United States
Environmental Protection
Agency
Office 01
Emergency and
Remedial Response
EP A/RODIR05-91/164
June 1991 .
C0.lf L
'PB '12~ 76 Lj !I(
"oEPA
Superfund
Record of Decision:
Fadrowski Drum Disposal, WI
'\
u . ~. Environmental Proteqtion Ag«cf
Region III Hazardous Waste ..""
Technical Information Center
841 Chestnut Street, 9th Floor
Philadelphia, PA 19107 "
Hazardous Waste CollectiOn
Information Resource Center
US EPA Region 3
Philadelphia, PA 19107
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REPORT DOCUMENTATION 11. AEPORT NO. I ~ 3. A8cIpIent'8 ACC888Ion No.
PAGE EPA/ROD/ROS-91/164
T11I8 8nd SWtl1l8 5. A8port D8t8
SUPERFUND RECORD OF DECISION 06/10/91
Fadrowski Drum Disposal, WI
I.
First Remedial Action - Final
7. Author(8) 8. P8rf0nnlng Org8nlzatlon Rept. No.
O. P8rf0nnlng Org8lnlzatlon N8me 8nd AddI888 10. Project/TuklWork Unit No.
11. Contr8ct(C) or Gr8nt(G) No.
(C)
(G)
1 ~ SpwworIng Org8J1lz8tlon N8me 8nd Addre.. 13. TypII 01 Allport & PerIod Covered
U.S. Environmental Protection Agency
401 M Street, S.W. 800/000
Washington, D.C. 20460 14.
15. Supplem8ntary No..
16. Ab8tr8ct (Umlt: 200 _1d8)
The 20-acre Fadrowski Drum Disposal site is an inactive industrial landfill within the
city of Franklin, Milwaukee County, Wisconsin. Surrounding land use is mixed
residential and commercial. The western portion of the site lies within the
floodplain of the Root River, and approximately nine acres of wetlands are located
on site. From 1970 until 1982 when the property was sold, the site was an unregulated
and unlicensed landfill allowed only to receive clean earth fill containing
construction debris. However, hazardous waste, including several hundred drums of
unknown material and lubricant sludges, were illegally buried onsite. State
investigations in 1981 identified evidence of improper disposal of solid wastes
including crushed drums, and boiler and foundry wastes. In 1982, the site was
purchased by Menard, Inc. with plans to use the property as a source of fill material.
In 1983, excavation began onsite and during this work various containers of waste and
sludge were uncovered, some drums were inadvertently crushed, and liquids and sludge
were released into onsite soil. The State directed the site owners to contain the
exposed waste until it could be sampled and characterized, but instead the owners
constructed berms, then covered the waste material with clay, without approval. The
(See Attached Page)
17. ~t An8Jy8l8 L DncrIpIora
Record of Decision - Fadrowski Drum Disposal, WI
First Remedial Action - Final
Cont'aminated Media: soil, sediment, debris
Key Contaminants: VOCs (toluene, xylenes), other organics (P AHs, pesticides (DDT),
metals (arsenic, chromium, lead)
b. Identifler8lOpen-Ended T......
Co COSA 11 FIeIdIGroup
16. Av1l18b111ty St8tement 10. S8cwfty CI- (Th18 Report) 21. No. 01 P8ge8
None 76
I 211. S8cwfty CI- (ThI8 P8ge) ~ PrIce
IITnnt>
on .._-~
~ )
50272-101
(888 ANSl-Z30.16)
SHIn8ln1Cllona
Re..,..
(Formelty NTlS-35)
Dep8rtment 01 Conwnerce
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EPA/ROD/R05-91/164
Fadrowski Drum Disposal, WI
\irst Remedial Action - Final
Abstract (Continued)
Remedial Investigation/Feasibility Study (RI/FS) was conducted by a Potentially
Responsible Party, Acme Printing Ink, Co. The RI located several buried drums and
identified locations likely to contain additional buried drums. Miscellaneous low-level
soil and sediment contamination was also delineated. Groundwater in the thick,
continuous layer of clay below the site was found to contain low levels of cyanide,
mercury, chromium, and barium. U.S. EPA sampling has shown that nearby residential
water supplies have not been impacted by the contamination. This Record of Decision
(ROD) addresses soil contamination to prevent or reduce the migration of contaminants
into the ground water. The primary contaminants of concern affecting the soil,
sediment, and debris are VOCs including toluene and xylenes; other organics including
PAHs and pesticides including DDT; and metals including arsenic, chromium, and lead.
The selected remedial action for this site includes excavating previously identified
drums and 25 cubic yards of hazardous soil, and recycling, or treating and disposing of
the drummed waste offsite; constructing trenches to locate and excavate additional
containerized waste and the surrounding characteristically hazardous soil; treating any
contaminated soil onsite, followed by offsite disposal of the residuals; constructing a
landfill cap and a leachate collection system, and disposing of any leachate exceeding
State levels offsite at a publicly owned treatment works (POTW) or RCRA treatment
facility; allowing natural attenuation to remediate ground water; monitoring ground
water and surface water for 30 years to ensure effectiveness of the cap; and
implementing institutional controls to limit land and ground water use, and site access
restrictions such as fencing. If ground water conditions worsen or do not improve over
, reasonable period of time, EPA may evaluate the options for a ground water treatment
rogram. The estimated present worth cost for this remedial action is $2,230,000, which
includes an annual O&M cost of $32,100 for 30 years.
PERFORMANCE STANDARDS OR GOALS: Through removal of buried drums and the containment of
remaining low-level contamination, it is anticipated that ground water will meet
clean-up standards through natural attenuation. Ground water clean-up standards are
based on Wisconsin Preventive Action Limits (PALs), which are more stringent than
Federal standards.
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DECLARATION
SELECTED REMEDIAL ALTERNATIVE
FOR THE .
FADROWSKI DRUM DISPOSAL SITE
FRANKLIN, WISCONSIN
Statement of Basis and Purpose
This decision document presents the selected remedial action for
the Fadrowski Drum Disposal Site, Franklin, Wisconsin, which was
chosen in accordance with the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) of 1980, as amended by the
Superfund Amendments and Reauthorization Act (SARA) of 1986, 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 (ROD), 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. The
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 buried drums at
the site have been identified as a principal threat warranting
treatment.
The major components of the selected remedy include:
Excavation of previously identified drums and
associated characteristically hazardous soils;
Construction of trenches to find and excavate
additional containerized waste and associated
characteristically hazardous soils;
Off-site recycling or treatment and disposal
of drummed wastes;
Treatment and disposal of contaminated soil;
Construction of a landfill cover (cap) in compliance
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2
with Chapter NR 504.07, Wisconsin Administrative Code
(WAC) landfill closure requirements;
Use of institutional controls on landfill property to
limit land and groundwater use; and
Monitoring of groundwater and surface water to ensure
effectiveness of the remedial action and evaluate the
need for future groundwater treatment.
statutorv Determinations
The selected remedy is protective of human health and the
environment, complies with Federal and state requirements that are
legally applicable or relevant and appropriate to the remedial
action, and is cost effective. This remedy utilizes permanent
solutions and alternative treatment or resource recovery
technologies to the maximum extent practicable and satisfies the
statutory preference for remedies that reduce the toxicity,
mObility, or volume as a principal element.
Because this remedy will result in 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.
Letter of Concurrence is attached to this ROD.
The
41
G/tO/I/
,
Valdas V. Ada
Regional Admi
Date
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.
~
State of Wisconsin \ DEPARTMENT OF NATURAL RESOURCES
Ca"otl D. Se..dny, Secretary
Box 7921
Madl80n, M8con.'n 53707
T£L.EFAX NO. 608-267.3579
TDD NO. 608-267.6897
SOUD WAST£ T£L.EFAX NO. 608-267.2768
May 29, 1991
IN REPLY REFER TO:
4440
Mr. Va1das V. Adamkus, Regional Administrator
U.S. Environmental Protection Agency
230 South Dearborn Street
Chicago, IL 60604
SUBJECT:
Selected Superfund Remedy
Fadrowski Drum Disposal Site
City of Franklin, Milwaukee County, WI
Dear Mr. Adamkus:
The Department is providing you with this letter to document our position on
the proposed remedy for the Fadrowski Drum Disposal Superfund Site. The
proposal, as identified in the draft Record of Decision, includes the
following:
Fencing of the site and implementation of deed restrictions.
Limited investigation to locate additional buried drums.
Removal .of drums and associated contaminated soil and debris.
Management of all excavated wastes in accordance with Wisconsin's
interim waste management guidelines.
Installation of a clay cap which meets NR 504.07 requirements over the
1 andfi 11 area.
Long-term monitoring of groundwater and any collected surface water.
The total 30 year present net worth for the Fadrowski Drum Disposal Site is
estimated to be approximately S2,230,000, of which SI,930,000 is estimated to
be capital cost and the annual operation and maintenance costs are estimated
to be S32,100 per year. The Department concurs with the preferred remedy, as
described above and discussed in detail in the Record of Decision.
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We un~erstand that if the potentially responsible parties (PRPs) do not agree
to fund the remedy, the State of Wisconsin will contribute 10 percent of the
capital costs, 10 percent of the first year operation and maintenance costs,
and 100 percent of the remaining operation and maintenance costs associated
with this remedy. .
We also understand that our staff will continue to work in close consultation
with your staff during the design and construction of the operable unit
remedies.
Thank you for your support and cooperation in addressing this contamination
problem. If you have any questions regarding this matter, please contact Mr.
Paul Didier, Director of the Bureau of Solid and Hazardous Waste Management,
at (60B) 266-1327.
Sincerely,
c~.
secretary!dny \
CDB:cv
cc:
Lyman Wible - AD/S
Linda Meyer - LC/S
Paul Didier - SW/3
Frank Schultz/Felix Binyoti - SOD
Mary Pat Tyson/Terese VanDonsel - EPA Region V (SHS/ll)
Mark Giesfeldt/Sue Bangert/Celia VanDerLoop - SW/3
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RECORD OF DECISION SUMMARY
Fadrowski prum Disposal Site
Franklin, WISCONSIN
SITE RAKE, LOCATION, AND DESCRIPTION
1.0
The Fadrowski Drum Disposal Site (FDDS) is located on
approximately 20 acres of semi-rural land in the southeast quarter
of section 1, Township 5 North, Range 21 East, Milwaukee County.
The site is situated within the boundaries of the City of Franklin,
which is located just outside of. the Milwaukee city limits.
Between 1970 and 1982, the FDDS was owned by Edward J. Fadrowski
(Fadrowski) and operated as an unregulated, unlicensed landfill.
In 1981, the Wisconsin Department of Natural Resources (WDNR)
received a complaint from a former employee alleging that the
property was used for the disposal of hazardous waste and that
several hundred drums of unknown material and lubricant sludges
were buried there. Early in 1983, Menard, Inc. purchased a portion
of the land and began construction of Menard's home improvement
center. Buried drums and sludges were uncovered during excavation.
The FDDS is located in an area of gently sloping ground
moraine and is on the west slope of a north-south-trending morainal
ridge (see Figure 1). Land surface elevations at the FDDS range
between 755 and 785 ft above mean sea level, which is about 175 to
205 ft above the level of Lake Michigan, approximately five miles
to the east. The primary fill area is located on the southern
third of the site, starting approximately 900 ft west of 27th
street. This area is marked by numerous small piles of concrete.
and asphalt rubble that extend westward for approximately 240 ft.
Directly west of the primary fill area there is an abrupt change in
elevation (approximately 30 ft) and slope (approximately 60
percent) westward to a man-made pond. Along the northern site
boundary adjacent to Menard's storage area, there is a storm sewer
outfall that slopes westward leading to the stream which forms the
western site bounqary.
The man-made pond is approximately 360 ft long and 120 ft
wide. Based on historic aerial photographs, a 1964 topographic map
and discussions with local residents, the pond and the flat area
west of the pond are not natural features. They were created
during the removal of material for the construction of the Menard
facility just north of the site. The u.s. Environmental Protection
Agency (u.s. EPA) evaluated the FDDS for ecological significance
and determined that there are approximately nine acres of wetlands,
over which the U. S. Army Corps of Engineers has jurisdiction,
present on the western edge of the pond. In addition, although the
. western portion of the site is located in a floodplain, there is no
. indication that fill areas containing waste lie within the
regulatory limits of the floodplain.
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FIGURE 1 -
FADROWSKI DRUM DISPOSAL
SITE FEATURES MAP
SITE
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ORIGINAL
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NOTES
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3
The unnamed stream that forms the western site boundary is a
tributary of the Root River that apparently has been straightened
and channelized at some time in the past. The stream carries
overflow water from Mud Lake located in Grobschmidt Park,
approximately one-quarter mile north of the site and also receives
stormwater discharge from 27th street and the Menard's parking lot
via the stormwater outfall and sewer previously described.
The southern site boundary from the Gilbert Puetz residence
westward is marked by a line of trees, except in the area adjacent
to the primary fill area. Fill on the FDDS and the adjacent
property to the south are contiguous in this area and the tree line
has been buried by filling from both sides. The U. S. Department of
Housing and Urban Development notified..U. S. EPAthat this property
to the south of the site is a possible site for the development of
low-income family housing.
The area surrounding the site is a mixture of residential and
commercial developments. There are several residences with private
wells located within 2,000 feet of the site, but drinking water has
not been impacted from the contamination at the Site.
The three generalized geologic units at the FDDS consist of:
(1) clay till; (2) undifferentiated sand, gravel, silt and clay;
and (3) dolomite bedrock. The clay till unit at the FDDS is the
Oak Creek formation, and is a clayey silt to silty clay with an.
average composition of 12 percent sand, 44 percent silt, and 44
percent clay. The clay till unit appears to be between 80 to 100
ft thick at the FDDS, and appears to be continuously saturated up
to within 3 to 10 ft of ground surface. Although this unit is
saturated, the soils are of such low permeability that they will
not sustain domestic use.
The clay in the clay till unit has been separated based on
color into two units, the brown and the gray clay. The brown clay
consists of the upper weathered surface of the Oak Creek till and
is a hard, yellow-brown lean clay. The thickness of this weathered
layer varies across the FDDS due to excavation of material, but is
approximately 8 ft thick in the relatively undisturbed areas of the
FDDS along the stream. The gray clay consists of the unweathered
Oak Creek till and is similar in composition to the brown clay.
The difference in color is probably the result of oxidation of the
till.
The undifferentiated sand, gravel silt and clay unit was not
penetrated during this study; thus site-specific information
regarding its nature and occurrence is not available. Review of
well construction reports indicate that this unit is heterogeneous,
being comprised of interbedded layers of sand and gravel, silt, and
clay. Where adequate thickne~ses of sand and gravel are present,
this unit will yield adequate amounts of water to support domestic
use. Several domestic wells in the vicinity of the FDDS are
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4
completed within this unit.
The dolomite bedrock unit also was not investigated as part of
this study. The Dolomite Bedrock unit is the primary source of
groundwater for domestic wells in the FDDS vicinity.
A more complete description of the site can be found in the
Remedial Investigation/Feasibility study (RI/FS) reports.
2.0
SITE HISTORY AND ENFORCEMENT ACTIVITIES
Between 1970 and 1982, the FDDS was owned and operated by
Fadrowski as an unregulated, unlicensed landfill. Pursuant to
applicable state regulations, the operation would have been exempt
from regulation (Chapters NR 151 and NR 180 of the Wisconsin
Administrative Code) if Fadrowski had only disposed of solid waste
consisting of clean earth fill, containing less than 25% by volume
of brick, concrete, and building stone. During the same timeframe,
Fadrowski was also the principal of a waste collection and
transportation company called Ed's Masonry & Trucking, Inc. (Ed's
Trucking). Ed's Trucking was licensed by the WDNR to collect and
transport noncombustible waste, wood matter, refuse and garbage.
The customers of Ed's Trucking consisted of a wide variety of local
businesses and industries, which generated a variety of wastes.
