-
United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response..
EP A/RODIR05-90/130
September 1990
C@'rV' t
SEPA
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Superfund.
Record of Decision:
Wheeler Pit, WI
Haiardc>us 'Waste .CotteCfion
Informatton Resource- Center
us EPA Region 3
PhlfacfeJph.o. PA 19107
EPA Report Collection :
Information Resource Centcl
US EPA Region 3
Philadelphia. PA 19101
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REPORT DOCUMENTATION 11. REPORT NO. I ~ 3. ReclpIent'l Acce88lon No.
PAGE EPA/ROD/ROS-90/i30
4. Tile end Subtile 5. Report Dlte
SUPERFUND RECORD OF DECISIQN '. .
Wheeler Pit, WI . 09/28/90
6.
First Remedial Action - Final .
7. Author(l) 6. Perfonnlng OrglniZ8t1on Rept. No'
8. Perlonnlng Orgllnlzetlon Heme Ind Adelre.. 10. Pl'ojectlTl8klWork Unit No.
11. Contr8ct(C) or Grlnt(G) No.
(C)
(G)
1~ --DrIng OrglnlZ8llon Heme Ind Addre.. 13. Type 01 Report & Period Covered
U.S. Environmental Protection Agency 800/000'
401 M, Street, S.W.
Washington, D.C. 20460 14.
15. Suppfementery Notel
16. Abetrlct (Umlt: 200 wordl)
The 3.4-acre Wheeler Pit site is a former industrial waste disposal pit in LaPrairie
Township, approximately 1-1/2 miles from Janesville, Wisconsin. The soil beneath the
site is generally sand and gravel, and the uppermost aquifer, also composed of sand and
gravel, serves as a major source of drinking water for the Janesville area. From 1900
to the 1970s, the site was used as a sand and gravel pit by a railroad company, which
may also have used the pit for refuse disposal. In 1956, General Motors Corporation
(GMC) leased 3.82 acres of the pit, and from 1956 to 1960, disposed of general refuse
onsite. From 1960 to 1974, GMC disposed of an estimated 22.3 million gallons of
industrial wastes, including paint spray booth sludge, residue from part hanger
stripping systems, clarifier sludge, and powerhouse coal ash. In 1974, the State
required closure of the disposal area along with ground water monitoring. Onsite
elevated levels of several contaminants, including TCE and chromium, were detected in
the ground water after the site was closed. This Record of Decision (ROD) addresses
control of the source area, as well as monitoring of ground water. Natural attenuation
(See Attached Page)
17. Document Anelyell L Deacrlptore
Record of Decision - Wheeler Pit, WI
First Remedial Action - Final
Contaminated Media: soil, debris, gw
Key Contaminants: VOCs (benzene, PCE, TCE, toluene, xylenes), organics (PAHs),
metals (arsenic, chromium, lead)
b. IdentifierLlOpen-Ended Terms
c. COSio TI Reid/Group
18. Avell_bllty Statement 18. SeCW'ity ClI.. (Thil Report) 21. No. 01 Pegee
-
None 124
20. Security Cle.. (Thll Pege) n PrIce
Nf"Inp
FORM 272 (4-77)
(See ANSI-Z38.18)
See Inelruel/one on Reve-
(Formet1y NTlS-35)
Depertrnent01 COmnMWCB
50272-101
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EP~/ROD/R05-90/130
Wheeler Pit, WI
First Remedial Action - Final
..
Abstract (Continued)
will be relied upon to remediate the ground water.
affecting the waste, soil, and/or ground water are
xylenes; other organics including PAHs; and metals
lead.
The primary contaminants ~f concern
VOCs including benzene, toluene, and
including arsenic, chromium, and
The selected remedial action for this site includes consolidating waste and contaminated
soil from adjacent property into the original onsite disposal area; removing trees from
the area to provide a regular surface for the cap; capping the landfill with a solid
waste ca~ to comply with State requirements; installing a gas venting system in the cap,
if necessary, to release gas generated during tree root decomposition; monitoring of
ground water and private wells, and evaluating results to determine the need for any
additional remedial action; implementing institutional controls to limit land and ground
water use, and site access restrictions including fencing. The estimated present worth
cost for this remedial action is $2,940,000, which includes an annual O&M cost of
$137,300 per year for 30 years. Costs associated with the gas venting system are not
included.
PERFORMANCE STANDARDS OR GOALS: Cleanup levels identified for ground water are based on
State Preventive Action Limits and include arsenic 5.0 ug/l and chromium 5.0 ug/l.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
.
REGION V
MEMORANDUM
DATE:
October 11, 1990
SUBJECT:
Wheeler pit Record of Decision
FROM:
Mary Beth Novy, RPM -/lZf57L
Addressees
TO:
Attached is the final Record of Decision (ROD) for the Wheeler
pit site in La prairie Township, Wisconsin. The ROD was signed
by the Regional Administrator on September 28, 1990. The
selected remedy includes consolidation of the waste,
installation of a multi-layer clay cap and groundwater
monitoring. If you have any questions, please contact me at
(312)353-7556 or FTS 353-7556.
Addressees:
Tom Kenney, ORC
Mike Schmoller, WDNR
Darsi Foss, WDNR
Ernie Watkins, OWPE
vOERR, (with diskette)
Judy Kleiman, RCRA
Louise Fabinski, ATSDR
Sheila Huff, DOl
Y lLo.s.t f\ oQ.. :
A ~rLL+e Acl~l~~~c..
\ n~ V\.~ PuA \V\&J1+u{.
\(~ccrd
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DECLARATION
!
SELECTED REMEDIAL ALTERNATIVE
FOR THE
WHEELER PIT SITE
LA PRAIRIE TOWNSHIP, WISCONSIN
Statement of Basis and Purpose
This decision document presents the selected remedial action for
the Wheeler pit Site, La prairie Township, 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, 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.
Assessment of the site
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action in
this Record of Decision, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
Description of the Selected Remedv
The selected remedial action is a final remedy for the site.
purpose of this remedy is to eliminate or reduce migration of
contaminants to the groundwater and to reduce the risks
associated with exposure to the contaminated materials.
The
The major components of the selected remedy include:
-Construction of a landfill cover (cap) in compliance with
Chapter NR 504.07, Wisconsin Administrative Code (WAC)
landfill closure requirements;
-Consolidation of waste and soil from adjacent property onto
original disposal area:
-Use of institutional controls on landfill property to limit
land and groundwater use:
-Monitoring of groundwater to ensure effectiveness of the
remedial action:
-Evaluating monitoring results to determine if additional
action is necessary: and
-Monitoring private wells.
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2
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statutory -Determinations
The selected remedy is protective of human health arid the
environment, complies with Federal and state requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This remedy utilizes
permanent solutions and alternative treatment technologies, to
the maximum extent practicable. However, because treatment of
the principle threats of the site was not found to be .
practicable, this remedy does not satisfy the statutory
preference for treatment as a principal element. .
Because this remedy will result i~ hazardous substances remaining
on-site above health-based levels, a review will be conducted
within five years after commencement of the remedial action to
ensure that the remedy continues to provide adequate protection
of human health and the environment.
state'Concurrence
The state of Wisconsin concurs with the selected remedy. The
Letter of Concurrence is attached to this Record of Decision
(ROD) .
t-
~PL)9"O,
Date
Valdas V. Adamk s
Regional Admin'strator
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State of Wisconsin \ DEPARTMENT OF NATURAL RESOURCES
..
Carroll D. Besadriy, Secretary
Box 7921
Madison, Wisconsin 53701.
TELEFAX NO. 608-~67-3579
TOO NO. 608-267-6897
September 19, 1990
IN REPLY REFER TO:
4440
Mr. Valdas Adamkus, Regional Administrator
U.S. Environmental Protection Agency.
230 South Dearborn Street
Chicago, IL 60604
SUBJECT:
Selected Superfund Remedy, Wheeler Pit, La Prairie Township,
Wisconsin
Dear Mr. Adamkus::
The Department is providing you with this letter to document the State of
Wisconsin's concurrence on the proposed remedy for the Wheeler Pit Superfund
site. The proposal, as identified in the draft Record of Decision, includes
the fo 11 owi ng:
Alternative 3B:
Enhanced Capping
This alternative provides for the hazardous substances to be consolidated
into the original disposal area and capped with a new clay cap according
to the requirements of NR 504.07, Wisconsin Administrative Code. In
addition to the capping requirement, institutional controls will be
implemented at the site. These controls will include a fence around the
disposal site and deed restrictions on future land uses on the disposal
site. Long-term ground water monitoring will occur to evaluate the
performance of the remedy, as well as to determine if any additional
actions are necessary. Long-term operation and maintenance of the cap
will be required, in addition to sampling of private wells.
Estimated Costs:
Construction - $829,600
Operation and Maintenance - 137,300/year
30-Year Total Present Worth - $2,940,000
The Department concurs with the selected remedy described above and presented
in the Record of Decision for this site.
The State of Wisconsin will contribute 10 percent of the remedial action costs
associated with the Wheeler Pit site if the potentially responsible parties
(PRPs) do not agree to fund the remedy. This assurance is provided on the
condition that the U.S. EPA will pursue legal action against the PRPs, to the
extent feasible. The State's preferred enforcement approach is for U.S. EPA
to issue a unilateral order to the PRPs requiring them to undertake remedial
design and remedial action of the selected remedy.
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Mr. Valdas Adamkus - September 19, 1990
we also understand that our staff will continue to work in close consultation
with your staff during the remedial design and remedial action phases of the
Wheeler Pit site.
"
Thank you for your support and cooperation in addressing
problem at the Wheeler Pit site in La Prairie Township.
questions regarding this matter, please contact Mr. Paul
of the Bureau of Solid and Hazardous Waste Management.
Sincerely,"
O\~~
C.D. :Besa ny 1
Secre"t"dfY
CDB:MS:ps
d:\swm\wlrpt.mrs
cc:
Lyman Wible - AO/S
Linda Meyer - LC/S
~aul P. Didier - SW/3
.,oe Brusca - SO
Mike Schmoller - SO
~Mary Pat Tyson - EPA
Mary Beth Novy - EPA
Mark Giesfeldt - SW/3
Sue Bangert - SW/3
this contamination
If you have any
P. Didier, Director
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RECORD OF DECISION SUMMARY
.. WHEELER PIT SITE
LA PRAIRIE TOWNSHIP, WISCONSIN
1.0
SITE NAME, LOCATION, AND DESCRIPTION
The Wheeler pit site is located in rural La prairie Township
approximately 1-1/2 miles east of the City of Janesville,
Wisconsin, population 51,000, directly northwest of the
intersection of County Highway 0 (Old Delavan Road) and County
Highway J. (See Figure 1) The site (Wheeler Pit) is within a
physical depression approximately 50 feet deep and spanning an
area 'of approximately 35 acres, which previously operated as a
sand and gravel pit. The site, as originally defined by General
Motors Corporation in their Notification of Hazardous Waste site,
consists of 3.82 acres of lan4 iri the southeast portion of
Wheeler pit which was used as a disposal area for industrial
wastes for approximately 18 years.
The base of the gravel pit is fairly flat, and the sides.
slope steeply upwards, particularly to the north and east. The
ground surface is sloped for an access roadway from County
Highway J to the floor of the gravel pit. The road runs around
the southern and western edges of the site.
The soils under the site are generally glacial outwash sands
and gravels. A clay layer was found near the ground surface
south of the site as well as northeast of the site. In the
disposal area, the clay layer did not exist or was removed
during sand and gravel mining operations and was replaced by the
waste material.
The area surrounding the site is mainly used for agriculture
and for sand and gravel mining. There is a small asphalt plant
on property owned by Frank Brothers, Inc., which is north of and
adjacent to the property on which the site is located. Tanks and
piping associated with this operation encroach on the northern
portion of the site. There is a well located on this property,
but is not currently in use. Along the eastern site boundary on
County Highway J, the Rock County Highway Department maintains a
salt storage facility. No water supply well exists on this
property. West of the site, in the western portion of Wheeler
Pit, a fertilizer company, Green-Rock FS Cooperative, leased a
parcel of land in 1962. The buildings and equipment of the
fertilizer plant were demolished and removed in early 1989.
The Rock River is located approximately 2 miles west of the
site and flows in a southerly direction. The river is mainly
used for recreational purposes. Groundwater beneath the site in
the upper aquifer flows to the southwest at a rate ranging from
30-365 feet/year. The upper aquifer is composed of outwash sand
and gravel deposits, and regional information indicates that this
sand and gravel outwash is at least 200 feet thick beneath the
site. This aquifer is a major source of drinking water in the
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Janesville area. The aquifer below the sand and gravel outwash
is composed of sandstone and is most likely hydraulically
connected to the upper aquifer. The nearest municipal water.
supply well is the City of Janesville Municipal Well NO.8, which
is located approximately 6,000 feet northwest of the site.
Private wells located near the site are 900 feet south, 1,000
feet southwest, and just across County Highway J to the east of
the site. These wells are screened in the upper aquifer. The
site does not lie in wetlands or a floodplain. '
A more complete description of the site can be found in the
RI/FS Reports.
2.0
SITE HISTORY AND ENFORCEMENT' ACTIVITIES
The Wheeler Pit property was purchased in 1900 by the
Janesville and Southeastern Railway Company, predecessor in
interest to the Chicago, Milwaukee, st. Paul and Pacific
Railroad, which filed for bankruptcy in the 1970s. Upon
completion of the bankruptcy proceedings, CMC Real Estate
Corporation, successor to the Railroad, acquired ownership of the
property on which the site is located. In early 1990, CMC Real
Estate Corporation reformed to become CMC Corporation. CMC
Corporation is the current owner of the property on which the
site is located. The Wheeler Pit property was originally bought
to provide sand and gravel for the Railroad. It has been
reported that the Railroad also used Wheeler Pit for refuse
disposal.
In 1956, General Motors Corporation (GM) leased a 3.82 acre
portion of the pit from the Railroad as a general waste disposal
site. From 1956 to 1960, GM disposed of general refuse at the
site. From 1960 through 1974, GM disposed of paint spray booth
sludges, residue from the part hanger stripping system, clarifier
sludges and powerhouse coal ashes from its automobile assembly
plant in Janesville. The disposal site was reported to be
approximately 400 feet long, 250 feet wide and 8 feet deep. An
estimated 22.3 million gallons of organic and inorganic sludges
were disposed of at the site, as reported by GM to the United
States Environmental Protection Agency (U.S. EPA) in GM's
Notification of Hazardous Waste site form submitted in June 1981.
The,Railroad also filed a Notification of Hazardous Waste site.
At the site, waste was disposed of by depositing it within
a diked area and allowing it to spread freely. The material was
quite dense, so that compaction equipment was not used. The
waste was deposited in layers, alternating between layers of
sludge and layers of coal ash. Trucks were then able to drive
over the previously filled area. The dike, which contained the
materials, was located on the north and west sides of the
disposal area. In August 1981, some liquid seepage was noticed
on the ground surface outside the disposal area. The Remedial
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4
!
Investigation (RI) results showed that the ash/waste boundary
extends beyond the original disposal boundary to the north and
northwest, indicating that the waste spilled. over the dike to.
some extent during the active life of the site.
At the request of La Prairie Township, disposal at the site
was discontinued in 1974. The disposal area was covered and
closed during the fall of 1974 and summer of 1975 in general
accordance with guidelines provided by the wisconsin Department
of Natural Resources (WDNR) in a letter dated May 6, 1974. . WDNR
required that GM implement a groundwater monitoring program;
generate a site topographic map; stabilize surface water runoff;
and grade, cover and re-vegetate the site.
Groundwater monitoring was performed by GM on an irregufar
basis after closure in 1974. In respons~ to complaints
concerning potential groundwater quality impacts related to waste
disposal practices at the site, WDNR and GM sampled on-site
monitor wells and certain private water supply wells in April
1981. Elevated levels of trichloroethylene, chromium, zinc and
barium were noted in both WDNR and GM samples taken on site.
Results from these analyses and GM's January 1981 sampling round
were used by u.s. EPA in the Hazard Ranking System (HRS)
evaluation of the site performed in April 1983. The site was
placed on the National Priorities List on September 21, 1984.
This NPL listing was published in 49 Federal Register 37070.
In June 1987,' two known PRPs for the site, GM and CMC
corporation (CMC), received special notice letters, which
provided them with the opportunity to conduct the Remedial
Investigation and Feasibility Study (RI/FS). GM and CMC signed a
consent order with u.S. EPA and WDNR which became effective
December 1, 1987. This order outlined the scope and schedule for
the RI/FS at the Wheeler pit site. GM and CMC assumed
responsibility for the site investigation, and Warzyn Engineering
Inc., under contract to the PRPs, conducted the RI/FS. U.S. EPA
and WDNR oversaw activities at the site.
RI field activities began in September 1988 and included two
phases. Activities included digging and sampling of four test
pits, installation of six monitor wells (three nests), hydraulic
conductivity testing, groundwater level monitoring and
groundwater sampling. Phase II activities included three
additional test pits, an electromagnetic survey to help determine
the waste boundary and volume, waste/soil borings and sampling,
shallow soil borings, surface soil sampling, four additional
monitor wells (two nests), and a second round of hydraulic
conductivity testing and groundwater sampling. Figure 2 shows
the locations of the monitoring wells, soil borings, surface
soil samples and test pits. The RI Report describing these
activities was finalized on March 1, 1990. An Endangerment
Assessment was also prepared and was included as part of the RI
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...
5
Report.
In September 1989, it was decided to streamline the
remainder of the RI/FS based on the straightforward nature of the
site. The number of alternatives considered for this site was
reduced very early in the FS process, and all groundwater
alternatives were eliminated from the list, based on the levels
of contaminants detected in the groundwater and the limited
extent of contamination. Four alternatives remained and were
evaluated in the FS Report. The Public Review Draft of the FS
Report was submitted on May 30, 1990. .
u.S. EPA has not yet sent out special notice letters for
Remedial Design and Remedial Action (RD/RA) to the PRPs. Thes~
.should be issued after the time that this ROD is signed.
3.0
HIGHLIGHTS OF COMMUNITY PARTICIPATION
A community relations plan was developed in 1988 to document
community concerns and to plan an information strategy. u.S.
EPA has held one public meeting and one informal availability
session to keep the public informed about the activities at the
site. u.S. EPA has also sent out fact sheets at various times
during the RI/FS process.
As part of its community relations program, u.S. EPA has
maintained two information repositories: one is at the
Janesville Public Library, 316 South Main street, Janesville,
Wisconsin: and the other is at the La prairie Township Clerk's
Home/Office, 915 Sharon Road, Janesville, Wisconsin. All formal
reports submitted by the PRPs during the Wheeler Pit RI/FS are
available at these locations. The repositories also contain
documents prepared by U.S. EPA, such as fact sheets and the
Proposed Plan, as well as documents prepared by u.S. EPA's
oversight contractor.
u.S. EPA notified the local community, by way of the
Proposed Plan, of the recommendation of a remedial alternative
for the Wheeler pit. To encourage public participation in the
selection of a remedial alternative, u.S. EPA scheduled a public
comment period from July 12 to August 11, 1990. This public
comment period was extended to August 24, 1990. Additionally, on
August 8, 1990, U.S. EPA held a public meeting to discuss the
recommended remedial alternative and the other alternatives
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7
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identified and evaluated in the FS. A transcript of this
meeting is included as part of the Administrative Record for the
Wheeler pit site. u.s. EPA's responses to comments received.
during this public meeting and to written comments received
during the public comment period are included in the
Responsiveness Summary which is attached to this ROD.
Press releases were sent to Janesville and Rockford,
Illinois, media, and advertisements were placed in the Janesville
Gazette concerning the availability session, public meeting and
comme.nt period.
4.0
SCOPE AND ROLE OF RESPONSE ACTION
The selected remedy for the Wheeler pit site is intended to
be the final response action at the site. The remedy will
combine source control, site access and land-use restrictions,
and long-term groundwater monitoring. In summary, the selected
remedy will include consolidating waste that is currently on
adjacent property onto CMC property, removing trees and
vegetation from the landfill, installing an NR 504.07 cap,
providing for institutional controls including fencing the site
and restricting site use via land use restrictions, and
conducting long-term groundwater monitoring. The components of
the selected remedy are described in greater detail in section
9.0. This remedy will be subject to a review in five years since
waste material above health-based levels will be left on site.
