria
and the Modifying criteria are used to further evaluate the
alternatives, selecting an alternative based on the best balance of
all the criteria. The Modifying Criteria are used to further
assess U.S. EPA's Proposed Plan after the public comment period is
over and comments from the community have been received. The
criteria are as follows:
THRESHOLD CRITERIA:
OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
addresses whether a remedy provides adequate protection
of human health and the environment and describes how
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risks posed through each pathway are eliminated, reduced
or controlled through treatment, engineering controls, or
institutional controls.
COMPLIANCE WITH ARARS (APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS) addresses whether a remedy will
meet all of the applicable or relevant and appropriate
requirements of other Federal and state environmental
statutes and/or provide grounds for invoking a waiver.
An Interim Action or operable unit need not meet all
ARARs but any subsequent final remedial action must
satisfy all ARARs or meet the criteria justifying
waiving an ARAR.
PRIMARY BALANCING CRITERIA:
LONG-TERM EFFECTIVENESS AND PERMANENCE refers to expected
residual risk and the ability of a remedy to maintain
reliable protection of human health and the environment
over time, once cleanup goals have been met.
REDUCTION OF TOXICITY, MOBILITY, OR VOLUME THROUGH
TREATMENT is the anticipated performance of the treatment
technologies a remedy may employ.
SHORT-TERM EFFECTIVENESS addresses the period of time
needed to achieve protection, and any adverse impacts on
human health and the environment that may be posed during
the construction and implementation period, until cleanup
goals are achieved.
IMPLEMENTABILITY is the technical and administrati ve
feasibility of a remedy, including the availability of
materials and services needed to implement a particular
option.
COST includes estimated capital and. operation and
maintenance costs, also expressed as net present worth
costs.
MODIFYING CRITERIA:
STATE ACCEPTANCE reflects aspects of the preferred
alternative and other alternatives that the state favors
or objects to, and any specific comments regarding the
state ARARs or the proposed use of waivers. The Proposed
Plan should address views known at the time the plan is
issued but should not speculate. The assessment of state
concerns may not be complete until after the public
comment period is held.
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COMMUNITY ACCEPTANCE summarizes the pUblic's general
response to the alternatives described in the Proposed
plan, based on public comments received. Like state
Acceptance, evaluations under this criterion usually will
not be completed until after the public comment period is
held.
See Table 2 for an evaluation of the alternatives for the site
using these criteria.
Table 2
Evaluation of Interim Action Alternatives
Threshold criteria:
1)
Overall protection of human health and the environment;
Alternative 1: Imminent threats to public health or the
environment would not be reduced or eliminated. Contaminants
may reach unsafe levels in the public drinking water supply
and in residential areas. Risks due to direct contact
contaminants will still exist.
Alternative 2: Imminent threats to human health due to
ingestion of contaminated groundwater would be minimized by
controlling the source of contamination. Exposure to vocs,
heavy metals, and other contaminants would be reduced during
the time it takes to determine the final cleanup for the
Better Brite site. This alternative is protective,
considering the limited scope of the action.
2)
Compliance with applicable
requirements (ARARS): .
or
relevant
and
appropriate
Alternative 1: There have been and will continue to be levels
of contaminants which reach or exceed u.s. EPA and WDNR MCLs,
Enforcement Standards and/or PALs in the groundwater. ARARs
will not be met with this alternative.
Alternative 2: Prior to discharge to the City of De Pere
wastewater system, the collected groundwater and surface water
will need to be treated to meet the pretreatment standards as
set by the receiving Publicly Owned Treatment Works, pursuant
to the Clean Water Act. The city of De pere is responsible for
implementing a pretreatment program in accordance with 40 CFR
Part 403. Pretreatment program requirements are included in
the National Pollutant Discharge Elimination System (NPDES)
permit reissued to the city pursuant to the Clean Water Act
(CWA) in March 1991. The WDNR approved the De Pere
pretreatment program on January 31, 1985. The objectives for
the general pretreatment program include preventing the
introduction of pollutants to publicly owned treatment works
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(POTW) which will interfere with operations of the POTW or
which will pass-through the POTW (40 CFR 403.2) The discharge
from the Better Brite Plating Co. Chrome and Zinc Shops
Superfund site must comply with the requirements established
by the City of De Pere pursuant to its approved pretreatment
program. These requirements include compliance with local
limitations and reporting requirements. Table #3 list the
pretreatment standards. Wisconsin's Waste Management guidance
will be followed when managing the pretreatment residuals.