A WDNR inspection of the FDDS conducted in February 1981, .
disclosed that Fadrowski had been disposing of non-exempt solid
waste at the FDDS without a license. The WDNR had warned Fadrowski
that he could not dispose of regulated solid waste at the FDDS;
however, Fadrowski did not apply for a solid waste disposal
license. Later that same year, Marcia Smith (Smith), a former
employee of Ed's Trucking, telephoned in a complaint to the WDNR in
which she informed the agency of her belief that substantial
quantities of non-~xempt wastes were being disposed of at the FDDS
by Fadrowski. WDNR employees again inspected the FDDS and found
further evidence of non-exempt solid waste disposal, including
metal, wood, foundry waste, crushed drums and slag-type boiler
waste.
Later in 1981, the City of
provide a schedule for bringing
ci ty , s code. Fadrowski did
requirements.
Franklin requested that Fadrowski
the FDDS into compliance with the
not comply with the City code
In December 1982, Menard, Inc. purchased the FDDS. Menard
also purchased the two other parcels adjacent to the FDDS to the
north, on which it planned to build its store. Menard planned to
use the FDDS as a source of fill material to change the grades of
the other parcels and make all three properties suitable for
commercial development. Excavation and grading work began in early
May 1983. During this work, various-sized containers of waste and
sludges were uncovered, and their contents inadvertently released
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5
on the property as work continued. The excavation process
'continued until June 28, 1983, when a bulldozer operator ran over
a drum containing an unknown liquid material. The drum was
ruptured and the contents squirted out. The Franklin Fire
Department was notified and it, in turn, contacted the WDNR. A
hazardous waste investigator for the WDNR arrived at the FDDS and
saw several drums exposed, all of which were crushed to some degree
with their contents oozing out. The WDNR investigator took
pictures and sampled the waste at the FDDS for analysis by the
state Laboratory of Hygiene.
The WDNR directed Menard to retain a consultant to perform
waste analyses and arrange for containment and storage of exposed
waste material until it could be properly disposed of. An
environmental consulting firm retained by Menard arrived at the
FDDS the' next day to collect additional samples of the exposed
materials. Samples were collected and split with WDNR. Due to the
fact that luggar boxes could not be readily obtained and plastic
covering material was not available, plus the fact that rain was
forecast for that evening, it was decided that on-site clay should
be used to construct containment berms and to cover selected
portions of the exposed waste material. Areas of exposed waste on
the west end of the excavation were surrounded by a berm to contain
any runoff, but was not covered because of concerns about its
location and consistency. The WDNR felt the waste would be more
difficult to locate again, and the berm was felt to be adequate to
contain the material and any runoff.
The following morning, Menard ordered the contractor to cover
all of the exposed waste and waste mixtures with at least two ft of
clay. The WDNR arrived at the FDDS later that day, and found that
all of the previously exposed waste had been buried on the orders
of Menard, without consulting the WDNR.
The WDNR advised Menard that it was Menard's responsibility to
properly characterize the waste material by conducting appropriate
chemical analyses and, if the waste proved to be hazardous, arrange
for the proper disposal. After burying the wastes at the FDDS:
however, Menard did not allow its' consultant to perform the
laboratory analyses requested by the WDNR. The WDNR was informed
of Menard's orders not to run the chemical analyses on the waste
samples and WDNR again requested that Menard have the analyses
performed. However, Menards refused to analyze the samples they
had collected. As a result, the only data generated on the
characteristics or composition of the exposed waste in 1983 was the
data generated by the State Laboratory of Hygiene on samples
obtained by WDNR. '
Initial laboratory analyses of the WDNR waste samples
indicated that the drum contents were hazardous, as defined by
Chapter NR 181 of the Wisconsin Administrative Code (WAC). Samples
contained high concentrations of lead (32,700 ppm), chromium {6,800
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6
ppm), the pesticide DDT (1,450) and a trace of arsenic (less than
5 ppm). The samples. were also analyzed for volatile organic
compounds (V-OCs) and were found to contain petroleum-derived
hydrocarbons, but not chlorinated hydrocarbons. Ignitability test
resul ts for the WDNR waste samples indicated that other wastes
sampled at the FDDS were characteristic hazardous wastes because
their flash point was below 140. F. .
U.S. EPA and the State of Wisconsin signed an Administrative
Order by Consent with Acme Printing Ink Company in May of 1987.
Acme Printing Ink conducted the RI/FS under U. S. EPA and WDNR
supervision.
3.0
HIGHLIGHTS OF COMMUNITY PARTICIPATION.
A community relations plan was developed in 1987 to document
community concerns and to plan an information strategy. U.S. EPA
held four public meetings and one informal availability session to
keep the public informed about the activities at the site. U.S.
EPA also sent out fact sheets and letters at various times during
the RI/FS process.
As part of its community relations program, U.S. EPA
maintained two information repositories: one at the Franklin
Public Library and the other at the Franklin City Hall. Both are
located at 9229 West Loomis Road, Franklin, Wisconsin. All formal
reports submitted by the Potentially Responsible Parties (PRPs)
during the Fadrowski Drum Disposal 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 FDDS.
To encourage public participation in the selection of a remedial
alternative, U.S. EPA scheduled a public comment period from April
8, 1991 to May 8, 1991. Additionally, on April 25, 1991, U.S. EPA
held a public meeting to discuss the recommended remedial
alternative and the other alternatives identified and evaluated in
the FS. A transcript of this meeting is included as part of the
Administrative Record for the Fadrowski Drum Disposal 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 both Franklin and Milwaukee,
Wisconsin, media, and advertisements were placed in the Milwaukee
Journal and the Franklin Hub concerning the public meeting and
comment period.
4.0
SCOPE AND ROLB OF RESPONSE ACTION
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7
The selected remedy for the Fadrowski Drum Disposal site is
intended to be the final response action at the site. The remedy
will combine- source control, treatment, site access and land-use
restrictions, and long-term groundwater monitoring. In summary,
the selected remedy will include the limited excavation of
containerized waste and associated characteristically hazardous
soil from the fill area, grading the site in preparation for
capping, and the installation of an NR 504.07 cap. The remedy will
also require fencing of the site, the restriction of site use via
land use restrictions, and long-term groundwater and surface water
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.
The existence of buried drums has been identified as a
principal threat warranting treatment. The contents and condition
of the drums are not fully known and their presence at the FDDS
consti tutes a potential future threat to human health and the
environment. Therefore, to the extent practicable, containerized
waste and associated characteristically hazardous soils will be
excavated from the site, treated, and managed in accordance with
wisconsin waste management guidelines and Federal Land Disposal
Restrictions. The level of contamination remaining on site after
removal of containerized wastes and associated characteristic
hazardous soils can be reliably controlled over time through
engineering and institutional controls. .
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. .
5.0
SUMMARY OF SX~E CBARACTERXSTXCS
See Appendix A for ranges of contaminants found in each media.
GROUNDWATER
Groundwater in the clay till unit flows to the west at the
FDDS. The water table is between 3 and 10 ft below ground surface.
Water in the lower dolomite aquifer flows generally eastward
towards Lake Michigan. Groundwater flow in the undifferentiated
sand, gravel, silt and clay unit and in the dolomite bedrock is
generally eastward towards Lake Michigan.
The clay till unit described in section 1.0 appears to be
continuously saturated up to within 3 to 10 ft of ground surface
based on observations collected during the RI. Although the unit
is saturated, in-field permeability testing show that the clay has
a relatively low permeability. The calculated hydraulic
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8
. conductivities ranged from between 2.1 x 10-5em/sec and 3.1 x 10-7
cm/sec and between 4.6 x 10-6em/sec and 6.2 x 10-8cm/sec using the
Hvorslev Method. Horizontal groundwater flow in the Clay Till at
the FDDS is to the west towards the man-made pond and the stream.
Horizontal hydraulic gradients are quite variable across the FDDS,
due to changes in topography. Calculated horizontal gradients
generally ranged between 0.01 and 0.06 ft/ft. Vertical hydraulic
gradients at the FDDS are downward and varied between 0.02 and 0.55
ft/ft. The aver,ge linear velocities at the FDDS were calculated
to be 1.9 x 10- em/sec assuming an average horizontal hydraulic
gradient of 0.02 and 2.6 x 10-6 assuming an average vertical
hydraulic gradient of 0.28.
Although there were very few inorganic' or. organic compounds
observed. at elevated levels in groundwater at the FDDS, the
groundwater in the clay till unit was found to be impacted by the
contamination at the FDDS. Cyanide (max. 67 ppb) , chromium (max.
13 ppb) and barium (max. 273 ppb) were found in groundwater
throughout the clay till at levels exceeding Wisconsin Preventive
Action Limits (PALs). Benzene was found above the PAL at 3 ppb at
well P-2 during the first round of sampling, but was not found
during the second round. Mercury was detected at 2.3 ppb in well
P-3 during the first round of sampling, but was not found during
the second round. The level of mercury detected at the site
exceeded Wisconsin Enforcement Standards (ESs).
Surface Water/Sediments
Surface water exists on site in the form of a man-made pond in
the west-central part of the FDDS. The pond intercepts most of the
surface water runoff from the FDDS and also receives groundwater
discharge from the FDDS. There were no organic compounds detected
in the surface water of the pond. Cyanide levels appear to be
elevated due to contributions from the FDDS with levels of 40 ug/L
and 47 ug/L (duplicate).
Surface water also exists on site in the form of a stream on
the western boundary of the FDDS. There were low levels of VOCs
detected in the unnamed stream. The downstream sample contained
ethylbenzene and xylenes. However, neither of these compounds were
detected on site. Cyanide levels were elevated both upstream (28
ug/L) and downstream (36 ug/L). Mercury was found downstream at a
level of 0.2 ug/L and was not detected upstream. No semi-
volatiles, pesticides or polychlorinated biphenyls (PCBs) were
detected in stream samples.
Sediments were collected from the on-site pond. Acetone was
the only VOC detected in the sediments. The detection of acetone
is acknowledged as a probable laboratory artifact, because no
acetone was detected in associated surface water samples. Sediment
analyzed from the pond did not detect any polynuclear aromatic
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9
hydrocarbons (PARs). Sediment from a drainage-swale area to the
southeast of the pond was analyzed and found to contain 3,840 ug/kg
total PARs. However, this drainage-swale sample point is on
property adjoining the FDDS and is now under approximately 10 to 15
ft of fill. .
Sediments from the unnamed stream contained several organic
compounds (mostly semi-volatiles). Many semi-volatiles were
detected in the upstream samples, but the highest concentrations
were detected in the downstream sample. Surface runoff or seeps
from the primary fill pile may be impacting downstream sediments in
the stream. Total PARs downstream (2,350 ug/kg) are approximately
five times those upstream (490 ug/kg). Several metals, including
aluminum, barium, beryllium, calcium., lead and magnesium had
slightly elevated downstream levels.
Surface soil/Subsurface Soil
One surface soil sample was collected at the base of the
western slope of the primary fill pile on the south-central part of
the FDDS. The organic and inorganic character of this sample is
similar to the character of the subsurface soil samples collected
on site. PARs were detected frequently and at the highest
concentrations of organics (total PARs 10,290 ug/kg). It appears
runoff or seeps from the fill pile may be impacting surface soil
adjacent to the fill and west to the unnamed stream.
Subsurface soils were collected predominantly from the area
containing construction and demolition debris mixed with native
clay. Toluene was the predominant VOC detected in fill samples and
was found in levels ranging from 34 ug/kg to 1,800 ug/kg. Toluene
was detected in each fill sample and is likely from on-site
sources. The PAR group of semi-volatiles were detected frequently
and at the highest concentrations of semi-volatiles. The maximum
total PARs found was 24,300 ug/kg. PARs are commonly associated
with coal tars. Foundry sand encountered in the test pits was
analyzed and also contained PARs.
Test pits
Test pit excavations were performed mainly in areas containing
a mixture of construction debris and native soil. The chemical
character of the fill material is similar to that of the subsurface
soil borings. Toluene was the VOC detected most frequently, with
concentrations ranging from 29 ug/kg to 240 ug/kg. Several other
VOCs were detected in test pit samples, but at lower concentrations
than toluene. PARs were the most frequently detected semi-
volatiles, with total PARs ranging from 1,100 ug/kg to 180,000
ug/kg. Levels of 4,4-DDT and its associated degradation products
were found in several test pi~s at concentrations ranging from 120
ug/kg. to 310 ug/kg. The PCB Aroclor 1254 was detected in three of
seven test pits, with a maximum concentration found of 1,900 ug/kg.
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10
A large number of inorganic elements were detected in test pits at
concentrations exceeding baseline concentrations. Total cyanide
was detected -in one test pit at 6,360 ug/kg, with the results from
the other test pits considered unusable due to matrix problems.
There were no analytical samples collected from the
containerized waste and sludge located in the primary fill pile on
the south-central part of the FDDS. Knowledge of drum contents is
limited to information gathered by the WDNR previous to the RI.
WDNR results revealed drums containing high concentrations of DDT
(1,450 ppm), chromium (6,800 ppm), lead (32,700 ppm) and low levels
of arsenic (less than 5 ppm). The samples were also analyzed for
VOCs and were found to contain petroleum-derived hydrocarbons, but
not chlorinated hydrocarbons. The drum contents were identified as
characteristic hazardous waste due to their toxicity and because
ignitability tests revealed that their flash points were below
140.F. Information gathered for litigation suggests that
additional containerized waste, with distinct chemical profiles,
could also be buried at the site.
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 Risk
Assessment Guidance for Superfund (RAGs): Volume I, Human Health
Evaluation Manual.
After evaluating potential current and future exposure
pathways at the si te, 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. Thes~ exposure scenarios are:
1.
Trespasser Scenario: A trespasser would be exposed to
contaminated surface soils, sediment and surface water
currently on site via ingestion and dermal absorption.
This scenario assumed that a child (age 5-15) would
trespass twice a week, eight months/year, for 10 years.
2.
Groundwater Scenario: Children living on-site would
drink contaminated water from a private well and come in
contact with contaminated fill material. It is assumed
that the child (age 1 to age 21) would live in the
residence and be exposed to contaminants for 21 years.
Al though this length of exposure is slightly shorter than
the 30 years recommended by RAGs, the body mass was time-
weighted to estimate a child's weight. This ensured that
the exposure scenario would be more conservative than the
30 years of exposure at 70 kg ordinarily estimated for
adults. In addition, the scenario is extremely
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11
conservative in that it assumed the most contaminated
water from an aqui tard was used for residential purposes,
al though the aqui tard i tsel f would not even support
residential use. .
3.
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,
five days/week, for eight months. This future risk
scenario is one of the most likely, since this site was
purchased for commercial development.
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 carcinogenic
chemical is called a slope factor, and the constant for a
noncarcinogen is called a reference dose.
The results of these calculations are estimates of cancer risk
for carcinogenic risks and estimates of Hazard Indices for
noncarcinogenic risks. The cancer risk number is expressed in.
scientific notation and represents an estimate of the increased
risk of getting cancer. For example, 1.0 x 10-6represents a risk
of one additional case of cancer per 1 million people, under the
exposure conditions assumed. U.s. EPA considers this 1.0 x 10-6
number as a point of departure when determining risk at a site.
Risks calculated to be less than this value are considered
protectiv! of huma~ heal~h and the environment, while risks between
1.0 x 10- and 1.0 x 10- are within a range acceptable to U.s. EPA
but may not be considered protective due to site-specific
conditions. Risks greater than 1.0 x 10-4are unacceptable.
The Hazard Index (HI) represents the risk of adverse effects
occuring due to exposure to the site. The 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 estimates that no
adverse effects will occur due to the hypothetical exposure, while
a Hazard Index greater than 1 estimates that adverse effects due to
site exposure may occur and is not protective of human health and
the environment. .
Table 1 summarizes the cancer risk numbers and HI values
calculated for each chemical under the current land-use scenario.
Table. 2 summarizes future residential risk and hazard index values
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12
and Table 3 summarizes the future construction worker scenario.
The numbers listed in these tables represent the maximum exposure
conditions by using the greatest concentration of a chemical found
in each media or the 95 percent upper-bound confidence limit of the
arithmetic mean. The cUn\ulative risk for each scenario is included
beneath each table.