No principal threat which warrants treatment at the site has
been identified. The level of contamination remaining in the
waste on site can be reliably controlled over time through
engineering and institutional controls: therefore, treatment is
not practicable. However, the waste mass in place represents a
potential threat through contact and a release of contaminants to
the environment,' and the present and potential future groundwater
contamination may be a threat to the environment and public
health. This remedial action will address these concerns.
During the groundwater monitoring program, if it is shown
that the groundwater conditions become worse or do not improve
over a reasonable period of time, u.S. EPA may evaluate options
for a groundwater treatment program. Whether additional measures
are needed will be determined by u.s. EPA and the WDNR as
discussed in section 9.0.
5.0
SUMMARY OF SITE CHARACTERISTICS
The source of contamination at the site is the estimated
22.3 million gallons of sludges and coal ash which GM disposed of
in Wheeler pit. The disposal area was located in a portion of
. the former sand and gravel pit and was not lined. According to
the results of the RI, the waste/fill covers an approximately 3.4
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..
acre area and ranges from 0-23 feet in thickness. At its deepest
point the waste is approximately 10 feet above the water table.
The estimated volume of waste is 60,600 cubic yards (cu yds). .
The predominant contaminants in the waste materials are toluene,
ethylbenzene, xylenes, phthalates, polynuclear aromatic
hydrocarbons (PARs) and metals. Concentration ranges for organic
compounds detected in test pit waste samples are as follows:
- toluene, ethylbenzene, xylenes: total concentrations
ranging from 3,302 ug/kg to 508,000 ug/kg.
- phthalates: detected as individual compounds at
concentrations ranging from 450 ug/kg to 630,000 ug/kg.
- PARs: total PAR concentrations ranged from 9,520 ug/kg to
152,000 ug/kg.
Toluene, ethylbenzene and xylenes are volatile organic compounds
(VOCs). VOCs are compounds which tend to evaporate when exposed
to air. Phthalates are semi-volatile organic compounds
associated with plastics and plastic-making processes. PARs are
semi-volatiles derived from coal and oil tars and the incomplete
combustion of carbonaceous materials.
Nine metals were detected in test pit wastes at maximum
concentrations that were at least 10 times the background soil
concentrations. They are (with maximum concentration):
antimony (20 mg/kg)
barium (14,500 mg/kg)
cadmium (20.2 mg/kg)
total chromium (1,250
copper (151 mg/kg)
mg/kg)
lead (3,130 mg/kg)
mercury (0.28 mg/kg)
nickel (608 mg/kg)
zinc (13,100 mg/kg)
The waste/fill material also contains metal, concrete and
wood debris, chunks of paint sludge, and a variety of other
. materials such as wire, insulation and bricks.
The present cover at the site consists of 0-6 inches of
sand, ash or silt plus 0-2 inches of topsoil. This cover is
vegetated with grass and trees. Phthalates and three metals were
detected in surface soil both on-site and southwest of the waste
disposal boundary. The highest phthalate concentration detected
was 7,200 ug/kg, and cadmium and lead were detected at levels 2-3
times background. The range of background concentrations for
cadmium was .10 -.36 mg/kg and for lead was 10.3 - 34.9 mg/kg.
Approximately 27,600 cu yd of contaminated subwaste soil in
the 3.4-acre area are present beneath the waste. Concentrations
of contaminants in subwaste soil were low relative to the
concentrations in the test pits. Staining of subwaste" soils was
observed, but it only extended approximately 6 inches below the
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waste, in the areas sampled.
As stated earlier, the groundwater flows to the southwest at
a rate of 30-365 feet per year. Based on the wells sampled at.
the site, the groundwater contamination appears to be limited in
terms of contaminant concentrations and extent. However, the
plume leaving the site was not well-defined. Chlorinated benzene
compounds -- such as 1,4-dichlorobenzene, 1,3-dichlorobenzene and
chlorobenzene -- were detected in two downgradient water table
wells, as were elevated concentrations of certain metals. 1,4-
dichlorobenzene was detected at 24 ug/l at a well adjacent to
the site and at 25 ug/l at a well further downgradient.
Arsenic, chromium, iron and manganese were detected in
downgradient wells at concentrations which exceed Preventive
Action Limits (PALs). PALs are Wisconsin state groundwater.
standards and are 10 or 20% of Wisconsin's Enforcement Standards
(ES), which are generally equivalent to Federal Maximum
contaminant Levels (MCLs). MCLs are drinking water standards set
forth in the Safe Drinking Water Act (SDWA). In addition, PALs
are a trigger by which the state of Wisconsin contemplates taking
an action at a site, which can range from no action to active
remediation. Manganese exceeded its ES at the furthest
downgradient well. Maximum concentrations of these metals in
the groundwater and the corresponding PAL and ES are as follows
(for well locations see Figure 2):
Arsenic: 32 ug/L in Well MW03A
PAL - 5.0 ug/L ES - 50.0 ug/L
Chromium: 5.8 ug/L in Well MW04A
PAL - 5.0 ug/L ES - 50.0 ug/L
Iron: 9,120 ug/L in Well MW03A, and 170 ug/L in Well MW03B
PAL - 150 ug/L ES - 300 ug/L
Manganese: 818 ug/L in Well B, and 158 ug/L in Well MW03A
PAL - 25.0 ug/L ES - 50.0 ug/L
The levels of 1,4-dichlorobenzene detected do not presently
exceed PALs or ESs, since the current standards are 150 ug/L for
PALs and 750 ug/L for ESs. It is expected, however, that the PAL
will be lowered to 15 ug/L and the ES will be 75 ug/L as of
October 1, 1990. Under these new standards, 1,4-dichlorobenzene
will exceed its PAL at MW03A and Well B.
Background groundwater quality indicates elevated total
dissolved solids, zinc and nitrate concentrations upgradient from
the site. However, elevated alkalinity, total dissolved solids,
specific conductance and oxygen deficient conditions in
downgradient groundwater indicate groundwater impacts have
resulted from the site as well as from possible upgradient
sources. Nitrates exceeded ESs at 10 wells, and total dissolved
solids exceeded ESs at the site in 4 wells, but this may be in
part due to background conditions.
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At this time, groundwater seems to be the primary potential
contaminant migration pathway. However, bas~d on available data,
groundwater contamination appears to be limited. The closest
downgradient private well is 900 feet away. It was sampled by
the WDNR in 1984 and 1985 for volatile organic compounds (VOCs),
and the analyses determined no VOCs were present. No analysis
for metals was done. Three municipal wells are approximately 2
miles west of the site, with the nearest well 6000 feet northwest
of the site. .
The RI Report states that reducing conditions in the
groundwater may be partially responsible for the.metals present
in the groundwater. These.reducing (oxygen deficient) conditions
may increase the solubility of such metals as arsenic and iron. .
and to some extent manganese, causing the release of these metals
from th~ subwaste soils. As the reducing conditions diminish
away from the site, the affected metals will readsorb to the.
soils. While this theory may partially explain the presence of
certain metals in the groundwater, u.s. EPA and WDNR still
believe that, based on groundwater data, these and other metals
not affected by the oxidation/reduction chemistry, as well as the
semi-volatile chlorinated benzene compounds, are migrating from
the waste at the site.
other attenuating mechanisms identified in the RI Report
were adsorption of organic and inorganic contaminants to sludge
and fly ash: physical encapsulation of liquid and volatile
contaminants by dried paint sludges, which would reduce the
interaction of waste contaminants with percolating water: and
biochemical degradation of organic contaminants in the waste,
evidenced by possible reducing conditions in one monitoring well
(MW03A) and observations of septic odors from the waste material
during soil borings. All of these mechanisms may be contributing
to some undetermined extent to limit the migration of organics
and inorganics found at elevated levels in the waste. However,
the extent of these mechanisms in the waste and the permanence of
these conditions is not certain.
6.0
SUMMARY OF SITE RISKS
In accordance with the Administrative Order by Consent, the
PRPs prepared the baseline risk assessment during the RI/FS.
This assessment, called an Endangerment Assessment in the RI
Report (chapter 8), followed the guidance provided in u.s. EPA's
superfund Public Health Evaluation Manual. U.S. EPA has since
issued a new risk assessment guidance document called Risk
Assessment Guidance for Superfund: Volume I, Human Health
Evaluation Manual. This more recent guidance was not used.
In order to calculate actual and potential risks to human
health and the environment posed by the Wheeler pit site,
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indicator chemicals were selected to represent the contamination
at the site. This list of indicator parameters is only a subset
of the constituents of concern identified du~ing the RI. The.
indicator chemicals which were identified for each medium, with
the maximum concentration at which they were found, are listed
below:
Surface Soil
Cadmium - 1.0 mg/kg
Butylbenzyl phthalate (BBP) - 7,200 ug/kg
'Bis(2-ethylhexyl)phthalate (BEHP) - 160 ug/kg
Waste/Subwaste Soils
Lead - 3130 mg/kg
Cadmium - 20.2 mg/kg
Naphthalene - 110,000 ug/kg
BBP - 630,000 ug/kg
BEHP - 47,000 ug/kg
Ethylbenzene - 53,000 ug/kg
Xylenes - 370,000 ug/kg
Groundwater .
BEHP - 3.0 ug/L
1,4-Dichlorobenzene - 25
Ethylbenzene - 0.8 ug/L
Xylenes - 6.0 ug/L
ug/L.
After evaluating potential current and future exposure
pathways at the site, three exposure scenarios were chosen to
represent possible risks posed by the site. One considers
current site conditions, and two assume hypothetical future site
conditions. These exposure scenarios are:
1.
Trespasser Scenario: A trespasser would be exposed to
contaminated surface soils currently on site via
ingestion and dermal absorption. This scenario assumed
that a child would trespass twice a week, eight
months/year, for 10 years.
2.
Groundwater Scenario: Future site
contaminated water from a private
assumed that a person would drink
for a lifetime of 70 years.
occupants would drink
well. This scenario
2L of water every day
Construction Worker Scenario: Future construction
workers would build on the site and would be exposed
directly to waste via ingestion, dermal absorption, and
inhalation of fugitive dust and VOCs. This scenario
assumed that a worker would be exposed eight hours/day,
seven days/week, for six months.
Using these scenarios, risk numbers are calculated for each
contaminant. These calculations factor in the amount of exposure
assumed, the dose of the chemical received (based on the
concentrations found during the RI), and a constant set for each
individual chemical which quantifies the toxicity of that
chemical. Different constants and equations are used based on
whether or not the chemical is carcinogenic. The constant for a
3.
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carcinogenic chemical is called a slope factor, and the constant
for a noncarcinogen is called a reference dose.
The results of these calculations are a cancer risk number
for carcinogenic risks and a Hazard Index number for
noncarcinogenic risks. The cancer risk number is expressed in
scientific notation and represents a probability of getting
cancer. For example, 1.OE-06 represents a risk of one additional
case of cancer per 1 million people, under the exposure'
conditions assumed. U.S. EPA considers this 1.OE-06 number as a
point of departure when determining risk at a site. Risks
calculated to be less than this value are considered protective
of human health and the environment, while risks. between 1.OE-04
and 1.0E-06 are within a range acceptable to U.S. EPA but may not
be considered protective due to site-specific conditions. Risks.
greater than 1.OE-04 are unacceptable.
The Hazard Index (HI) number generated is interpreted.
differently than the cancer risk number. To evaluate risk at a
site due to noncarcinogenic contaminants, U.S. EPA has determined
that a Hazard Index less than 1 is protective, while a Hazard
Index greater than 1 is not protective of human health and the
environment.
Table 1 summarizes the cancer risk numbers and Table 2
summarizes the hazard index values calculated for each chemical
under each scenario and exposure pathway. The numbers listed in
these tables represent the maximum exposure conditions by using
the greatest concentration of a chemical found in each media.
The cumulative risk for each scenario is included beneath each
table.
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TABLE 1
MAXIMUM CALCULATED CANCER RISKS
.,
.D. CHEM TRESPASS TRESPASS GRNDWTR WORKER WORKER WORKER WORKER
INGEST DERMAL INGEST INGEST DERMAL DUST VOCS
.. HP I 3.7E-10 1 1.9E-10 I 1. 3E-06 I 6.7E-09 1 1.lE-08 I 1.SE-09 I NA I
4Dichlorl NA I NA I 1.9E-OS I NA I NA I NA 1 .NA I
dmium NA 1 NA I NA I NA I NA 1 2.8E-07 I NA I
OTALS: S.6E-10 I 2.0E-OS I 3.0E-07 I
TABLE 2
MAXIMUM CALCULATED HAZARD INDEX SCORES
D. CHEM TRESPASS TRESPASS GRNDWTR WORKER WORKER WORKER WORKER
INGEST DERMAL INGEST. INGEST DERMAL DUST VOCS
ad I NA 1 NA I NA I 2.3E-02 I 3.7E-02 I 1.7E-02 1 NA
lenes I NA 1 NA I 9.3E-OS I 1. 9E-06 I 3.1E-OS I 9.8E-06 I 6.8
dmium I 1.7E-04 I 8.4E-OS I NA I 2.0E-04 I 3.4E-04 I 4.6E-OS I NA
HP I 1.4E-06 I 6.8E-07 I 4.7E-03 I 2.4E-05 I 3.9E-05 I 5.5E-05 I NA
p I 6.1E-06 I 3.0E-06 I NA I 3.2E-OS I S.3E-OS I 7.2E-06 I NA
pthalenel NA I NA I NA I 2.8E-06 1 4.6E-06 I 6.4E-07.1 NA
hylbenz I NA 1 NA I 2.SE-04 I S.4E-06 I 8.8E-OS I 1.2E-06 I 1.5
JTALS: I 2.7E-04 I 5.0E-03 I 8.4
- The totals at the bottom of each table represent the total risk for each
~nario considered. This risk is the sum of all the individual chemical's r:SK
r all pathways of exposure (i.e. ingestion, dermal, etc.) under each scendr
1sidered.
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In summary, the risk assessment highlights two. potential future
risks at the site (refer to Tables 1 and 2):
1.
a possible carcinogenic risk of 2.0E-OS for groundwater
if a well is placed on site: and
a potential noncarcinogenic risk for a construction
worker who inhales VOCs while digging in the waste.
(Average HI = 1.1, Maximum HI = 8.J)
2.
In addition, if no action is taken at the site, there is the
potential for erosion to continue to degrade the present cover
and eventually expose more of the waste. If this occurs, a
trespasser at the site under these conditions might encounter a
. risk similar to that posed to.a construction worker.
6.1 UNCERTAINTIES
In addition to the chemicals considered in the endangerment
assessment, there are several other contaminants present in the
waste and groundwater which were not included as indicator
chemicals. These were either screened out when the indicator
chemicals were selected or did not have known slope factors or
reference doses. The most notable of these omissions is arsenic
in the groundwater. Arsenic was detected in one downgradient
well in both phases of groundwater sampling at levels of 29. ug/L
and J2 ug/L. When U.S. EPA calculated the risk for this
contaminant using the assumptions made in the endangerment
assessment, the carcinogenic risk is 1.9E-OJ. According to the
current well placement and sampling data, this risk would be
present only if a well were placed on site or in very close
proximity to the site, or if groundwater contaminated at these
levels migrated from the site to an off-site water supply well.
6.2 ENVIRONMENTAL RISKS
No critical habitats or endangered species are affected by
contamination at 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.
7.0
DESCRIPTION OF ALTERNATIVES
In September 1989, it was decided to streamline the
remainder of the RI/FS based on the straightforward nature of the
site. The number of alternatives considered for this site was
reduced very early in the FS process, and all groundwater
alternatives were eliminated from the list, based on the levels
of contaminants detected in the groundwater and the limited
extent of contamination. The four remaining alternatives
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1.5
evaluated in the FS Report are source control actions which rely
on natural attenuation to remedy the groundwater. Source control
will address the area of contamination (AOC), which is defined by
the aSh/waste boundary as denoted in Figure 2~. The remediation
goals are to reduce the threat of direct contact with the waste,
to reduce the infiltration of water into the waste which might
lead to further groundwater contamination, and to achieve PALs
where technically and economically feasible.
The four alternatives are summarized in Table 3 and are
described in greater detail in the text which follows. The major
applicable or relevant and appropriate requirements (ARARs) which
were identified for these alternatives will be discussed in
section 8.0 - Comparative Analysis of Alternatives, under
ComDliance with ARARs. -
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TABLE 3
SUMMARY OF ALTERNATIVES AND COSTS
ALTERNATIVE
ALTERNATIVE 1:
NO ACTION
ALTERNATIVE 2:
COVER REPAIR AND ACCESS
RESTRICTIONS
-Repair present soil.
cover in needed areas
-Fence site.
-Institutional controls
-Groundwater and cover
monitoring
ALTERNATIVE 3:
ENHANCED CAPPING
-Consolidate waste
into original
disposal area
-Install one of
three cap systems
proposed
-Fence site
-Institutional controls
-Groundwater and. cap
monitoring
CAPITAL
$0
$42,000
Cap A
$522,500
Cap B
$829,600
Cap C
$1,226,500
COST
*O&M PRESENT NET WORTH**
$0
$137,000
per year
$137,300
per year
"
"
ALTERNATIVE 4:
TREATMENT BY FIXATION
-In-situ fixation
OR
-Excavation and
fixation
Annually:
. 1st 5 yrs
$11,563,900 $137,000
OR 2nd 5 yrs
$12,223,600 $73,800
last 20 yrs
$42,100
-Cap treated waste
-Institutional controls
-Groundwater and cap
monitoring
* - These Operation and Maintenance (O&M) costs are
conservative groundwater monitoring program. .
** - Present net worth cost is calculated over a 30
at a 5% discount rate.
$0
.$2,084,000
Cap A
$2,633,000
Cap B
$2,940,000
Cap C
$3,337,000
$12,731,000
OR
$13,391,000
based on a
year period
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Alternative 1:
No Action
u.s. EPA is required to evaluate a no-action alternative at
every Superfund site. It is used as a basis of comparison during
the evaluation of other a1.ternatives. Under this alternative,
u.s. EPA would take no further action at the site to monitor,
control, treat, or otherwise cleanup contamination. The cost of
this alternative is zero. However, since waste is being left on
site, a five-year review of conditions at the site would be
required. .
This alternative will not reduce the threat of direct
contact with the waste and will not reduce the permeability of
the present cover.
Alternative 2:
Cover Repair and Access Restrictions
Under this alternative, the existing cover would be repaired
in select areas in accordance with the closure requirements
provided in 1974 in a letter to GM from WDNR. These requirements
stated that at a minimum, "adequate earthen cover materials and
subsequent planting of the area" be accomplished in the closing
of the site. As part of Alternative 2, a cap analysis would be
performed during the remedial design/remedial action phase to
determine where cover repair is required. Cover repair would
then take place in areas where wastes are at or near the surface
to provide a uniform cover, promote runoff and promote
vegetation. Existing trees, which are rooted in the waste, would
not be removed. The objective would be to achieve a permeability
of the repaired cover in the range of 1E-04 em/see to 1E-05
em/sec.
other components of this alternative are installation of a
fence around the site, institutional controls, and a program to
monitor groundwater and the cover. The waste which is on Frank
Brothers property would be consolidated into the original
disposal area prior to cover repair, or the fence would be
installed on Frank Brothers property. If the waste were removed
from Frank Brothers property, sampling would be done to assure
that no waste remained.
This alternative would require careful maintenance to ensure
that the cover remains intact. This remedy would not
significantly reduce the rate of water infiltration into the
waste.
Time to Implement:
several months
Estimated Cost:
Capital: $44,000
O&M: $132,700 per
Present Net Worth:
year
$2,084,000
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Alternative 3:
18
.