Disposal of any residuals resulting from the pretreatment
system or from the excavation of contaminated soils will need
to meet applicable State and Federal disposal regulations
including Resource Conservation and Recovery Act (RCRA) Land
Disposal Regulations. In addition residuals will be managed
in accordance with Wisconsin's guidance, "In-State and On-site
Management of Hazardous Waste at Clean-up Actions" dated March
24, 1991. Both agencies agree to consider this guidance a "to
be considered."
u.S. EPA's EERB handled the disposal of residuals by labelling
them as F006 and 0007 wastes. Without evidence that
wastewater contaminated the soils and groundwater, RCRA ARAR' s
may not be applicable. Therefore, it is not yet possible to
determine if the waste is listed or characteristic. It will
be treated as a characteristic waste due to past groundwater
concentration levels.
TABLE 3
City of De pere
Pretreatment Plant Discharge Limits
Chromium
Zinc
Cadmium
Copper
Lead
Nickel
Mercury
Cyanide
VOCs
7.0 mg/l
4.2 mg/l
1.2 mg/l
4.5 mg/l
0.6 mg/l
4.1 mg/l
0.005 mg/l
1. 9 mg / 1
Not a fire
or explosion hazard
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Primary Balancinq criteria:
3)
Long-term effectiveness:
This criterion is not applicable to this action since this
action is deemed an Interim Action. This Interim Action is
intended to provide protection to human health and the
environment during the period the RIfFS is conducted, until a
final remedy is selected and implemented.
4)
Reduction of toxicity, mobility, or volume through treatment:
Al ternati ve 1: contaminant toxicity , mobility and volume
would be reduced only until September 1991, at which time the
pretreatment system will cease operation as it exists
currently, if this alternative is selected.
Al ternati ve 2: By pretreating the groundwater, chromium
contaminants are removed. The chromium sludge that is
recycled achieves the reduction of toxicity, mobility and
volume of contaminants because the contaminants will be
re-utilized in product. The chromium sludge that cannot be
recycled is stabilized prior to disposal and achieves a
reduction in mobility of the contaminants.
5)
Short-term effectiveness:
Alternative 1: No short-term effectiveness would be
achieved. The present pretreatment system would
operation, as it exists currently in October 1991.
cease
Alternative 2: The upgrades to the extraction system,
contouring the surface to collect surface water runoff,
installation of site security and monitoring wells can be
completed within several months. The pretreatment facility
will continue to operate. This alternative will reduce
exposure to contaminants in the soils, surface water, and
groundwater at and around the Chrome and Zinc Shops. No
adverse impacts on human health or the environment are
anticipated during the construction and implementation of this
alternative.
6)
Implementability:
Alternative 1: The pretreatment facility
operating. No additional services would
implementation problems.
Alternative 2: The technology for implementation of this
alternative is available, easy to implement and, for the most
part, already in place at the site. Services and materials
not already present at the site should be easily obtainable.
would
occur.
cease
No
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7)
Cost:
Alternative
alternative.
1:
There
is
no
cost
associated
with
this
Alternative 2: Approximate
alternative are as follows:
associated
costs
for
this
Estimated Construction Cost: $400,000
Estimated Annual operation and Maintenance:
Estimated Present Worth: $500,000
$100,000
MODIFYING CRITERIA:
8)
state Acceptance:
The WDNR has been actively involved in past and present
activities at this site. The WDNR agrees to this action and
WDNR's letter of concurrence is attached as Appendix B.
9)
community Acceptance:
This criteria will be addressed in the Responsiveness Summary,
attached to the ROD.
SELECTED REMEDY
U.S. EPA's preferred alternative for the Interim Action at the
Better Brite Plating Co. Chrome and Zinc Shops site is Alternative
2. This alternative includes the following actions:
* continue and expand the current operation of the
pretreatment facility, by including the pretreatment of
water collected by surface water collection systems and
groundwater extraction systems at the Chrome and Zinc
Shops and achieve Federal, State and local pretreatment
standards prior to discharge to the De pere wastewater
system.
* Improve surface water drainage at the shops and collect
the surface water runoff from the shops, preventing
contamination from leaving the shop areas. Modify the
groundwater collection systems as appropriate at the
Chrome and Zinc Shops.
* Secure the site grounds and facilities (Chrome and Zinc
Shops), as appropriate, to deter trespassers from
accessing the site and coming into contact with
contaminated soil and debris through installation of
fencing and siding material.
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* Install monitoring welles) to better monitor potential
contamination within the deep aquifer and serve as an
early detection system for potential contamination of the
municipal well.
