Superfund Record of Decision: Lemberger Landfill, WI


United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EP AIRODIR05-91/186
September 1991

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&EPA
Superfund
Record of Decision:
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Lemberger Landfill, WI
U S Environmentat Protection Agenc¥
Region U\ Hazard~S wa~:,
"echnica\ 'nformati~ c;h Floor
~r~9101 ..
HazardoUs woati. .
InformdflPn R~'
US EPA RegionS,
Philadelphia, PAJ9107.'
EPA Report Collection
Information ~esource Center
US EPA Region 3
Philadelphia, PA 19107

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50272-101
REPORT DOCUMENTATION 11. REPORTNO.
PAGE EPA/ROD/ROS-91/186
I ~
3. RecIpient. Acceaalon No.
4. TItle and Subtitle
SUPERFUND RECORD OF DECISION

Lemberger Landfill, WI

First Remedial Action - Final

7. Aulhor(.)
5. Report Date
09/23/91
6.
8. Perfonnlng Org.nlzatlon Rept. No.
8. P8rfonnlng Orgalnlzatlon Name and Addre..
10. ProjectlT.8klWork Unit No.
1,. Contract(C) or Grent(G) No.
(C)
(G)
1~ ~orIng Orgenlzatlon Name and Addte..
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type 01 Report " Period Covered
Agency
800/000
14.
15. Supplementery Note.
18. Abetrect (Umlt: 200 wold.)
The 4S-acre Lemberger Landfill (LL) site is a former land disposal facility in
Manitowoc County, Wisconsin. The site is located within one-quarter mile of another
Superfund site, the 4S-acre Lemberger Transport & Recycling (LTR) site. Land use in
the area is predominantly agricultural, with four residences within 1,000 feet of the
sites. Ground water as well as the Branch River, located less than 1 mile west of
both sites, are used as sources of drinking water. From 1940 to 1969, Franklin
Township used 21 acres of the LL site as an open dump. After 1970, the State
licensed the landfill to receive only municipal waste and power plant fly ash and
bottom ash. In 1976, the LL site ceased operations except for disposal of fly ash to
bring the site to final grade. All industrial waste was diverted to the nearby LTR
site. From 1970 to 1976, LTR received industrial waste and a variety of liquids,
sludge, and slurries, which were deposited onsite in unlined trenches. As a result
of reports of contaminated material seeping onto local properties, a number of State
investigations were conducted that identified VOCs levels above State standards in
residential wells. Affected residences received deeper replacement wells that have
not shown contamination. Because of the proximity of the sites and similarity in the
(See Attached page)
17. Document Analyal. L Deacrlptore
Record of Decision - Lemberger Landfill, WI
First Remedial Action - Final
Contaminated Media: soil, sediment, debris, gw
Key Contaminants: VOCs (PCE, TCE, toluene, xylenes), other organics
pesticides), metals (arsenic, chromium, lead),
b. IdentilieralOpen-Ended Terms
(PCBs,
Co COSA 11 ReIdIGroup
18. Avallebllty Statement
18. Secwlty a... (Thla Report)
None

20. SecwIty a... (Thl. Pege)
Nnn~
21. No. 01 Pegee
76
~ PrIce
(See ANSt-Z38.18)
See ImstrucUons on RlllfBrse
272 (4.71)
(Formerly NTIS-35)
Department 01 Commerce

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EPA/ROD/R05-91/186
Lemberger Landfill, WI
First Remedial Action - Final
Abstract (Continued)
g
types of wastes, the the LL and LTR sites will be remediated concurrently. This Record
of Decision (ROD) provides a final remedy for source contamination at the LL site and
ground water contamination at both the LL and LTR sites, as the first operable unit
(OUl). A future ROD will address the landfill contents at the LTR site, as OU2. The
primary contaminants of concern affecting the soil, sediment, debris, and ground water
are VOCs including PCE, TCE, toluene, and xylenes; other organics including PCBs and
pesticides; and metals including arsenic, chromium, and lead.
The selected remedial action for this site includes clearing and regrading the waste area
to smooth out the existing cap; constructing a multi-layer cap with a vegetative cover to
minimize cap erosion; constructing a slurry wall around the perimeter of the wastes;
installing at least one small volume extraction well in the upper aquifer to collect
ground water within the slurry wall; building an onsite treatment facility at the LL
site, and treating contaminated ground water from both sites using electrochemical
precipitation to remove inorganic contaminants and granular activated carbon to remove
organic contaminants, unless treatability studies deem another technology to be more
effective; blending water extracted from the slurry wall with ground water extracted for
remediation, and treating these at the treatment facility; temporarily storing the
residual sludge onsite in 55-gallon drums, followed by disposing of residual sludge as
part of the future LTR source control remedy or treating and disposing the sludge offsite
at a RCRA landfill according to Federal and State regulations; recycling spent carbon, if
possible; discharging the treated effluent onsite to the Branch River; providing an
alternate water supply to residents whose water supply is disrupted due to the operation
of the extraction system; investigating and mitigating any affected wetlands; monitoring
ground water; and possibly implementing institutional controls including deed and ground
water use restrictions, and constructing a security fence around the treatment facility
to limit site access. The estimated present worth cost for this remedial action is
$19,200,000, which includes an annual O&M cost of $731,000 for years 0-1 and $596,000 for
years 2-30.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific ground water clean-up goals are based
on the most stringent of State standards, SDWA MCLS, and risk-based levels, and include
TCE 0.18 ug/l (State), PCE 0.1 ug/l (State), toluene 68.6 ug/l (State), xylenes 124 ug/l
(State), arsenic 5 ug/l (State), chromium 5 ug/l (State), lead 5 ug/l (State), and PCBs
0.5 ug/l (pMCL).