Enhanced Cappinq
Under this alternative, one of three cap systems would be
installed over the waste at the site. Descriptions of the three
caps are provided below:
Cap A:
Cap B:
Cap C:
This cap would consist of 2 feet of compacted clay
and 6 inches of topsoil, as required by NR
181.44(12), wisconsin Administrative Code (WAC).
This cap is used for Resource Conservation.
Recovery Act (RCRA) facilities that have interim
status.
This cap is a. solid waste cap which would meet
RCRASubtitle D closure requirements. Solid waste
landfill closure requirements are more
specifically defined in wisconsin in NR 504.07
WAC. The components of an NR 504 cap, from bottom
to top, are 2 feet of clay, a layer of soil 1.5-
2.5 feet thick, and 6 inches of topsoil.
This cap is a hazardous waste cap which would meet
RCRA landfill closure regulations and RCRA
guidance for design of subtitle C closure. This
~ap is similar to a NR 181.44 (13) cap. The cap
would consist of, from bottom to top, 2 feet of
compacted clay, an impermeable synthetic
membrane, a 1 foot drainage layer, and 2 feet of
vegetated cover.
All three caps would provide a barrier between the .ground
surface and the waste to prevent direct contact. Each cap also
requires a hydraulic conductivity in the low permeability layer
of not more than lE-07, which would limit water infiltration.
Cap A, however, does not have a sufficient soil cover to protect
the low permeability clay layer from freeze/thaw damage, and does
not meet the requirements for closure of a solid waste facility
in wisconsin. Cap A will therefore not be considered further in
the comparative analysis section. Cap B does meet the
requirements for closure for a solid waste landfill under NR
504.07, WAC. While both solid and hazardous waste regulations
are potential ARARs, it was determined that an NR 504.07 cap
provides adequate protection at this site. Subtitle C landfill
requirements, while relevant were determined not to be
appropriate, based on site-specific circumstances. This
determination was made based on the hazardous properties of the
waste, its composition and matrix, and the nature of the release
from the site.
First, according to available records, no RCRA listed
hazardous waste was disposed of at the site. In addition, baseJ
on an analysis of the waste, the levels of hazardous constituer.~';
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19
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in the waste are not at levels that would be expected to be
characteristic for any of the newly identified organic Toxicity
Characteristic constituents or for metals. .
Second, there is some evidence that the dried paint sludges
and fly ash have acted to attenuate organic and inorganic
contaminants, to a degree which has yet to be determined which
limits migration from the waste matrix.
Finally, groundwater contamination appears to be limited to
a degree because of the attenuation mechanisms referred to above.
For these reasons, it is determined that a Subtitle C cap is not
appropriate in light of the circumstances of the site.
Therefore, only Cap B will be carried forward to the comparative
analysis section, and this alternative will be referred to as
Alternative 3B.
other components of this alternative are installation of a
fence around the site, institutional controls, and a program to
monitor groundwater and the cap. The waste which is on Frank
Brothers property would be consolidated into the original
disposal area prior to capping, in order to minimize the area to
be capped. To implement this alternative, trees on site would
have to be removed, either by pulling them up by the roots or by
cutting them off at grade. If the latter is done, a gas venting
system would have to be installed as part of the cap to release
gas generated as the tree roots decompose.
Time to Implement:
Six months
Estimated Cost: (for Cap B only) (does not include gas
Capital: $829,600 venting system cost)
O&M: $137,300 per year
Present Net Worth: $2,940,000
Alternative 4:
Treatment bv Fixation
Waste materials at the site would be uniformly fixated by
controlled mixing of the waste with additives such as portland
ceme~t, lime, gypsum, fly ash or other solidification agents.
The waste, surface soil and subwaste soil (approximately 91,900
cu. yds.) would be either treated in-situ or excavated and then
treated. This fixation process would convert the contaminated
soil and waste into a solidified mass with the consistency of
cement. The contaminants would be immobilized and would be
protected from interaction with infiltrating water, thereby
reducing their ability to leach into the groundwater. After
treatment, the solidified waste would be covered with a solid
waste cap, as required in NR 504.07, WAC.
other components of this alternative are institutional
controls to limit future site use and a program to monitor
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groundwater and the cap. The waste which is on Frank Brothers
property would be consolidated into the original disposal area
prior to in-situ treatment, and would be excavated and added. to
the rest of the waste for the excavation and treatment option.
To implement this alternative, trees and roots on site would be
removed prior to the treatment process. .
This alternative will prevent direct contact with the waste,
limit the mobility of the contaminants, and effectively reduce
infiltration of water into the waste and the potential for 'water
to come into contact with the contaminants. .
Time to Implement:
one year
Estimated Cost: .
Capital:
O&M: (annually)
0-5 yrs -
5-10 yrs -
10-30 yrs -
Present Net Worth:
In-situ Excavate.
$11,563,900 $12,223,600
$137,000:
$ 73,800;
$ 42,100
$12,731,000 $13,391,000
8.0
COMPARATIVE ANALYSIS OF ALTERNATIVES: THE NINE CRITERIA
In accordance with the NCP, the relative performance of each
alternative is evaluated using the nine criteria [Section
300.430(e) (9) (iii)] as a basis for comparison. An alternative
providing the "best balance" of tradeoffs with respect to the
nine criteria is determined from this evaluation.
A.
Threshold criteria
1.
Overall Protection of Human Health and the Environment
This criterion addresses whether a remedy provides
adequate protection and describes how risks posed through
each pathway are eliminated, reduced or controlled through
treatment, engineering controls, or institutional controls.
Alternatives 3B and 4 would provide adequate protection
of human health over time. Alternative 1 would not be
protective of human health and the environment in that it
does nothing to reduce current and future exposure to site
contaminants. Alternative 2 would reduce potential contact
with contaminants in the waste, but the vegetated soil cover
directly above the waste would remain less than 1 foot thick
and would be subject to freezing and thawing cycles which
would likely lessen the integrity of the cover. Fencing and
other institutional controls, which are implemented in
conjunction with the cover repair, are not as reliable as
the containment and treatment options offered in
Alternatives 3B and 4. Given these uncertainties,
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'1
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Alternative 2 may not adequately maintain protection over
time. Alternatives 3B and 4, while possibly exposing some
of the waste during implementation of the remedy, would.
ultimately provide a 4-5 foot clay and soil layer above the
waste material.
2.
Alternatives 3B and 4 also provide protection against
water infiltration, which would reduce the potential for
release of contaminants to the groundwater. Alternative 4
would immobilize contaminants and eliminate the potential
of or a future release of contaminants to the groundwater.
Present groundwater contamination should decrease over time.
While all alternatives would leave wastes remaining at the
site, Alternative 3B (capping) and Alternative 4 (fixation)
would reduce the short and long-term risks at the site by ,
utilizing standard engineering or treatment methods.
Compliance with Applicable or Relevant and Appropriate
Reauirements (ARARs)
This criterion evaluates whether an alternative meets
applicable or relevant and appropriate requirements set
forth in Federal, or more stringent state, environmental
laws pertaining to the site or proposed actions.
Since Alternatives 2, 3 and 4 are similar in that they
are source control remedies and address the same problem at
the site, the same ARARs apply to each and will be
identified and discussed below.
i.
Identification of ARARs
a.
Closure
There are no Federal or State closure requirements for
solid waste or hazardous waste landfills which are'
applicable to this site, because the site was originally
closed prior to the effective date of these regulations.
The existing landfill cover does not meet section NR 504.07,
WAC, the current State landfill closure requirements, which
are similar to the proposed federal Subtitle D regulations.
Chapter NR 504, WAC, is applicable to the closure of
(currently) permitted solid waste landfills in the State.
Since the Wheeler Pit site is sufficiently similar to a
solid waste landfill, Ch. NR 504, WAC, requirements are
relevant to the Wheeler Pit site. Chapter NRS04, WAC,
requirements are well-suited for the Wheeler Pit site due to
the reduction of infiltration by the clay layer and the
long-term effectiveness offered by the frost protection
layer. Thus, Ch. NR 504, WAC, the current solid waste
landfill closure requirements, are also appropriate for this
site. In part, section NR 504.07, WAC, requires that the
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22
cap be composed of a 2-foot layer of compacted clay overlain
by a frost-protective soil layer. The repaired cover
proposed in Alternative 2 would, at most, consist of 8
inches of soil over the waste and would not comply with this
ARAR. Alternative 3, Cap B and the cap placed after the
treatment process in Alternative 4 would both meet the
requirements of section NR 504.07, WAC.
The state of wisconsin is authorized to implement
portions of the RCRA subtitle C program. As stated in the
-description of Alternative 3 in section 7.0 above, RCRA
Subtitle C is considered a relevant but not appropriate
requirement at this site.
..
b.
Groundwater Standards
1.
Federal ARARs
Maximum contaminant Levels (MCLs), and to a certain
extent, Maximum Contaminant Level Goals (MCLGS), the Federal
drinking water standards promulgated under the Safe Drinking
Water Act (SDWA), are applicable to municipal water supplies
servicing 25 or more people. At the Wheeler pit site, MCLs
and MCLGs are not applicable, but are relevant and
appropriate, since the sand and gravel aquifer is a Class
IIA aquifer which is presently being used in the area
surrounding the site and which could potentially be used for
drinking in the area of concern. MCLGs are relevant and
appropriate when the standard is set at a level greater than
zero (for non-carcinogens), otherwise, MCLs are relevant and
appropriate at Superfund sites. The point of compliance for
MCLs and MCLGs is at the boundary of the landfilled wastes
or throughout the plume if wastes are removed from the site.
2.
State ARARs
The State of Wisconsin has promulgated groundwater
quality standards in Ch. NR 140, WAC, which the WDNR states
is being consistently applied to all facilities, practices,
and activities which are regulated by the WDNR and which may
affect groundwater quality in the State. Chapter 160, wis.
Stats., directs the WDNR to take action to prevent the
continuing release of contaminants at levels exceeding
standards at the points of standards application. Chapter
160 deals with all groundwater, not just drinking water or
potable aquifers. The groundwater quality standards
established are Preventive Action Limits (PALs) and
Enforcement Standards (ESs), which are described in detail
in section 5.0 of this document. The chemicals at the site
which exceed these standards are also discussed in section
5.0. (Wisconsin) Alternative Concentration Limits (WACLs)
may also be established pursuant to Ch. NR 140, WAC. These
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23
..
state standards are generally more stringent than
corresponding Federal standards set forth under the Safe
Drinking Water Act (SDWA) and are relevant and appropriate
for the Wheeler Pit site, since they address overall
groundwater quality rather than just drinking water quality.
Consistent with the exemption criteria of section NR
140.28, WAC, a WACL may be established as the clean-up
standard if it is determined that it is not technically and
economically feasible to achieve the PAL for a specific
'substance. Except where the background concentration of a
compound has been determined to exceed the ES set forth in
NR 140, WAC, the WACL that ~s established under 140.28(4) (b)
may not exceed the ES for that compound. A determination .of
. technical or economic infeasibility may be made after five
years if it becomes apparent that the contaminant level has
ceased to decline over time and is remaining constant at a
statistically significant level above the PAL (or any WACL
established due to high background concentrations) in a
discrete portion of the area of attainment, as verified by
multiple monitor wells.
The State, in Ch. 140, WAC, has set forth lists of
potential responses to be taken when either a PAL or ES is
exceeded. No active groundwater remediation is presently
proposed, with the intention that source control and natural
attenuation of the groundwater is a sufficient response at
this time. This is based on the chemicals and levels of
these chemicals found at the site during the RI. As both
Alternatives 3B and 4 qualify as potential responses
according to the list provided in Table 6 of Ch. 140, WAC,
"Range of Responses for Exceedance of Enforcement Standards
for Substances of Health or Welfare Concern", the State
concurs with the remedy selected in this document.
c.
Land Disposal Restrictions
Another set of RCRA regulations which may be an ARAR at
the site are Land Disposal Restrictions (LDR), 40 CFR Part
268. Waste would be potentially moved at the site in
Alternatives 2 and 3B during consolidation of the waste from
Frank Brothers property into the original disposal area, or
in Alternative 4 during excavation, treatment and
redisposal. What will trigger LDRs is whether this movement
constitutes placement of RCRA hazardous waste. For
Alternatives 2 and 3B, the consolidation of the waste is
taking place within the Area of Contamination (AOC). In
this instance, the LDR requirements are not applicable or
relevant and appropriate at the site. Alternative 4, under
the excavation and treatment option, may trigger LDR
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24
..
requirements~ Whether LDRs are applicable to this
alternative depends on if it is determined that RCRA
characteristic hazardous wastes are present, since listed
wastes were not disposed at the site. Based on this
existing information, LDRs are not applicable or relevant
and appropriate.
'u
ii. Discussion
As discussed earlier, solid waste closure standards are
~elevant and appropriate requirements for this site. The
landfill covers in Alternatives 1 and 2 do not meet current
wisconsin requirements for solid or hazardous waste landfill
closures. .
Although no groundwater treatment actions are being
proposed, it is estimated that groundwater contaminant
levels will decrease to levels that comply with wisconsin.
groundwater standards by reducing the infiltration of water
into the waste. Under Alternative 1, water would continue
to infiltrate at its present rate, with only a slight
decrease under Alternative 2. Alternative 3B would
significantly reduce infiltration. Alternative 4 would be
of similar effectiveness to Alternative 3B while also
greatly reducing the potential for any infiltrating water to
come in contact with contaminants.
The cap in Alternatives 3B and 4 will also help
minimize any future risks from the site. The cap, if
maintained, would prevent future direct contact with
contaminants and reduce infiltration which will minimize, to
the extent practicable, any future releases into the
groundwater from the site. It is expected that this will
result in future compliance with wisconsin statutes which
require that future releases of contaminants should not
exceed state groundwater quality standards.
B.
primarv Balancina criteria
3.
Lona-Term Effectiveness/Permanence
This criterion delineates the residual risk and
evaluates the ability of an alternative to maintain reliable
protection of human health and the environment over time,
once cleanup objectives have been met.
Under Alternative 1 (no action), protection from direct
exposure would not be achieved and water infiltration would
not be reduced. Alternative 1 would not maintain protection
over time due to freezing and thawing cycles and erosion
which would likely damage the present cover. Alternative 2
would be more effective in limiting direct contact than
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25
..
Alternative 1, but the cover would still be exposed to the
same weathering conditions as Alternative 1 and would need
to be continually repaired to maintain effectiveness.
Alternatives 3B and 4 will provide adequate protection
assuming the cap is maintained. . This is because
Alternatives 3B and 4 remove the direct contact threat and
reduce water infiltration into the disposal area.
Alternative 3B and 4 would also be affected by weathering
conditions, but the low permeability clay layer in these
alternatives would be protected by 2 to 3 feet of soil;
'which will minimize the impact of the freeze and thaw
cycles. The clay cap in Alternatives 3B and 4 may also be
affected by desiccation and cracking and by.subsidence of
the waste materials. Under these alternatives, the cap would
be monitored for continued effectiveness and would be
repaired as necessary.
4.
Reduction of Toxicitv. Mobilitv or Volume Throuqh Treatment
This criteria evaluates the anticipated performance of
the treatment technologies a remedy may employ.
Alternatives 1, 2, and 3B would not reduce the
toxicity, mobility, or volume of contaminants through
treatment. These alternatives do not meet the statutory
preference for treatment. Alternative 4 would reduce the
mobility of contaminants through fixation, but the toxicity
would not be reduced, and the volume of waste materials
would increase.
5.
Short-term Effectiveness
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.
Alternatives 2, 3B and 4 would involve moving a small
amount of waste at the site. Minimal risks to nearby
residents posed by dust from digging during the
implementation of Alternatives 2, 3B and 4 would be
controlled through standard dust control measures and health
risks to workers would be minimized with protective
equipment. There will be a fence around the site during
construction activities which will protect nearby residents.
This fence will remain after construction activities are
completed. In implementing Alternatives 3B and 4, the trees
on site would be removed in a way to minimize disturbance of
the waste materials. While it is recognized that placing a
cap on a site may initially disturb the waste, all standard
methods for minimizing such an impact will be employed. If
necessary, special equipment, engineering controls and
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6.
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26
design techniques can be utilized. Alternative 4 would
require 1 year to complete and Alternatives 2 and 3B could
be completed in approximately 6 months.. .
. It is unknown how long before groundwater standards
will be met in the aquifer. Groundwater quality will be
evaluated during the monitoring program to determine if it
is improving or remaining the same. The monitoring program
is expected to continue for at least 30 years. .
Implementabilitv
This criterion considers the technical. and
administrative feasibility of implementing an alternative,
including the availability of material and services needed.
to implement a particular option.
Alternatives 2, 3B and 4 are technically feasible,
although Alternative 4 might be slightly more difficult to
implement because the waste will be handled during the
treatment process. According to the RI, the waste contains
refuse such as steel-reinforced concrete and aluminum window
frames which probably would have to be separated out prior
to fixation. For Alternatives 2, 3B and 4, there might be
some administrative difficulties in receiving permission to
access adjoining property, since some waste currently exists
on neighboring property. For Alternative 4, the excavation
and fixation option may be subject to Land Disposal
Restrictions.
All pathways of risk will receive adequate monitoring
through the groundwater and cap monitoring programs. If
monitoring is not sufficient to detect failure of the remedy
and increased groundwater contamination, nearby downgradient
homes with private wells would potentially be affected. To
address this possibility, private wells downgradient will be
monitored to detect changes in groundwater quality. If
additional remedial action becomes necessary at the site,
this will be fairly easy to undertake under any of the
alternatives presented here.
7.
Cost
Costs include the estimated capital and operation and
maintenance (0 & M) costs, as well as present-worth costs.
These costs for each alternative are presented in Table 3.
C.
Modifvina criteria
8.
state Acceptance
u.s. EPA and WDNR agree on the selected alternative.
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9.0
27
9.
Communitv AcceDtance
Community acceptance is assessed in' the attached
Responsiveness Summary. The Responsiveness Summary provides
a thorough review of the public comments received on the
Proposed Plan, and the Agency's responses to those comments.
THE SELECTED REMEDY
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28
Based upon consideration of the requirements of CERCLA, as
amended by SARA, and the NCP, the detailed analysis of
alternatives and public comments, u.S. EPA and WDNR have selected
Alternative 3B -- the NR 504.07, WAC, multi-layer cap;
consolidation of waste; institutional controls and groundwater
monitoring -- as the cost-effective protective remedial action
.for the Wheeler pit site.
!
~
Under Alternative 3B, the cap will be placed on the site in
compliance with the current requirements of section NR 504.07,
WAC for closure of solid waste facilities. The cap will consist
of a grading layer, a minimum 2-foot clay layer (compacted to a
permeability of 1E-07 cmjs or less), a frost protective soil
layer at least 1.5 feet thick, and a minimum 6-inch topsoil
layer. The thickness of the soil layer will depend on the frost
penetration depth at the site. A drainage layer will also be
included as part of the cap on top of the clay layer to enhance
drainage off the clay layer. The waste and soil (approximately
400 cu yd) which is presently on the property north of the site
will be consolidated under the cap. Testing will be conducted to
assure all waste is contained under the cap and to verify that
all waste has been removed from Frank Brothers' property.
Institutional controls will be relied upon to enhance the
effectiveness of the remedy, including deed restrictions and
landfill development restrictions (NR 506). A cyclone fence will
also be installed around the site. State restrictions on the
installation of drinking water supply wells within 1200 feet of a
landfill (restrictions found in Ch. 112, WAC) cannot be relied
upon to limit off-site groundwater use over the long-term, since
variances provided for in section NR 112.04, WAC, may be. granted
in the future. Additional groundwater monitor wells will be
installed to more fully characterize the groundwater system. New
and existing wells will be monitored for at least 30 years.
Private wells located down-gradient of the site will also be
monitored to assess potential impacts to human health and the
environment. .
The risk due to direct contact with the waste will be
reduced immediately after cap construction is completed. It is
projected that the contamination presently in the groundwater
will begin to decrease over time once the cap is in place.