Approximate costs associated with the preferred alternative are as
follows:
Estimated Construction Cost: $400,000
Estimated Annual Operation and Maintenance Cost:
Estimated Present Worth: $500,000
$100,000
No unacceptable short term risks or cross media impacts will be
caused by implementation of this Interim Action.
STATUTORY DETERMINATIONS
Under its legal authorities, EPA's primary responsibility at
superfund sites is to undertake remedial actions that achieve
adequate protection of human heath and the environment. In
addition, Section 121 of CERCLA establishes several other statutory
requirements and preferences. These specify that when complete,
the selected remedial action must comply with ARARs under Federal
and State environmental laws, unless a statutory waiver is
justified. The selected remedy must also the cost effective and
utilize permanent solutions and alternative treatment or resource
recovery technologies to the maximum extent practicable. Finally,
the statute includes a preference for remedies that employ
treatment that permanently and significantly reduce the toxicity,
mobility or volume of hazardous substances, pollutants and
contaminants. The following sections discuss how the selected
remedy, where applicable, meets the statutory requirements and
preferences.
A. Protection of Human Health and the Environment
The selected remedy provides for protection of human health by
limiting the public from exposure to contaminated surface water,
groundwater, and soils during the performance of the RIfFS at the
site and subsequent final remedial action for the Better Brite
site. The Interim Action will limit the migration of contaminated
groundwater from beyond the Shop areas until a final remedial
action is selected and implemented.
The remedial objective of this operable unit is the protection of
human health. Protection of the environment will be achieved by a
subsequent final remedial action that will further address
contaminated groundwater, soils and on-site sources of
contamination. .
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B. Compliance with
Reauirements (ARARs)
Applicable
or
Relevant
and
Appropriate
The preferred alternative is designed to meet the City of De Pere's
wastewater standards. Any residuals from the pretreatment facility
or excavated contaminated soils will be managed in accordance with
Wisconsin's Waste Management guidelines and will meet Federal and
state regulations governing off-site disposal, including RCRA LDR.
ARARs not met by the Interim Action will be met by the subsequent
final remedial action or criteria for an ARAR waiver will be met.
C. Cost Effectiveness
u.s. EPA believes that the preferred alternative is cost effective
and is consistent with any subsequent final remedial action for the
site.
D. utilization of Permanent Solutions and Alternative Treatment
Technoloaies to the Maximum Extent Practicable
The preferred alternative does not propose to resolve the
contamination problems at the Better Brite Plating Co. Chrome and
Zinc Shops site, but is intended to act as an Interim Action until
a final remedy is selected and implemented. Additional
investigation work will be conducted by the WDNR and u.s. EPA to
study the contamination in and around the Chrome and Zinc Shops
more extensively. When the Agencies have developed plans to
address the remaining contamination, they will notify the community
and will hold a public meeting to discuss findings of the RI/FS and
any proposed final action to address the Better Brite site.
This Interim Action addresses the statutory preference for
reduction in toxicity, mobility and volume achieved through
treatment as a principal element of the selected remedy. Future
operable units will specifically address the remediation of on-site
sources and contaminated soils and groundwater with respect to
statutory ~equirements.
E. Preference for Treatment
Since the selected alternative treats inorganic contamination from
metal plating by-products and reduces their toxicity, mobility and
volume, this Interim Action addresses the preference for treatment.
This statutory preference will also be evaluated in future operable
units.
The preferred alternative is believed to provide the best balance
among alternatives with respect to the criteria used to evaluate
remedies especially the five (5) balancing criteria. Based on the
information available at this time and the limited scope of this
Interim Action, u.S. EPA believes that preferred alternative
protects human health and the environment, would comply with ARARs,
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;;
would be cost effective, would utilize permanent solutions and
alternative treatment technologies or resource recovery
technologies to the maximum extent practicable, would satisfy the
preference for treatment as a principal element and would be
consistent with any subsequent final remedial action selected for
the Better Brite Plating Co. Chrome and Zinc Shops site.
DOCUMENTATION OF SIGNIFICANT CHANGES
There have not been any significant changes from the remedial
action proposed in the U.S. EPA's Proposed Plan to the one
presented in this ROD.
RESPONSIVENESS SUMMARY
Appended to this ROD is the Responsiveness Summary which presents
background information and summarizes the public comments received
during the public comment period and U.S. EPA's responses to the
comments.