In summary, the risk assessment highlights two potential
future risks at the site (refer to Tables 1, 2 and 3):
1.
a possible carcinogenic risk of 4.5 x 10-6 under the
current scenario for children trespassing on the site and
swimming in the pond:
a possible carcinogenic risk of 1.3 x 10-5 under the
future residential scenario for children who would live
and play at the site for 21 years. This incluQes a 1 x
10-~isk from consumption of contaminated water from the
aauitard:
a possible carcinogenic risk of 9.7 x 10-7 under the
future scenario for construction workers on site five
days a week for eight months.
2.
3.
While U. S. EPA review of the RI determined that the Risk
Assessment adequately evaluates exposure to low-level contamination.
found in soils, sediments, surface water and groundwater, the Risk
Assessment failed to evaluate possible contact with the principal
threat, concentrated containerized waste buried at the site. While
it is difficult to evaluate these risks because of data collection
ommissions concerning the contents of drums found during the RI and
uncertainties surrounding numbers of drums buried at the site, the
u.s. EPA Region V Office of Health and Environmental Assessment has
approximated the worst case risks from exposure to drum contents
for residential and construction worker scenarios. Its evaluation
used WDNR sampling results from 1983, when Menard, Inc. began
construction of Menard's home improvement center and originally
uncovered buried drums. The evaluation found that:
1.
Should the site be developed residentially and, for some
reason, containerized waste is exposed at the surface,
the risk from a child living afd playing at the site for
21 years would exceed 1 x 10- .
The hazard index from possible future residential contact
with containerized waste exceeds 100.
2.
3.
Under the future scenario, risks to construction workers
who would work in the soil and come into contact with
containerized waste five days a week for eight months
would increase their cancer risk by greater than 1 x 10-4
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13
4.
The hazard index from possible future contact under a
construction worker scenario exceeds 100.
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. .
14
TABLE 1
HAZARD QUOTIENTS AND CANCER RISKS DUE TO EXPOSURE TO FILL AND SEDIMENT
CURRENT LAND USE CONDITIONS
HAZARD QUOTIENTS CANCER RISKS
Chemical Dermal Contact Inqestion Dermal Contact Inqestion
VOLATILES
Acetone S.Se-05 1.6e-06 ND ND
Carbon Disulfide 1.le-06 2.1e-OS ND ND
1,1-Dichloroethane 7.0e-07 1.2e-OS 9.0e-10 1. 6e-11
Chloroform 7.0e-06 1. 2e-07 6.1e-11 1.1e-12
1,1,1-Trichloroethane 5.Se-07 1.Se-OS ND ND
Trichloroethene ND ND 2.5e-10 4.6e-12
Benzene ND ND 3.Se-10 6.ge-12
Tetrachloroethene 1.3e-04 5.4e-06 9.2e-09 3.ge-10
Toluene 1.4e-04 2.5e-06 ND ND
Ethylbenzene 4.6e-07 2.1e-OS ND ND
Xylene 1.3e-07 5.4e-09 ND ND
SEMIVOLATILES
Phenol 3.1e-04 5.5e-06 ND ND
Di-n-butylphthalate 1. 4e-05 4.6e-06 ND ND
Butyl Benzyl Phthalate 1.ge-06 6.2e-07 ND ND
Bis (2-ethylhexyl) Phthalate 3.1e-03 5.Se-05 1. 2e-07 2.3e-09
PAHs(noncarcinogen) 4.4e-03 1.2e-02 ND ND
PAHs(carcinogen) ND ND 1. 2e-OS 4.2e
PESTICIDES/PCBs
Heptachlor 2.ge-05 1. Se-05 9.2e-09 5.7e-09
Aldrin 1.2e-05 2.1e-04 S.Se-10 1.5e-OS
4,4-DDT 9.5e-06 2.6e-04 2.3e-10 6.3e-09
4,4-DDD ND ND ND ND
4,4-DDE ND ND ND ND
Chlordane 7.Se-04 5.3e-03 S.7e-09 5.ge-OS
PCBs ND ND S.5e-10 S.le-OS
METALS
Antimony S.le-06 1. 5e-03 ND ND
Zinc 3.6e-06 6.5e-04 ND ND
Cadmium 4.2e-05 7.5e-03 ND ND
Lead 2.3e-03 4.2e-Ol ND ND
Mercury 2.1e-06 3.Se-04 ND ND
cyanide 7.4e-07 1. 3e-04 ND ND
Nickel 7.6e-05 1.4e-02 ND ND
TOTAL (~y exposure route) 1.1e-02 4.6e-01 1.7e-07 4.3e-06
TOTAL (all exposure routes) 4.7e-01 4.5e-06
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15
TABLE 2
HAZARD QUOTIENTS AND CANCER RISKS DUE TO EXPOSURE TO FILL
FUTURE LAND USE CONDITIONS
Chemical
HAZARD OUOTIENTS
Dermal Contact Inqestion
CANCER RISKS
Dermal Contact Inqestion
VOLATILES
Carbon Disulfide
l,l-Dichloroethane
Chloroform
l,l,l-Trichloroethane
Trichloroethene
Benzene
Tetrachloroethene
Toluene
Ethylbenzene
Xylene
SEMIVOLATILES
Phenol
Di-n-butylpphthalate
Bis (2-ethylhexyl) Phthalate
PAHs(noncarcinogen)
PAHs(carcinogen)
STICIDES/PCBs
rteptachlor
Aldrin
4,4-DDT
4,4-DDD
4,4-DDE
Chlordane
PCBs
METALS
Antimony
Lead
Cadmium
Nickel
cyanide
Mercury
Zinc
TOTAL (by exposure route)
TOTAL (all exposure routes)
1. 8e-06
1. le-06
3.6e-06
9.le-07
ND
ND
2.0e-04
2.2e-04
7.3e-07
2.0e-07
4.ge-04
2.2e-05
4.8e-03
6.ge-03
NO
4.5e-05
l.ge-05
1. 5e-05
ND
ND
1. 2e-03
ND
1. 3e-05
3.7e-03
6.6e-05
l.2e-04
1. 2e-06
3.3e-06
9.ge-06
2.3e-08
1. 4e-08
4.6e-08
2.1e-08
ND
NO
6.0e-06
2.8e-06
2.3e-08
6.0e-09
NO
3.0e-09
6.7e-ll
NO
8.1e-10
l.3e-09
3.0e-08
NO
ND
NO
6.2e-06
5.le-06
6.5e-05
1. 3e-02
NO
ND
NO
4.0e-07
NO
4.ge-08
2.0e-05
2.3e-04
2.ge-04
NO
NO
5.ge-03
NO
3.0e-08
2.ge-09
7.6e-lO
NO
NO
2.ge-08
2.8e-09
1. 6e-03
4.7e-Ol
8.3e-03
l.5e-02
l.5e-04
4.2e-04
1. 3e-03
NO
NO
NO
NO
NO
NO
NO
NO
3.8e-ll
8.5e-l3
ND
1.le-ll
1. 6e-ll
9.2e-10
ND
NO
NO
NO
NO
5.4e-09
ND
1. 2e-05
1. 3e-08
3.5e-08
l.5e-08
NO
NO
l.4e-07
l.ge-07
NO
NO
NO
NO
ND
NO
ND
1.8e-02 5.1e-01
5.3e-01
5.5e-07 1.2e-05
1.3e-05
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16
TABLE 3
HAZARD QUOTIENTS AND CANCER RISKS DUE TO EXPOSURE TO FILL
FUTURE LAND USE CONDITIONS
HAZARD OUOTIENTS CANCER RISKS
Chemical Dermal Inaestion Inhalation Dermal Inaestion Inhalation
Contact Contact
VOLATILES
Carbon Disulfide 4.2e-06 3.4e-08 ND ND ND ND
1,1-Dichloroethane 2.5e-07 2.0e-09 2.0e-11 3.3e-10 2.6e-12 ND
Chloroform 8.5e-06 6.8e-08 ND 7.4e-12 5.ge-14 7.5e-15
1,1,1-Trichloroethane 2.1e-07 3.0e-09 8.7e-12 ND ND ND
Trichloroethene ND ND ND 9. 3e-11 7.4e-13 1.1e-14
Benzene ND ND ND 1. 4e-10 1.le-12 1.1e-14
Tetrachloroethene 4.6e-05 8.8e-07 ND 3.3e-09 6. 4e-11 4.0e-14
Toluene 3.8e-04 3.0e-06 2.1e-08 ND ND ND
Ethylbenzene 1.7e-07 3.4e-09 ND ND ND ND
Xylene 2.3e-07 4.4e-09 2.0e-09 ND ND ND
SEMIVOLATILES
Phenol 1.le-03 9.0e-06 ND ND ND ND
Di-n-butylpphthalate 5.2e-06 7.4e-07 ND ND ND ND
Bis(2-ethylhexyl)Phthalate 1.le-02 9.5e-05 ND 4.3e-08 3.8e-10 ND
PAHs(noncarcinogen) 1.6e-02 1.ge-02 ND ND ND ND
PAHs(carcinogen) ND ND ND 5.4e-09 8.2e-07 4.2e-09
PESTICIDES/PCBs
Heptachlor 1.0e-04 2.ge-05 ND 3.3e-09 9.3e-10 8.. ..2
Aldrin 4.4e-05 3.4e-04 ND 3.2e-10 2.5e-09 2. 4e-11
4,4-DDT 3.5e-05 4.2e-04 ND 8. 5e-11 1.0e-09 9.8e-12
4,4-000 NO NO NO NO NO NO
4,4-DDE ND NO ND NO NO ND
Chlordane 2.ge-03 8.7e-03 ND 3.2e-09 9.7e-09 9. 3e-11
PCBs NO NO NO 3.1e-10 1.3e-08 NO
METALS
Antimony . 3.0e-05 2.4e-03 ND NO ND NO
Lead 8.5e-03 6.8e-01 NO ND ND NO
Cadmium 1.5e-04 1. 2e-02 ND ND ND 1.0e-08
Nickel 2.8e-04 2.2e-02 NO ND ND 5.1e-08
Cyanide 2.7e-06 2.2e-04 NO ND NO NO
Mercury 7.6e-06 6.1e-04 ND ND ND ND
Zinc 2.3e-05 1.8e-03 ND ND ND NQ
TOTAL (by exposure route) 4.0e-02 7.5e-01 2.3e-08 6.0e-08 8.5e-07 6.6e-08
TOTAL (all exposure routes) 7.ge-01 9.7e-07
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17
6.1 UNCERTAINTIES
since it is unknown how many drums of waste are buried at the
site, there is significant uncertainty concerning the magnitude of
the threat posed to public health and the environment. In
addi tion, uncertainties concerning drum contents result in an
unquantifiable explosive risk if the site were to be significantly
disturbed.
Although historical data is usually not considered in
assessing risks, because the presence of buried drums at the site
constitutes an imminent threat to public health and the
environment, u.s. EPA determined that it is appropriate to consider
this data. .
The Risk Assessment also could not quantify risks from those
contaminants without known slope factors or reference factors.
There is also no method available to quantify risks and possible
synergistic effects due to exposure to multiple contaminants.
6.2 ENVIRONMENTAL RISKS
Approximately nine acres of wetlands are located on the west
side of the man-made pond at the FDDS. No threatened or endangered
species were identified in the area affected by contamination at
the site.
Levels of cyanide in the surface water at the site exceed
Clean Water Act Ambient Water Quality criteria for the Protection
of Aquatic Life. Cyanide was found in the pond and in both
upstream and downstream samples of the unnamed stream. Although
cyanide was found upstream of the site, its presence in the pond
and in site groundwater suggests that the site is contibuting to
the contamination ~f the stream. with the inevitable degradation
of drummed waste buried at the site, the pond, the stream and the
wetlands are at significant risk for large increases in contaminant
loading should releases of concentrated waste occur. Lead,
chromium, and DDT were identified in drums on site and their
release could impact the health of plant and animal species living
at and near 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
six alternatives were developed during the Alternatives Array.
and FS stage of the project. Based on the levels of contaminants
detected in the groundwater and the limited extent of groundwater
contamination, no groundwater alternatives were among the six
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18
. alternatives. The alternatives evaluated in the FS Report are
source-control actions which rely on natural attenuation to remedy
the groundwater contamination. The remediation goals are to:
.
treat the principal threat (containerized waste) to the
extent practicable;
reduce the threat of direct contact with the waste;
.
.
reduce the infiltration of water into the waste which
might lead to further groundwater contamination;
.
reduce contamination to surface waters on site; and
.
achieve PALs where technically and economically feasible.
The six alternatives are summarized in Table 4 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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19
TABLE 4
SUMKARY OF ALTERNATIVES AND COSTS
1
No Action
Institutional controls1
Fencing of site
Deed Restrictions
Groundwater monitoring for 30 years'
2 is not Protective of HUlllln Health and the
and therefore will not be exami ned further in th i s
Alternative 1:
Alternative 2:
Alternative
Envi ronnent
docunent.
Alternatives 3A and 3B:
containment
Fencing of site
Deed Restrictions
Groundwater/Surface Water Monitoring
for 30 years
Cap fill area with either:
A) - wisconsin 504 cap
B) - RCRA Subtitle C compliant cap
Construct leachate collection trench
Monitoring and Maintenance of cap for 30
years
lternative 4:
Excavation of Drums & contaminated Soil and
Fence site during excavation
Groundwater/Surface Water Monitoring
for 30 years
Excavation and treatment and/or
drums and contaminated soil and
reach risk-based cleanup levels
Debris
disposal of
debris to
or background
Al ternati ves SA and 5B:'
Limited Excavation of Drums and containment
Fencing of Site
Deed Restrictions
Groundwater/Surface Water Monitoring
for 30 years
Unearth previously identified drums and
excavate to locate additional drums
Remove, treat and/or dispose of drums and
associated characteristically hazardous soils
Cap fill area with either:
A) - Wisconsin 504 cap
B) - RCRA Subtitle C compliant cap
Construct leachate collection trench
Monitoring/Maintenance of cap for 30 years
I
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20
TABLE 4 - continued
SUMMARY OF ALTERNATIVES AND COSTS
Alternative 6:
In-Situ vitrification lISV)
Fence site during treatment
Deed Restrictions
Groundwater/Surface Water Monitoring
for 30 years
Treat fill area using ISV
Alt. Alt. Alt. Alt. Alt. Alt. Alt.
1 3A 3B 4 * SA * 5B * 6
capital 0 1. 73 M 3.6 M 11.2 M 1.93 M 3.8 M 63.3 M
a & M 0 32,100 32,100 22,700 32,100 32,100 22,700
NPW ** 0 2.03 M 3.9 M 11. 4 M 2.23 M 4.1 M 63.5 M
ESTIMATED COSTS
*
Note:
Approximate costs for additional material
(costs based on incineration of hazardous materials and
Subtitle D disposal of non-hazardous soils)
$1,400 /drum containing characteristically
hazardous material
$
$
750 /cubic yard characteristically hazardous soil
57 /cubic yard non-hazardous soils
** Note:
Present net worth cost is calculated over a 30 year period
at a 10 percent discount rate.
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. Al ternati ve 1:
21
No Action
The NCP requires that u.s. EPA evaluate a no-action
alternative. It is used as a basis of comparison during the
evaluation of other alternatives. Under this alternative, u.s. EPA
would take no further action at the site to monitor, control,
treat, or otherwise clean up contamination. The cost of this
alternative is zero. However, since waste would be left on site,
a five-year review of conditions at the site would be required.
This alternative would not reduce the threat of direct contact
with the waste or reduce the infiltration of water into the
contaminated fill area. This alternative was not found to be
protective of human health and the environment.
Alternative 2:
Institutional Controls
Under this alternative, U.s. EPA would take no action to
address contamination at the site. The alternative relies on
access restrictions and monitoring to reduce risks at the site.
The alternative would include construction of a fence around the
site to prevent site access. Restrictions would also be placed on
the property deed to control future use of the site. In addition,
Alternative 2 includes a 30-year groundwater and surface water
monitoring program.