However, groundwater quality will be evaluated during the
monitoring program to determine if it is improving or remaining
the same. The goal of the source control action will be to
attain the groundwater clean-up standards at the waste boundary
of Wheeler Pit, which is the suggested NCP point of compliance
for groundwater. The clean-up goals which have been established
are PALs.
The initial review of the groundwater monitoring data will
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TABLE 4-
COST SUrflARY
ALTERNATIVE 3 - ENHANCED CAPPING
WHEELER PIT SITE
/,
:APITAL COSTS CAP A CAP B CAP C
.- ..----
INSTITUTIONAL CONTROLS S10,000 SIO, 000 S10,000
- CHA INtI Nt( ftNC I NG ;,lGA TES' . _19.1 100 19 , 100_. 19,1 OQ--'-k'-
- - -'
CAPPING - - -'
CAP A -NR 181.44(12) $331,200
CAP B - NR 504.07 * 543,100
CAP C - NR 181.44(13) 816,700
CAPITAL COST SUBTOTAL S360,300 S572,200 S845,800
ADMINISTRATION, LICENSING (5%) 18,000 28,600 $ 42,300
ENGINEERING (20%) 72 , 100 114,400 $169.200
CONTINGENCY (20%) 72,100 114,400 $169,200
TOTAL CAPITAL COSTS $522,500 $829,600 $1,226,500
PERATION AND MAINTENANCE COSTS (ANNUAL)
CAP MAINTENANCE $ 4.700
MONITORING - CAP 4,300
MONITORING - GROUNDWATER -' - ~.-"..=-dlG,400.-_,
- - - -'.-.,. -. -'-'-- '- - 0- - - .,-... ...- ,..'..-- - . -~.
ANNUAL OPERATION AND MAINTENANCE $119,400
COST SUBTOTAL
CONTINGENCY (15%)
. -.--
.--' -- $"11,'900 '
$137,300
ANNUAL OPERATION AND MAINTENANCE
COST TOTAL .
}-YEAR PRESENT NET WORTH
(5% Discount Rate)
$2.633.000
$ 4,700 S 4,700 .
4,300 4,300" .
'. :- lJD......40&-.:--- ",-:- --'1-10-; 400:: .~:~::..~
$119,400
$119,400
- . ...~ -- ..-- .' - ...
-.-.- - --. --.'.
$ 17,900
S 13 7,300
S 17,900
S 13 7,300
$2.940.000
$3,337,000
"*. CasT does not i nclu.d~
. d(ai t'1~e \~er
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30
..
be conducted within 5 years after the commencement of.remedial
action. Thereafter, the monitoring data will be reviewed at no
longer than 5-year intervals. In the event .that conditions at
the site degrade, or the remedy does not provide for timely
improvement of groundwater, the EPAand WDNR will consider
additional actions, as appropriate, to achieve protection at the
site.
Table 4 presents the details of the cost.
10.0
STATUTORY DETERMINATIONS
The selected remedy must satisfy the requirements of Sect~on
121 (a-e) of CERCLA, as amended by SARA, to:
,
a.
b.
c.
d.
e.
Protect human health and the environment;
Comply with ARARs;
Be cost-effective;
utilize permanent solutions and alternative treatment
technologies to the maximum extent practicable; and,
Satisfy the preference for treatment as a principal
element or provide an explanation as to why this
preference is not satisfied.
The implementation of Alternative 3B at the Wheeler pit site
satisfies the requirements of CERCLA, as amended by SARA, as
detailed below:
a.
Protection of Human Health and the Environment
This selected remedy provides adequate protection of
human health and the environment.
Implementation of the selected alternative will reduce
and control potential risks to.human health and the
environment posed by exposure to site contaminants and will
reduce the site as a source of groundwater contamination.
Since groundwater contaminant loading will be reduced due to
decreased in~iltration of water through the cap,
groundwater quality is expected to improve over time.
No unacceptable short-term risks will be caused by the
implementation of the remedy. The community and site
workers may be exposed to dust and noise nuisances during
construction of the cap. Standard safety programs, such as
fencing, use of protective equipment, monitoring and dust
control measures,' should mitigate any short-term risks.
Standard methods for minimum disturbance of the waste and
for prevention of infiltration, such as placing a tarp over
exposed areas, will also be employed.
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b.
ComDliance with ARARs
The selected remedy will comply wi~h all. Federal and/or
state, where more stringent, ARARs. The following ARARs
will be attained.
1.
Chemical-sDecific ARARs
Chemical-specific ARARs regulate the release to the
environment of specific substances having certain chemic~l
'characteristics.
Applicable or Relevant and ~ppropriate Requirements
- Ch. NR 140, WAC, and Ch. 160, Wisconsin statutes.
PALs will be established as the remediation goals.
- SDWA MCLs and MCLGs
RTo Be ConsideredR Criteria
Occasionally, advisories that do not meet the
definition of ARAR may be necessary to determine what is
protective at a site. Although the new chemical specific
clean-up standards for 1,4-dichlorobenzene, which were
mentioned in Section 5.0 o.f this document, have not been
promulgated yet, it is a "To Be Considered" criteria which
is presently exceeded at the site.
2.
Location-sDecific ARARs
Location-specific ARARs are those requirements that
relate to the geographical position of a site.
Applicable Requirements
- NR 112, WAC. Requires that no drinking water wells
be located within 1200 feet of a landfill, unless a variance
is obtained from the WDNR.
- NR 506 and NR 540, WAC.
landfills.
Regulates the development of
3.
Action-sDecific ARARs
. Action-specific ARARs are requirements that define
acceptable treatment and disposal procedures for hazardous
substances.
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32
Applicable Requirements
There were no applicable action-specific requirements.
Relevant and Appropriate Requirements
<:>
- NR 504.07, WAC.
landfill cap.
- Additional state action-specific ARARs can be found
..in the FS Report.
Regulates design of solid waste
c.
Cost-effectiveness
A cost-effective remedy is one for which the cost is .
proportional to the remedy's overall effectiveness. Table 3
lists the costs associated with the implementation of the
remedies.
d.
Alternative 3B affords a high degree of effectiveness
by providing protection from exposure to the contaminants in
the waste and minimizing the infiltration of water into the
waste. Treatment of the source (Alternative 4) is greater
than 10 times the cost of a cap and does not provide a
significant benefit proportional to its cost. Although
Alternative 2 is less expensive than Alternative 3B, it is
not protective. Alternative 3A, although less expensive
than Alternative 3B, does not provide for frost protection.
Alternative 3C, which includes a flexible membrane liner, is
not believed to be appropriate for this site. Therefore
Alternative 3B is a cost-effective alternative which-
provides overall effectiveness proportional to its cost.
utilization of Permanent Solutions and Alternative Treatment
Technoloaies or Resource Recoverv Technoloaies to the
Maximum Extent Practicable
u.S. EPA and the State of Wisconsin believe the selected
remedy represents the maximum extent to which permanent
solutions and alternative treatment technologies can be
utilized in a cost-effective manner for the Wheeler pit
site. Of the alternatives that are protective of human.
health and the environment and comply with ARARS, u.S. EPA
and the State have determined that the selected remedy
provides the best balance of tradeoffs in terms of long-term
effectiveness and permanence, reduction of toxicity,
mobility or volume through treatment, short-term
effectiveness, implementability, cost and State and
community acceptance. The selected remedy can be
implemented and completed more quickly with less difficulty
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..
and at less cost than the waste treatment alternative.
cost of the fixation option was an order of magnitude
greater than the cap, with not much increased benefit.
The selected remedy represents the maximum extent to
which permanent solutions and treatment can be practicably
utilized for this action, since the waste poses a low-level,
long-term threat and no "hot spots" were identified. The
level of contamination remaining in the waste on site can be
reliably controlled over time through engineering and, '
institutional controls, and treatment is therefore not
practicable. A cap provides adequate protection from
exposure to waste and acts as a barrier to precipitation
infiltration, assuming the cap is effectively maintained.
The
e.
Preference for Treatment as a PrinciDal Element
The Wheeler Pit site contains waste mixed with fly ash,
and other debris. The landfill does not appear to contain
"hot spots", and no principal threat which warrants
treatment at the site has been identified. Therefore,
satisfaction of the preference for treatment as a principal
element of the remedy is not applicable. In addition, based
on the comparative analysis of alternatives, it has been
determined that treatment does not provide a significant
benefit proportional to its cost.
11.0
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for the Wheeler Pit site was released for'
public comment in July 1990. The Proposed Plan identified
Alternative 3B, a solid waste landfill clay cap with groundwater
monitoring, as the recommended alternative. EPA reviewed all
written and verbal comments submitted during the public comment
period. Upon review of these comments, it was determined that no
significant changes to the remedy, as it was originally
identified in the Proposed Plan, were necessary.
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-
RESPONSIVENESS SUMMARY
This Responsiveness Summary has been prepared to meet the
requirements of Sections 113(k) (2) (B) (iv) and 117(b) of the
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980, as amended by the superfund Amendments and.
Reauthorization Act of 1986 (CERCLA), which requires the united
states Environmental Protection Agency (U.S. EPA) to. respond
n...to each of the significant comments, criticisms, and new data
submitted in written or oral pre~entationsn on a.proposed plan
for remedial action. The Responsiveness summary addresses
concerns expressed by the public and potentially responsible
parties (PRPs) in the written and oral comments received by the
u.s. EPA and the State regarding the proposed remedy for the
Wheeler pit site.
A.
OVERVIEW
I. BACKGROUND/PROPOSED PLAN
The Wheeler pit Superfund site is a 3.8 acre property
located in rural La Prairie Township, Wisconsin,
approximately 1.5 miles east of the City of Janesville.
This site is located in the southeast portion of the
former 34-acre Wheeler Sand and Gravel Pit.
The Remedial Investigation (RI) identified several
concerns at the site: 60,600 cubic yards of waste in
the pit and groundwater contaminated with constituents
in excess of state groundwater standards. The
Feasibility Study evaluated four cleanup alternatives to
address these concerns. The Proposed Plan for remedial
action included:
- consolidation of off-site waste into the original
disposal area:
- installation of a cap to meet current State landfill
closure requirements:
- institutional controls: and
- groundwater monitoring.
II. PUBLIC COMMENT PERIOD
A public comment period was held from July 12, 1990 to
August 24, 1990 to allow interested parties to comment
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2
..
on the Proposed Plan in accordance with Section 117 of
CERCLA. On August 8, 1990, a public meeting was held in
La Prairie Township, Wisconsin, at which the U.S. EPA'and
Wisconsin Department of Natural Resources (WDNR) .
presented the Proposed Plan, answered questions, and
accepted comments from the public. During the public
comment period, U.S. EPA received approximately 29
written and several verbal comments concerning the
proposed plan.
B.
COMMUNITY INVOLVEMENT
Public interest regarding the site has been low. The
community generally seems to favor taking only limited
action at the site and were concerned with the types and
extent of institutional controls which would be placed on
land near the site.
The above concerns will be addressed in the following
section.
C.
SUMMARY OF SIGNIFICANT COMMUNITY COMMENTS
Comment 1
One commentor requested that U.S. EPA sample the groundwater
across Highway O. He further stated that the site should be
"covered on a slant to protect the groundwater."
ResDonse
As part of the Remedial Investigation, one well south of
Highway 0 was monitored. Based on the limited groundwater
contamination identified at the site, it seems unlikely that
significant contamination would be discovered off-site.
However, U.S. EPA agrees that additional samples should be
taken in this location. Therefore, as part of the
groundwater monitoring program described in the preferred
alternative and adopted as the selected remedy in the ROD,
we estimate that three wells south of Highway 0 will be .
sampled. These wells will include well 'B', which was
monitored during the RI, and at least two private wells. We
anticipate monitoring the groundwater for approximately
thirty years.
The commentor also stated that the site should be "covered
on a slant to protect the groundwater", so that groundwater
runs off the site instead of sinking into the soil at the
site. The cap described in the preferred alternative will
do just that. The cap will consist of a grading layer, a
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3
minimum 2-foot clay layer, a frost protective soil layer at
least 1.5 feet thick, and a minimum 6-inch topsoil layer. A
drainage layer may also be included as part of the cap on
top of the clay layer. The specific plan for grading the
. surface of the site will be developed as part of the
remedial design.
Comment 2
Another commentor suggested adding a couple of feet of clay
and grading the surface so that the rain would drain to the
southwest. '
Response
The cap described in the Proposed Plan as the preferred
alternative, and now chosen as the Selected Remedy, will be
designed so that water cannot enter the soil and mix with
the waste at the site. The cap will be basically an
engineered version of the concept described by the
commentor. State regulations require that the cap meet
current solid waste landfill closure requirements. These
regulations call for the landfill cover to be composed of a
grading layer, a minimum 2-foot clay layer with a
permeability of lE-07 em/see, a frost-protective soil layer,
and a minimum 6-inch topsoil layer. Although relying on a
cap made solely out of clay may seem like a simpler and
cheaper approach, the requirements outlined above better
protect human health and the environment by enhancing the
long-term effectiveness of the cap.
Comment 3
Another 'commentor requested that the existing residential
wells be monitored. She also requested information on how
deed restrictions imposed at the site could impact adjoining
properties.
Response
As part of the monitoring program described in the selected
remedy, nearby residential wells will be monitored.
Deed restrictions may be used as part of the institutional
controls that will be used for the remedial action.
possible additional restrictions or limitations could be
instituted by utilizing zoning restrictions, or by
purchasing the land outright. It is likely that any
restrictions will be related to the site itself, and if they
are used they would have a minimal impact on adjoining
landowners. If restrictions need to be placed on adjoining
property owner's land, these property owners will be
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4
!
notified prior to any action.
Comment 4
Another commentor felt that the preferred alternative was
too expensive. She also stated that the agency was moving
too fast, because a remedy had been selected before a
prqblem had even been found.
Response
The Selected Remedy, Alternative 3B, is cost~effective.
affords a high degree of eff~ctiveness by providing
protection from exposure to the contaminants in the waste
and minimizing the infiltration of water into the waste.
detailed discussion of the costs of the various
alternatives may be found in the Record of Decision.
u.S. EPA does not believe that it is too early to select a
remedy and take action at the site. In fact, there are'
several reasons why action must be taken at the site. The
Risk Assessment has identified sufficient hazards to
necessitate an action to protect human health and the
environment. In addition, the u.S. EPA and the State of
Wisconsin have identified Ch. NR 504 WAC as a relevant
requirement for the site. Also, on a practical level, it
makes sense to take action now. By constructing a sound cap
over the site, any future risks to groundwater will be
minimized. It will also be less expensive to respond now,
rather than in the future. Contamination could spread
making cleanup more costly. Also, cleanup costs in general
will likely increase if remediation is required in the
future.
It
A
Comment 5
Another resident inquired as to whether GMC would be liable
for a new well if an existing well became contaminated due
. to the waste disposed of at the Wheeler Pit site, and who
would be liable if a lawsuit was filed in response to use of
the existing well.
Response
The groundwater monitoring program provided for under the
remedial action is intended to address groundwater .
contamination resulting from the site. If it is determined
at a future date, for example during the five year review
provided for under CERCLA, that active groundwater
remediation is required, those parties who can be linked to
the contamination may be required to carry out those
activities. Concerning a potential lawsuit, the lawsuit
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would be between private parties and U.S. EPA would not be
involved. To reiterate, u.s. EPAand WDNR believe that the
groundwater monitoring program to be carried out under the
remedial action, in conjunction with the other aspects of
the action, is protective of human health and the
environment.
D.
SUMMARY OF SIGNIFICANT PRP COMMENTS
The PRPs disagree with the Proposed Plan and its selection
of Alternative 3B. The PRPs believe that conditions at the
site, and the absence of any ~ignificant threat to human
health or the environment," warrant the selection of
Alternative 1, No Action, or at most Alternative 2, Cover"
Repair, for this site. They feel U.S. EPA's proposed remedy
poses a greater potential threat to human health and the
environment than current conditions, because it may disrupt
stable waste and cause the release of contaminants into the
environment. The comments from the PRPs are organized below
based upon issue.
I. SITE HISTORY AND CURRENT CONDITIONS
a. Waste Fixation
Comment 1
Disposal practices at the site resulted in the mixing
of paint booth sludges, fly ash and clarifier sludges
from General Motor's automobile assembly plant. Since
the fly ash, acting as a pozzolanic material, was mixed
with clarifier sludges containing lime all in the
presence of water, the three necessary ingredients for
pozzolanic stabilization / solidification were present
to immobilize chemicals.
ResDonse
U.S. EPA acknowledges that these materials were present
during disposal at the Wheeler pit site. However,
disposal at the site was not an engineered
solidification / stabilization process. The
percentages of each material disposed there is not
known, so the materials may not have been in the proper
proportions to result in an effective treatment
process. In addition, the method of disposal was a
layering process, not a process in which the materials
were mechanically mixed, which is required as part of a
properly implemented solidification / stabilization
technique. Also present in the waste are pieces of
concrete, bricks, aluminum frames, "and other debris
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which lessen the effectiveness and uniformity of any
supposed treatment process. As a result of these
unknowns and deviances, u.s. EPA does not think that'it
can be conclusively stated that all the waste at the
site has been stabilized and that the disposal methods
used at the site have achieved the same degree of
effectiveness that an engineered solidification /
stabilization treatment process can. Therefore, the
chemicals may not be entirely immobile and may still
come in contact with infiltrating water and be carried
into the groundwater.
Comment 2
In addition to the chemical fixation of waste
contaminants, there is evidence of encapsulation of
volatile organic compounds (VOCs). The lack of
significant VOC detects in the subwaste soils or .
groundwater attest to the capacity of the paint "clods"
to prevent the migration of VOCs from the waste.
Response
The sampling method utilized during the RI does not
conclusively prove that all the volatiles in the waste
are contained in the "clods". The RI did not
investigate the ability of the "clods" to contain the
VOCs, nor did it subject any of the waste samples to
the Toxicity Characteristics Leaching Potential (TCLP)
analytical procedure, which is designed to ascertain
this very issue. Thus, contrary to the PRPs'
assertion, there is little hard evidence of
encapsulation of the VOCs. The PRPs have themselves
identified in the FS Report, under the evaluation of
Alternative 4, Treatment by Fixation, that
. stabilization / solidification has not been
demonstrated to adequately address VOCs. Some VOCs
may be available for contact with infiltrating water.
Comment 3
The effectiveness of the fixed waste to reduce
contaminant migration, meets or exceeds the 90% to 99%
reduction guidelines stated in the NCP for treatment
that would be required for a CERCLA remedy.
Response
As stated in the response to comment 2, there is little
evidence that the waste is chemically fixed. In fact
there are contaminants from the waste which indicate
that the mobility of the contaminants remains a
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concern. There is no evidence that the waste has been
treated to reduce the mobility of contaminants by 90-99
percent.
The NCP was clarifying the agency's goal to consider a
wide variety of treatment technologies to address
hazardous substances at Superfund sites, and thus
specified a treatment range that the technology should
be designed to achieve. .
b. Groundwater
Comment 4
No evidence of significant migration could be found in
subwaste soils and groundwater. Chemicals detected in
the waste were either not detected in subwaste soils or
were detected in very low concentrations. The most
plausible explanation for the lack of contaminant
migration is that the waste has stabilized and does not
interact with the percolating water.
ResDonse
As stated in the responses to comments 1, 2 and 3 in
section I(a), u.s. EPA and WDNR do not think that it
can be conclusively stated that all the waste at the
site has been stabilized and that the disposal methods
used at the site have achieved the same degree of
effectiveness that an engineered solidification"/
stabilization treatment process can. In fact, the PRPs
acknowledge that sufficient stabilization /
solidification has not been demonstrated to adequately
address VOCs (see comment 2, section I(a)).
Therefore, the chemicals may not be entirely immobile
and may still come in contact with infiltrating water
and be carried into the groundwater. See also
responses in the following Sections I(c) and IV(a).
c. Reducinq Conditions
Comment 5
The effect of "reducing conditions" on groundwater
chemistry immediately downgradient of the site is to
enhance the solubility of certain multivalent inorganic
parameters (such as iron, arsenic and to some extent
manganese contained in the natural soils). The result
in groundwater samples collected from monitoring well
MW3A is concentrations of iron and arsenic in excess of
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Chapter NR 140, Wisconsin Administrative Code,
Groundwater Standards.