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DECLARATION
SELECTED REMEDIAL ALTERNATIVE
FOR THE
LEMBERGER LANDFILL, INC. SITE
MANITOWOC COUNTY, WISCONSIN
Statement of Basis and Purpose
This decision document presents the selected remedial action for
the Lemberger Landfill Site, Manitowoc County, 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 the final remedy for the site. The
purpose of this remedy is to eliminate or reduce migration of
contaminants to the ground water and to reduce the risks associated
with exposure to the hazardous substances.
The major components of the selected remedy include:
Installation of ground-water extraction wells;
Extraction of contaminated ground water to actively
restore the aquifers to Federal and State of Wisconsin
ground-water quality standards;
Construction of a ground-water treatment system;
Construction of a landfill cover (cap) in compliance
with state of Wisconsin landfill closure requirements;

Construction of a slurry wall around the site;

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Monitoring of ground water to ensure effectiveness of
the remedial action.
statutorv Determinations
The selected remedy is protective of human health and the
environment, ~omplies with Federal and State requirements that are
legally applicable or relevant and appropriate to the remedial
action, and is cost effective. This remedy utilizes permanent
solutions and alternative treatment technologies to the maximum
extent practicable for this site, and satisfies the statutory
preference for remedies that employ treatment that reduces
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 wi th the selected remedy.
Letter of Concurrence is attached to this ROD.
The
~-yfJ.

ate
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State of Wisconsin \ DEPARTMENT OR NATURAL RESOURCES
CarroU D. Dcsadny
SccTc\ary .
101 South Webster Street
Box 1921
Madisoc1, W" ISOOIISin S3707
SOlID WASTf! 'IE..EPAX 6m-267-T168
.. TEl.EPAX 608-267-3579
roD 6m-267~
September 5, 1991
IN REPLY REFER TO:
FID #3601679
Manitowoc Co.
ERISFND
Mr. Valdas V. Adamkus,
U.S. EPA Region V
230 S. Dearborn St.
Chicago, III 60604
Administrator
SUBJECT:
Concurrence on Selected Remedies, Lemberger Landfill, Inc.
(a/k/a Lemberger Fly Ash Landfill) and Lemberger Transport and
Recycling, Inc. (a/k/a Lemberger T & H Site), Town of Franklin,
Manitowoc Co., WI .

Dear Mr. Adamkus:
The Department is providing you with this letter to document our concurrence
with the remedies selected for the two Lemberger Superfund sites. The
proposed remedies, as outlined in the May, 1991 Proposed Plan, includes the
following:
A.
Groundwater Remedy
The proposed groundwater remedy will address the contaminated groundwater in
the vicinity of the two sites, and is considered the final remedy for the
groundwater at both sites. The remedy includes:
GROUNDWATER ALTERNATIVE 5
(Labeled as Alternative 3 in the Proposed Plan)

. A series of groundwater extraction wells in the vicinity of both sites,
designed to withdraw water from the upper and lower groundwater systems, to
actively restore the groundwater in both systems; .
. Treatment of the extracted groundwater in a treatment facility constructed
at the Lemberger Landfill site;
. Groundwater monitoring; and
. Groundwater use restrictions.

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I
"
t
Mr. Valdas V. Adamkus, Administrator - September 5, 1991
2
Capital Cost S 3,000,000
Annual O&M 1st year S 651,000
Each year thereafter S 552,000
Total Present Worth~ S 9,300,000
Estimated time to implement 16 Years

Lemberger"Landfill Source Control Remedy
B.
This portion of the proposed remedy will only address the
contamination at the Lemberger Landfill site. The source
the Lemberger Transport and Recycling, Inc., site will be
separate action. The remedy includes:
sourc~ of
of contamination at
addressed through a
SOURCE CONTROL ALTERNATIVE 5
(Labeled as Source Control Alternative 4 in the Proposed Plan)

. A slurry cut-off wall around the perimeter of the waste at the site;
. A series of extraction wells within the waste,~ischarging to the
groundwater treatment system, operated to maintain inward gradients within the
entire waste mass;
A new soil cover over the entire waste area, designed and constructed to
meet the requirements of s. NR 504.07, Wis. Adm. Code;

An active landfill gas extraction system; and
A fence around the site and deed restrictions.
Capital Cost $9,200,000
Annual O&M 1st year $ 80,000
. Every year thereafter $ 44,000
Total present worth" $9,900,000
Estimated time to implement 19 Months

" Based on 30 years of operation and maintenance (O&M)
.
The Department concurs with the selection of these remedies, as described
above and in the Record of Decision for the sites.
We understand that if the potentially responsible parties (PRP's) do not agree
to fund the remedy, the State of Wisconsin will contribute 10% of the remedial
action costs associated with the actions and 10% of the O&M costs for the
first 10 years of groundwater extraction and treatment. In addition, if the
PRP's do not. agree to fund the O&M, the State of Wisconsin will contribute 10%
of all other O&M costs for the first year and provide for all O&M after that.
We provide this assurance on the assumption that U. S. EPA will pursue all
actions with the PRP's prior to expending the Fund at the site.

We understand that if the Fund is expended to conduct the remedy and if
hazardous waste needing disposal is required to be managed off-site as part of

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Mr. Valdas V. Adamkus, Administrator - September 5, 1991
.,
J
the remedy, that the State of Wisconsin will be required to provide the
assurances for hazardous waste management in ~40 CFR 300.510(d) and (e) of the
National Contingency Plan. The assurances are that a compliant hazardous
waste facility is available, and that facility's use is consistent with our
approved Capacity Assurance Plan. However, we understand the groundwater
treatment system can be designed and operated so the waste requiring disposal
can be managed. in-state as a solid waste.