This alternative was not found to be protective of human
heal th and the environment and therefore will not be carried
forward for further evaluation.
Alternative 3:
Containment
Under this alternative, one of two cap systems would be
installed over the .waste at the site. Descriptions of the caps are
provided below:
Cap A:
Cap B:
This cap is a solid waste landfill cap which would
meet RCRA Subtitle 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 landfill cap which
would meet RCRA landfill closure regulations and
RCRA guidance for design of Subtitle C closure.
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
vegetative cover.
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22
Both caps would provide a barrier between the ground surface
and the waste to prevent direct contact. Each cap also requires a
hydraulic co,ductivity in the low permeability layer of not more
than 1 x 10- ,which would limit water infiltration.
A leachate collection trench would also be constructed as part
of the cap. The trench would serve as a means to monitor cap
effectiveness and would include the capacity to store and remove
any collected liquids should the liquids be contaminated. If
Wisconsin PALs are exceeded, leachate would be disposed of
appropriately to a POTW or RCRA treatment facility.
Although not in a regulatory floodplain, the
elevation would reach the toe of the containment.
relevant and appropriate floodplain requirements,
containment would be armored to prevent washout.
Other components of this alternative are installation of a
fence around the site, institutional controls, and a program to
monitor groundwater, surface water and the performance of the cap.
100-year flood
To comply with
the toe of the
Time to Implement:
One construction season
(spring, summer, fall)
Estimated Cost:
Cap A -
Capital: $ 1.7 million
O&M: $ 32,100 per year
Present Net Worth: $ 2.0 million
Capital: $ 3.6 million
O&M: $ 32,100 per year
Present Net Worth: $ 3.9 million
Cap B -
Alternative 4:
Excavation of Drums and Contaminated Soil & Debris
The entire fill area of the FDDe would be excavated to meet a
risk-based cleanup level of 1 x 10- ,or background, (whichever is
greater). This alternative would constitute "clean closure" of the
site. All characteristically hazardous waste material would be
removed and managed in accordance wi th Federal Land Disposal
Restrictions and Wisconsin waste management guidelines. Other
components of this alternative are fencing during the excavation
program, institutional controls to limit future site use and a 30-
year program to monitor groundwater and surface water. The costs
presented below assume that 100 drums containing hazardous
materials and 25 cubic yards of characteristically hazardous soils
would be excavated and incinerated off site. The costs assume that
142,000 cubic yards of soil with low levels of contamination .would
be removed and disposed of off site at a solid waste landfill.
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23
This alternative will effectively remove the source of
contamination, thus eliminating the direct contact threat and the
cause of groundwater contamination.
Time to Implement:
Estimated Cost:
Capital:
O&M:
Present Net
One construction season
Worth:
$ 11. 2 million
$ 22,700
$ 11.4 million
Removal of additional material would increase
approximately $1,400 per drum, $750 per cubic yard of
soil, and $57 per additional cubic yard of soil with
contamination.
costs by
hazardous
low level
Alternative 5:
Limited Excavation/Containment
Portions of the fill area of the FDDS would be excavated to
remove previously identified drums. Approximately six trenches
would be dug to locate additional drums. All drums found and any
associated characteristically hazardous soil would be removed and
managed in accordance with Federal Land Disposal Restrictions and
Wisconsin waste management guidelines. Because of the unknown
nature of the wastes buried at the site, waste characterization
will be necessary to determine the appropriate method for handling
excavated materials. In accordance with the Wisconsin "Interim.
Policy for Promoting the In-State and On-Site Management of
Hazardous Wastes in the State of Wisconsin", there will be a
preference for recycling hazardous wastes removed from the site.
If recycling is determined not to be feasible, the waste will be
treated with any residuals disposed of off-site. If drum contents
prove to be non-hazardous, the waste would be placed off-site in a
RCRA Subtitle D di~posal facility.
Under this al ternati ve, one of two cap systems would be
installed over the remaining waste at the site. Descriptions of
Cap A and Cap B are provided under the description of Alternative
3 (Containment). Both caps would provide a barrier between the
ground surface and the waste to prevent direct contact. Each cap
. also requires a hydraulic conductiv~ty in the low permeability
layer of not more than 1 x 10-, which would limit water
infiltration.
As in Alternative 3, a leachate collection trench would also
be constructed as part of the cap. The trench would serve as a
means to monitor cap effectiveness and would include the capacity
to store and remove any collected liquids should the liquids be
contaminated. If Wisconsin PALs are exceeded, leachate would be
disposed of appropriately to a POTW or RCRA treatment facility.
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24
Although not in a regulatory floodplain, the
elevation would reach the toe of the containment.
relevant and appropriate floodplain requirements,
containment would be armored to prevent washout.
Other components of this alternative are installation of a
fence around the site, institutional controls, and a program to
monitor groundwater, surface water and the condition of the cap.
The costs presented below assume that 50 drums containing hazardous
materials would be excavated and incinerated off site.
100-year flood
To comply with
the toe of the
Time to Implement:
One construction season
(spring, summer, fall)
Estimated Cost:
Cap A -
capital: $ 1.9 million
O&M: $ 32,100 per year
Present Net Worth: $ 2.2 million
Cap B -
Capital: $ 3.8 million
O&M: $ 32,100 per year
Present Net Worth: $ 4.1 million
Removal of additional material
approximately $1,400 per drum and
characteristically hazardous soil.
would
$750
increase costs
per ,cubic yard
by
of,
Alternative 6:
In-Situ Vitrification CISV)
In-situ vitrification would be used to treat contaminants in
the fill area. ISV uses electrically generated heat to virtually
mel t the soil. The high temperature generated in the process
(2,900.F to 3,600~F) destroys many contaminants. Once the soil
cools, contaminants which were not destroyed by the heating process
are immobilized in the resulting glass-like material. Once the ISV
has been completed, a soil cover would be placed over the treated
area. Other components of this al ternati ve are insti tutional
controls to limit future site use and a 30-year program to monitor
groundwater and surface water.
This alternative will effectively remove the source of
contamination, thus eliminating the direct contact threat and the
cause of groundwater contamination.
Time to Implement:
Estimated Cost:
Capital:
O&M:
Present Net
Seven Years
Worth:
$ 63.3 million
$ 22,700 per year
$ 63.5 million
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25
8.0
COMPARATIVE ANALYSIS OJ' ALTERNATIVES: '!'BE 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
Overall Protection of Human Health and the Environment
1.
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 3 through 6 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. Alternatives 3 and 5 provide protection against
water infiltration, which would reduce the potential for
release of contaminants to the groundwater. The caps in
Alternatives 3 and 5 would also serve to protect against
contact with waste materials. Alternative 4 would excavate
contaminants to safe levels, thereby virtually eliminating the
source of groundwater contamination and the source of risk.
Alternative 5 would excavate a portion of the waste at the
site, thereby offering less risk to groundwater than
containment alone. Alternative 6 would immobilize
contaminants and eliminate the potential for a future release
of contaminants to the groundwater.
2.
ComDliance with ADDlicable
Reauirements lARARs)
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.
or
Relevant
and
ADDroDriate
i.
Identification of ARARs
a.
Closure
State closure requirements (Chapter NR 600 et. seq., WAC)
for hazardous waste landfills are not 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 the requirements of section NR 506.08 or section NR
504.07, WAC, the current State solid waste landfill closure
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26
requirements. These requirements are applicable to the site.
In part, section NR 504.07, WAC, requires that the cap be
composed of a 2-foot layer of compacted clay overlain by a
frost-protective soil layer. Caps A and B considered in
Alternatives 2 and 4 meet the requirements of section NR
504.07, WAC. Chapters NR 514 and NR516, WAC are ARARs for
landfill cap construction and documentation.
Subtitle C landfill requirements, while relevant, have
been determined not to be appropriate based on the specific
circumstances of this site. This determination was made
because of the nature of the site as a solid waste landfill.
and the known hazardous properties of the waste, its
composition and matrix, and the nature of the releases from
the site. First, since a portion of the landfill waste is
below the water table, the additional precipitation
infiltration reduction achieved by a subtitle C geomembrane
cap (versus a clay cap) will not significantly affect the
contaminant loading caused by immersed waste. Second,
according to available records, no RCRA listed hazardous waste
was disposed of at the site. Third, groundwater contamination
appears to be limited because of the thick, continuous layer
of clay below the waste. Finally, there is a very limited
release of hazardous substances into the groundwater. For
these reasons, it has been determined that a Subtitle C cap is
not appropriate in light of the circumstances of the site.
b.
Groundwater Standards
1.
Federal ARARs
Maximum contaminant Levels (MCLs), and to a certain
extent, Maximqm 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 FDDS, MCLs and MCLGs are
not applicable, but are relevant and appropriate, since the
sand and gravel and dolomite aquifers are presently being used
in the area surrounding the site and could potentially be used
as a source for drinking water 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 I at the boundary of the
landfilled wastes or throughout the plume if wastes are
removed from the site.
2.
state A1U\Rs
The State of wisconsin has promulgated groundwater
quality standards in Ch. NR 140, WAC, which are applied to all
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27
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 PALs and ESs, which are described in
detail in section NR 140.10, WAC. The chemicals at the site
which exceed these standards are discussed in Section 5.0.
PALs and ESs, contained in Section NR 140.10, WAC, are
generally more stringent than corresponding Federal standards
set forth under the SDWA and are applicable to the FDDS.
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
140.20, WAC, the WACL that is established under section NR
140.28 may not exceed the ES for that compound. 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 monitoring wells, u.s. .
EPA in consultation with the State will re-evaluate
groundwater remediation alternatives to determine whether or
not it is technically or economically feasible to achieve the
PAL or any previously established WACL.
The remedy will achieve PALs contained in section NR
140.10, WAC, unless WACLs are established pursuant to the
criteria in section NR 140.28, WAC, in which case WACLs will
be met. These standards will be met in accordance with the
NCP, at the waste boundary or throughout the groundwater plume
if wastes are removed from the site.
Mercury was detected within the waste boundary at a level
exceeding ESs. Alternative 5A qualifies as a potential
response according to Table 6 of Ch. 140, WAC, "Range of
Responses for Exceedance of Enforcement Standards for
Substances of Health or Welfare Concern." In addition to
mercury, several other contaminants were detected in levels
exceeding PALs. Alternative 5A also qualifies as a potential
response according to Table 5 of Ch. 140, WAC, "Range of
Responses for Exceedance of a Preventive Action Limit for
Indicator Parameters and Substances of Health and Welfare
Concern." .
c.
Land Disposal Restrictions (LDRs)
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. .
28
Another set of RCRA regulations which may be an ARAR at
the site are LDRs, 40 CFR Part 268. Waste would be moved from
the site in Alternatives 4 and 5 during excavation, treatment
and redisposal. Al ternati ve 4 , under the excavation and
treatment option, may trigger LDR requirements. Because it is
known that some of the drums buried at the site contain
characteristic hazardous wastes, LDRs would be applicable for
disposal of those wastes.
ii. Discussion
As discussed earlier, solid waste closure, construction
and documentation standards are ARARs for this site. The
landfill covers in Alternatives" 3 and 5 meet current wisconsin
requirements for solid or hazardous waste landfill closures.
section NR 140, WAC, is an ARAR. containment would
likely mitigate future releases in excess of PALs at the waste
management boundary and beyond. Al though no groundwater
treatment actions are evaluated in the FS, it is estimated
that groundwater contaminant levels would 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.
Alternative 3 would significantly reduce infiltration.
Alternative 4 would be effective in that it would virtually
eliminate the source of groundwater contamination.
Alternatives 5A and 5B would eliminate the principal threat to
the maximum extent practicable and cap' the fill area to
significantly reduce infiltration into remaining waste.
Alternative 6 would treat the contaminated area by virtually
immobilizing the waste, thereby eliminating the groundwater
contamination route.
The caps in Alternatives 3 and 5 would also help minimize
any future risks from the site. The cap, if maintained, would
prevent future direct contact with contaminants and reduce
infiltration which would minimize any future releases into the
groundwater from the site. It is expected that capping would
result in future compliance with wisconsin statutes which
require that future releases of contaminants not exceed State
groundwater quality standards.
B.
primarv Balancina criteria
3.
Lana-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.
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29
Under Alternative 1 (no action), protection from direct
exposure would not be achieved and water infiltration would
not be reduced. Alternatives 3 and 5 will provide adequate
protection assuming the cap is maintained. This is because
Al ternati ves 3 . and 5 remove the direct contact threat and
reduce water infiltration into the disposal area. However,
the long-term effectiveness and permanence of Alternatives 3
and 5 are dependent on proper monitoring and upkeep of the
containment system. Alternatives 4 would be effective in the
long term in that only safe levels of contamination would be
left on site. Alternative 6 would destroy or immobilize
contaminants at the site, thereby offering a virtual permanent
remedy.
4.
Reduction of Toxicitv. Mobilitv or Volume Throuah Treatment
This criterion evaluates the anticipated performance of
the treatment technologies a remedy may employ.
Al ternati ves 1 and 3 would not reduce the toxicity,
mobility, or volume of contaminants through treatment. These
alternatives do not meet the statutory preference for
treatment. Alternatives 4 through 6 would reduce toxicity,
mobility and volume through treatment or recycling.
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.
Al ternati ve 3 would involve moving a small amount of
waste at the site for construction of the cap. Minimal risks
to nearby residents posed by dust from digging during the
implementation of Alternative 3 would be controlled through
standard dust control measures. Heal th risks to workers would
be minimized wi th protective equipment. There would be a
fence around the site during construction activities which
will protect nearby residents. This fence would remain after
construction activities are completed. Alternative 4 involves
full excavation of drums and contaminated soil and debris.
Alternative 5 involves limited excavation of drums and
associated characteristically hazardous soil. Alternative 6
would use ISV to treat the contaminants at the site.
Al ternati ves 4 and 5 pose short-term risks stemming from
possible significant movement of waste material, with the
primary risk being the potential explosive hazard posed by
drum removal. Alternative 4 would pose significantly more
short-term risk than Alternative 5 because of the volume of
waste and fill that would require excavation. Use of ISV
(Alternative 6) in an area with buried drums near the surface
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30
also poses potential explosive hazards. However, the
explosive hazards and any dust and noise nuisances would be
mitigated with standard safety programs, such as fencing, use
of protective equipment, monitoring and dust control measures.
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. All alternatives with
the exception of Al ternati ve 6 could be completed in one
construction season. Alternative 6 would require 7 years to
complete cleanup at the site.
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.
6.
ImDlementabilitv
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 3 through 6 are technically feasible.
Alternatives 3 and 5 utilize traditional technologies
(capping, excavation/capping) and would be easily
implementable at the site. Alternative 4, "clean closure,"
would be difficult to implement because of the large volume of
fill that is potentially contaminated and contains drums.
Alternative 6, ISV, would be extremely difficult, if not
impossible to implement, at the site. The FDDS contains a
large variety of debris (including concrete, rebar, paint
cans, etc.). .Drums may also be buried near the surface. ISV
is not recommended for sites with deep fill areas containing
such diverse waste materials.
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 4.
Modifyina Criteria
C.
8.
state AcceDtance
WDNR concurs with the selected alternative.
9.
Communitv AcceDtance
Community
acceptance
is
assessed
in
the
attached
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31
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. .
9.0
THE SELECTED REMEDY
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 5A
-- limited excavation of drums and associated characteristically
hazardous soils: a NR 504.07, WAC, cap: institutional controls and
groundwater monitoring -- as the most appropriate remedial action
for the FDDS.
Under Alternative 5A, 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 1 x 10-7cm/s 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 may also be
included as part of the cap on top of the clay layer to enhance
drainage off the clay layer. Testing will be conducted to assure
all waste is contained under the cap.
Institutional controls will be relied upon to enhance the
effectiveness of the remedy, including deed restrictions, well
installation restrictions, and landfill development restrictions
(NR 506). A cyclone fence will also be installed around the site.