1.
The extent of the downgradient reducing
conditions appears limited.
2.
As background groundwater quality conditions
return downgradient of the Site, the
solubilized metals are reabsorbed and
precipitate out of solution.
The degree of reducing conditions will
diminish wit~ time as organic matter in the
fill decomposes. . .
J.
4.
No current risk to human health or the
environment exists as a result of the
reducing conditions.
ResDonse
u.S. EPA acknowledges that reducing conditions may be
in part responsible for the present groundwater
contamination. However, concentrations of arsenic in
groundv.rater at the site and immediately downgradient of
the site indicate that exceedances of the NR 140, WAC,
Preventative Action Limit (PAL) exist, and that this
level presents a risk of 1.9E-OJ to a consumer of that
water. While groundwater at the site is not presently
used for potable purposes, the potential for such
future use exists. Such use would result in an'
unacceptable health risk to the user. In addition,
further migration could impact groundwater wells
downgradient.
Comment 6
The current impact of chlorinated benzenes is low
(concentrations are less than 1/4 of the NR 140 PAL
standards and there is no current risk to human
health). The chlorinated benzenes were not detected in
fill materials and may well be related to off-site.
activities.
ResDonse
u.S. EPA acknowledges that the chlorinated benzene
compounds were not detected in the fill material during
test-pit activities, but notes that another
explanation offered by the RI Report was that
chlorinated benzene compounds in the waste were very
localized. The fact the compound was not found during
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the limited test pit activities does
the waste is from off-site, and u.s.
chlorinated benzene contamination as
site.
not prove. that
EPA considers the
a release from the
The potential future risk, under the exposure
conditions identified in the risk assessment section of
the RI Report, is greater than the point of departure,
1.0E-06. Furthermore, the actual extent of 1,4- .
dichlorobenzene contamination is uncertain, since the
furthest downgradient well still showed elevated
levels, with a concentration of 25 ug/L and a risk of
2.0E-05. This risk, calculated solely. on the basis of
1,4-dichlorobenzene., is greater than the point of
departure. .
In addition, PALs and Enforcement Standards (ESs) for
1,4-dichlorobenzene will be lowered as of October 1,
1990, at which time this chemical at the site will
exceed its PAL. These new levels are "To Be
Considered" criteria at the site. u.s. EPA believes
that their use is consistent with the statutory
requirement to protect human health and the
environment.
d. Human Health
Comment 7
Exposure to contaminants in groundwater does not affect
current health risks because the area of impacted
groundwater is not used for potable purposes. The
future risk was above 1 in 1 million (1.OE-06), but can
be further reduced by access and deed restrictions.
ResDonse
u.s. EPA acknowledges that contaminated groundwater at
the site is not used for potable purposes, and that
future risk due to groundwater usage can be partially
addressed by access and deed restrictions. In fact,
the Selected Remedy, Alternative 3B, incorporates
access and deed restrictions along with groundwater
monitoring. Alternative 3B also incorporates a cap as
a means of reducing infiltration and percolation, and
thus will help further minimize the potential future
releases of site waste constituents to groundwater.
Alternative 2 does not use an adequate cover or cap,
and thus does not adequately address infiltration and
protection of groundwater.
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It is u.s. EPA's expectation, as promulgated in the
NCP, that "contaminated groundwaters will be returned
to their beneficial uses wherever practicable within a
timeframe that is reasonable given the particular
circumstances". As explained earlier, u.s. EPA
believes that by capping the site, and reducing
infiltration into the waste, groundwater quality will
improve. If this is not the case, u.s. EPA and WD~
may require additional remedial action. u.s. EPA
believes that institutional controls can beused,as
appropriate to prevent exposures to releases of .
hazardous substances during remedy implementation and
to supplement engineering controls. These
institutional controls should not substitute for
active response measures as the sole remedy, unless
these measures are impracticable.
u.s. EPA also notes that groundwater is used by
downgradient residences for potable purposes. While
the nearby residential wells were not sampled and
analyzed during the RI, testing by the state of
Wisconsin in 1984, 1985 and 1988 indicated that the
nearby residential wells tested did not show detectable
levels of VOCs. This testing, however, did not analyze
for other site contaminants. The Selected Remedy
includes testing of nearby residential wells as part of
its groundwater monitoring program.
II. REMEDIAL ACTION ALTERNATIVES
a. Alternative 2
Comment 1
Waste stability and groundwater quality will be
monitored to measure groundwater quality improvement
over time as reducing conditions diminish.
Response
u.s. EPA acknowledges that groundwater quality
monitoring will be key to ascertaining groundwater
quality improvement over time, and as such will be the
indirect measurement. of waste stability and
effectiveness of the implemented remedy for both
Alternatives 2 and 3B. However, Alternative 2 does not
adequately provide for overall protection of human
health and the environment. Alternative 2 does not
sufficiently provide for limitation of infiltration and
reduction of potential leaching of site waste
constituents to groundwater. Alternative 3B, through
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use of an engineered NR 504 cap, does provide for
limitation of infiltration and reductiop of potential
leaching of site waste constituents to.groundwater.
Comment 2
Physical contact with the waste will be prevented
through cover repair, cover monitoring and maintenance,
perimeter fencing and institutional controls.
ResDonse
U.S. EPA acknowledges. that an important aspect of the
remedy is the prevention of physical contact with the
waste through capping, monitoring and maintenance of .
the cap, perimeter fencing, and institutional controls.
While the "cover" to be implemented under Alternative
2, Cover Repair and Access Restrictions, provides.
limited protection to restrict physical contact with
the waste through the combination of controls as stated
above, it does not provide for adequate protection from
freeze / thaw cycles and erosion. Hence, Alternative 2
may subject the waste to disturbance through erosion
and subsequent releases to the environment.
Furthermore, Alternative 2 does not adequately provide
protection of groundwater. Alternative 2 does not
sUfficiently provide for limitation of infiltration' and
reduction of potential leaching of site waste
constituents to groundwater. As a result, Alternative
2 does not adequately provide for overall protection of
human health and the environment. Alternative 3B,
through use of an engineered NR 504 cap, does provide
for limitation of infiltration and reduction of
potential leaching of site waste constituents to
groundwater, as well as affording protection from
freezes and thaws.
Comment 3
Use of impacted groundwater would be prevented both
through the groundwater monitoring activities and
restrictions (institutional controls) over groundwater
use.
ResDonse
U.S. EPA ac~owledges that groundwater monitoring
activities and restrictions (institutional controls)
over groundwater use are key components of. a remedy
which provides for overall protection of human health
and the environment. These elements are included in
the Selected Remedy, Alternative 38, Enhanced Capping.
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See the response to comment 7 in Section I(d).
Comment 4
Implementation of Alternative 2 minimizes disturbance
of the stabilized wastes and therefore eliminates the
potential for adverse effects due to destabilization
and subsequent releases of fixed contaminants.
ResDonse
While Alternative 2, Cover Repair and Access
Restrictions, does minimize disturbance of wastes, it
does not eliminate the potential for adverse effects
due to destabilization and subsequent releases of .
contaminants. Alternative 2 does not provide for
adequate protection from freeze / thaw cycles, and
hence may subject the waste to disturbance through
erosion and subsequent releases to the environment.
u.s. EPA disagrees with the PRPs contention that the
wastes are "stabilized" or "fixed". See the response
to Comment 1 under section I(a) above for further
discussion of the stabilized / fixed issue.
b. Alternative 3
Comment 5
Evidence collected during the RI indicated the paint
sludges had dried into "clods" encapsulating
potentially mobile VOCs. The release of VOCs to air
upon disturbance of the waste and subsequent breaking
of clods was documented during test pit activities as
elevated HNu readings. .
. ResDonse
While test pitting activities during the RI encountered
some "clods", no testing has been done of these clods
to evaluate the assertion that they are "encapsulating"
potentially mobile VOCs nor is it known how extensive
these "clods" are. While U.S. EPA acknowledges that
breaking of clods during test pit activities resulted
in elevated HNu readings at the exposed cut face of the
excavation, U.S. EPA notes that no elevated HNu
readings were detected in the breathing zone (i.e., at
face level) in the same location. This lack of
detection in the breathing zone is an indication of
minimal air impacts. However, the potential impacts of
excavation and earthmoving activities associated with
Alternative 3B will need to be evaluated during the
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design phase. The design phase will also ascertain the
need for an air monitoring program in the work zone and
at the site perimeter during implementation of
Alternative 3B.
Comment 6
The result ofWarzyn's model is that a significant
release of toluene, ethylbenzene, xylenes and other
waste constituents could occur due to the disturbance
of only the upper 2 feet of waste materials. The
contaminant concentrations potentially occurring in
groundwater from such.a release would' result in
substantial impacts to groundwater quality. The
benefit of reducing infiltration through the
implementation of Alternative 3 would be minimal at
best and, in light of the demonstrated potential for a
release due to waste disturbance, would be
inappropriate and in fact more dangerous.
Response
The model referred to here was prepared by warzyn on
behalf of the PRPs. That model theorizes that a
release to groundwater of toluene, ethylbenzene and
xylenes could occur due to disturbance of the upper two
feet of waste materials, but only with the exposure of
these waste materials'to a one-inch rainfall event.
Simple engineering controls, however, exist to address
this very problem, and can be very easily implemented
with little cost impact. An example of one such
control is placement of a tarp over the exposed waste
material, thereby eliminating the possibility of
infiltrating rainfall to leach the contaminants out of
the exposed waste materials. without this rainfall
exposure, the modeled release will not occur. The
Selected Remedy, Alternative 3B, can be adequately
engineered and implemented to address this risk of
release. However, if a release were to occur during
or after the implementation of the selected remedy,
U.S. EPA and WDNR will reevaluate whether further
remedial action is appropriate. U.E. EPA is concerned
that if no action is taken ,at the site, a release such
as that described above would be inevitable. U.S. EPA
and WDNR therefore believe remedial action is necessary
at Wheeler Pit.
III. Protection of Human Health and the Environment
Comment 1
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Although Alternative 3 would- be more effective in
reducing infiltration than the cover repair option,
Alternative 2 provides adequate protection from risks.
Monitoring would enable detection of a future change in
groundwater quality. The length of time the wastes have
been in place (approximately 30 yrs) and the minimal
groundwater impact to date supports the assertion that
contaminants have been stabilized, even given the
permeability of the existing cover.
ResDonse
While u.s. EPA acknowledges that groundwater monitoring,
to be implemented under both Alternatives 2 and 3B, will
enable detection of future changes in groundwater .
quality, u.s. EPA disagrees with the PRPs' assertions
that contaminants have been adequately stabilized, and
that Alternative 2 provides adequate protection from'
risks. See the responses to Comments 1 and 2 under
Section I(a) above for a discussion of the
"stabilization" issue. See the response to comment 3
under Section III below for a discussion of the
"protectiveness" issue.
Comment 2
The lack of evidence supporting the agency position that
groundwater quality will necessarily improve in the
short-term with the implementation of Alternative 3, as
well as the possibility of detrimental impacts through
alternative implementation, do not support selection of
Alternative 3 over Alternative 2 as the Site remedy.
ResDonse
The NCP established nine evaluation criteria for
selection of remedies at Superfund sites. The first two
of these criteria are "threshold" criteria--i.e., if the
alternative considered can not meet both of these
criteria, the alternative can not be further considered.
These two threshold criteria are: 1) overall protection
of human health and the environment, and 2) compliance
with state and federal ARARs. Alternative 2 does not
comply with federal and State applicable or relevant and
appropriate requirements (ARARs). Because Alternative 2
does not meet this threshold criteria, it cannot be
considered further for implementation as the final
remedy. The issue of "detrimental impacts" due to
implementation of Alternative 3B is addressed under the
response to Comment 6 under Section II(b) above. Again,
the PRPs are stating that they believe a release is
inevitable if the waste is disturbed. This concerns us
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since we are required to protect human health and the
environment over the long-term. u.s. EPA does not
believe Alternative 2 will provide -that protection since
institutional controls may not be effective, and,the
cover repair is not protective of groundwater.
Comment 3
Alternatives 2 and 3 are equally protective because they
both rely on institutional controls (e.g., deed
restrictions) to restrict the types of acceptable future
site development.
ResDonse
u.s. EPA acknowledges that Alternatives 2 and 3B both
rely on identical institutional controls to restrict the
types of acceptable future site development. .
Alternative 2, however, does not provide the same level
of effectiveness as Alternative 3B in relation to
prevention of direct contact risk, nor in terms of
reduction of infiltration and limitation of potential
groundwater contamination. U.S. EPA has determined that
Alternative 2 is not protective.
IV. ARARs
a. NR 140
Comment 1
The only ES exceedances at Well B were TDS (total
dissolved solids) and manganese. ES exceedances are
not attributable to the Site, directly nor indirectly.
None of these exceedances pose a significant threat to
human health nor the environment. Under these
circumstances, therefore, the "No Action" or
groundwater monitoring alternatives may be appropriate
and could satisfy the requirements of NR 140.
ResDonse
The State of Wisconsin established Chapter 160,
Wisconsin Statutes, and Chapter NR 140, Wisconsin
Administrative Code, to protect not only drinking water
quality in the State of Wisconsin, but more importantly
to protect the State's overall groundwater quality. In
doing so, it developed a set of actions that the
Wisconsin Department of Natural Resources could take t:
mitigate present and future releases, regardless of
whether the contamination is from public health
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contaminants or public welfare contaminants (such as
TDS, iron, nitrate, and manganese). Also see the
responses to comments 1 and 2 under Section IV(a).
The agencies and PRPs continue to disagree on whether
action, pursuant to Chapter NR 140, WAC is required at
the Wheeler Pit site. Regardless of whether or not
action is specifically mandated at this site by Chapter
NR 140 (which the State believes it is), the WNDR would
like to point out that nothing in Chapter NR 140, WAC
precludes the State from taking action under other
State laws. In particular, NR 140.24(7) states "the
department may take ,any actions within the context of
regulatory programs established in statutes or rules
outside of this chapter, if those actions are.
necessary to protect public health and welfare or
prevent a significant damaging effect on groundwater or
surface water quality for present or future consumptive
or nonconsumptive uses, whether or not an enforcement
standard and preventative action limit for a substance
have been adopted under this chapter."
The U.S. EPA and State disagree with the statement that
the exceedances are not attributable to the Site, for
sev~ral reasons. First, the agencies do not believe
that sufficient evidence has been provided to
satisfactorily demonstrate that Wheeler Pit is not the
source nor cause of the contamination. The commentors
allude that the contamination is from high background
levels or other off-site sources. However, sampling to
support this statement has not been conducted. In
particular, the sampling conducted does not meet the
criteria for establishing background water quality
pursuant to NR 140.24, WAC.
With respect to whether certain contaminants, such as
manganese, were disposed of at the site, historical
data was unavailable on specific waste types disposed
of at Wheeler Pit. The U.S. EPA 103(c) notification
filed by General Motors-Janesville stated that General
Motors disposed of organics, inorganics, solvents,
heavy metals, and wastes from painting processes, coal-
fired boilers, and wastewater treatment processes.
Information on the type of wastes produced at the GM
Janesville plant in later years is available. In
particular, General Motors records available as of
1979 indicate that manganese was a chemical found in
the Janesville-GM plan's sludge lacquer, elpo
ultrafiltrate, primer sludge, truck enamel sludge, anj
clarifier sludge. This information was made available
to the u.S. EPA and WDNR, by GM, as part of the
Janesville Superfund site investigations.
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.
The RI report, prepared by the PRPs, does not support
the conclusion that the exceedances of TDS and'
manganese are not attributable to the Site, directly or
indirectly. The RI report (December 1989( states
"Background ground water quality indicates elevated
total dissolved solids, zinc and nitrate concentrations
upgradient from the site. Elevated alkalinity, total
dissolved solids, specific conductance and reducing
(oxygen deficient) conditions in downgradient ground
water suggest possible ground water impacts resulting
from the Site, and/or other upgradient sources."
The PRPs state that none of the exceedances pose a .
significant threat to human health or the environment,
thus no action or monitoring is acceptable under State
law. It is u.S. EPA's and the WDNR's continued belief
that this site poses an actual or potential risk which
requires more aggressive action than what is being
proposed by the PRPs. In addition, it should be made
clear that the decision to take active response
measures at this site was made pursuant to the federal
Superfund law and the NCP - not State law.
State laws, such as Chapter 160, wis. Stats. and
Chapter NR 140, WAC do come into play in determining
whether an alternative is eligible for selection. In
order for an alternative, such as groundwater
monitoring, to be eligible for selection, that
alternative must be both protective of human health and
the environment and comply with federal and state
environmental requirements (ARARs). Any potential
remedy, then, would need to comply with Chapter 160,
wis. Stats. and Chapter NR 140, WAC.
U.S. EPA and the WDNR believ~ that no action and
groundwater monitoring are unacceptable alternatives
for the Wheeler Pit Site, because those alternatives
are neither protective, nor do they comply with federal
and State ARARs. Specifically, the WDNR believes those
alternatives do not comply with Chapter 160, Wis.
Stats., and Chapter NR 140, WAC.
According to Chapter NR 140, WAC, no action and
groundwater monitoring are not acceptable responses
where there are ES exceedances of public health and/or
public welfare standards at or beyond the point of
standards application.
Comment 2
In the alternative, an exemption under NR 140.28 would
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be appropriate and is hereby requested since detected
concentrations do not pose a threat to public health or
welfare.
ResDonse
The WDNR may grant an exemption from taking remedial
action, if certain factors pursuant to NR 140.28 are
met. In the case of the Wheeler Pit Superfund Site,
the WDNR will not grant an NR 140.28 exemption from
taking remedial action since this action is being taken
pursuant to federal law, not State law. Further, if
this action was solely being taken pursuant to State
law, the WDNR would not grant an exemption. The PRPs
have not sufficiently characterized background, ..
pursuant to NR 140.24. Additionally, the exceedances
of chromium, arsenic, 1-4 dichlorobenzene, manganese,
TDS and iron are unacceptable from a public health and
welfare perspective.
b. NR 504
Comment 3
NR 504 standards have not been uniformly applied to old
sites regardless of current conditions.
ResDonse
The WDNR is consistently applying Ch. NR 504, WAC at
Superfund sites in Wisconsin. There are many other
landfill sites in Wisconsin which are Superfund sites
where similar action is taking place or will take place
to comply with this regulation and Ch. NR 140, WAC
(e.g., Janesville, Onalaska, Hunts Disposal, Hagen Farm
and Master Disposal). 504 is also being consistently
applied to recent remedial actions where groundwater
contamination has been found.
Comment 4
Installation of an NR 504 cap will result in greater
risks to human health and the environment and threaten
greater impacts to groundwater and air pathways than
currently exist. NR 504 would involve removal of
existing trees and roots and operating heavy equipment
on top of the waste, and would weigh considerably more
than the existing cover. Construction of an NR 504 cap
could very well prompt exceedances of NR 140 standards,
relating to protection of human health. Releases to
air could occur if the encapsulated wastes are
disturbed.
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Response
The commentor concludes that installation of an NR 504
cap will potentially create impacts to groundwater,
based on the Warzyn contaminant transport model
referenced earlier in this Responsiveness Summary. The
catalyst for this model is a rainfall event, which may
create a release of VOCs to the groundwater if it rains
after the waste has been disturbed during cap.
construction. The rain would have to come in to
contact with the waste in order to cause this
groundwater impact. If, as stated in the response to
Comment 6, in Section II (b), an engineering control
were implemented during construction activities, such
as placement of a tarp over the waste to prevent
rainwater infiltration, the modeled impact to
groundwater would not occur.
The commentor also states that a release to air could
occur if the encapsulated wastes are disturbed. u.S.
EPA acknowledges that, during the RI, VOCs were
released when an encapsulated waste "clod" was
disturbed. However, the HNu only detected such a
release right next to the waste, not in the ambient
air. Air will be monitored during construction
activities to assess air quality.