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APPENDIX B
,~j""~~"""":"',
la
State of \Viscons1n
, DEPARTMENT Of NATURAL RESOURCES
Carrol 0. SNadny
s.a*'7
LM8 IIIcItItIM DMfnct ~
112S It. IIiIIIIIIy A\118nU8
P.Q. au 100U8
GrMft ...,., ~ 5a07-0448
JUnE' 26, 1991
File Ref: WID-560010118
Brown Co. - SW/SF
Mr. Va1das Adamkus, Regional Administrator
U.S. Environmental Protection Agency
230 South Dearborn street
Chic:ago, IL 60604
SUb~1 ect:
Selected Superfund Remedy - Interim Action
Better Brite Plating Chrome and Zinc Plating Shop
Dear Mr. Adamkulii:
The Wisconsin Department of Natural Resources (WDNR) is providing
you with this letter to document the state of Wisconsin's
conc:urrence on the Interim Action Remedy proposed for the Better
Brit:e Superfund Site. The proposal, as identified and more fully
desc:ribed in the Record of Decision, includes the following
acttvities:
1)
EPA will continue operating the groundwater pretreatment
plant, constructed through EPA's Emergency Response Program,
for a five (5) year period, commencing October 1991.
The pretreatment plant is to continue operating as a
temporary remedial mealiiure, fundQd through EPA. The
continued operation of the pretreatment system is
necessary to reduce and control contaminant migration.
The state will be responsible for contracting for
operation of tha plant. The State will pay the selected
contractor and be reimbursed by EPA over the five (5)
year period.
Operation of the on-site extraction systems is included
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;;
Mr. Valdas AdamkuB - June 26, 1991
Conl:urrenCQ - Better Brite Superfund 8i te
Treatment residuals will be managed in accordance with
Wisconsin's "Interim Policy for Promoting the In-State
and On-Site Management of Hazardous Wastes in the State
of Wisconsin".
2)
Construct a berm or berms to divert surface water away from
nearby residential areas, with collection and treatment of
diverted water prior to discharge.
3)
Improve existing fencing at the Chrome Shop and install
fencing at the Zinc Shop.
Apply siding and/or durable plastic to the exterior of the
building at the Zinc Shop, to prevent direct contact.
4)
5)
Install a limited number of groundwater monitoring wells «5)
to provide information concerning flow direction and chemistry
of the groundwater.
Until the limits of contamination are better understood,
none of the monitoring wells are to penetrate the
sandstone aqui!Qr of the area. Without an evaluation of
the extent or contamination at the site, the risks
associated with penetrating the sandstone aquifer may
outweigh the potential benefits ot such a well.
It is expected that these wells would consist of water
table observation welles) and piezometer(s) screened in
the unconsolidated sediments and possibly piezometer(s)
screened in the upper portion of the underlying dolomite
bedrock unit. .
Estimated costs associated with the above activities, including
cont.inued operation of the pretreatment system for a five year
period, are presented below. The state of Wisconsin will
contribute ten percent (lot) of the costs associated with the
Better Brite site Interim Action.
Estimated Construction Cost
Estimated Operation Present Worth
Estimated Total Present Worth
$400,000
$100,000
$500,000
The WDNR conours with the selected remedy described above and
presented in the Record of Decision for this Interim Action at the
Better Brite site. EPA has assur$d the WDNR that this Interim
Action will not triqqer the ten (10) year operation and maintenance
provision of CERCLA, section 104(c) (3)(C). The state of Wisconsin
assures the EPA, pursuant to section 300.510 of the NCP, that it
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Mr. Valdas Adamkus - June 26, 1991
Concurrence - Better Brite Superfund site
Than~ you for your support and cooperation in the contamination
problem at the Better Brite Site of DePere, wisconsin. The state
recognizes and appreciates U.S. EPA's efforts as the lead agency to
date on this project. We anticipate that this favorable working
relationship will be continued in the future when the state is the
lead agency on all future actions. We a1so understand that our
staff will continue to work in close consultation with your staff
during the Remedial Design and Remedial Action Phases associated
with this Interim Action.
If you should have any questions regarding this matter, please
contact Mr. Paul Didier, DirectQr Qf the Bureau Qf SQli~ and
Hazardous Waste Management, at (608) 266-1327.
sincerely,
L~f,fJ-~W.
.D. Besadny
Secretary
cc:
Lyman Wible - AD/5
Paul Didier - SW/3
Patricia Hanz - LC/5
Lee Bouschon - WS/2
Dave Hantz - WW/2
Robert Barnum - LMD-WS
Doug Rossberg/Terry Koehn - LMD-SW
Mark Giesfeldt/Sue Bangert/Celia VanDerLoop - SW-3
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