Additional groundwater monitoring wells will be installed to more
fully characterize the groundwater system. New and existing wells
will be monitored for at least 30 years.
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 hot-spot remediation is complete and 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 the FDDS, which is the suggested NCP point of compliance for
groundwater. The groundwater clean up standards which have been
established are PALs; unless WACLs are established pursuant to the
criteria in section NR 140.28, WAC, in which case WACLs will become
the clean up standards.
The initial review of the groundwater monitoring data will be
conducted within five years after the commencement of remedial
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32
action. Thereafter, the monitoring data will be reviewed at no
longer than five-year intervals. In the event that conditions at
the site degrade, or the remedy does not provide for timely
improvement of groundwater, the u.s. EPA and WDNR will consider
additional actions. .
Table 5 presents the details of the cost for the selected
alternative.
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33
TABLE 5 - DETAILED COST BREAKDOWN OF SELECTED ALTERNATIVE
NR 504 CaD with container Removal
.PITAL COSTS OUANTITY UNIT UNIT COST
DEED RESTRICTIONS 1 @ $ 10,000.00
:ONTAINER REMOVAL
a. Excavation & Backfill 1000 cy $ 12.00
b. Container staging Area 1 @ $ 1,200.00
c. Overpack container 50 @ $ 120.00
d. Sampling Cost for Disposal 50 @ $ 720.00
e. Transport Containers to
Incinerator 1 LS $ 2,400.00
f. container Incineration 50 @ $ 528.00
g. Management of Haz Soils 12 cy $ 750.00
h. supervision and container
Handling (2) 1 LS $ 33,000.00
i. Additional Fill Sampling 10 @ $ 2,000.00
CAP (per NR 504.07)
a. Grade site 11900 cy $ 3.00
b. Import Soil
- 6" topsoil 9060 cy $ 9.25
- 18" soil 27180 cy $ 8.00
- 24" clay 36240 cy $ 9.25
- soil to meet min. slope 25500 cy $ 8.00
c. Place Soil for Cap Construction
- 6" topsoil 9060 cy $ 2.00
- 18" soil 27180 cy $ 2.87
- 24" clay 36240 cy $ 3.00
- vegetate cover 54440 sy $ 0.25
- soil to meet min. slope 25500 cy $ 2.87
d. Construct Leachate Collection Trench
- excavation 324 cy $ 3.03
- pipe placement 250 ft $ 8.00
- manhole construction 1 ea $ 1,800.00
- 1/2" to 2" stone 85 cy $ 12.50
- backfill trench 239 cy $ 2.00
e. Construct Floodplain Protection
- filter fabric 400 sy $ 2.00
- rip rap 130 cy $ 15.00
Subtotal
Construction Management (20%)
Design Engineering (15%)
Construction Documentation (10%)
TOTAL CAPITAL COST
NET PRESENT WORTH OP 0 , H
TOTAL NET PRESENT WORTH
COST
$ 10,000
$ 12,'000
$ 1,200
$ 6,000
$ 36,000
$ 2,400
$ 26,400
$ 9,000
$ 33,000
$ 20,000
$ 35,700
$ 83,805
$ 217,440
$ 335,220
$ 204,000
$ 18,120
$ 78,007
$ 108,720
$ 13,610
$ 73,185
$ 982
$ 2,000
$ 1,800
$ 1,063
$ 478
$ 800
$ 1,950
$1,333,000.
$ 266,606
$ 199,950
$ 133,300
$1,930,000
$ 300,000
$2.230.000
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34
10.0
STATUTORY DBTBRKIHATIONS
The selected remedy must satisfy the requirements of section
121 (a-e) of CERCLA, as amended by SARA, to: .
Protect human health and the environment:
Comply with ARARs (or justify a waiver):
Be cost effective:
utilize permanent solutions and alternative treatment
or resource recovery 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 5A at the FDDS satisfies
the requirements of CERCLA, as amended by SARA, as detailed
below:
a.
b.
c.
d.
e.
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 influence of site as a source of groundwater
contamination. Since groundwater contaminant loading will
be reduced due to the removal of a portion of the waste and
the decreased infiltration of water through the cap,
groundwater quality is expected to improve over time.
No unacc~ptable short-term risks will be caused by the
implementation of the remedy. The community and site
workers may be exposed to explosive hazards from excavation
of drums and 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.
b.
ComDliance with ARARs
The selected remedy will comply with all Federal and
State ARARs. The following ARARs will be attained.
1.
Chemical-sDecific ARARS
Chemical-specific ARARs regulate the release to the
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35
environment of specific substances having certain chemical
characteristics. .
Applicable or Relevant and Appropriate Requirements
- Ch. NR 140, WAC, and Ch. 160, Wisconsin statutes.
- SDWA MCLs and MCLGs
2.
Location-sDecific ARARs
Location-specific ARARs are those requirements that
relate to the geographical position of a site.
Applicable Requirements
- 40 CFR Part 6 Appendix A sets forth u.s. EPA policy
for carrying out the provisions of Executive Orders 11988
(Floodplain Management) and 11990 (Protection of Wetlands).
It requires action to avoid or minimize adverse impacts on
wetlands, and to preserve and enhance the natural values of
wetlands and floodplains.
3.
Action-sDecific ARARs
Action-specific ARARs are requirements that define.
acceptable treatment and disposal procedures for hazardous
substances.
Applicable or Relevant and Appropriate Requirements
- Land Disposal Restrictions (LDR), 40 CFR Part 268
- solid waste landfill closure requirements of Ch. NR
504, 506, 514' and 516, WAC. Regulates the design,
operation, construction and documentation of landfills.
- Ch. NR 600 et. seq., WAC. Regulates manifesting,
transport, recycling, management, and disposal of excavated
hazardous waste.
- Additional state action-specific ARARs can be found
in the FS Report.
"To Be Considered" Requirements
- CERCLA Off-site Policy. (May 12, 1986), Revised
November 13, 1987, OSWER DIR. 9834.11.
- Wisconsin ItInteri~ POlicy for Promoting the In-state
~nd On-Site Management of Hazardous Wastes in the State of
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36
Wisconsin" provides a prioritization outline for the
treatment and disposal of hazardous wastes and is a "to-be-
considered" for the site.
c.
Cost Effectiveness
A cost-effective remedy is one for which the cost is
proportional to the remedy's overall effectiveness. Table 4
lists the costs associated with the implementation of
Alternatives 1 through 6. Table 5 provides a detailed
breakdown of the costs associated with the selected
alternative.
d.
Alternative SA affords a high degree of effectiveness
by excavating and treating a portion of the principal
threat, providing protection from exposure to remaining
contaminants in the waste and minimizing the infiltration of
water into the remaining waste. Clean closure of the site
to reduce source levels of contamination to acceptable
levels (Alternative 4) is greater than four times the cost
of limited excavation with a cap and does not provide a
significant benefit proportional to its cost. Although
Alternative 3 (containment) is less expensive than
Alternative SA, it does not treat the principal threat or
satisfy the statutory preference for treatment. Alternative
6, ISV, is prohibitively expensive and may not be
implementable due to the variety of waste and debris buried
at the site. Alternative SB, which includes limited
excavation with a RCRA subtitle C compliant cap would be
more expensive than its solid waste counterpart (SA) and
provide limited additional benefits. Therefore, Alternative
SA 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 believes and the state of Wisconsin concurs that
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 FDDS. Of the
alternatives that are protective of human health and the
environment and comply with ARARs, U~S. EPA has 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 and at less
cost than the total excavation alternative.
-------
37
The selected remedy represents the maximum extent to
which permanent solutions and treatment can be practicably
utilized for this action, since the waste mass poses a low-
level, long-term threat. To the extent practicable, "hot
spots" are being addressed through excavation and removal of
drums. The level of contamination remaining on site can be
reliably controlled over time through engineering and
institutional controls, and treatment of the entire fill area
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.
e.
Preference for Treatment as a Principal- Element
The FDDS contains construction debris, sludges and buried
drums. The presence of the buried drums has been identified
as a principal threat because of the potential for further
contamination of the environment as the condition of the drums
degrades. Therefore, the excavation of drums has been
selected as the most practical way to address concentrated
site contamination. Specific decisions concerning the actual
treatment of the hazardous wastes will be made on a drum by
drum basis, per Wisconsin waste management guidelines.
Therefore, satisfaction of the preference for treatment as a
principal element of the remedy is satisfied.
11.0
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for the FDDS site was released for public
comment on April 8, 1991. The Proposed Plan identified
Alternative SA which includes limited excavation of drums and
associated characteristically contaminated soils, a solid waste
landfill clay cap with groundwater monitoring as the recommended
alternative. U.s. 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. However, based on the response to PRP comments,
U.s. EPA would like to note that the selected alternative may
incorporate some consolidation of contaminated soil and debris in
an effort to minimize the extent of the cap and the loss of
potentially useful land.
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. .
1
Appendix A
ORGANIC AND INORGANIC ANALYTES DETECTED
Analvte Concentration
Humber of Locations
S&mDled for Anal vsis
positive
Detection
Environmental
edium Analyte Minimum Maximum Total
Monitoring Volatiles YSILIt YSILIt
Wells
Chloromethane 0.5 0.5
Carbon Disulfide 0.6 0.6
Benzene 3 3
Acetone 3 5
semi volatiles u U
Pesticides/PCBs U U
Metals/CN YSILIt YSILIt
Arsenic 2 2
Barium 69 273
Calcium 69,300 297,000
chromium, Total 10 13
Mangesium 21,800 487,000
Manganese 119 655
Mercury 2.3 2.3
Sodium 14,900 121,000
Zinc 24 24
Cyanide, Total 5 67
Surface Volatiles YSILIt YSILIt
'ater -
.reek Toluene 3 3
Bthylbenzene 3 3
Total Xylenes 4 .-
Semivolatiles U U
Pesticides/PCBs U U
Metals/CN YSILIt YSILM
Barium 50 51
calcium 90,000 93,000
Magnesium 41,900 42,700
Manganese 85 90
Mercury 0.2 0.2
8
1
2
1
2
6
o
6
o
6
1
5
«»
6
1
6
1
4
2
1
1
~
2
o
2
o
2
2
2
2
2
1
-------
Enviromaental
Medium
ADalyte
Minimum
Maximum
Humber of Locations
S"Dled for ADalvsis
positive
Detection
Total
2
ADalvte concentration
sodium 57,000 57,400 2
Zinc 29 40 2
Cyanide 28 36 2
Surface Volatiles U U 1 0
Water -
Pond Semivolatiles U U 1 0
Pesticides/PCBs U U 1 0
Metals/CN ygLJ4 ygLJ4
Aluminum 200 300 1 1
Arsenic 1 1 1
calcium 49,900 50,300 1
Maqnesium 30,400 30,600 1
Manqanese 43 52 1
potassium 5,200 5,400 1
sodium 50,800 51,000 1
Zinc 22 26 1
cyanide 40 47 1
sediment - Volatiles ua/ka ua/ka
.:reek
Acetone 145 145 3 1
Carbon ~isulfide 0.4 0.4 1
Toluene 7 7 1
semivolatiles ua/ka ua/ka
Butylbenllyl-
phthalate 110 110 "
Bis(2-ethylhexyl)-
phthalate 86 86 2
Total PARs
(carcinoqenic) 450 1000 2
Total PARs
(non-carcinoqenic) 330 900 3
Pesticides/PCBs U U 2 0
Metals/CN ma/ka ma/ka
Aluminum 10,500 21,500 3 2
-------
3
ADalvte concentration
N11JDber of Locati'
SamDled for ADal \
...A.
EnviroDmental
Medium
ADalyte
Minimum
Maximum
Total
positive
Detection
Arsenic 3.7 5.1 2
Barium 60 127 2
Beryllium 0.73 1.20 2
Cadmium 4.8 9.2 2
Calcium 9,470 10,500 2
Chromium, Total 18 35 2
Cobalt 7.5 12.0 2
copper 15.0 35.0 2
Iron 16,500 26,000 2
Lead 34 69 2
Magnesium 6,350 9,200 2
MangaDese 337 469 2
Mercury 0.047 0.139 2
Nickel 15 30 2
Potassium 1,230 3,020 2
Selenium 0.6 0.6 1
silver 0.2 0.2 1
Thallium 0.3 0.6 2
Vanadium 26 45 2
Zinc 83 154 2
cyanide U/R U/R )
Sediment - Volatiles ua/ka ua/ka
Pond
Acetone 380 380 1 1
semi volatiles U U 1 0
Pesticides/PCBs U U 1 0
Metals/CN ma/ka ma/ka
AIWlinWl 18,000 18,000 1 1.
Arsenic 4.6 4.6 1
Barium 76 76 1
BerylliWl 1.1 1.1 1
Cadmium 6.4 6.4 1
Calcium 62,100 62,100 1
Chromium, Total 27 27 1
Cobalt 12 12 1
Copper 22 22 1
Iron 21,200 21,200 1
Lead 9.0 9.0 1
Magnesium 29,900 29,900 1
MaDCJaDese 437 437 1
~ /
-------
.wironmental
..'1edi um
4
Analvte Concentration
Humber of Locations
SamDled for Analvsis
positive
Detection
Analyte
Minimum
Maximum
Total
Mercury 0.034 0.034 1
Hickel 28 28 1
potassium 3,310 3,310 1
Thallium 0.4 0.4 1
Vanadium 39 39 1
Zinc 52 52 1
Cyanide U/R U/R 1
soil Borinq
Fill Materials Volatiles ua/ka ua/ka
Acetone 121 121 1 1
Carbon Disulfide 0.5 5 25 3
1,1-Dichloroethane 3 3 1
Total 1,2-Dichloro-
ethene 0.6 0.7 2
1, 1, 1-Trichloro-
ethane 0.8 " 3
Trichloroet.hene 0.8 1 2
Benzene 0.4 0.4 1
Tetrachloroethene 3 32 3
Toluene 34 1,800 24
Et.hylbenzene 0.8 3 4
Total Xylenes 4 4 1
Semivolatiles ua/ka ua/ka
Bis(2-ethylhexyl)-
phthalate 31 1,800 25 18
Total PABs
(carcinoqenic) 450 10,420 11
Total PABs
(non-carcinoqenic) 500 14,600 12.
Pesticides/PCBs ua/ka ua/kq
septhachlor 1,200 1,200 25 1
4,4-DDT 280 280 1
Alpha-chlordane 100 100 1
Gamma-chlordane 670 670 1
Metals/CH ma/ka ma/ka
Aluminum 7,120 20,700 25 25
Arsenic 2 6 25
-------
5
ADalvte Concentration
Number of LocatiC'
Sampled for ADalv...,....;l
nvironmental
Medium
ADalyte
Minimum
Maximum
Total
positive
Detection
Barium 30 103 25
Beryllium 0.6 1.4 24
cadmium 1.5 3.6 25
calcium 4,360 99,900 25
chromium, Total 12 29 25
Cobalt 6 13 24
copper 14 126 25
Iron 11,700 23,300 25
Lead 5.9 136 25
Magnesium 4,700 48,100 25
Manganese 310 738 25
Mercury 0.032 0.043 3
Nickel 14 28 25
Potassium 792 2,690 18
silver 1.7 1.7 1
Thallium 0.1 0.5 23
Vanadium 20 52 25
Zinc 36 133 25
Cyanide VIR VIR 0
Test Pit
Fill Material Volatiles ua/ka ua/ka
Carbon Disulfide 3 5 7 2
1,1-Dichloroethane 0.4 0.7 3
chloroform 0.5 1 6
1,1,1-Trichloro-
..thane 0.5 1 2
Trichloroethene 0.3 7 3
Benzene 1 4 2
Tetrachloroethene 0.9 130 5
Toluene 9 240 5
Bthyll:»enzene 0.9 5 3
Total Xylene. 3 26 ~
semi volatiles ua/ka ua/ka
Butyll:»enzylphthalate 160 300 7 2
Bis(2-ethylhexyl)-
phthalate 59 2,800 4
Total PABs
(carcinogenic) 560 65,600 5
Total PABs
(non-carcinogenic) 690 114,000 7
pesticides/PCBs ua/ka ua/ka
-------
.vironmental
..edium
6
Analvte Concentration
. .1.