Comment 5
The stabilization process prevents the interaction of
waste constituents with water percolating through the
fill material, and these substances are not migrating
out of the waste.
Response
u.S. EPA acknowledges that the waste constituents
appear to have limited mobility at this time. However,
based on the uncertainties associated with the
stabilization process that may have occurred to some
extent at the site and the presence of VOCs, (these
uncertainties are outlined in the response to Comment 1
under Section I(ağ, u.S. EPA is not confident that
infiltrating water cannot interact with contaminants in
the waste and believes that future releases are
possible.
Comment 6
Even if an NR 504 cap were required by the regulations
themselves, ,an ARARs waiver would be and is hereby
requested S1nce (a) the State has not consistently
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20
..
applied NR 504 requirements to old landfills and (b)
compliance (installation of a clay cap) will result in
greater risks to human health and the environment- than
Alternative 2.
Response
While an NR 504.07 cap is not an applicable
requirement, it is relevant and appropriate to the
site. An ARARswaiver is not appropriate in this
instance. The WDNR is consistently applying Ch. NR
504, WAC at Superfund sites in wisconsin. There are
many other landfill sites' in Wisconsin which are .
Superfund sites where similar action is taking place or
will take place to comply with this regulation and Ch. .
NR 140, WAC (e.g., Janesville, Onalaska, Hunts
Disposal, Hagen Farm and Master Disposal). See
responses to comment 6 in section II (b) and comment 4
in section IV(b) for responses to the PRPs' assertion
that the selected remedy will result in greater risks
to human health and the environment.
Comment 7
Alternative 2 also meets the other criteria for review
established by the NCP.
Response
In support of this comment, the comment or evaluates
Alternative 2 according to the nine criteria in Tabl~ 1
of the PRPs' comments. u.S. EPA does not agree with
the commentor that Alternative 2 provides the best
balance of the nine criteria because Alternative 2 does
not meet the threshold criteria. Alternative 2 is not
protective and does not comply with ARARs, which
excludes it from selection as a remedy for this site.
V. Deletion
Comment 1
One commentor suggested that an appropriate remedial
alternative for the site is the "No Action" alternative
and that u.S. EPA delete the Wheeler Pit site from the
National Priorities List (NPL). He further stated that
1)
there has been no significant release of hazardous
constituents from the waste:
2)
appears that no substantial threat of a release is
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-
21
..
present: and
3)
there are no current risks at the site, and only a
highly unlikely noncarcinogenic future risk and
carcinogenic risk within the risk range.
ResDonse
u.s. EPA has determined that remedial action is necessary
at the Wheeler pit site in order to protect. the pUblic
health or welfare or the Environment. Therefore, the
request for deletion of the site from the NPL is
premature. .
There has been a release of hazardous substances,
pollutants or contaminants into the environment. This
release includes chlorinated benzene compounds, arsenic,
chromium, iron, and manganese into the groundwater. .
There also continues to be a substantial threat of a
release of hazardous substances, pollutants or
contaminants into the environment which may present an
imminent and substantial endangerment to the public
health or welfare or the environment. This is due to the
fact that high concentrations of a large variety of
contaminants are "contained" in the waste at the site.
The PRPs submitted information describing the fragile
nature of the "solidified" material at the site and
express concern that this material will both leach into
the groundwater and volatilize into the air if the site
is disturbed. By their own admission, the breaking up of
the "pods", or' "clods" that are at the site will create a
potentially hazardous situation. This information
further substantiates the Agency's concern over the need
to take a remedial action in order to protect human
health and the environment from a release over the long
term. Monitoring-will detect any release that may occur.
That information will be assessed to determine if further
groundwater action is necessary. The cap [along with
institutional controls] will help to prevent infiltration
into the waste and prevent disturbance of the waste over
the long-term. If no remedial action is taken, there is
no assurance that waste disturbance can be avoided
through the use of a fence and deed restriction alone.
The PAL exceedance of Arsenic (As) in the groundwater
does, in fact, pose a threat to human health and the
environment. .The cancer risk due to exposure to As in
groundwater is 1.9E-03. The total carcinogenic risk due
. to groundwater exposure, excluding arsenic, is 2.0E-05.
Although this falls within the range of risk levels that
may generally be acceptable levels, u.s. EPA uses an
individual lifetime excess cancer risk of 10-6 as a point
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-
22
..
of departure for established remediation goals for the
risks from contaminants at sites. This point of
departure has been exceeded at Wheeler Pit.
The NCP envisions that both current and future exposures
are to be considered. The future scenario describing
exposure to site waste is a reasonable scenario. The
risk posed under this scenario is significantly above the
noncarcinogenic acceptable level at which no adverse
affects occur. .
Because there are unacceptable risks due to exposure to
contaminants at the si~e, remedial action is appropriate
for the site. Once it has been determined that action is
required, ARARs must be met (or a waiver from meeting
ARARs granted). Since closure (i.e., NR504) regulations
are triggered, the site, at least, needs to be closed in
accordance with those regulations.
Although the commentor believes that the future risk at
the site is a highly unlikely scenario, u.s. EPA and WDNR
disagree. By the PRPs own assessment, they believe that
even minimal disturbance of the waste may create a
release.
Again, "no action" is an inappropriate response and a
limited action alternative will not meet ARARs and is not
protective.
Finally, regarding the commentor's request that the site
be deleted from the NPL, u.s. EPA has determined that it
is not an appropriate time to consider deletion
proceedings. u.s. EPA must consider whether any of the
following criteria has been met:
(i)
Responsible parties or other persons have
implemented all appropriate response actions
required;
(ii)
All appropriate
CERCLA has been
response action
appropriate; or
Fund-financed response under
implemented and no further
by responsible parties is
(iii)
The remedial investigation has shown that the
release poses no significant threat to public
health or the environment and, therefore, taking
of remedial measures is not appropriate.
u.s. EPA has determined that none of these criteria have
been met since it is determined that taking of remedial
measures is appropriate based on the future risks from
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-
E.
23
..
the site.
In addition, section 121 of CERCLA specifies that U.'S.
EPA will conduct five year reviews at sites where
remedial actions result in hazardous substances,
pollutants or contaminants remaining on-site. There is a
policy that U.S. EPA conduct at least one five-year
review before deleting such a site from the NPL. Again,
the request for deletion is premature in that even if the
action chosen were a "limited action", a five year' review
would still be required since the site would not provide
for ~nrestricted use. .
SIGNIFICANT STATE COMMENTS
The WDNR submitted their comments on the selected remedy in
a letter to U.S. EPA dated July 20, 1990. All of the,
State's comments have since been addressed in the Record of
Decision. The State of Wisconsin has reviewed the ROD and
concurs on the selected alternative.
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,-
I,), ,...
1- .
?V
fRANg PAGES DArg .
12
74/05/06
89/02/17
89/02/17
10
8~IOUI8 ..
ADNINIsrRArIVI RICaRD 11Dll . UPDArr '2
fBlgLIR Plf SUPIRla.D 51"
LAPRAIRl1 rOf'SHIP, flSCOISll
rIfLE
A arBOR
Letter re: Letters dated
tUI 5/74-12176, listJD9
requitelents tor tbe
proper ab~ndonlent
at tbe fbeeler Pit
State at fircansin
D'R
. .
letter re, Letter
tarvarding COllentr
on tbe captioned
!!ubjut vitb tbe
'beeler Pit Site
Respondent'
Valentino, 1.,aSI'A
Letter reI response
to U.S. 'PA Rerier
COllents on recbnical
Nelo '1
Kolberg,D., farzya
LettH reI fheelH Pit VdltatiDO, If. ,a.s. ,,.
Site, Pba!!e 1 Groundrater .
SUllary
2 ~0/08/06 Leeter re: nev ioter- Peteuon, g.,
latioo coocernJn9 GenHal No tors
issues to be discussed
In 8/~/90 leetiog.
3 ~0/08/10 Respoose!! to IPA Kolberg, D., farzya
questioo!! on Public
Revier IS. attached
art tro lelos.
RlC1PlIn.
DOCUKERr rypg
DO'C'UN8BR ,
Correspoodence
rolberg, D., farzyn Correspondence
Valeatiao,If.,aSIPA
Correspoodeoce
J
Buetor, C., fheeler Correspoadence
Pit
IOV1, 1.8., USIPA
Correspondeoce
'ory, lary Betb,
aSIPA
Corrupoodence
~OI08/16 Letter reI to contirl Keoney, rbolas .J.,aSIPA Ratterr,R., Vogel, Correspondence
telepbone discussion A.
,hieb stated tbat the
u.s. 'PA bas decided
to 9rant request tor
an erteDsioD at tile
for request
2 90/08/24 Letter reI coolirlin? Coacles , Brady lenney, r.,aSIPA C:orrupondeoce
a leetiD9 beld 00 8/17,
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-
U 'J. :
~ J '90 ;.
ADII.IsrIAflrl RICOID IIDII - UPDAfr 12
1811LII PIr SUPIR'UID SIfE
LAPIAIIII rOlrSHIP, IIscorSI.
eBB. G PAGIS D~rr fIrLl AUfBOI RlCrnUf DaCUI/ENf ffPI' . DOCIU/fBlR
co di.eas. cbe tloal
reledial aetioo plao
tor Ibeeler Pit.
89102/21 . 'beeler Pic - Pbase 1 (olberg, D.,larr,D ,ile Helor3Ddul
89104104 'beeler Pit - Pbase 11 Kolberg,D.,'arryo ,ile Ifeioraodul 10
89104127 Prirace vell vater Oscev, I., larr,o 89104/27 Heiorandul 11
ebeli,trr data trol
'beeler Pit ',ite
area.
12 9010J/29 Ibeeler Pit 'easibilit, DadislaD, I., .arr,o ,ile Ifelouodul 12
Studies
J 9010411,J lelO reI torvardiog larr,a ID,iaeeriD, ,ile Helor3odul JJ
Aaal,tical Laborator,
Rualts
90105/02 1adieator ebelical Cbrist1.D, B., .arr,a 'beeler Pit '11'5 lfelor3odUl J4
eraluatioo tor
arseoie aod oapbtbaleae
90105/09 ague, cOluotl larr,D 'DgiDeerio, ,1le lfuor3odu. 15
OD'S
16 90107105 Ibeeler '1t S1te, rUr,D . lile luoraadUl 16
le,poD.e to aSI'.
ler1ev cOlleDt. tor
tbe Dratt lea.ibi11t,
Stad,. COlleDt Letter
Diced larcb J3, 1"0.
1J 90107118 'beeler 'it Site, Cbri't1.., '.Dadi'I'., J. 111e luoraadal 11
RespoI.e to as.,a 1rer,ol, I., lolber" D.
reriell eouuts
tor cbe Dratt
'ea.ibi11t, Stud,
-------
- --------------..------------- ---------- --------.
-
~ MJ. J #-
t :J.90 AD'I'ISr'ArIrr .rCORD I'Drl . UPDArr ,z
'BIlL " PIr supr'lUID SIrr
LAP'AIIII roi.SHIP, 'ISCOISI.
H~/!RAHE PAGES DArE rrru Aurea, IIcIPIifr .
DOCUHur rrpg DOCMUHSE..
90/07/18 'beeler Pit Site, 'arz,a lilt Itt.oran~u. 18
Rupoase to 'OIR
rerftll' COlltn t. tor
tbt Oratt ltasibilit1
Study. COllent letter
dattd ltbruar1 28, J990
90/071J8 'beeltr Pit Site, 'arz1a lilt Ituoran~u. 19
Responst to '0"
rtvitll' cO.ltat. tor
tbt Dratt ltasibilit1
Study. COlleat letter
dattd larcb J2, J990
12 90/07/18 'betler Pit Site, 'uzya rilt luorandul 20
Rt.poue to '011
COlltats tor tbe
Dratt leasibility
.. Study, COlleat
letter dated larcb
15, J990
90108/1 J 'betltr Pit Os tea, I. 'arzya rile Ittioraadul 21
Project113728.30
attacbed are pboto.
5 90108/U 'buhr Pit Ostea, I., r.rzya lile Ituoraadul 22
Projtctl J3728.30
attacbtd are pboto.
, 90/09106 rb"l,r Pic Sit' .. '0",'.'., USIPA ril, Ifuoraadul 23
CbroloJof' ot IrtDt.
coac,raia, IzteD.ioa
ot tt, ,.blic COII,.t
Period .ad Scb,duli.,
ot . lettia, ritb ebe
PII.
5 90108100 Htaltb Hazard Re,itr St.te ot ri'CoD.ia, OBSS Oeber 24
Serie, 'beeler 'it
90108/08 Pbolt record re, '0", 1.'.,aS'PA Petersoa, I. Pboat Rtcord : ~
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-
,: j q~ II J.
;~<~'9v
ADIIIISf.Aflrl RICaRD IIDrl - UPDAfr 12
rlrlLI. Plf suprR1UID SIfr
LAPRAIRII fOI.SII', IISCOISII
RBclPlflf
!']C ANE PACES' DArE UfLl AUflOI
Irteas10a at Publ1c
COlleat Period tor
lbeeler Pit
61 90/02/27 Sectioa 8.0 larzra
ladaagerleat js.es'leat
JH 89 /..0 1100 Reledial Iavestigat10a larzya lagiaeeriag
aad leasibility Study
fecbaical leioraadul "
321
90/0J/00
lort Plaa Reledial
Iatestlgatioa aad
leasibllity Study
larzya lag1aeeriag
Iacorp.
,
DOCUHUf ffPg
Report/Studies
Respoadeats Steeri~g Reports/Studies
Call
Respondeats Ste~riag Reports/Studi~s
COli
r
DOCNUHBBR
26
27
28
-------
i- -----,"----- ---- - - ----- -- --- -
~ .~ ~. ;-
:~'?O
ADNIllSflAflVI IICOID 1'0'1 . UPDAf' 12
PUBLIC CONN"fS
rRII"R PI' SUPIR1U.D SIfl
'APRAIR11 forlSRIP, 'ISCO.Sl.
. AurlOR RICIPIlRf DOCNU/fBBR
:~/FRAI1B PAGKS DArK rIrU DOCU""f "frPl
90/07/15 Co..tats for. vitb Scott, J. UUPA Public COlltDt$'
haodvr1tttn CO..tDtS
conctrojn~ vtll
conta.inatioo dut to
tbe vastt dj~posal
S8 ~0/OS!08 rraoscript of rbttltr Pit USIPA public COII!otS 2
, P rocttdJDgs
18 ~0/08/1 3 'ttter rt: toclosed lolbtrg, D., 'UZ,D 'or" '.B.,USIPA Public COlltOt, 3
tor reritv art 'ar=10',
respODses to fD.R's
Co..tot letttr OD tbt
public revitr 1S.
29 90/08/11 Letttr re: reSpOD!eS 101btrg, D., 'arz,D 'or" ".B.,USIPA Public COlltDtS 4
.. to USKPA Jul, 11, 1"0
COlleot Ittttr OD Pablic
GevJtv !S
4 90/08/13 Letter re: in r~gards lolberg, D., 'arZ,D '0", If. B. , USIPA Public CCllents 5
to Ad.ioiscratire
Record; attacbed is a
copy of the joder
143 90/08113 Letter re: torrardiag Kolberg, D., 'arz,a DSIPA Public COlleats 6
tbe su"arie~ ca tbe
cOI.eots CD 'beeler
Pit
90/08/13 Letter reI Rtqaest fhrua, S., GIf 'or" I.B.,USIPA Public COlleots
for d,li,tiag trc.
In
-------
-
FJge NJ.
07/12/90
ADHI.ISfRAfIVE RECORD INDEI - ORIGINAL
fBEELER Plf SUPERfUND SIrE '.
. LaPRAIRIE rOf.SBIP, fISCONSIN
.
FICHE/FRANE PAGES DAfE flfLE AUfBOR RECIPIENr DOCUNE.f rYPE DOC'UHBER
6 70/08/12 Letter J.C.Stepbens B.Bobbitt - CHStP&P Correspondence
Re: Lease No. 67599 GItC RR
- tbe so called
"rbeeler Gravel Pit"
~itb Attacblents
2 72/02108 Le t te r David Holun G.Hill Correspondence 2
Re: On-Site USEPA
Investigation
2 75/08/14 Letter Pbll Bull D.Kolberg - rDRR Correspondence 3
Re: AbandoDient GItC
of tbe fbeeler Pit
Liquid faste Disposal
Site
~itb attacblent
22 77/12101 Letter Daniel ,. Kolberg B.Peterson - CHC Correspondence 4
Re: tbe receipt David G. 'lcbols
and revie~ of fDNR
inforlation concerning
rbeeler Pit
~itb attacblents
2 81/02/26 Letter ItcLaugblin S.Clor - fDRR Correspondence 5
Re: Lab Analysis
results
~itb Attachlent
81/03/23 Letter Bruce Peterson J.Brusca - fDRR Correspondence 6
Re: Pbone GItC
Conversation
, on Harcb 2, 1981
~itb attacblent
2 81/08/03 Letter Bruce Pe terson O.Horn - rO'R Correspondence 7
Re: rest results GItC
on sa.ples collected
on Apnl 21, 1981
witb attacblent
82/06/15 Letter Alan J. Schildt K.Gugin - GNC Correspondence 8
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-
Page No.
07/12/90
2
FICHB/FRANB PAGBS DArB
rIfLE
ReI Hydrogeologic
Investigation of
tbe fbeeler Pit
Site
Ifitb attachent
3
8U07/16
Letter
ReI Heeting
of June 29, 1982
between tbe fDJR
and GHC
3
83/07/07
Letter
ReI SublittaJ
of neeler Pit,
(Rock Co.) for
Possible EPA
Superfund National
Priority List (NPL)
Listiog
witb attacblents
ADHINIsrRArIVE RECORD IJDEI - ORIGINAL
fHEELER Plr SUPERIUND SIrE .,
LaPRAIRIE rOfNSHIP, fISCONSIN
AUfBOR
RECIPIENf
DOCUHBNf ffPE
DOCNUBsBR
Daniel fi Hall
farzyn Engineering
Inc.
Iii Gugin
GIIC
I.Stautz - fDNR
. Correspondence
9
Hark ,. Giesfeldt
fDNR
II.J.lrey - GHC
Correspondeoce
10
00 87/UO/00 Responses to requests USEPA Correspondence 11
tor intorlation trol
GH, CHC-REC, GR(IS)C,
RC, & IB, Inc. are
at tbe USBPA Region
V Offices; tbey can be
reviewed upon request
14 87/03/30 Letter Basil G. CostanteJos GHC Correspondence 12
Re: Request tor USEPA
inforlation Pursuant
to Section 104(e)
of CKRCL! and
Section 3007 of
RCRA
Ifitb attachent
2 87/03/30 Letter Basil G. Constantelos CHStP&P Railroad Correspondence 13
ReI Request for USEPA
Inforlation Pursuant
to Section 104(e)
of CERCL! and
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-
Page NQ,
07/12/90
ADKIIIsrRArIVE RECORD INDEI - ORIGINAL
fBEELER Plr SUPERIUND SIrE "
LaPRAIRIE rOfNSBIP, fISCONSIN
fICHK/FRAKK PAGKS DAfK
rIfLE
AurBOR
RKCIPIENf
DOCUKKNf rYPK
DOCNueSER
"
SectioD 3007
ot RCRA
87/05/08 Letter G.J. LeDtzDer J.Hatt - USKPA CoruspoDdeDce 14
ReI Request Soo LiDe Railroad
tor IDtonatioD Co.paDY
4 87/06/23 Letter BasH .G. CoostaDteloB GKC CorrespoDdeDce 15
ReI 'beeler Pit USKPA
LaDdtill
- Special Notice
ot PoteDtial
Liability
87/06/23. Letter Basil G. CODstaDteloB CKC - BEC CorrespoD6eDce J6
ReI rbeeler Pit Site USfPA
Special Notice aod
104 lei Request
87/07/29 Letter Rebecca L. Rattery H.VaJeotino - USBP! Correspoodence 17
ReI BPA's JeDDer & Block
docu.eDt request.