We also understand that pur staff will continue to work in close consultation
with your staff during the pre-design, design and construction phases of the
remedy. ~
Thank you for your support and cooperation in addressing the contaminatton
problem at the Lemberger sites. Should you have any questions regarding this
matter, please contact Mr. Paul Didier, Director of the Bureau of Solid &
Hazardous Waste Management, at (608)266-1327.
Sincerely,
C.~d~

Secretary Iny \
CDB:GAE
cc:
Lyman Wyble - AD/5
Linda Meyer - LC/S
Paul Didier - SW/3
Doug Rossberg/Jennifer Huffman - LMD
Mary Elaine Gustafson - U. S. EPA Region V,
Mark Giesfeldt/Sue Bangert/Gary Edelstein -
SHS/11
SW/3

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RECORD OP DECISION
Lemberger Landfill, Inc.
Lemberger Transport & Recycling, Inc.
Manitowoc County, Wisconsin
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TABLE OF CONTENTS
A.
site Location and Description. . . . . . . . .
B.
site History and Enforcement Activities.
community Relations.
. . . . .
. . . .
C.
. . . . .
. . . . .
D.
Scope of the Selected Remedy. . .
. . . .
. . . . .
E.
Summary of Current site Conditions. . . . . . .
F.
Summary of site Risks
. . . . . ~. . . . . . . . .
G.
Environmental Standards not met at the Site
. . . . 1
. . . 2
. . 3
. . 4
. . . . 5 .
. . 8
. . .13
H.
Description of Remedial Alternativess . . . . . . . . .14
I.
Summary of Comparative Analysis of Alternatives. . . .23
. . .29
J.
The Selected Remedy. . . .
statutory Determinations
. . . .
. . . . .
. . . . . .
K.
Responsiveness Summary
. . . . .
. . . . .
. .33
. .40

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FIGURES AND TABLES
Fiaures
1.
Location
Map. . . . . . . . . . . . . 0 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
2.
Potential Limits of Upper Ground Water System...............6
3.
Contaminant Plume in Upper Ground Water System.............. 7
Contaminant Plume in Lower Ground Water System.............. 7
Conceptual Flow Diaqram of Ground Water Treatment Process..16
4.
5.
6.
Ground Water Alternative 5.................................19
7.
Cross Section of Clay cap..................................20
8.
Source Control Alternative 3..... .'.'....................... .20
9.
Cross Section of Mulitlayer
Cap. . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
10. Cross Section of Slurry and
Cap. . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
11. Conceptual Design for Source Control Alternative 5.........22
12. Recommended Cleanup
Acti vi ty. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .29
Tables
1.
Chemicals
of Potential Concern.............................. 9
2.
Toxicity Data for Chemicals of Concern... ',' . . . . . . . . . . . . . . . .11
Classification System for Carcinogenicity..................11
3.
4.
Risk Characterization Summary for Land Use Scenarios.......11
Source of Federal and State Ground Cleanup Standards.......13
5.
6.
Cost Estimates for each Alternative........................28

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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
Lemberger Landfill, Inc.
Lemberger Transport' Recycling, Inc.
The Lemberger Landfill, Inc. (LL) Sit~ and the Lemberge~ Transport
& Recycling, Inc (LTR) Site are listed separately on the National
Priorities List (NPL), but were studied together resulting in one
Remedial Investigation (RI) and one Feasibility Study (FS) that
addresses both sites. The proximity of the sites to each other,
operation of both sites by Lemberger Landfills, Inc., and the
ini tiation of the RI for each si te at the same time, made it
feasible and cost effective to study the sites simultaneously.
Although both sites are addressed in this Record of Decision (ROD),
the sites are physically separate.

As a result of the complexity of conditions at the sites, cleanup
actions have been di vided into two operable units. This ROD
addresses the first operable unit, which includes a treatment
system for contaminated ground water associated with the LL and the
LTR sites and a source control at the LL site. A second operable
unit will address source control at the LTR site.
A.
SITE LOCATIONS AND DESCRIPTIONS
The LL Site and the LTR Site consist of two former land disposal
facilities located within one quarter mile of each other in
Manitowoc County, Wisconsin. The study. area is bounded
approximately by Haas Road to the north, San Road to the south,
Madson Road to the east and Korinek Road to the west. Figure 1
shows the locations of the sites. The sites are located near the
intersection of Hempton Lake and Sunny Slope Roads. The Branch
River, which drains into Lake Michigan, is located less than one
mile west of both sites. The river is used for fishing and
canoeing and as a potable water supply. The entire Branch River
system is managed as a smallmouth bass stream. The LL site
occupies approximately 45 acres. Twenty one of those acres were
used for waste disposal. The LTR site also occupies approximately
45 acres, with 16 acres used for industrial landfilling. Both
sites were unlined and portions of both sites cover areas that
contained gravel quarries. Land in the vicinity of the sites is
rural and agricultural, with dairy farms in the area. Most
residences are located along Reifs Mills Road. Four residences are
located within 1,000 feet of the sites. The ground water is used
by residents as a drinking water. supply and for agricultural
activities.
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B.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
Lemberger Landfill, Inc.

Franklin Township used the LL site, previously called the Lemberger
Fly Ash Langfill, as an open dump for approximately thirty years.
The LL site was excavated prior to 1951 as a gravel quarry. The
site was used as an open dump between 1940 and 1969. In 1969, the
Wisconsin Department of Natural Resources (WDNR) licensed the site
as a sanitary landfill, meaning it could receive only municipal
waste and power plant fly and bottom ash. Industrial waste was
di verted to the nearby LTR Site. No leachate collection system was
installed at the LL site.
After 1970, the landfill received primarily municipal waste and
power plant fly ash from Manitowoc PUblic Utilities. Past
inspections have shown that fly ash and bottom ash were used as
daily cover instead of being buried along with the general refuse.
The quantity of municipal refuse disposed and if any hazardous or
toxic substances were deposited are both Unknown.

