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 ------- 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 ------- 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. ------- 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 ------- 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 ------- . ~ 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. ------- 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 ------- 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. ------- FIGURE 1 - FADROWSKI DRUM DISPOSAL SITE FEATURES MAP SITE ",OCR QUALITY ORIGINAL .; -'-- .-. .1 Ii; . '" IE, 1-' .. X l- I- .. ~ o III \MIAMf.Q .TIIIE.III N NOTES lEGEtV I. tAK...!. .rlt..u ,... III .'1"" 511"1' "-... " AI" ""11( fCI.III'" II( . "IIIG'I(;,IIII. 1I11(88i11. M" n_: "1".. '0 11I'11i0IrS" 1t".IIII..t 10 ".S.,., ",1"'. c...- '1111'''', I nu. .. UIIIm. ilI1U ,.,IC t- _tli ,lit 10(.111. IS 11"-', ......-..., SOIIlIIUif I'., KCIIIII I. ,---.., "'II, ...... '1 (All. .h',r """'1111_'11'11""'. .."....",,-- "'II flU" ===== --..IICUU.. . ...Illn... 11081 "YIII ~ north o 100 200 lJ"V1.,r--, SCALE IN fEET } .-.t "nul n '1"1 0- IIIKOII\II 1'111 ......... C"''''. ""'M. SClUi. ,.. .......,.., I. (GIIl'Of ....,...1 -n- 'I~ '8"0118" .I~I "I; '1" I'." "(11111 I. I~I" "'II. ""'" "'AS': CCIOIfII.'U . _III '41-' II. '1\1 1)"1.",. ......, ,. WI 1- "" III 'In...., I' '"'111HII0II Of 1""'.cIII .".... .&III \OUIII'''. ".u; saullC"' U"III If 11(1'011 I. If""',>"" \ _'". U&4 II"". UIC.GI...IU. ..... )..,," n. '1\1 '\4'I~.' '" GJIOIIIII.."p "'NO.."",........, 0-0 0' lIun ... ..". WUMI l1li". ..,-.: ...(11. 1UOCI'.,'...,,-r;WlIIi .tllAIII UM "111..1 " -""- -'I"'~ tlll'Ut I&InAl' Klllt n . r ! j ~I iIr,~: I: ! . ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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. ------- 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 ------- 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 ------- 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 ------- 13 4. The hazard index from possible future contact under a construction worker scenario exceeds 100. ------- . . 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 ------- 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 ------- 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 ------- 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 ------- 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. ------- 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 ------- 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. ------- . 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. ------- 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. ------- 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. ------- 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 ------- 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 ------- 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 ------- 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) ------- . . 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. ------- 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 ------- 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 ------- 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 ------- 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. ------- 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 ------- 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 ------- 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 ------- 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. ------- . . 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 ------- 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 ------- 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 ------- - 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 ------- 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 ------- 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 ------- . 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 ------- 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 ------- 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 ------- 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 ------- 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. ------- () 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 ------- 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 ------- o 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 ------- 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. .... ~ j . . " .. , .... '" ~ . -. ------- |