1fWDber of Locationa
S_Dled for Anal 'Ysr
posi ti ve;1
Total Detectio~
Analyte
Minimum
Maximum
Bepthachlor 11 11
Aldrin 10 15
4,4-DDT 120 310
4,4-DDS 150 330
4,4-DDD 110 160
Alpha-chlorodane 64 64
Gamma-chlorodane 71 71
AROCLOR-1248 460 460
AROCLOR-1254 140 1,900
Metals/CN mq/kq ma/ka
Aluminum 4,310 14,000
Antimony 0.6 1.4
Arsenic 3 14
Barium 43 134
Beryllium 0.74 12
Cadmium 0.61 18
calcium 15,200 130,000
chromium, Total 13 269
Cobalt 51 51
copper 23 232
Iron 11,800 113,000
Lead 49 868
Magnesium 7,200 36,600
Manqanese 344 1,210
Mercury. 0.039 0.272
Nickel 13 656
potassium 680 1,220
silver 0.1 0.2
Sodium 680 680
Thallium 0.1 0.3
Vanadium 15 171
zinc 82 311
cyanide 6.4 6.4
7
[
~
~
P
I,
i
3
7
7
7
7
7
4
6
7
7
1
7
7
7
7
7
7
7
2
3
1
3
7-
7
1
-------
RESPONSIVENESS SUMMARY
This Responsiveness Summary has been prepared to meet the
requirements of Sections l13(k) (2) (B) (iv) and l17(b) of the
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986, which requires the United States
Environmental Protection Agency (U.S. EPA) to respond "...to each
of the significant comments, criticisms, and new data submitted in
written or oral presentations" 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 Fadrowski Drum Disposal site
(FDDS).
A.
OVERVIEW
I.
BACKGROUND/PROPOSED PLAN
The FDDS is a 20 acre property located at 6865 South 27th
Street in Franklin, wisconsin.
The Remedial Investigation (RI) identified several concerns
at the site. The fill area was found to contain an unknown
number of buried drums containing lead, chromium, the
pesticide DDT and arsenic. The fact that there is
significant uncertainty concerning the number and types of
wastes at the site does not rule out the presence of other
drummed hazardous materials. Soil at the site was found to
be primarily contaminated with Polynuclear Aromatic
Hydrocarbons (PAHs) and slightly elevated levels of metals.
The groundwater below the site was found to be contaminated
with cyanide, benzene, and slightly elevated levels of
metals, including mercury. contamination from many of these
constituents is in excess of state groundwater standards.
The Feasibility Study evaluated four cleanup alternatives
to address these concerns. The Proposed Plan for remedial
action included:
.
Limited removal of drums and associated contaminated
soil and debris;
.
Off-site recycling or treatment and disposal of drummed
waste;
.
Treatment and disposal of excavated contaminated soil;
1
-------
. .
Installation of a solid waste cap to meet current state
landfill closure requirements:
.
Installation of a leachate collection trench to monitor
the effectiveness of the cap:
.
Institutional controls: and
.
Groundwater and surface water monitoring.
II.
PUBLIC COMMENT PERIOD
A public comment period was held from April 8, 1991 to May
8, 1991 to allow interested parties to comment on the
Proposed Plan in accordance with Section 117 of CERCLA. On
April 25, 1991, a public meeting was held in Franklin,
Wisconsin at the Franklin City Hall. 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 3 written comments
and several verbal comments concerning the proposed plan.
B.
COMMUNITY INVOLVEMENT
Public interest regarding the site has been moderate. The.
community generally seems to be in favor of the recommended
alternative, but would like to see the drum excavation program
be very extensive.
The above concerns will be addressed in the following
section.
C.
SUMMARY OP SIGNIFICANT COMMUNITY COMMENTS
comment 1
The first commentor at the public meeting represented the
Franklin Environmental Commission and expressed concern about
methodology to be used to identify the location of buried drums.
He feared that it would be a "hunt and peck" and that many drums
would not be discovered and, thus, the cleanup would not achieve
its desired goal.
ResDonse 1
The methodology to be used to identify locations where
drums are likely to be located will be based on the results of
the geophysical studies performed at the site and historical
2
-------
information. More. detailed information concerning
methodology will be developed in the design process.
the
,~
Because the exact number of drums buried at the site is
unknown, it will be very difficult to judge the percent removal
that can be achieved under the excavation program outlined in
Alternative SA. In fact, the concrete and other debris buried
at the site will likely make the excavation program very
difficult. However, U.S. EPA is confident that placement of
mUlti-layer cap A over the waste area after excavation will
protect human health and the environment from risks remaining
from any drums and contaminated soil left on site.
Comment 2
The second comment at the public meeting also addressed the
issue of drum removal. The commentor stated that she would like
to see as many of the drums removed as possible. She also
stated that she would like to see more equipment used to test
where the metals are in the area, so that the drums can be
thoroughly searched out.
ResDonse 2
U. S. EPA would also like to see as many of the drums
removed as possible. Problems that could hinder removal include
the large amount of debris at the site, the depth of the drums,
and worker safety issues associated with excavation. All these
issues will have to be considered in the development of a
thorough, yet reasonable, excavation program.
As stated above in the response to Comment 1, existing
geophysical results will be reviewed to identify the location of
drums. The accuracy of the geophysical results is limited by
the debris buried at the FDDS and the high water table in the
clay below the site. At this time, it is not thought that
addi tional geophysical testing could provide significant further
information.
Comment 3
Another commentor stated that she was concerned about
henpecking spots in search of drums. She also supported removal
of as many drums as possible because she felt that sooner or
later the contamination is going to come down on those who live
close to the creek.
ResDonse 3
See the response to Comment 1 above.
Comment 4
3
-------
"
\ .
- Another representative from the Franklin Environmental
Commission expressed concern about the way that the test borings
and search for barrels were conducted during the investigation.
He also stated that since Alternative 5 would leave some drums
at the site, the state or the u.s. EPA should provide water
alternatives for those living around the site and suggested
putting in additional water mains. .
ResDonse 4
Test pit locations were identified based on the geophysical
results at the site. soil borings were purposely placed outside
the area where drums were likely to be found to avoid the
possibility of puncturing any drums. Sufficient information was
gathered to support remedy selection at the site.
The commentor also requested that the u.s. EPA or the state
provide an alternate water supply for residents near the site.
The u.s. EPA and the WDNR have carefully reviewed the
groundwater sampl ing results. The agencies have determined
that, thus far, groundwater contamination on site is minimal.
No off-site groundwater contamination from the FDDS has been
identified. If monitoring results in the future show that the
levels of contamination from FDDS threaten drinking water
supplies, remedial actions will be re-evaluated to address the
risk. currently, the levels of contamination found at the site
do not justify the construction of an alternate drinking water
supply.
Comment 5
Another citizen wrote in concerning the Acme Printing Ink
Company's lawsuit against parties it believes should be involved
in the cleanup. He stated that he is not responsible for the
cost of cleanup.
ResDonse 5
The lawsuit which the commentor references is a private
legal action. u.s. EPA has no pa~ in the proceedings.
Comment 6
A neighbor of the site wrote in to say that the time it
will take to clean up the site is ridiculous. She would like to
see the site cleaned-up as soon as possible, with the question
of "who pays" taken care of after the cleanup is completed. She
feels that the delay will allow for further degradation of the
drums and aggravate the contamination problem at the site.
ResDonse 6
4
-------
. Whenever practicable and in the public interest, the u.s.
EPA is required under section 122 of CERCLA to negotiate with
the PRPs to have them conduct the cleanup. At this time, no
condition at the site has been identified which would
demonstrate that the additional time required for negotiations
would be detrimental to the public interest; and thus warrant
use of the Superfund. PRPs have indicated interest in
conducting the RD/RA and should then be afforded the opportunity
to negotiate. However, should negotiations fail achieve an
agreement, the PRPs could be ordered to conduct the RD/RA under
section 106 of CERCLA or the Superfund could be used to conduct
the action.
r; "..
D.
SUMMARY OP SIGNIPICANT PRP COMMENTS
On behalf of Menard, Inc., Dames and Moore commented on
documents available in the Administrative Record.
Comment 1
Dames and Moore determined that the "RI fails to adequately
characterize site contamination in sufficient detail to allow a
Baseline Risk Assessment to be conducted." Specifically, they
were critical that the contaminants identified as contributing
most significantly to site risk were PAHs, which are relatively
immobile and commonly found in asphalt roadways. In addition,
they noted that other contaminants were:
a) not found in the waste (benzene);
b) are found in upstream samples (cyanide); or
c) are common and expected compounds in storm water runoff
(metals, PAHs, and petroleum related compounds).
ResDonse 1
u.S. EPA disagrees with the statement concerning the
development of a Baseline Risk Assessment. Sufficient
information was available for the development of a Risk
Assessment. Although the containerized waste was not evaluated
in the Risk Assessment in the RI, The u.S. EPA Region V has
evaluated site data and prepared two memos concerning risks from
containerized waste. See memos in the Administrative Record
dated January 3, 1991, and February 22, 1991, from Lee Gorsky,
Ph.D., to Terese Van Donsel.
Although PAHs are commonly found in asphalt roadways, the
hiqh levels of PAHs found in test pit samples are not common.
Further, the fact that PAHs are found in asphalt is no.
justification for failinq to recoqnize the risk posed by their
5
-------
presence. The. U. S.. EPA currently is addressing PAB
contamination at numerous Superfund sites across the country.
The fact PABs are relatively immobile is irrelevant in dermal
contact and soil ingestion scenarios.
u.S. EPA is bound to protect human health and the
environment. Because benzene was found in a groundwater sample
at the site, u.S. recognized the proximity of private wells and
responded in a conservative fashion. Benzene is a common
industrial contaminant and was assumed to be site related
because of the uncertainties concerning the number and content
of buried drums at the site. The groundwater monitoring program
outlined in the ROD should provide more information concerning
the presence of benzene at the site.
Cyanide was found in both upstream and downstream samples
of the stream. Concentrations found downstream show a slight
increase from those upstream. This information alone cannot
dismiss the cyanide present at the site. The reviewers must
recognize that cyanide was also found in the pond on site at
levels exceeding Clean Water Act Ambient Water Quality criteria.
In addition, cyanide in the groundwater at the FDDS exceeded
Wisconsin Preventive Action Limits. The location of the
groundwater sample with the highest level of cyanide (MW-3 at
the base of the pond) seems to indicate that the contamination
is site related, and thus it was justifiably assumed that the
FDDS was contributing to the surface water contamination in the
stream.
The reviewer stated that contaminants found at the FDDS are
"common and expected compounds in storm water runoff (metals,
PABs and petroleum related compounds)". In response, the u.s.
EPA would like to note that the compounds found at the FDDS are
common industrial contaminants and common contaminants addressed
in Superfund response actions. In fact, the toluene found in
the soils and the containerized wastes buried at the site are
not "common and expected compounds in storm water runoff". As
stated earlier, the fact that some contaminants found at the
FDDS may be "common" does not reduce the agency's concern with
their presence at the site.
Comment 2
The Dames and Moore commentor stated that the Baseline Risk
Assessment uses worst case assumptions and can only substantiate
a hypothetical cancer risk of 4 x 10-6. He states that this is
well within the range of acceptable risk levels and could
justify a no-action alternative.
ResDonse 2
6
-------
- The agency considers the assumptions used in the Risk
Assessment to be Reasonable Maximum Exposure assumptions
appropriate for the FDDS. The U. S. EPA disagrees that the
statement that the agency can only substantiate a 4 x 10-6risk.
The future residential scenario presented in the RI was found to
have a risk exceeding 1 x 10-5. In response to the statement
concerning the justification of the no-action alternative, u.s.
EPA would like to note that qualitative, in addition to
quantitative, data can be used to establish site risk. In this
case, the presence of buried drums at the site poses a threat to
human health and the environment and necessitates action at the
site. Two memos prepared by the u.s. EPA Region V Office of
Health and Environmental Assessment addressing the risks from
the drummed waste can be found in the administrative record.
See memos dated January 3, 1991, and February 22, 1991, from Lee
Gorsky, Ph.D., to Terese VanDonse~.
In addition, Office of Solid Waste and Emergency Response
Directive 9355.0-30, dated April 22, 1991, entitled "The Role of
the Baseline Risk Assessment in Superfund Remedy Selection
Decisions", states that chemical-specific ARARs may also be used
to determine whether a site warrants remedial action. State
groundwater standards have been exceeded at the FDDS. The u.S.
EPA and the WDNR have determined that source control is an
appropriate response to address ARAR exceedances at the site.
Comment 3
The reviewers state that the Feasibility Study (FS) fails
to consider on-site treatment options for the FDDS and that the
alternatives considered show a preconceived preference for
capping. Commentors state that Alternative 2 was eliminated
without evaluation. They state that Alternatives 3 and 4 are
only subsets of Alternative 5 and Alternative 6 is an absurd
throwaway technology that is not applicable for the site.
Commentors also. note that "there are many more cost efficient
and effective technologies that could be reasonably considered
for this site".
ResDonse 3
The conditions at the FDDS site do not easily lend
themselves to on-site treatment. The commentor did not identify
other technologies which are more effective and efficient than
those evaluated in the FS. With the exclusion of Alternative 6
(ISV), anyon-site treatment would require excavation of the
drummed waste. The drums must then be excavated, and their
contents characterized, before individual treatment technologies
can be identified as per the Wisconsin "Interim Policy for
Promoting the In-State and On-Site Management of Hazardous
Wastes in the state of Wisconsin". Excavation and treatment of
7
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drums on-site would still leave high volumes of low-level
contamination in the soil at the FDDS requiring treatment or
containment.
Alternative 2 was eliminated from further consideration
because the evaluation revealed that it was not protective of
human health and the environment.
The U.S. EPA agrees that Alternatives 3 and 4 are subsets
of Al ternati ve 5, but disagrees that Al ternati ve 6 is an
"absurd, throwaway technology." The commentors stated that they
would have liked an on-site treatment technology considered.
The only technology identified that would allow for treatment of
the site without excavation is ISV. We agree that ISV was found
not to be appropriate for use at the FDDS.
Commentors note that "there are many more cost efficient
and effective technologies that could be reasonably considered
for this site" yet do not provide any examples. Identification
of a specific technology for treatment requires a complete
characterization of drums contents. Until the drums are
excavated, there can be no such determination. In addition, the
"Interim Policy for Promoting the In-State and On-site
Management of Hazardous Wastes in the State of wisconsin"
necessitates an individualized approaCh to waste management that
would be very difficult to implement on-site.
Comment 4
Commentors state that they have concluded that the only
significant risk present at the FDDS is the buried drummed
material.
Resnonse 4
While U. S.. EPA agrees that the drummed material is the
principal threat at the site, it also recognizes the threat from
the low-level contamination found in the soil and debris at the
FDDS, and the risks due to drum leakage.
Comment 5
Dames and Moore commentors state that Alternative 5 would
remove the site from beneficial use for the foreseeable future
without "reducing the 'potential' risk to the environment, and
require a considerable monitoring effort to be conducted in
perpetuity." They further go on to suggest that the following
modification of Alternative 5 be considered:
"The 80 to 110 feet of low permeability glacial
tills and clays below the site make an excellent
barrier to downward movement of any mobile
8
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contaminants. The existing man-made pond on the
site was constructed originally as a source of clay
and the location for burial of the si te waste
materials. If this pond were first dewatered and
a layer of recompacted clay created along its base,
the waste material could be moved by standard
excavation equipment from its present location into
the area of the present pond. During this removal
process the drummed material would be excavated and
disposed of off-site. By moving the waste material
to the man-made pond area and constructing a cap,
the eastern portion of the site could be developed
for use as commercial, light industrial or
warehouse use. The western portion of the site
could then be preserved as floodway, or perhaps
artificial wetlands could be constructed to serve
as a natural treatment system for storm water
runoff or leachate treatment for leachate from a
collection system along the west side of the filled
man-made pond."