In 1976, when the license for operation of the LL site expired, the
state required that it be properly closed; however, the state
allowed the continued disposal of fly ash to bring the site to
final grade. In 1980, following complaints by local residents that
contaminated liquid, or leachate, had seeped onto their properties
on the west side of the Site, the Wisconsin Department of Natural
Resources (WDNR) ordered the owners to conduct an investigation to
address contamination problems at the landfill. A bankruptcy
petition filed on behalf of Lemberger Landfill Inc. in 1983
resulted in termination of investigation activities. In June 1986,
the LL site was added to the NPL, and U.S. EPA became the lead
agency responsible for the Remedial Investigation and Feasibility
study (RIfFS).
Transport' Recycling, Inc.
The LTR Site operated between January 1970 and September 1976 under
the same license issued by the WDNR for the LL site. The Site
ceased operations in 1976 when the WDNR did not renew the license.
The wastes were deposited in trenches excavated to an approximate
depth of five feet. Records of the types and quantities of wastes
were maintained, but no specific records were kept to indicate what
types of wastes were deposited in each trench. No engineered liner
or leachate collection systems were ever installed at the LTR site.

The LTR site is documented as receiving industrial waste and a
variety of liquids, sludges, and slurries between 1969 and 1977.
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Industrial wastes, including wood tar distillates, aluminum dust,
and oil and water mixtures were disposed at the Site.
The WDNR had expressed concern that the site had not been covered
properly, as indicated by wastes exposed at the landfill's surface.
Subsequently, in 1982, the WDNR entered into a consent order with
Lemberger Landfills Inc., which operated both sites, to investigate
the extent of contamination at the site. WDNR also issued a notice
of violation-in August 1982 to Lemberger Landfills, Inc. regarding
failure to implement groundwater monitoring requirements at the LTR
site. In September 1984, the LTR site was added to the NPL, and
u.S. EPA became the lead regulatory agency.
Residential Wells
In 1985, after receiving complaints from people living northwest of
the Lemberger sites, the WDNR sampled residential wells in the
area. Sample test results indicated volatile organic compounds
were present in seven residential wells near the sites and the
groundwater under the sites in amounts that exceeded Wisconsin
groundwater standards. Affected residents received replacement
wells, which were drilled 160 to 220 feet deeper than their
original wells. Later, from 1985 through 1987, the new wells were
sampled and no contamination was found.
Ridgeview Landfill

A third landfill, the Ridgeview Landfill, is located immediately to
the northeast of the LL Site and is not a Superfund site.
Groundwater samples were collected at the Ridgeview Site to obtain
addi tional information related to the extent of contamination;
however, because of its proximity to the Lemberger sites. The
Ridgeview Landfill was approved to accept nonhazardous municipal,
commercial, and general industrial waste. Additional information
on the Ridgeview Landfill may be found in the RIfFS.
C.
COMMUNITY RELATIONS
u.S. EPA hosted a "kick off" public meeting on August 10, 1987, at
st. Patrick/Maple Grove School, Reedsville, Wisconsin. The purpose
of the meeting was to inform the local residents of the Superfund
process and the work to be conducted under the RI. An RI fact
sheet update was issued in April 1990 and January 1991.

The RI Report for the Lemberger sites was released to the public
for review in January 1991. The FS and Proposed Plan were released
on May 20, 1991. Information repositories have been established at
the following three locations: The Manitowoc Public Library, 808
Hamilton Street, Manitowoc, Wisconsin; the Whitelaw village Hall,
232 East Menasha Avenue, Whitelaw, Wisconsin;. and the Franklin Town
Chairman, Steve Brooks, Home Office, Route 1, Box 293A, Whitelaw,
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Wisconsin. The Administrative Record for the sites has been made
available to the pUblic at the U.S. EPA Docket Room in Region V and
at the Manitowoc Public Library.

A pUblic meeting was held on May 22, 1991 to discuss the FS and the
Proposed Plan. The meeting was chaired by representatives from the
U.S. EPA, WDNR, the Wisconsin Department of Health and attended by
approximately 60 residents.
The FS and Proposed Plan were available for public comment from May
20, through July 29, 1991. Comments received during the public
comment period and the U.S. EPA's responses to those comments are
included in the attached Responsiveness Summary, which is a part of
this ROD. Advertisements announcing the availability of the
Proposed Plan, start of the comment period and extension of the
comment period were published in the Manitowoc Herald Times
Reporter.
The public participation requirements of CERCLA sections
113 (k) (2) (i-v) and 117 of CERCLA have been met in the remedy
selection process. This decision document presents the selected
remedial action for the Lemberger sites in Wisconsin, chosen in
accordance with CERCLA, as amended by SARA and, to the extent
practicable, the National contingency Plan (NCP). The decision for
this site is based on the administrative record.
D.
SCOPE OF THE SELECTED REMEDY
As with many Superfund sites, the conditions at the LL and LTR
Sites are complex. As a result, U.S. EPA organized the work into
two planned activities. The remedial action selected in this ROD
addresses the first of these two planned activities or operable
units at the sites. This ROD addresses groundwater contamination
at both the LL and LTR sites, and source contamination at the LL
. site only (hereafter referred to as "the sites"). This response
action will treat the groundwater in the shallow and deep aquifers
and install a slurry wall around the waste in theLL Site and place
a cap on the LL Site. This remedy utilizes permanent solutions and
al ternati ve treatment or resource recovery technology to the
maximum extent practicable for each site, and satisfies the
statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as a principal element.