42 87/09/04 Letter Artbur A. Vogel r.reDDey - USBPA CorrespoDdeDce 18
ReI PRPs tor guarles & Brady
rbeeler Pit
witb attacb.eDts
87/09/22 Letter rbo.as J. leoDey A.Vogel - guarles & Correspoodeoce 19
ReI fbeeler Pit Site USBPA Brady
2 87/09/23 Le t tee Basil G. CODstaDteloB GR(lSIC/ RC/ FB, Correspondence 20
ReI Request USEn IDc.
tor iDtonatioD
Pursuant to
Section 104(el
ot CERCL! aDd
Section 3007
at RCRA tor
rbeeler Pit
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Page No.
07/12/90
ADHIlIsrRArIVI RICORD IIDEI . ORIGINAL
rBUUR PIr SUPERFUND SIrE .,
LaPRAIRIE fOrNSHIP, rISCONSIN
FICHE/FRAHE PAGES DArE
rIfLE
AurBOR
RECHIENr
DOCUHENf fYPE
DOCNU1{BER
87/11/12
Letter
ReI Response
to Request tor
Intonation by
USKPA
vitb attacblent
Pbillip D. Irant .
Irank Bros., Inc.
I. Justus - USBPA
Correspond~nce
21
2
88/07/12
Letter
ReI rbeeler Pit Site
RIllS Scbedule
vitb attacblent
Hicbael A. ValeDtiDo
USEPA
D.Kolberg - rE, Inc. Correspondence
22
88/07/28 Letter Hicbael A. Valentino C.Buetov - GHC Correspondence 23
Re: Appro val USEPA
ot RI/fS rork Plan
aDd OAPP
2 88/08/11 . Letter Hicbael A. Valentino C.Buetov - GHC Correspondence 24
Re: Revised RIlfS USBPA
Scbedule Starting
Date
38 88/09/14 Letter Dean Geers H.ValeDtiDo - USEPA CorrespoDdeDce 25
vitb attacbed Jacobs Bngineering Group
tield lo~, veIl and IDC.
test pit log, ulple
log, aDd tbe pboto
log tor activities at
tbe rbeeler Pit Site
2 88/J0/11 Letter Ilary Gade Parker Pen USA Correspondence 26
ReI Request tor USBPA LilHed
Intorlation Pursuant
to Section 104(eJ
ot CERC£A and SectioD
3007 ot RCRA tor
tbe rbeeler Pit Site
88/12/20 Letter Robert B. Collins N.Justus - USEPA Correspondence 27
Re: reply to letter Novlan & lIouat
dated Decelber 12tb Ln fin
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-
rage No.
07/12/90
5
ADKI'IsrRArIVI RICORD I'DII - ORIGIiAL
fHKKLKR PIf SUPKRIUMD SIfK "
LaPRAIRIE rOfNSHIP, fISCONSIN
..
FICHE/FRAKE PAGES DArE
frru
AUfHOR
RECIPIKNr
DOCUKENf ffPE
DOCNUlfBER
to Parker Pen USA Ltd.
concerning request tor,
intonation
89/02103 Letter Kichel A. Valentino GKC/ CKC-RKC Correspondence 28
Re: fbeeler Pit Site USEPA
89/02108 Letter Kicbael A. Valentino. C.Buetoli - GKC Correspondence 29
Re: fbeeler Pit Site USEPA
- Revieli COllents tor
fecbnical Keiorandul
11
4 89/02110 Letter Kicbael A. Valentino C.Buetoli . GKC Correspondence 30
Re: rbeeler Pit Site USEPA
- Review COllents tor
Nark Plao, OAPP aod
Salpling Pla~ Addenda
89/03/05 Letter Ilicbael A. Valentino C. BuHOIi - GKC Correspondence 31
Re: fbeeler Pit Site USEPA
- Approval ot Nork
Plan Addendul
liitb attacblent
89/03/13 Letter Iticbael !. Valentino C.Buetoli - GKC Correspondence 32
Re: fbeeler Pit Site USEPA
- OAPP Addeodul Approval
89/03/15 Letter Cbristioe Diebel. I.Valentino - USEPA Correspondence 33
Re: fbeeler Pit rDn
Superfund Site
- COllents on Revised
recbnical Ileiorandul
II
3 89/03/24 Letter licbael A. Valentino C.Buetow - GKC Correspondence 34
Re: fbeeler Pit Site USrP!
- Pbase II Activity
Scbedule
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-
Page No.
07/J2I90
FICHE/FRANE PAGES DArE
2
89/04/04
5
89/08/28
. J
89/09/J 5
..
rIrLE
Letter
ReI Revised
Pbase II
Activity Scbedule
~beeler Pit RIllS
vitb attacblent
Letter .
ReI ~beeler Pit Site
- Review COllents .tor
Tecbnical Neiorandul
12
Letter .
ReI ~beeler Pit Site
RIllS
- Hodifications to ~ork
ADHINISTRATIVB RECORD INDEI - ORIGINAL
~HEELER PIT SUPERIUND SITE -,
LaPRAIRIB rO~NSBIP, WISCONSIN
AUTHOR
RECIPIBNT
DOCUHENr rIPE
DOCNUKBBR
Daniell. Kolberg.
~arzyn Engineering
Inc.
H.Valentino - USEPA Correspondence
35
Iticbael A. Valentino
USBPA
C.Buetow - GHC
Correspondence
36
Nary A. Gade
USBPA
C.Buetow - GHC
Correspondence
37
89/JI/OJ Letter H1cbael A. Valentino C.Buetow - GNC Correspondence 38
ReI ~beeler Pit Site USBPA
- Review COllents tor
tbe Draft Reledial
Investigation Report
2 89/JI/30 Letter Niche! A. Valentino L.Little - GltC Correspondence 39
ReI Wbeeler Pit Site USBPA
20 89/JI130 Letter Nike Scholler It.Valentino - USBPA Correspondence 40
ReI WDNR's response ~DNR
to tbe request for
ARARs for tbe ~beeler
Pit Site
vitb attacblents
89/J 2/06 Letter H.Scholler It.Valentino - USBPA Correspondence 4J
ReI State groundwater fUR
pUlp requirelents
related to Wbeeler P1t
89/J2I06 Letter Niche 1 A. Valentino L.Little . GltC Correspondence 42
ReI ~beeler Pit Site USBPA
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. Page No.
07/J2/90
ADHINISfRArIVE RECORD INDEI - ORIGINAL
'BEELER Plr SUPBRFUND SIrB
LaPRAIRIB fO'NSHIP, 'ISCONSIN
..
FICHB/FRAHB PAGES DAfE
rIfLE
AUfHOR
RBCIPIEJr
DOCUHENr rfPE
DOCNunER
<)
- COllents on tbe
Alternatives Array
Doculent
90/01116
Letter
ReI 'beeler Pit Site
- Revie~ COllents
to Revised Reledial
Investigation Report
I(i tb at tacbleD t
Kicbael A. Valentino
USEPA
L.Littlt - GHC
Correspondence
43
2 90/04/04 Letter Hary Betb Navy
ReI 'beeler Pit Site USBPA
- Reledial Investigation
Report Approval
witb cover sheet
3 90/04/06 Letter Itary Betb Novy
ReI 'beeler Pit Site USBPA
- Scbudule tor Sublittal
of Revised 1easibility
Study
witb c~ver sheet
L.Little - GHC
Correspondence
44
L.Little - CltC
Correspondence
45
J 90/04/09 Letter Darsi Fou H.B.Novy - USEPA Correspondence 46
Re I Region V's Kike Scbloller
ARARs Deterlination 'DIIR
on 'aste at tbe
'beeler Pit Supertund
Site
90/04/11 Letter Hary Betb Novy D.KJlberg - 'E, Inc. Correspondence 47
Re: 'beeler Pit Site USEPA
- Feasibility Study
Revisions
witb cover sheets
90/04/J8
Letter Jobn D. Dadisldn
ReI 'beeler Pit Superfund 'arryn Engineering Inc.
Site Benrene Detects, .
Round 1 Ground~ater
salpling
witb attacblent
H.B.Novy - USEPA
Correspondence
48
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-
[age HJ. B
07112/90
ADHINISrRArIVI RECORD I.DEI - ORIGINAL
fHEELER Plr SUPERIUND SIrE
LaPRAIRIB rOfHSHIP, fISCONSli
FICHE/FRANE PAGES DArE rrru AurHOR RECIPIKNr DOCUNKNr rYPK DOCNUMBER
5 90/05/02 Letter Artbur A. Vogel r.Keooer - USEPA Correspoodence 49
Re: rbeeler Pit puarles & Brady
Superfund Site
Scbedule for
COlpletion of IS
2 90/05/11 Letter rbOUB J. Kenoey A.Vogel - puarles & Correspondence 50
ReI IfbeeJer Pit USEPA Brady
Superfund S1te
- Scbedule ot
COlpletion of 1S
9 90/07/11 Letter Itary Betb 'ovy L.Little - GHC Correspondence 51
Re, Public IS Report USEPA
lIitb attacblent
00/00100 National Priorites USEPA Fact Sheets 52
List Site lact Sbeet
entitled
'lfheeler Pit'
6 SB/n/OO Supertund lact Sbeet USEP! lact Sbeets 53
Ifbeeler Pit Superfund
Site
3 89/09/00 lact Sbeet USBPA Fact Sbeets 54
Update ot
Investigation fbeeler
Pit Superfund Site
81/01/09 Itelo C.!. Belli A.V. Gagliardi - GHC Heioraodul 55
ReI GNAD Janesrille GHC
inquiry on
Ifbeeler pit
lIith attacbleots
2
81/02/02
Ilelo
Re, GHAD - Jaoesr1lJe
Ifbeeler Pit
Leonard 1. Cbarla
GNC
If.lfard/H.lrey GHC
Heioraodul
56
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,-
rage Nv.
07/J2/90
ADHINIsrRArIVE RECORD INDEI - ORIGINAL
NBEELER Plr SUPERFUND SIrE..
LaPRAIRIE rONISHIP, NISCONSIN
..
FICHE/FRAHE PAGES DATE rrru AUrHOR
3 81/02106 Helo N.P.Nard
Re: GHAD - Janesville GHC
- Nbeeler Pit
81103/27 Helo Untitled
entitled
.Nbeeler Pit.
RECIPIENT
DOCUHur TYPE
DOCNI1KBER
L.F.Cbarla - GHC
Heiorandul
57
Heiorandul
58
2 81109/08 Helo State of Nisconsin Heiorandul 59
Re: Evaluation ot
Nater puality Results
tor Nbeeler Pit
86/03/19 Helo USBPA USEPA HeloranduJo 60
Re: Prelilioary
Natural
Resources Survey
Nbeeler Pit Site
2 88/03/03 Helo Susan Pastor File Heiofandul 61
Ret rrip Report USEPA
tor Nbeeler Pit
COllunity Intervie~s
10 88/l0m Helo Curtis ROBS N.Kiedergang - USEPA Heiorandul 62
Ret Perforunce USEPA
and Systels Audit
Report for Narzyn
Engineering Laboratory
tor Nbeeler Pit PRP
Lead Site
~itb attacbunt
89/03/J3 Helo 'oel loel 1.liedergang - USEPA Heiorandul 63
Ret Approval ot tbe USEPA
puality Approval Project
Plan (PAPPI tor tbe
Pbase II Reledial
Iovestigdtioo/
Feasibility Study
IRI/FS) Activities at
~beeler Pit
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-
Fage No.
07/12190
10
ADKIRIsrRArIvi RECORD IJDEI - ORIGINAL
fBEELBR PIr SUPBRIUND SIrE
LaPRAIRIB rOfNSBIP, fISCONSIi
FICHE/FRAKE PAGES DArE
rIrLE
AurHOR
RECIPIENr
DOCUKENr rYPE
DocillHlBER
14 89/05/04 Kelo Cbristine 1. Diebels fbeeler Pit lile Keiorandul 64
Re: Oversigbt State ot fisconsin
Activities
and COllents
April 4, 5, 6, 7,
1989
J6 89/06/02 Kelo Curtis Ross- N.Niedergang - USEPA Keiorandul 65
ReI Data Review USEPA
aDd SystelB Audit
Report tor farryn
Engineering Laboratory
tor rbeeler Pit
PRP Lead SHe
.
3 89/06/13 Kelo Kicbael Valentino lile Keiorandul 66
Re: ~beeler Pit Site USrPA
Keeting - Discussion
ot Pbase II Gf Results
89/07/21 Kelo . Curtis ROBS USBPA Heiorandul 67
Re: Revie~ ot USBPA
Region V CLP
Data tor
fbeeler Pit Site
89110/27 Kelo Judy Kl e i Ian K.Valentino - USBPA Keiorandul 68
Re: Reaedial USBPA
Investigation
tor tbe fbeeler Pit Site
89110/27 Kelo Judy KIeilan K.Valentino - USEPA Keiorandul 69
ke: fbeeler Pit Site USEPA
Reledial Investigation
(IS rHIS A DUPLICArE}
89/10/31 Kelo Andrew Podowski X.Valentino - USEPA Kelor3ndul 70
ReI ReviH USKPA
ot Dratt RI tor
fbeeler Pit Site
(HAND fRIrrBJI J
-------
.-
3g.: NJ.
)7/12/90
11
ADHINISfRAfIVE RECORD INDEI - ORIGINAL
rHEELER PIf SUPERFUND SIrE "'
LaPRAIRIE fOfKSHIP, fISCOKSIN
?ICBE/FRAHE PAGES DAfE
fInE
AUfHOR
RECIPI8Nr
DOCUHENf fYPE
DOCNUHBER
2
89/11/03
Helo
ReI Reviev
ot tbe Alteroatives
Array Docu.eot tor tbe
fbeeler Pit Site
. Ideotiticatioo ot ARARs
Hicbael A. Valeotioo
USEn
Addressees
Heioraodul
71
2 89/11 /24 Helo fbolas"J. Kenney H.Valentino - USEPA Heiorandul 72
ReI Nbeeler Pit USEPA
Dratt
Alteroative Array
Doculent
89/11/27 Helo Judy lleiuo H.Valentino". USEPA Heiorandul. 73
Re: Alteroatives Array USEPA
~beeler Pit Landfill
2 89/11/30 Helo f.Beyer X.Valeotioo - USEPA Heiorandul 74
Re: Reviev ot tbe USEPA
Alteroative Array
Doculent tor
fbeeler Pit Site
2 89/12/07 Helo Cbarles H. Sutfin 8.Constantelos - Heiorandul 7S
ReI rater Divis100 USEPA USBPA
Reviev of tbe .
Alternatives
Array Doculeot tor tbe
fbeeler Pit Supertuod
Site
2 90/02/07 Helo Cbristioe 1. Diebel. S.Bangert/H.Scblolle Heiorandul 76
Re: Reviev cOlleots State ot riscoosio r
00 fbeeler Pit
AA & RI Reports
90/02126 Helo Judy !l e i un H.Valentino . USEPA He.orandul 77
ReI rbeeler Pit Landt1ll USEPA
Feasibility Study
-------
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-
. Page No.
07/12/90
12
ADHINIsrRArIVE RECORD I.DEI - ORIGINAL
fBEELER Plr SUPERFU'D SIrE .,
LaPRAIRIE rOfNSBIP, fISCONSIN
..
FICHE/FRAHE PAGES DArE rIfLE AurBOR RECIPIUr DOCUHE;Nr rYPE DOCNUHfJER
90/03/02 Huo lIary Betb Novy File Heiorandul 78
Re: fbeeler Pit USEPA
Reledial Investigation
Revisions
901.06/19 Helo Judy II e i tan H.B.'ovy - USEPA .Heiorandul 79
Re: fbeeler Pit USEPA
Landtill Proposed
Plan
90/06/21 Helo filliaa Beyer H.B.Novy - USEPA Heiorandul 80
Re: Revie~ ot Dratt USEPA
Proposed Plan (PP)
tor tbe
fbeeler Pit Site,
90/06/25 Helo Dale S. Brysoo D.Ullricb - USEPA Heioraodul 81
Re: fater Division USEPA
Revie~ ot tbe
Dratt Proposed Plan
tor
fbeeler Pit Site,
90/07/02 Helo Hary Bttb .ovy File Heiorandul 82
Re: Addition USEPA
ot Drainage Layer
to NR 504 Cap
16 90/07/03 Helo Hichel A. Valentino File Heiorandul B3
Re: Streaalined USEPA
Approacb to FS
tor tbe fbeeler Pit
Site
83100/00 Ne~s Article Scott Angus Ne~s Article 84
entitled Gaulle Staff
'Hazardous' dUlps
no tbreat: City'
81/03/30 Intervie~ ot Cronin OnkDo~n Otber 85
Falily
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Page No.
07/12190
13
ADHIRIsrRArIVE RECORD INDEI - ORIGINAL
rHKELKR Plr SUPBRFUND SIrB
LaPRAIRIE rOrRSHIP, rISCOHSIN'
FICHE/FRAHE PAGES DArE
rIfLE
AurHOR
RECIPUNr
DOCUKEar rYPE
DOCRUNBER
3
81/06/09
Notification
ot Hazardous raste
Site
~itb cover letter
Robert K. Fronczak
Cbicago, Nil~aukee,
St.Paul and Pacitic
Railroad COlpany
USEPA
Otber
86
2 81/95/29 Notification GNC USEPA Otber 87
at Hazardous E.O. Siegele
raste Site
83/04128 Pbone Conversation Anne C. Sause J. Bakken - fDNR Otber 88
Bcology
& Bnrironlent,
Inc.
. 3 83/04/28 Pbone Conversation Anne C. Sause J. Brusca - fDRR Otber 89
Ecology i
EnviroDient,
Illc.
83/05/02 Pbone Conversation UnkDo~n D.Lindorl - fDNR Otber 90
12 89/04/00 Field Notes Jacobs Bngineering USBPA Otber 91
Harcb 30, 1989 Group Inc.
tor rbeeler Pit
RIllS Oversigbt
2 90/02/00 recbnical Revie~ Jacobs Engineering USrPA Otber 92
Conents on tbe Group Inc.
January 29, 1990
Revision Pages to PRPs
Final Reledial
Investigation Report
9 90/03/00 recbnical Revie~ Jacobs Engineering USEPA Otber 93
COllents on tbe PRPs Group lac.
Jaouary 1990
Feasibility Study Report
rbeeler Pit Site
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Page No.
07/12/90
14
ADKIIISfRAfIVI RICORD IIDII - ORIGINAL
'BEELIR Plf SUPIRlUND SIfE
LaPRAIRIE fO'NSBIP, 'ISCOIS!!
!
lICHI/lRAKI PAGES DArE
fIfLE
AUfBOR
RECIPIllf
DOCUKENf rYPE
DOCllfJltSER
JO
90/03/07
'beeler Pit Site,
- Review COlleots tor
tbe Dratt leasibility
Study
witb cover letter
Kary Betb Novy
USEPA
L.Little - GKC
Otber
94
72
90/03/16
Review
ot tbe Dratt
leasibility Study
tor the 'heeler fit
Supertund Site
with cover letter
Kike Schloller
'UR
K.Valentioo - USEPA Other
95
52 87/1UDO Adlioistrative Order Kathryn Curcner GKC , CKC-RIC Pleadings~Orders 96
By Cooseot 'DIlR
Rei Reledial Valdas V. Adaltus
Investigatioo and USIPA
leasibility Study
witb attacblent
2 87/J'2I01 Press Release: USEPA Press Release 97
G.H. aod CKC Sigo
Agreelent with IPA
3 90/06/28 Press Release USEPA Press Release 98
eo ti t1 ed:
IPA Seeks COlleots
00 'heeler Pit Study;
Public Neetiog Aug. 8
with cover letter
24 74/J0/28 Saapling 'ell Bruce A. 'eber J.Olestoo - GKC Reports/Studies 99
Installation 'arzyn Engioeering
'aste Disposal Site Ioe.
14 83/04/29 Potential Hazardous Aooe C. Sause USIPA Reports/Studies JOO
'aste Site leology ,
Iospectioo Report Eovirooleot,
Ioc.