ResDonse S
The commentors state that Alternative S would remove the
si te from beneficial use for the foreseeable future without
"reducing the 'potential' risk to the environment, and require
a considerable monitoring effort to be conducted in perpetuity."
Their proposed modification would clear a portion of the
property, thus allowing for development, but it is unclear how
it would further reduce the risk to the environment or reduce
required monitoring.
u.s. EPA recognizes that the Dames and Moore modification
could allow for more efficient removal of drummed waste.
However, implementation of their modification would require
placing contam1nated material in an area that is not currently
considered to be a disposal area, thus placing waste in an
unregulated unit. In addition, by moving contaminated soil and
debris into the man-made pond area, the contaminated soil and
debris would be moved from the edge of the floodplain into the
floodplain. Constructing a landfill within a floodplain is
prohibited by NR 504.04(3).
These two issues would make implementation of the proposed
modification less desirable than implementation of Alternative
SA as outlined in the Proposed Plan. u.s. EPA would like to
note that it recognizes that some consolidation within the
disposal area may be appropriate to minimize of the extent of
the cap.
Comment 6
9
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- Dames and Moore noted that only one surface soil sample was
taken. They state that the Risk Assessment conclusion that the
primary risk is from ingestion or contact with PAHs is then
rendered suspect.
ResDonse 6
U.S. EPA agrees that additional surface soil sampling could
have been valuable. However, a close review of the Baseline
Risk Assessment would show that the residential scenario assumed
that sub-surface levels of contamination were available for
contact at the surface, as would be the case if gardening were
to be conducted at the site.
Comment 7
Commentors stated that the lack of any analysis of drummed
waste is the most important oversight in the characterization of
the site and that the RI also failed to characterize the lateral
extent of drummed waste.
ResDonse 7
The U.S. EPA agrees that the nature and extent of
waste contamination could have been characterized in
detail, but feels that sufficient information exists
purpose of remedy selection.
drummed
greater
for the
Comment 8
The commentors took issue with statements on page 6-5 of
the RI. They note that the lack of characterization of the
drummed waste does not support conclusions concerning the impact
of drummed waste on groundwater and stream sediments.
ResDonse 8
U.S. EPA would like to note that although the statements
referenced in the RI imply that groundwater contamination at the
site is not due to the drummed waste, the U.S. EPA agrees with
the commentors that additional drummed waste characterization is
necessary to fully support the conclusions drawn in the RI. The
Agency feels that the additional waste characterization
information can be best obtained during remedial action when
drummed wastes are removed.
Comment 9
Commentors state that the "flagged" data (from samples held
beyond holding times or from samples which received improper
preservation) severely restricted the database used to evaluate
the site.
10
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ResDonse 9
Comment noted. However, the Agency notes that there is
sufficient information to support remedy selection at the FDDS.
Comment 10
Dames and Moore commentors note that MW-4 and P-1 did not
have the full scale of analyses run because of low sample
volumes. They state that because of the importance of these
locations, full analyses should have been run.
ResDonse 10
See the response above to Comment 9 of this section.
Comment 11
Commentors noted that the discussion of benzene in the RI
was accidentally placed in the inorganic summary.
ResDonse 11
Comment noted.
Comment 12
Commentors state that sample SW-4 should have been filtered.
prior to analyses to more clearly determine whether the elevated
concentration of TAL analytes was due to the sample location's
proximity to the fill area or the amount of suspended solids in
the sample that could have interfered with the laboratory
analysis.
ResDonse 12
The Quality Assurance Project Plan approved by u.S. EPA
specified that surface water samples would not be field
filtered. Surface water sampling without filtering is the
preferred method in u.S. EPA Region V.
Comment 13
The Dames and Moore commentors state that the number of
samples used for the Student's "t" test of cyanide
concentrations was insufficient to support the conclusions drawn
concerning site contributions to the stream.
ResDonse 13
u.s. EPA agrees that a Student's "t" test with so few
sample results is far from conclusive, however, the Agency does
11
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belj.eve that the site is contributing to the cyanide problem in
the stream. See the response to Comment 1 of this section for
further discussion of cyanide at the site.
Comment 14
Commentors note that throughout the RI, it is stated that
additional sampling would need to be conducted to determine
whether or not benzene is site related. They state that without
re-sampling, it is unknown whether or not benzene is a hazard at
the site.
ResDonse 14
U.S. EPA agrees. Benzene was found at P-2 in one of two
sampling rounds, and additional sampling is needed to verify its
presence. The groundwater monitoring program outlined as part
of the Alternative 5A should provide the needed information.
Comment 15
Commentors note that the groundwater should be re-sampled
for mercury to determine whether or not mercury is a hazard at
the site.
ResDonse 15
U.s. EPA agrees. Mercury was found in elevated.
concentrations in one out of two sampling rounds at P-3.
Additional sampling is needed to verify its presence. The
groundwater monitoring program outlined as part of the
Alternative 5A should provide the needed information.
Comment 16
Commentors, note that the RI states that benzene, carbon
disulfide and chloromethane were found in groundwater and that
these detections were not likely the result of contamination
from the FDDS.
ResDonse 16
As discussed above in Comments 1 and 14, it is unclear
whether benzene is present at the site. Benzene was found in
one of two sample rounds at the deep well P-2, and was not found
in the shallow well MW-2. If it is actually present at the
site, the location of P-2 near the stormwater outfall casts
doubt on any automatic that the contamination is related to the
waste at the site. The groundwater monitoring program included
in Alternative 5A should provide the needed data to examine the
subject further.
12
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. Chloromethane was found at a very low level (0.5 ppb) in
one out of two sampling rounds at MW-5. Chloromethane was not
detected in any other location at the FDDS.
Carbon disulfide was found at very low levels (0.6 ppb) in
the first round of samples at wells MW-4 . and P-3. Carbon
disulfide was not detected in any wells during the second round
of groundwater sampling. Carbon disulfide was found to be
present at low levels in the waste. Future groundwater
monitoring should provide further information concerning the
presence or absence of this contaminant in the groundwater at
the site.
-----------------------------------------------------------------
-----------------------------------------------------------------
Marv prochaska, vice President of Real Estate for Menard,
Inc., commented on the proposed Plan for the FDDS.
Comment 17
Mr. Prochaska stated that Menard would like to develop the
property for commercial use and believes that the eastern
portion of the site could be developed if the cleanup plan were
to be modified in the manner suggested by Dames and Moore (see
Comment 5 of this section).
ResDonse 17
See the response to Comment 5 of this section.
Comment 18
Mr. Prochaska also commented that other PRPs do not have
the same long-term interest in the site that Menard has. He
states that the proposed remedy does not "go far enough" and
that" for a small addi tiona1 cost EPA' s goal can be better
achieved."
ResDonse 18
u.s. EPA recognizes that as the current owner of the FDDS,
Menard, Inc. has great interest in the configuration of the
cleanup plan. However, U.S. EPA feels that Alternative 5A is
protective of human health and the environment and thus does "go
far enough." The proposal made by Menard's consultant, Dames
.and Moore (and discussed in Comment 5 of this section) seems to
be a variation of the recommended a1 ternati ve with the goal
being to clear the eastern portion of the property for
commercial development. Insufficient information was provided
to make a detailed evaluation of the Dames and Moore proposal.
However, several important issues have been raised in the
13
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response to Comment 5. As a result, the agency may allow
consolidation of material in order to minimize the extent of the
cap. Language to that extent has been added to the ROD and
details of any consolidation efforts would be worked out in RD.
-----------------------------------------------------------------
-----------------------------------------------------------------
On behalf of Acme Printinq Ink Company, Friebert, Finerty
, st. John, S.c., commented on the documents available in the
Administrative Record.
Comment 19
The commentor states that Acme generally concurs with the
proposed remedy, however they contend that a remedy without
contai~er removal would also satisfy ARARs and the requirements
of the NCP.
ResDonse 19
Acme concurrence with proposed remedy is
EPA would like to note that a containment
excavation does not satisfy the statutory
treatment of the principal threat.
recorded. u.s.
remedy without
preference for
Comment 20
The commentor states that the site should have been closed
under existing state authority and regulations in 1981.
ResDonse 20
Comment noted.
Comment 21
The Friebert, Finerty & st. John commentor maintains that
the Agency Fact Sheet is misleading with respect to risks
presented by containerized waste. The commentor disagrees with
many statements made during the Proposed Plan public meeting and
states that it is apparent that very few of the persons making
oral comments reviewed the RI and FS reports. The commentor
feels that the comments at the public meeting may also be
attributable to the manner in which information was
characterized in the Proposed Plan Fact Sheet and disagree with
the way that the number of drums at the site was estimated.
They felt that the fact sheet should have supplied information
about: (a) whether the "high levels" represented total
concentrations or leachable concentrations: (b) the
ramifications of the difference between total and leachable
concentrations: and (c) the relative volumes of the ruptured
14
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con~ainers and wastes that were sampled in 1983.
ResDonse 21
u.s. EPA disagrees with the commentor and feels that the
fact sheet fairly outlines the results of the RI and FS
documents. The number of drums estimated in the fact sheet was
based on evaluation of what was drum discoveries during field
investigations, geophysical results, and from the records of
Ed's Masonry and Trucking. u.s. EPA agrees that field
investigations to date have not shown the large numbers of drums
indicated by Ed's Masonry and Trucking receipts. This could be
because other dump sites could have been used besides the FDDS.
However, the agency feels that it would be irresponsible to
disregard the information found in the receipts and present what
could be a overly optimistic picture-of what could be buried at
the site.
The comment also questioned why the agency did not supply
information to the public concerning "total" versus "leachable"
concentrations. supplying "total" versus "leachable"
concentrations may be valuable when modeling future risks to
groundwater, but is irrelevant when direct contact/ingestion
scenarios are considered. .
The relative volumes of ruptured containers and wastes
sampled in 1983 was not considered to be appropriate for
inclusion in the Fact Sheet because the sizes of containers and.
volume of wastes found are not necessarily representative of the
material buried at the site. However, the 1983 sampling results
did provide a general indication of the types of wastes present
at the FDDS.
Comment 22
The commen:tor states that the "existence and type of
containerized waste at the FDDS II not dissimilar from that
which is typical of the large number of 'natural attenuation'
landfill sites... constructed during the 1970' s when regulations
were relatively lax." They state that the geology underlying
the site makes it vastly superior to many licensed, natural
attenuation sites.
ResDonse 22
The risks from the FDDS were found to be unacceptable, and
u.s. EPA and the WDNR have determined that remedial action is
necessary to address contamination at the site. The u.s. EPA
and the WDNR would like to note that a large number of landfills
are currently Superfund sites. .
Comment 23
15
-------
. The commentor disagrees with the Fact Sheet statement that
the "drummed waste" is the "principal threat" posed by the FDDS
and feels that the characterization may misinform and cause
unnecessary apprehension on the part of the public. They state
that the contents of the drummed waste found during the RI are
"inconsistent with the suggestion that the drums contained the
type of liquid, highly toxic chemical wastes that the layman
usually associates with 'drummed waste'." They also state that
the wastes found are not "exotic organic chemicals normally
associated with 'drummed wastes'."
ResDonse 23
u. S. EPA and WDNR stand by the determination that the
containerized waste at the FDDS is the "principal threat" and
feel that the Proposed Plan Fact Sheet fairly informs the public
of the risks presented by the site. contaminants do not have to
be "exotic" or "liquid, highly toxic wastes that the layman
usually associates with' drummed waste'" to be unacceptable.
u.S. EPA and WDNR have evaluated the FDDS and have determined
that remedial action is necessary to address site contamination.
The waste samples analyzed in 1983 were found to be hazardous
due to characteristics for toxicity and ignitability.
Comment 24
The Friebert, Finerty & st. John commentor states that the
Fact Sheet failed to disclose that the wastes eX9avated in 1983.
were reburied by Menard. They also note that the Fact Sheet
does not describe the variety of sizes and types of containers
found.
ResDonse 24
Information on both topics can be found in the
administrative record located in the Franklin Public Library.
Comment 25
The commentor states that because the drums have
years to commingle with the sampled soils, the data
that the "principal threat" posed by the site is not
waste".
had many
indicate
"drummed
ResDonse 25
u.S. EPA and WDNR disagree with the commentor and believe
that the containerized waste, wi th associated characteristic
hazardous material, is the "principal threat" at the FDDS.
However, the commentor is correct in saying that the contents of
some drums may be intermingled with the soil. For that reason,
the Proposed Plan recommends that drums and associated
16
-------
characteristica11v hazardous materials will be removed.
Comment 26
The Friebert, Finerty & st. John commentor states that the
RI found that the principal risk at the site is associated with
PAHs. Approximately 93 to 95 percent of the risks evaluated in
the RI was associated with PAHs. PAHs were not associated with
"drummed waste", but were highly correlated with other fill
materials.
ResDonse 26
The commentor I s statement is correct in that the PAHs
contributed the majority of the risk evaluated in the RIo
Samples taken from test pits had high levels of PAHs. As stated
previously, the risks from containerized wastes were not
evaluated in the RI, but were evaluated by the u.s. EPA.
Comment 27
The Friebert, Finerty & st. John commentor "urges u.s. EPA
to clarify its factual statements and to carefully avoid the
possibility of misleading the public."
ResDonse 27
u.s. EPA maintains that the Fact Sheet fairly presents the.
results of the RIfFS and does not mislead the public.
Comment 28
The commentor states that the Fact Sheet did not fairly
characterize long-term health risks associated with "drummed
wastes." The commentor references a January 3, 1991 memo
prepared by Lee Gorsky. The commentor is critical of the
document and state that the fundamental flaw in the calculations
is the assumption that persons would be exposed to concentrated
material for extended periods of time. He states that the
contents of the containers found during the RI do not compare
to those that were excavated, ruptured and reburied in 1983. He
is critical that the information used was not developed in
accordance with the requirements for utilizing such data in the
RIfFS. The commentor requests that the memo be made part of the
Administrative Record.
ResDonse 28
The U. S. EPA fully supports the memos dated January 3,
1991, and February 22, 1991, from Lee Gorsky, Ph.D., concerning
risks at the site. Both documents were made part of the
Administrative Record at the start of the public comment period.
17
-------
. Although the.commentor disagrees with the assumptions used
for the calculations, the exposure assumptions are identical to
those used by the PRPs in the Baseline Risk Assessment in the
RI. The Risk Assessment assumes that subsurface soils are
exposed in the future residential scenario and that construction
workers contact subsurface soils. The Gorsky memos use the same
assumptions. The wastes found in the drums were sludges, it is
not unreasonable that these sludges could be exposed at the
surface and available for long-term contact in a residential
scenario. The construction worker scenario, as addressed in the
February 22, 1991 memo, is even more likely than the residential
scenario with its assumption of subsurface contact with the
concentrated waste.
The wastes sampled by WDNR during the initial discovery of
the drums were reburied at the FDDS. The RI did not
characterize these or other containerized wastes found at the
site. Therefore, to protect human health and the environment,
it was necessary to use historical data ~o quantify risks which
could otherwise only be qualified. See Section 6.0 of the ROD.
Comment 29
The commentor states that the Fact Sheet incorrectly states
that there was an exceedance of the wisconsin Enforcement
Standard for benzene.
Response 29
The commentor is correct. The wisconsin standard for
benzene was revised and the Fact Sheet did not reflect the
change. The discussion of benzene in the ROD utilizes the
revised standard.
-----------------------------------------------------------------
------------------~----------------------------------------------
On behalf of Acme Printing Ink company, Warzyn Engineering
commented on the January 3, 1991 memo from Lee Gorsky.
Comment 30
The Warzyn commentor points out that the raw waste is
buried and, thus, inaccessible to humans.
ResDonse 30
See the response above to Comment 29.
Comment 31
The commentor states that the Gorsky memo utilizes data
18
-------
from raw waste rather than waste commingled with site soils for
both the current and future site risk estimates.
ResDonse 31
The agency conservatively assumes that concentrated waste
is present at the site.