The second and final action will address the source of
contamination at the LTR site. The LTR landfill contains hot spots
which need to be further characterized. When this continued
investigation is completed, a remedy for the second planned
activity or operable unit will be selected. .
Treatment of the groundwater plumes and containment of the source
material in the LL site included in this first operable unit will
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be conducted in accordance with applicable or relevant and
appropriate requirements of Federal and State law. U. S. EPA
considers containment of the landfill material, which is a source
of groundwater contamination, to be the most practicable remedy.
Because hazardous substances are remaining at the site, as-year
review will be conducted to assure human health and the environment
are being protected by the remedial action being implemented at the
site.
E.
SUMMARY OF CURRENT SITE CONDITIONS
The RI involved sampling and analysis of groundwater, air, surface
water, sediment, leachate, subsurface soil, and surface soil in
order to determine site conditions. Water samples were collected
from numerous residential and monitoring wells around the site. A
geophysical investigation consisting of a magnetic survey, an
electromagnetic survey and a seismic survey was conducted.
Site geology, landfill characteristics, and groundwater flow
patterns were also examined.
Based on the results of the RI, U. S. EPA determined that the
threats to human health and the environment are through exposure by
ingestion or direct contact to volatile organic compounds (VOCs),
semi-volatile organic compounds (SVOCs), and inorganic compounds
found in the groundwater near the sites and in landfill contents on
the sites. The following conditions were observed at the sites:
1.
Topography
The Branch River, which drains into Lake Michigan, is less than one
mile west and northwest of the sites. The area consists of rolling
to hilly terrain and numerous wetlands. The area is generally
characterized by glacial deposits and variable bedrock. The LL
Site terrain generally. slopes to the west and northwest.
Elevations on the LL site range from about 860 feet above mean sea
level (MSL) to 820 feet. The LTR site slopes to the west,
northwest with steeper slopes in the east. Elevations on the LTR
site range from 870 feet to 852 feet above MSL. There are four
general geologic uni ts present at the study area, the upper
granular unit (UGU), the cohesive unit (CO)", the lower granular
unit (LGU) and the bedrock. The UGU is composed of sandy, gravelly
deposits at or close to the ground surface. It does not cover the
whole study area. The CU, or clay layer, is composed of silty,
clayey deposits and has low hydraulic conductivity. The LGU is
composed of sandy, gravelly deposits underlying the clay layer and
rests on the bedrock.
2.
Hydrogeology
There are two groundwater systems at the sites.
granular unit is a localized perched aquifer.
Within the upper
The clay layer
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separates it from the lower aquifer in the lower granular unit and
bedrock. A groundwater divide as a result of a bedrock ridge runs
northeast-southwest on the southeast side of the study area. The
water flows away from the divide in all directions but primarily to
the northwest and the southeast.
a.
b.
The upper aquifer is within the upper granular unit and
is localized in the area of the LL site, apparently
extending east into Ridgeview Landfill, south into the
LTR site, and north at least as far as monitoring well
RM-4. The potential boundaries of the upper aquifer are
shown in Figure 2. The upper aquifer may be a single
perched system or there may be more than one independent
perched water table system in the area. Groundwater in
the upper aquifer appears to flow to the west through the
waste disposed of at the LL site. The average depth of
the upper aquifer is thirteen feet.

The cohesive or clay layer, underlies the upper aquifer
and is interbedded with granular material at the
interface. The thickness of the clay layer varies
considerably across the study area, ranging from 1 to 3
feet thick over the bedrock ridge to almost 50 feet thick
at several locations where the bedrock surface is lower
in the north, northwest, and west portions of the
Lemberger sites study area.
c.
The lower aquifer is vertically and laterally continuous
west of the LTR site. It is composed of well-graded,
dense sandy gravel and gravely sand and is hydraulically
connected with the underlying bedrock. The thickness and
depth of the aquifer increases away from the bedrock
ridge, ranging from 1 to 3 feet thick at the bedrock
ridge to 25 feet thick northwest of the Lemberger sites
between monitoring wells RM-4 and RM-2.

The bedrock, under the consolidated deposits is a
dolomitic limestone that ranges from a highly weathered
condition in its upper surface to a highly fractured and
then unfractured bedrock below.
d.
The lower water system is in the limestone bedrock and
has a regional direction of groundwater flow to the east,
toward Lake Michigan. Locally; however, the groundwater
flows to the northwest, toward the Branch River. An area
of local recharge of the lower aquifer runs northeast-
southwest on the southeast side of the Lemberger sites
study area. The recharge area functions as a groundwater
di vide, wi th flow moving away from the di vide in all
directions but primarily to the northwest or the
southeast.
6
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J.Wtm
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~TINT"'L U"IT ~ ""~III G- WATlII 8't8T1I1oI(S)
_ID ON UIDAIDIL C~FlCAT1OHI

WILL LOCATON AND D_T1OH

8IIOIMC WATlllIUlll'AClILIVAT1OH, DlC....... 'M'
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8CAU
POTENTIAL UNITS OF UPPER GROUND WATER
SYSTEM AND WATER SURFACE ELEVATIONS.
DECEMBER 1888
-
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-------
3.
contamination
a.
Source
The source of contamination from the Lemberger sites is the
landfilled waste. The exact volume of waste in the LL Site
has not been determined. The volume is estimated in the FS at
479,000'cubic yards; however, additional information about the
site is required to refine the estimate. The waste in the LL
Site is in direct contact with the shallow or perched aquifer,
which means the waste is in direct contact wi th' laterally
moving groundwater. Groundwater contamination is produced in
two ways: 1) by the horizontal movement of groundwater
through the waste and, 2) by the vertical movement of
precipitation down through the existing cap and into the waste
mass. Both means of groundwater contamination are present at
the LL Site. The source of contamination at the LTR site is.
contributing to groundwater contamination; however, the risks
from soils will be addressed in the second response action or
operable unit, and subsequent ROD.
b.
Groundwater
The presence of hazardous constituents in the landfill is
indicated by the chemical composition of the groundwater.
Volatile and semi-volatile organic compounds, and inorganic
compounds were detected in the groundwater including 1-1
dichloroethane, trichloroethelene, 1,2 dichloroethene,
acetone, toluene, ethylbenzene, xylene, 4-methyl-2-pentanone,
chloroethane, 1-1-trichloroethane barium, chromium, methylene
chloride, 2-butanone and cadmium. Contamination above MCL's
was found at a depth of 95.4 feet.