-------
-
jqe NJ,
)7/12190
15
ADHINISfRAfIVE'RECORD INDEI - ORIGINAL
WHEELER PIf SUPERFUMD SIrE
LaPRAIRIE fOWISHIP, WISCONSIN"
..
IICBE/FRANE PAGES DArE
fIfLE
AUfHOR
RECIPIENf
DOCUHENr rfPE
DOCNUKBER
83/06/02 Potential Hazardous Lisa Perencbio File ReportslStudies 101
Waste Site Ecology and Environlent,
Prelilinary Inc.
Assesnent
vitb cover leiO
45 84/03123 Wbeeler Pit Alan J. Schidt K.Kerrick - GKC Reports/Studies 102
Hydrogeologic Daniel W. Hall
Investigation Warzyn'Engineering
Inc.
335 88/06/00 Reledial Investigation Warzyn Engineering. PRP Steering ReportslStudies 103
And Feasibility Study Inc. COllittee
Wbeeler Pit Site
(Revised Work Plan
VolUle 1J
350 88/06/00 Reledial Investigation Warzyn Engineering' PRP Steering ReportslStudies 104
And feasibility Study Inc. COllittee
Wbeeler Pit Site
(Revised guality
Assurance Project Plan
Volule 2J
34 88/08/00 Flnal Conunity Jacob. rngineerlng USEPA Reports/Studies 105
Relations Plan Group Inc.
For
Wbeeler Pit Site
154 88/09/23 guality Assurance Jacobs Engineering USEPA Reports/Studies 106
Project Plan Group Inc.
Wbeeler Pit Site
RIIFS Oversigbt
gAPP tor RI
Ground Water
Spli t Suples
152 89/02100 Groundvater Jacobs rngineering USEPA Reports/Studies 107
Analytical Results Group IDC.
Sunary
Pbase I ot tbe
Reledial InvestigatioD
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Pdge No.' 16
07/12/90
ADHINIsrRAfIVE RECORD INDEI - ORIG~AL
, fHEELER PIf SUPERIUND SIfE
LaPRAIRIE fOfNSHIP, fISCONSIN
FICHE/IRAHE PAGES DAfE fIfLE AUfHOR RKCIPIlNf DOCUHENf rYPE DOCNUHSER
'beeler Pit Site
RIllS Oversigbt
9 89/02/00 fecbaical Review Jacobs Eagineeriag USEPA Reports/Studies 108
Conents 00 tbe Group lac.
PRPs fecbaical
Heioraadul No.1
'beeler Pit
RI/IS Oversigbt
132 89/03/00 lield Activities Jacobs Eagineeriag USEPA Reports/Studies 109
Hoaitoriag Report Group lac.
Phase I
Reledial Iavestigatioa
'beeler Pit Site
RIllS Oversigbt
350 89/03/00 Reledial IDvestigatioD rarzya EDgiaeeriag PRP Steeriag Reports/Studies 110
Aad leasibility Study lac. Couittee
rbeeler Pit Site
(Revised fecbaical
Heioraadul III
19 89/06/00 Phase II RI Jacobs EDgiaeeriag USEPA Reports/Studies 111
Grouadwa te r Group IDC.
Aaalytical Results
Sunary
fheeler Pit
RI/IS Oversight
270 89/07/00 Reledial IavestigatioD farzya EDgiaeeriDg PRP Steeriag Reports/Studies 112
Aad leasibility Study lac. Couittee
rbeeler Pit Site
(fecbaical Heioraadul 12)
89/08/00 fecbaical Review Jacobs EagiaeeriDg USEPA Reports/ Stud i e s 113
Couea ts Group IDC.
00 the PRPs
fechnical HeloraDdul 12
tor tbe Reledial
Iavestigation ot tbe
'beeler Pit Site
RIllS Oversight
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Page No.' 17
07/12/90
..
ADNIIIsrRArIVE RECORD INDEI - ORIGINAL
WHEELER Plr SUPERFUND SIrE
LaPRAIRIE rOWNSHIP, WISCONSIN
FICHE/FRANE PAGES DArE
rIfLE
AurBOR
RECIPIEIr
DOCUNEHf ryPE.
DOCHUHBER
87 89/08/00 Field Activities Jacobs Bngineering USBPA Reports/Studies 114
Honitoring Report Group Inc.
Pbase II
Reledial Investigation
Wbeeler Pit
RIIFS Oversigbt
89/08/31 Reledial Investigation/ Warzyn Bngineering, USBPA/WDNR Reports/Studies 115
Feasibility Study Inc.
fecbnology Identification
Wbeeler Pit Site
65 89/10/00 Alternatives Array Warzyn Bngineering PRP Steering Reports/Studies 116
Doculent Inc. COllittee
fbeeler Pit Site
255 89/12100 Reledial Investigation Warzyn Bngineering PRP Steering Reports/Studies 117
Report Inc. Couittee
Wbeeler Pit Site
Volule 1 of 2
316 89/12/00 Reledial Investigation Warzyn Bngineering PRP Steering Reports/Studies 118
Report Inc. Couittee
Wbeeler Pit Site
Volule 2 ot 2
7 89/12/00 Prelilinary Healtb Wisconsin ArSDR Reports/Studies 119
AssesBient Division ot Healtb
Wbeeler Pit
Rock Coun ty
Janesville, Wisconsin
169 90/01100 Dratt Feasibility Warzya Eagin~eriag, PRP Steering Reports/Studies 120
Study Report Inc. Couit tee
Agency Reviev Draft
223 90/05/00 Public Revieli farzya Eagineering PRP Steering Reports/Studies 121
Feasibility Report Study Inc. Couittee
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-
P1Jge No.
07/12/90
ACRONYM GUIDE for the Adlinistrativl Record
. fHEELER PIT SUPERFUND SIr8
ADRIAN, MICHIGAN
ACRONYH DEFINITION
G
AA Alternatives Array
ARAR Applicable or Relevant
and Appropriate Standards,
Lilitations, Criteria and
Requirelents
ArSDR Agency for
TOlic Substances
and Disease
Registry
CERCLA COlprebensive EnvironleDtal
Response, COlpensatioD and
Liability Act of J980
CHC-REC CHC
Real Estate CoporatioD
CHStP&P RR Cbicago, Hil~autee,
St.Paul , Pacific
Rail road
FB, Inc. Frank Brothers, IDC.
GHC General Hotors
Coporation
GR(FS}C Green Roct FS Cooperative
JiG, Inc. Jacobs Engineering
Group Inc.
NPL National Priority
List
PP Proposed Plan
PRP Potentially
Responsible
Parcy
QAPP Quality Assurance
Project Plan
RC Rock COUDty. rr
RCRA Resource
Conversation and
Recovery Act
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-
. Page No.
0"7112/90
DArE
rIfLE
81/04/14 Grouad~ater data
tor' the ~heeler Pit
Site
~ith cover letter
(H pgs.)
81/04/21 Iatorlatioa
oa the ~el1s
at ~beeler Pit
at tile ot salpliag
(4pgs.)
81/06/22 Pesticides
aad rOlic Ketals
data sheets
~itb cover sbeet
{14 pgs. J
88/10/10 Pbotocopy ot tbe
tield log book coveriog
the grouad~ater split
salpllag activities
ot ~ctober 5-6, 1988
(26 pgs.)
89/06/09 Data Assessleat Request
(J9 Pgs.)
ADKINIsrRArIVE RECORD SAKPLING/DAfA INDEI
~HEELER PIr SUPERfUND SIrE
DOCUKENrs Nor COPIED, KAY BE REVIE~ED Af rHE
USEPA REGION V OfFICES, CHICAGO, ILLINOIS.
AurHOR
RECIPIBNr
David Lindortt - State ot ~iscoosia S. Glor - S~
Debbie HarD - ~DNR .
D.Liadort - SN
Debbie Hora - NDNR
D.LiDdort - S~
DOCUKENr rYPE
SaJpliag Data
SalpliDg Data '.
SaJpliag Data
Deaa Geers - JEG lac.
H.ValeDtiDo - USEPA SalpliDg Data
Norl Niedergaog - USEPA
C.Ross - USEPA
Saapliog Data
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-
{age No.
07/12/90
ACRONYH
RI
RIIFS
Sli
USEPA
IiDNR
liE, Inc.
2
..
DEFINIrIOM
Reledial
Investigation
Reledial Investigation/
Feasibility Study
State ot liisconsin
United States
Environlental
Protection.
Agency
liisconsin Departlent
ot Natural Resources
liarzyn Engineering,
Inc.
ACRONYK GUIDE tor tbe Adlinistrati~~ Record
IiBEELER Plr SUPERFUND SIrE
ADRIAN, KICBIGAM
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-
Page No. 1 *
08110/90
ADNIIISfRAfIVE RECORD IIDEI - UPDAfE II
IHEELER Plf SUPBRfUID SIfB .,
LAPRAIRIE fOIISHIP, IISCO.SII
FICHE/FRANE PAGES DArE rIfLE AUfHOR RECIPIENT DOCUNBRr TYPE DOCNUNBBR
5 90/07/20 Letter Nad Giuteldt I.B.'0'1 - USEPA Correspondence
ReI COllelts Josepb f. Brusca
on tbe fUR
Pablic RHier
Feasibility Study (FSI
tor tbe fbeeler Pit
Site
2 90/07/30 Letter Kary Betb lo,y L.Little - GKC Corrupondence 2
ReI Adlinistrati,e USBPA
Order tor tbe
fbeeler Pit Site
2 90/08/08 Letter Rebecca L. Rattery f.lenney - USEPA Correspoadence 3
ReI Pablic COllent Jenner & Block
period tor tbe Lar Ottices
rbeeler Pit Site
9~/08/09 Letter Artbar A. Vogel f.lenney -. USBPA Correspondence 4
Re: Objection paules & Brady
to BPA's decisicn
not to eltend tbe
pablic cOllent
period
9~/08110 Letter rbolas J. lenner A.Vogel - gaarles & Correspondence 5
ReI telepbone USBPA Brady
conversation (8-9-901
and letters
(8-8-90 & 8-9-901
4 9~/04/00 fact Sbeet: USBPA fact Sbeets 6
Investigation
COlpleted
. Ibeeler Pit Supertund
Site
90/04105 Kelo Pei-Tung Buut I.B.lovy - USEPA Knorandul 7
Re: rOlici t1 USEPA
intorlation to be
ased at tbe
Ibeeler Pit Site
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Page No.
08110/90 -
2
ADHIRIsrRArIVE RECORD IRDEI - UPDArE 11
rHEELER PIr SUPER1U'D SIrE-'
LAPRAIRIE rorRSBIP, 'ISCOISI'
rIfLE
RECIPIERr
DOCUHERr rYPE
DOCNUHBER
FICHE/FRAHE PAGES DArE
AurHOR
90/07/25 Helo reuse A. Van Douel I.B.'ov, - USEPA Helorandu. 8
ReI rbeeler Pit USEPA
Risk AssesSient
- Dratt Co..ents
and Calculations
.
20 89106/00 Pbase II Hicbael J. Stri.bu !.Valentino - USEPA Reports/Studies 9
RI Groondlfater Jacobs Bngineering
Analytical Results Group lac.
SOllar,
Wbeeler Pit Site
RIllS Oversigbt
-------
--
Page No.
08/10/90
!
ACRONYH
"
FS
(.>
GHC
R1I1S
DEFINITION
Feasibility Study
General Hotors
Corporation
Reledial Investigationl
Feasibility Study
USEPA
United States
EnviroDlental
Protection Agency
f(DNR
f(isconsin Depart.ent
of Natural Resources
ACRONfH GUrDE for the Ad.inistrative Record'
Upda te 11
rbeeler Pit Superfund Site
LaPrairie rornlbip, f(isconsin
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-
: ~ \0" r- j.... .
, ~O/~O
AOHINISfRAfIVE RECORD IJOEI - UPOAfl /2
rBEELER PIf,SUP8R1U.D SIf8
LAPRAIRIE fOr'SHIP, 11SCO.SIJ
19l1'''h''~ PAGES DArB rIfL8 , AUfBOR RBCIPIBU DOCUH8Nf rYP8 ,DOCliUKB8R
12 74/05/06 Letter re: Letters dated State of ri,consin ' Correspondence
frel 5/74-12/76, listing DliR
requite.ents for tbe
proper abandeo.ent
of tbe rbeeler Pit
'-'
7 89/02117 letter reI Letter Valentino. r.,US8PA rolberg, D., farzyn Correspondence 2
forvarding co..ents
. on tbe captioned
subject vitb tbe
rbeeler Pit Site
Respondents
7 89102117 Letter reI respense Kolberg.D.. 'arz,n Valentino.I.,USfPA Correspondence 3
to U.S. 8PA Re,iev
Co..ents on recbnical
Ke.o II
10 89102118' Letter reI 'heeler Pit Valeatiao, K..O.S. 'PA Saetor, C., 'beeler Correspoadeace
Site. Pbase 1 Groundvater Pit
Sunary
2 90/08/06 Letter reI nev infer- Peterson, 8., '0'" I.B., USfPA Coruspondence
.atien concerning General Hotors
issues to be discusse1
in 8/9/90 .eeting.
3 90/08110 Respenses te IPA Kolberg, D., rarzyn 'o,y. lar, Beth, Correspondence 6
questiens en Public US8PA
Reviev 15. attacbed
are tve .e.os.
90/08/16 Letter reI to contin Kenney, rholas J..US'PA Raftery,R., Vogel, Correspoadeace
telephone discussien A.
whicb stated tbat th~
U.S. IPA bas decided
to grant request tor
an eltensien of ti.e
ior r!queH
Z 90/08/24 Letter reI confir.ing Cuarles & Brady Kenney, f.,USIPA Correspondence 8
a leeting beld on 8/17,
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.' <,1/90
ADKI.ISfRAfIVI RICORD INDII - UPDArE 12
'BBBLBR PIf SUPBRfUND SIrE
LAPRAIRII fO'.SHIP, ,ISCO.SIr
'lCBb/lnAHB PAGBS DAfB fIfLB . AafHOR RBCIPIUr DOCaHBN! fYPB . DOCNUHBBR
to di.cus. tbe tinal
reledial actioa plan
.~ tor 'beeler Pit.
v 89/02l2J 'beeler Pit - Pbase I Kolberg, D.,'arzra lile Heiocandul 9
89/04/04 'beeler Pit - Pbase II Kolberg,D.,'arzyn lile Keiocandul JO
89/04/27 Pri,ate well water O.tew, I., ~arzyn 89/04/27 Heiocandul 11
cbeli,try data trol
'beelec Pit site.
area.
12 90/03/29 'beeler Pic leasibility Dadislaa, I., 'arzya lile Heioundul J2
Studies
J 90/04l]J lelO re, tor~ardiag 'artya fagiaeeriag lile Kelor30dUl 13
Aaalytical Laboratory
Results
2 90/05/02 Iadicator cbelical Cbri,tlaa, B., 'artya 'beeler Pic RI/1S Heiorandul J4
evaluation for
arsenic aad napbtbalene
90/05/09 Agency cOllent. 'arzyn Ingiaeeriag 111e Kelouodul 15
on IS
16 90/07/05 'beeler Pit Site, 'arzya lile Helocaadal 16
Re.poa.e to aSIP.
Review cOlleat. for
the Draft leasibility
Stady. COlleat Letter
Dated larch 13, 1990.
13 90/07/J8 'beeler Pit Site, Cbri,tiaa, B.Dadi'laa, J. lile Heiocaadul 17
Response to aSIPA I'erson, B., Kolberg, D.
review COlleats
for cbe Draft
leasibility Stud,
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. " . i-
:u. ~ J
ADIINIsrRArIVf RrCORD IIDrl - UPDArr 12
WBlrLI. PIr suprRIUID SIrr
LAPRAIRIf rOWNSBIP, WISCONSIN
~Hgll~iHr PAGES DArr rULI . AurHOR R8CIPIUr DOCUKur. rrPr DOCNUHBBR
90/07/18 Wbeeler Pit Site, lfarzYD lile KeloraDdul 18
. Respoase to IfDIR
v
rerfew COlieDt. for
tbe Dratt leasibility
J Study. COlieDt letter
dated February 18, 1990
b 90/0'7/18 Wbeeler Pit Site, lfarzYD lile HeloraDdul 19
RespoDse to WD'R
review COlleDt. for
tbe Dratt leasibility
Study. COlleot letter
dated Harcb 11, 1990
12 90107/18 Wbeeler Pit Site, WarzYD File KeloraDdul 20
RespoDse to WD'R
cOlleots for tbe
Dratt leasibility
, Study, COlleot
letter dated Harcb
15, 1990
90/08/13 Ifbeeler Pit Osteo, r. Ifarzyo lile HeloraodUi 21
Project',3728.30
attached are pbotos
5 90/08/1 3 Ifbeehr Pit Ostea, '., lfarzYD lile KelouDdUi 12
Project' 13728.30
attached are photos
90/09106 Ifbeeler Pit Site -- 'or" H.I., osrPA lile KuoraDdul 23
Chroaolog, ot Breat.
coaceraiag Bzteasioa
of the Public COlleat
Period aDd Scheduliag
ot a Heetiag witb tbe
PRPs
90/08/00 Health Hazard Reriew State of riscoosia, DBSS Otber 24
Series Ifbeeler Pit
90/08/08 Phooe record re, '0", H.I.,OSBPA Petersoo, r. PboDe Record 25
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. J1; ~ J.
) 9 ':iJ '~iJ
.' '
'[CHEIll/ANE PAGES DArE
-
, J46
61
90/02/17
89/~1/00
JZJ
90/03/00
ADNIMIsrRArlfl RICORD INDBI - UPD,TB 12
rHIBLIR Plr SUPIRfUND SIrB
LAPRAIRII rorNSHIP, rISCONSIN
rIfU
!
l,ceasioa ot Public
COlleat Period tor
rbeeler Pit
Sectioa 8.0
ladaagerleat Assessleat
Reledial Iavestigatioa
aad feasibility Study
recbaical Neioraadul 11
rork Plaa Reledial
Iatestigatioa aad
feasibility Study
,
AurHOR
farzya
rarzya ragiaeeriag
rarzya ragiaeeriag
Iacorp.
RICIPIUr
DOCUHlar rrPI
Report/Studies
Respoadeats Steeriag Reports/Studies
COli
Respoadeats Steeriag Reports/Studies
COli
:.-
, DOCNUHSIR
26
27
28
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::" ,10
ADHIRISrRAfIVE RECORD IRDEI - UPDArE ; 2
PUBLIC COMMurs
WHEELER PIf'SUPER1UID SIrE
LAPRAIRIE rO'RSHIP, 'ISCO.SI.
HK/FRANK PAGIS DArK rrru AurHOR RlCIPIlRr DOCUN"r rrPl DOC/iUHBKR
90/07/15 Co..ent$ tor. vitb . Scott, J. USIPA Poblic COllent$
~ handvr1tten co..ents
concerning veIl
conta.ination due to
; tbe vaste disposal
58 ~0/OS/08 rraoscript ot 'beeler Pit USIPA Public COllents 2
, P roceeding$
18 90/08/13 Letter re: enclosed Kolberg, D., 'arzTn 'O'T, K.B.,USIPA Public COllent' 3
tor review are 'srzTo',
respenses to 'DRR's
co..ent letter on the
public reviev 1S.
29 90/08/13 Letter re: responses Kolberg, D., 'arzTn '0", N.B.,USIPA Puhlic COllents 4
.. tc USEPA July 11, 1990
CCllent letter cn Public
Revi elf FS
90/08/13 Letter r~: in r~gar~s Kolberg, D., 'srzTn '0", If.B.,USIPA Poblic COllents 5
to Ad.inistratire
Record: attached is a
ccpy ct the iodel
143 90/08/13 Letter r!: torvardiog Kolberg, D., 'srzyo USBPA Public COlleots 6
tbe su..aries co tbe
co..ents on Wheeler
Pit
90/08/13 Letter re: Request rbunan, 5., G/f la", If.B.,USIPA Public COllents 7
tor delistiog tre.
/iPL
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