Comment 32
The Warzyn commentor states that the magnitude of the
health risk associated with construction worker exposure cannot
be made because of the unknown nature of the chemical exposure.
He also states that the excavation of drums is not known to have
caused harm to potentially exposed workers at the FDDS during
excavation of a portion of the drummed waste. In addition, the
commentor states that, "as demonstrated by the 1983 construction
activities, the exposure duration would be more realistically
measured in days rather than years."
ResDonse 32
U. S. EPA acknowledges that the actual risk from both
residential and construction worker exposure to the drummed
waste is very difficult to calculate because of uncertainties
concerning the types and volume of waste buried at the site.
However, U.S. EPA felt that a qualitative expression of the risk
did not sufficiently stress the seriousness of the
concentrations and the toxicity of the contaminants known to be
present at the FDDS.
The commentor states that excavation of drums in the past
is not known to have caused harm to potentially exposed workers
at the FDDS. Although this may be true, U.S. EPA uses Risk
Assessments to determine potential threats for future exposure
scenarios. U.s. EPA does not consider it appropriate or
necessarily protective to only consider observed health effects
due to exposure.
The commentor states that the exposure duration for future
workers on-site should be in days rather than years. In fact,
the exposure assumptions in the Gorsky memo concerning
construction worker are the same as those used the PRP Baseline
Risk Assessment portion of the RI. A construction worker is
assumed to be exposed to the waste for eight hours per day, five
days per week for eight months.
Comment 33
The Warzyn commentor states that there seems to be a
perception by the public that the test pits and soil borings
investigations during the RI were located in a haphazard manner.
19
-------
The. commentor points out that the sample locations were
identified from geophysical data with the concurrence of the
review agencies. The commentor states that the excavation
program outlined in the Proposed Plan will provide an acceptable
remedy because it will target areas where containers are known
to be present and several other areas where the presence of
additional drums is likely.
ResDonse 33
The U. S. EPA agrees that the determination of sampling
locations for soil borings and test pits was acceptable. The
Agency also notes the commentors concurrence with the excavation
strategy as outlined in the Proposed Plan.
Comment 34
The Warzyn commentor stated that the RI results did not
indicate that there are a large number of drums buried at the
FDDS.
ResDonse 34
The u.s. EPA agrees that the RI results do not demonstrate
that there are large numbers of drums present at the site.
However, receipts from Ed's Masonry and Trucking indicate that
there may be many more barrels buried at the site than the RI
results would indicate. See also the respo~se to Comment 21 in
this section.
Comment 35
Warzyn states that they support the Proposed Plan as
prepared by the U.S. EPA.
ResDonse 35
Comment noted.
E.
SIGNIFICANT COMMENTS FROM PUBLIC OFFICIALS
Comment 1
Frederick F. Klimetz, the Mayor of the city of Franklin,
commented that he would like to see the u.s. EPA proceed with
the cleanup without first negotiating with the PRPs. He stated
that once the remedial action is completed, the Agency could
pursue the PRPs to reimburse the Superfund.
Response 1
20
-------
. Whenever practicable and in the public interest, the U.S.
EPA is required under Section 122 of CERCLA to facilitate
agreements that are in the public interest and consistent with
the National Contingency Plan in order to expedite effective
remedial actions and minimize litigation. At this time, no
condition at the site has been identified which would
demonstrate that the additional time required for negotiations
would be detrimental to the public interest, and thus warrant
use of the Superfund. PRPs have formally indicated interest in
conducting the RD/RA and should then be afforded the opportunity
to negotiate. However, should negotiations fail achieve an
agreement, the PRPs could be ordered to conduct the RD/RA under
section 106 of CERCLA or the Superfund could be used to conduct
the action. .
P.
SZGNZPZCANT STATE COMMENTS
The State of Wisconsin has reviewed the ROD and concurs on
the selected alternative.
21
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Page No.
(' '91
ADMINISTRATIVE RECORD INDEX
FADROIoISKI DRIJ4 DISPOSAL SITE - UPDATE' 1
FRANKLIN, WISCONSIN
FICHE/FRAME PAGES DATE TITLE AUTHOR RECIPIENT DOCUMENT TYPE DOCNIJ4BER
91/04/29 Letter re: Remedial Klimetz,F. - Mlyor, Plsto~, S. - U.S. Correspondence
Alternative selected City of Frlnklin EPA
for Fedrowski Drllll
Site
10 91/05/01 Letter re: RI/FSi Cutright,B. - Demes ~ Ven Donsel, T. - U.S. Correspondence 2
Ittlched is Comments Moore EPA
On Final RI/FS Study
Report
91/05/03 Letter re: Fadrowski Prochaska,M. - Menard Van Donsel, T. - U.s. Correspondence 3
Drum RI/FS Study Inc. EPA
18 91/05/03 Final Feasibility Study Tennont-Schenk,S. Van Donsel, T. - U.S. Correspondence 4
Warzyn EPA
10 91/05/24 Residential Well Sempling Termont-Schenk,S. Vln Donsel,T.- U.S. Correspondence 5
Report Warzyn EPA
2 91/05/24 Feasibility Study Report Tennont-Schenk,S. Van Donsel,T.- U.S. Correspondence 6
Warzyn Inc. EPA
39 91/04/25 Public Meeting re: Wahlberg ~ Wlhlberg Plstor,S. - u.S. EPA Meeting Notes 7
F8drowski Drun Disposil Accurate Reporting
Site Proposed Plan for Services
Clean-up
91/05/07 Publ ic Comment frOll Tretow,V.A. U.S. EPA Other 8
a resident regarding
the F8drowski Site
91/05/10 Publ ic comment frOll Prien,V. u.S. EPA Other 9
a resident regarding
the Fedrowski Site
396 79-80/00 Various statements Various Acae Printing Receipts 10
for site
26 91/04/25 Comments of Acme Printing Acme Printing Ink COIIP8"Y u.S. EPA Reports/Studies 11
Ink CCIq)8ITf Regarding
-------
Page No.
06/04/91.
2
FICHE/FRAME PAGES DATE
ADMINISTRATIVE RECORD INDEX
FADROWSKI DRUM DISPOSAL SITE - UPOATE II 1
FRANKLIN, WISCONSIN
TITLE
AUTHOR
RECIPIENT
DOCUMENT TYPE
DOCNUMBER
Proposed Remedy and
Public
Hearing On April 25, 1991
. .
-------
Page No.
,06/04/91
TITLE
CERCLA Compliance with Other
Laws Manual, Part I
Guidance for Conducting
Remedial Investigations
and Feasibility Studies
(RI/FS) under CERCLA
Policy for Superfund Compliance
with the RCRA Land Disposal
Restrictions
Superfund LOR Guide '1 Overview
Superfund LOR Guide '2: Overview
Superfund LOR Guide 13: Overview
Superfund LOR Guide #It: Overview
Superfund LOR Guide 15: Overview .
The Feasibility Study:
Developement and Screening
of Remedial Alternatives
The Feasibility Study: Detailed
Analysis of Remedial Action
Al ternetives
A Guide to Selecting
Superfund Remedial
Actions
CERCLA Waste Capacity Assurance
GUIDANCE DOCUMENTS INDEX
FADROWSKI DRUM DISPOSAL SITE - UPDATE f1
Guidance Docunents are avai lable for review at
USEPA Region V-Chicago IL
AUTHOR
DATE
88/07/00
88/10/00
89/04/00
89/07100
89/07100
89/07100
89/07100
89/07100
89/11/00
90/03/00
90/04100
90/08/00
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Page No.
OS/23/9,1
ADMINISTRATIVE RECORD INDEX
FADROWSKI DRUM DISPOSAL SITE
FRANKLIN, WISCONSIN
FICHE/FRAME PAGES DATE TITLE AUTHOR RECIPIENT DOCUMENT TYPE DOCNUHBER
7 86/06/26 Letter re: U.S. EPA Constantelos,B. - Kratzmeyer,J. Correspondence
has documented the U.S.EPA
release or threatened
release of hazardous &
substances, pollutants
and contaminants at the
Fadrowski Drum Site
5 86/06/27 Letter re: U.S. EPA Constantelos, B. - Acme Printing Ink Correspondence 2
has documented the U.S.EPA C~ny
releases or threatened
releases of hazardous
substances, pollutants
and contamminants at the
Fadrowski Drum Site
8 86/07/02 Letter re: U.S. EPA Constantelos,B. - Davis,J. - Correspondence 3
has documented the U.S.EPA Chromiue,lnc.
release
or threatened release of
hazardous substances,
pollutants and
contaminants
at the Fadrowski Drum
Site
6 86/07/24 Letter re: U.S. EPA Constantelos,B. - Drexler,R.-Lubricant Correspondence 4
has docuimented the U.S.EPA s,lnc
release or threatened
release of hazardous
substances, pollutants
and contaminants at the
'Fadrowski Drum Site
2 91/03/0r Management of Hazardous VanOerLoop,C.-Mich. Van Donsel, T. - Correspondence 5
Wastes During Clean-up DNR U.S.EPA
Fadrowski Drum Disposal
Superfu-v:j Site
4 87/10/00 Fact Sheet re: U.S.EPA Fact Sheet 6
Fadrowski Drum
Disposal Site
Franklin, Wis.
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()
Page No.
"'3/91
2
ADMINISTRATIVE RECORD INDEX
FADR~SKI DRUM DISPOSAL SITE
FRANKLIN, ~ISCONSIN
FICHE/FRAME PAGES DATE TITLE AUTHOR
18 89/07/00 Fact Sheet re: Prog. U.S.EPA
Report Fadrowski
Drum Disposal Site
4 89/07/00 Fact Sheet re: Prog. U.S.EPA
Report Fadrowski
Drum Disposal Site
4 90/10/00 Fact Sheet re: Quick U.S.EPA
Reference Fact Sheet
- Compliance with Third
Third Requirements under
the LDRs
4 90/10/00 Fact Sheet re: Quick U.S.EPA
Reference Fact Sheet;
CERCLA Compliance with
the RCRA Toxicity
Characteristics (TC)
Rule: Part II
RECIPIENT DOCUMENT TYPE DOCNUMBER
Fact Sheet 7
.
Fact Sheet 8
Fact Sheet
9
Fact Sheet
10
5 91/01/00 Environmental Investi- u.S. EPA Fact Sheet 11
gation Complete
13 91/04/00 u.s. EPA Recommends U.S.EPA Fact Sheet 12
Clearq> Plan
2 83/07/13 Barrel waste samples Degenhardt,D. . Tacka,F. Memorandum 13 ,.
from the Menard State Lab of Hygiene
Construction Site,
Milwaukee
3 91/01/03 Baseline Risk Assessment Lee D. Gorsky, Ph.D. Van Donsel, T., Memorandull 14
for the Remedial Investi- U.S.EPA
gation at the Fadrowski
Drum Disposal Site
2 91/02/22 Baseline Risk Assessment Lee D. LGorsky, Ph.LD. Van Donsel, T., Memorandull 15
for the Remedial Investi- U.S.EPA
gation at the Fadrowski
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Page No.
OS/23/91
3
ADMINISTRATIVE RECORD INDEX
FADROWSKI DRUM DISPOSAL SITE
FRANKLIN, WISCONSIN
FICHE/FRAME PAGES DATE
TITLE
AUTHOR
RECIPIENT
DOCUMENT TYPE
DOCNUMBER
Drum Disposal Site
22 91/03/14 Memo re: Transmittal Memo Didier,P.-State of U.S.EPA Memorandum a 16
Wisconsin
for the "Interim Policy
for
Promoting the In-State
and
On - Site Management of
Hazardous Wastes in the
State of Wisconsin."
14 87/10/22 Various news articles Various Publ ic News Articles 17
dated from 1984 - 1989
regarding the Fadrowski
Drum DUJ1) Si tee
51 87/05/11 Administrative Order U.S. EPA Pleadings/Order.s
By the Consent re:
Remedial Investigation
and Feasibility Study
6 89/07118 Public Notice re: U.S.EPA Public Notice 19
Fadrowski Drum Site
2 00/00/00 Toxic Chemical Series State of Wisconsin U.S.EPA Reports/Studies 20
PAHs - Polycyclic
Aromatic Hydrocarbons
I, 00/00/00 Health Information for State of Wisconsin U.S.EPA Reports/Studies 21
Hazardous Waste Sites Dept. of Health &
Social Services
32 87/12/00 Final COIII\U\ity Jacobs Engineering U.S.EPA Reports/Studies 22
Relations Plan Group Inc.
Fadrowski Drum Site
55 -88/06/00 Remedial Investigation Warzyn Engineering Inc. Acme Printing Ink Reports/Studies 23
Work Plan CClq)Bny
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Page No. 4
''191
ADMINISTRATIVE RECORD INDEX
FADRO~SKI DRUM DISPOSAL SITE
FRANKLIN, ~ISCONSIN
FICHE/FRAME PAGES DATE TITLE AUTHOR RECIPIENT DOCUMENT TYPE DOCNUMBER
10 88/06/24 Letter re: Fadrowski Romich, M.- ~arzyn ~ippo,R. - U.S.EPA Reports/Studies 24
Drum site RI/FS Data
Management Plan
.
264 88/08/15 Memo re: memoranduns Adams, J. Chief of Dikinis,J. Reports/Studies 25
dated 8/15/88 - 12/12/88 Quality Assurance
covering the Quality Section
Assurance Project Plan
dated 6/88.
* 71 88/10/13 Report on the Applied Technology ~arzyn Engineering Reports/Studies 26
Electromagnetic Inc.
Magnetic Surveys
Conducted at
the Fadrowski Drum
D i sposa l.
9 88/11/09 Preliminary Health ~isconsin Division ATSDR Reports/Studies' 27
Assessment Fadrowski of Health
Drum Disposal Site
70 89/02/00 Field Activity Jacobs Engineering U.S.EPA Reports/Studies 28
Monitoring Report Group Inc.
RI/FS Oversight
173 89/05/00 Technical Memoranda ~arzyn Engineering Acme Printing Ink Reports/Studies 29
1 and 2 Remedial Incorporated Co.
Investigation.
126 89/06/00 Technical Memoranda 3 ~arzyn Engineering Inc. Acme Printing Ink Reports/Studies 30
Remedial Investigation Co.
Fadrowski Drum Disposal.
..
194 89/01/00 Technical Memorandum 4 ~arzyn Engineering Acme Printing Ink Reports/Studies 31
Remedial Investigation Incorporated Co.
82 90/02/14 Memo re: Approval of the Jones,V. , U.S. EPA Kelly, J., U.S. EPA Reports/Studies 32
PRP - Lead Addendum to
the
Quality Assurance Project
Plan for Remedial
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Page No.
OS/23/91
5
FICHE/FRAME PAGES DATE
TITLE
Investi-
gation/Feasibility Study
Activity at the Fadrowski
Drum Disposal Site.
14
90/11/16
Fadrowski Drum Disposal
NPL Site Wetlands
Investigation
310
Final Remedial
Investigation Report
1 of 2 Fadrowski Drum
Site
91/01/00
ADMINISTRATIVE RECORD INDEX
FADROWSKI DRUM DISPOSAL SITE
FRANKLIN, WISCONSIN
AUTHOR
Technical Support Unit
U.S.EPA
Warzyn Incorporated
RECIPIENT
Acme Printing Ink
Co.
DOCUMENT TYPE
DOCNUMBER
.
Reports/Studies
33
Reports/Studies
34
351 91/01/00 Final Remedial Invest i- Warzyn Incorporated Acme Printing Ink Reports/Studies 35
gat ion Report 2 of 2 C~ny
Fadrowski Drum Site
...,
186 91/03/00 Draft Final Feasibility Warzyn Inc. Madison, Amce Printing Ink Reports/Studies 3
Study Fadrowski Drum Site Wisconsin C~ny
238 91/04/00 Final Work Plan and Warzyn Inc. Acme Printing Ink Reports/Studies 37
QAPP Private Well Madison, Wisconsin C~ny
SlIq)l ins Fadrowski
Drum Site
. .
i.
....
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. "
.. ,
.... '" ~ .
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