The upper aquifer contained high concentrations (3,000 to
5,000 ug/L) of acetone and 2-butanone, and high concentrations
(41,800 to 1.3 million ug/L) of calcium, iron, magnesium,
potassium and sodium. Moderate concentrations (100 to 220
ug/L)of methylene chloride, 1,2-dichloroethene, and
tetrachloroethene were detected. Three semivolatile phenols
were also identified.
Extensive volatile compounds (greater than 1,000 ug/L) were
found in the lower aquifer including chloroethane, methylene
chloride, 1,1-dichloroethane, 1,2-dichloroethene, and 1,1,1-
trichloroethane. Phenols, phthalates, pesticides and PCBs
. were also detected in the lower aquifer. Concentrations begin
to decrease north of the LTR site and toward the Branch River.
Figures 3 and 4 show the contaminant plumes in the upper and
lower groundwater systems.
c.
Soils
7
-------
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00
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\181.......-...-.
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H

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CONTAMINANT PLUME IN
UPPER GROUND WATER SYSTEM
8CALa
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Figure 3
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CONTAMINANT PLUME IN
LOWER GROUND WATER SYSTEM
Figure 4
IOI.R:E: ----
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Surface and subsurface soil samples at the LL Site indicate
the presence of volatile compounds ranging from 1 to 12 ug/kg
and semivolatile organic compounds ranging from 71 to 3,800
ug /kg. Pesticides including 4,4 -DDE, 4,4 -DDD and 4,4 -DDT were
found at concentrations of 70 ug/kg, 190 ug/kg, and 42 ug/kg
respectively.
At the. LTR si te, surface soils contain volatile organic
compounds at concentrations ranging from 230 to 2,000 ug/kg,
semivolatile compounds ranging from 94 to 2,000 ug/kg and
pesticides including Aldrin at concentrations of 240 ug/kg and
Deildrin at concentrations of 200 ug/kg. Subsurface soils at
the LTR site had lower concentrations of volatile compounds
than the surface soils, ranging from 3 to 620 ug/kg.
Semi volatiles , pesticides, and PCBs were not found in the LTR
subsurface soils. The risks from the soils from at LTR site
will be assessed in the second response action or operable
unit. .
d.
Sediment, Surface Water and Leachate

Sediment and surface water samples were collected at and near
the LL and LTR sites, including the wetland area. Sediment
samples showed low concentrations of volatile compounds;
however, one sample south of the LL Site contained acetone
detected at 510 ug/kg. Surface water samples contained
phthalates, methylene chloride and acetone at low levels. Of
the four leachate sample locations planned, leachate was found
at only one location, in the northwest corner of the LL Site.
Organics were not detected in this sample.
F.
Summarv of Site Risks
The analytical data collected during the RI and the baseline risk
assessment indicated the presence of contaminants in various media
at levels that may present a risk to human health. Pursuant to the
NCP, a baseline risk assessment was performed based on data from
the RI. The baseline risk assessment assumes no corrective action
will take place and that no site-use restrictions or institutional
controls such as fencing, groundwater use restrictions or
construction restrictions will be imposed. . The risk assessment
then determines actual or potential risks or toxic effects the
chemical contaminants at the site pose under current and future
land use assumptions.
The baseline risk assessment for groundwater and soils on the LL
Site included the following assumptions:
No direct air emissions were occurring, and the soil will not
be disturbed by plowing or excavation which cause significant
air emissions in the future;
8
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current land use includes approximately 2,700 residents within
a three mile radius of the Lemberger sites;

Residents will only be exposed to contaminants currently
detected in the residential wells sampled during the RI
(replaced residential wells not included). Monitoring well
data were not included in the estimate of current residential
risks;
CUrrent residential soil risks assume onsite exposures due to
trespassing on the sites;

Comparative future groundwater residential risks assume
residents will be exposed to the quality of water currently in
all monitoring wells.
1.
Contaminant Identification
The medium of concern for human. exposures for current and
future scenarios was identified primarily as groundwater which
has been contaminated by the vertical infiltration of
precipitation through the waste and by direct contact of the
waste with the groundwater. The RI detected several chemicals
in different media at both sites and developed a list of
"chemicals of potential concern" using the following criteria:

Chemicals retained included those positively detected
in more than one sample in a given medium, including
chemicals with no qualifiers attached and chemicals
with qualifiers attached that indicated known
identities and estimated concentrations (such as J-
qualified data).
Chemicals were retained that were detected at levels
at least five times greater than levels detected in
associated blank samples. .
Future LL soil risks assume on site exposures due to
residential use.
Chemicals of potential concern are listed in
Table 1.
2.
Human Health Effects
The health effects for the contaminants of concern may be
found in the appendices section of the FS.
3.
Exposure Assessment
9
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Me':hylene Chloride
Acc.tone
1, I-Di~hloroclhene
1,1- Dich loroethane
1,2- Dichlol octhene
2-ButKnunc
l,l,I-Trichloroethane
TrJchloroethene
4-Methyl-Z.pcn1811011e
TetraChloroethene
Toluene
Xylene
Bis ~2-ethyJhexyl)phthalate
Heptachlor
Alelrin
Dif:Jdrin
4,4--DDT
ArochJor-1248
Arc)chlor-12S4
BliJium
Cso:1mfum
Chromium'
Lead
Zinc
Ar':»cnic
BeryJJi:um
MZ1nganese
Mc:rcury
Selenium
SU'/er
~.
//
TABLE 1
Chemicals of Potential Concern
I
f/
-------
potential exposure to contaminants from these sites can come
about through the following potential pathways. or routes of
exposure:

Exposure to drinking water through various routes,
including direct ingestion, dermal contact (drinking
water/shower exposure) or inhalation of VOCs in the
groundwater by residents or others using contaminated
groundwater;
Direct contact with, or ingestion of contaminated soil by
site workers, farmers, hunters and trespassers;

Indirect exposures to contaminants from ingestion of
animals that feed on contaminated crops (current and
future) .
4.
Risk Characterization
The non-carcinogenic and carcinogenic health risks associated
with each of the pathways and potential receptors listed above
have been evaluated. Basic toxicity information used to
calculate risk was derived from the Integrated Risk
Information system (IRIS), Health Effects Assessment Summary
Tables (HEAST), and Naphthalene RfD Value (NAPH).
a.
Non-carcinogenic Health Risks
Reference doses (RfDs) have been developed by EPA for
indicating the potential for adverse health effects from
exposure to chemicals exhibiting non-carcinogenic effects.
RfDs, which are expressed in units of mg/kg-day, are estimates
of lifetime daily exposure levels for humans, including
sensitive individuals. Estimated intakes of chemicals from
environmental media (e.g., the amount of a chemical ingested
from contaminated drinking water) can be compared to the RfD.
RfDs are derived from human epidemiological studies or animal
studies to which uncertainty factors have been applied (e.g.,
to account for the use of animal data to predict effects on
humans). These uncertainty factors help ensure that the RfDs
will not underestimate the potential for adverse non-
carcinogenic effects to occur.
The Hazard Index, an expression of non-carcinogenic toxic
effects, measures whether a person is being exposed to adverse
levels of non-carcinogens. The Hazard Index provides a useful
reference point for gauging the potential significance of
multiple contaminant exposures within a single medium or
across media. The Hazard Index for non-carcinogenic health
risks is the sum of all contaminants for a given scenario.
Any Hazard Index value greater than 1.0 suggests that a non-
carcinogen potentially presents an unacceptable health risk.
10
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b.
Carcinogenic Health Risks
Cancer potency factors (CPFs) have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime
cancer risks associated with exposure to potentially
carcinogenic chemicals. CPFs, which are expressed in units of
(mg/kg-day) -1, are multiplied by the estimated intake of a
potential carcinogen, in mg/kg-day, to provide an upper-bound
estimate of the excess lifetime cancer risk associated with
exposure at that intake level. The term "upper bound"
reflects the conservative estimate of the risks calculated
from the CPF. Use of this approach makes underestimation of
the actual cancer risk highly unlikely. Cancer potency
factors are derived from the results of human epidemiological
studies or chronic animal bioassays. The excess lifetime
cancer risks are the sum of all excess cancer lifetime risks
for all contaminants of a given scenario.
Excess Lifetime Cancer Risks are det~rmined by multiplying the
intake level with the cancer potency factor for each contaminant of
concern. These risks are probabilities that are generally
expressed in scientific notation (e. g. 1 X 10-6). An excess
lifetime cancer risk of 1 x 10-6 indicates that a person's chance
of contracting cancer as a result of site related exposure over a
70- year lifetime maybe increased by as much as 1 in one million.
The U.S.EPA generally attempts to reduce the excess lifetime cancer
risk at Superfund sites to a range of 1 x 10~ to 1 X 10-6 (1 in
10,000 to 1 in one million), with an emphasis on the lower end (1
x 10-6) of the scale. Table 2 describes the acceptable intakes and
carcinogen potency factors for chemicals of concern at the
Lemberger Sites. Table 3 lists the weight of evidence categories
for potential carcinogens.

The following indicates the Excess Lifetime Cancer Risks for
different scenarios involving ingestion or inhalation of, or direct
contact with, site contaminants.
1.
Current and Future Soil Risks
-
The estimated excess cancer risk for potential future
residents at the LL site was slightly greater than 1 x 10~.
Arsenic was associated with risks of 1 x 10~ and
benzo(a)pyrene accounted for 2 x 10-6. These estimated risk
levels indicate an increased carcinogenic health risk due to
potential future residential exposures to contaminants in
. surface soil at the LL site. (Table 4 shows risk
characterization for land use scenarios).

The soils at the LTR landfill site contain hot spots that need
to be further characterized. The risks from the soils at this
site will be assessed in the second operable unit.
11
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Table 2
TOXICITY DATA FOR CHEMICALS OF CONCERN
ACCEPTABLE INTAKE CARCINOGEN POTENCY FACTORS
INHALATION INGESTON INHALATION INGESTON WEIGHT
CHEMICAl (mgJkg/day) (mg/kg/day) REFERENCE (mgJkg/day)'-1 ImgJkg/day)'-1 OF REFERENCE
RID RID SOURCE SLOPE FACTOR SLOPE FACTOR :viDENCE SOURCE
METHYLENE CHLORIDE 0.08 IRIS 0.014 0.0075 B2 IRIS
ACETONE ' 0.1 IRIS
1.1-DICHLOROETHENE 0.008 IRIS 1.2 0.8
1. 1-DICHLOROETHANE 0.1 0.1 HEAST 0.081 B2
1.2-D'CHLOROETHENE 0.02 HEAST
2-8UTANONE 0.08 0.05 HEAST/lAlS
1.1 0 I-TRICHLOROETHANE 0.3 0.08 HEAST/IRIS
TRICHLOROETHENE 0.00735 HEALTH ADV. 0.013 0.011 B2 IRIS
4-METHYL-2-PENTANONE 0.02 0.05 HEAST/lAlS
TETAACHLOROETHENE 0.01 IRIS 0.0033 0.051 B2 HEAST
TOLUENE 0.3 IRIS 0
XYLENE 0.2 2 HEAST/lRlS O
BIS (2-ETHYLHEXYL) PHTHALATE 0.02 IRIS 0.01. B2 IRIS
BARIUM 0.0001 0.05 HEAST/lRlS
CADMIUM 0.0005 HEAST 8.1 81
CHAOMIUM 0.005 IAIS ., IAIS
LEAD .0008 (b) B2
ZINC 0.2 HEAST
HEPTACHLOR 0.0005 IRIS 4.5 4.5 B2 IRIS
ALDRIN O.CIOCI03 IAIS 17 17 B2 IRIS
DIELDRIN 0.00005 IRIS 18 18 B2 IRIS
4.4-0DT 0.0005 IRIS 0.34 0.34 B2 IRIS
AROCLOA-1248 7.7 B2 IRIS
AROCLOA-1254 7.7 B2 IRIS
ARSENIC 0.001 HEAST 50 1.75 A HEASTn
BERYLLIUM 0.005 HEAST '.4 B2 HEAST
MANGANESE 0.0003 0.2 HEAST
MERCURY 0.0003 HEAST
SELENIUM 0.003 HEAST
SILVER 0.003 HEAST
NOTES:
IRIS -INTEGRATB) RESEARCH INFORMATION SYSTEM (2110)
HEAST - HEALTH EFFECTS ASSESSMENT SUMMARY TABLES (4ItI QUARTER. FY 1818)
NAPH - NAPHTHALENE AID VAlUE. THIS 18 NOT A UsePA VERIFIED AID.
la) EST. AID CALC. FROM THE PROPOSED DRINKING WATER STANO. OF 1.3 mg/L BY BVWST.
(b) AID CALC. IY IVWST FOR THIS ASSESSMENT lASs) ON PREVIOUS PROPOSED MCLG
OF 0.02 moll. THIS 18 NOT A U8EPA VEAlFls) AID.
AID - REFERENCE DOSE
-------
Table 3
USEPA WEIGHT-Of-EVIDENCE
CLASSIFICATION SYSTEM fOR
CARCINOGENICITY
GROUP DESCRIPTION
A. Human carcinogen
S1 or S2 Probable human carcinogen
S1 indicates that limited
human data are available.
82 indicates sufficient
evidence In animals and
Inadequate or no evidence
in humans.
C Possible human carcinogen
D Not classifiable as to
human carcinogenicity
E EvIdence of noncarclnogenlclty
of humans
-------
TABLE 4
RISK CHARACTERIZATION SUMMARY FOR LAND USE SCENARIOS
LEMBERGER SITES REMEDIAL INVESTIGATION REPORT, BVWST 1990
LAND USE CHRONIC HAZARD INDEX(age group) \EXCESS CANCER RISI<
SCENARIO 0-1 1-6 6-11 11-18 18-70 UFETlME
CURRENT <0.1 <0.1 <0.1 <0.1 <0.1 WWtmm;:t~:EHtfiMM;K@
FUTURE-LL SITE 0.8 8mt1';!Hi.~%! 0.2 0.1 <0.1 ;i~*~~?lrtt~~~~Efii~f.~*l~1r~?~$
NOTE: Exposure. include Invelllon oland dermal contact with IUrface 1011..
Shaded area. repre..nt rillk. >1 Chronic Hazard Inde. or >10-41 Cancer Rillk.
-------
2.
Future Groundwater Risks
For excess cancer risks, contaminant concentrations in samples
from 29 of the 33 monitoring wells were associated with risks
greater than 1 x 10~. Eight of the monitoring wells showed
an excess cancer risk of equal to or greater than 1 x 10~
risks. . The greatest risk of 2 X 10-2 was found at two
locations beneath the LTR site and risks as high as 3 X 10~
were associated with samples found beneath the LL Site. The
individual chemicals assessed to determine the excess cancer
risk may be found in Table 1.
5.
Risk Summary
Health risks for each site were evaluated based on a
residential use scenario. Contaminant concentrations used
were those identified during the RI.

All residents on the LL site would be exposed to contaminants
through ingestion and dermal contact with surface soils.
These soils exposures would result in an excess cancer risk of
1 X 10~ and, for children age 1 through 6, a chronic health
hazard index of 1.1.
Future residents on the LL site who installed a well into the
upper groundwater system would also be exposed to contaminants
through ingestion, dermal shower contact, and inhalation of
chemicals when showering. Based on concentrations .,of
compounds identified in monitoring wells on the LL site, this
could result in an excess cancer risk of 9 X 10~ and, for
children age 1 through 6, a chronic health hazard index of
28.8. Utilization of the lower groundwater system would
result in an excess cancer risk of 3 X 10~ and, for children
age 1 through 6, a chronic health hazard index of 1.5. .

All residents on the LTR site would be exposed to contaminants
through ingestion and dermal contact wi th surface soils.
These soils exposures would result in an excess cancer risk of
2 X 10~ and, for children age 1 through 6, a chronic health
hazard index of 3.3.
Future residents on the LTR site who installed a well into the
upper groundwater system would also be exposed to contaminants
through ingestion, dermal shower contact, and inhalation of
chemicals when showering. Based on concentrations of
compounds identified in monitoring wells on the LTR site, this
could result in an excess cancer risk of 3 X 10~. Utilization
of the lower groundwater system would resul t in an ,excess
cancer risk of 2 X 10~ and, for children age 1 through 6, a
chronic health hazard index of 30.8. (Table 5 shows the
12
-------
chronic hazard index and the excess lifetime cancer risk for
the monitoring wells at the site).

The risk assessment concluded that the primary health and
environmental threats posed by the .sites are through
consumption of hazardous substances in the groundwater through
ingestion, dermal absorption while showering or bathing, and
inhalation of chemicals emitted while showering and direct
contact with contaminated soil at the sites. The people at
risk of exposure to site-related contaminants are ~hose using
the groundwater at the sites as a potable water source and
farmers, hunters and trespassers entering the sites. If the
sites are further developed, construction workers or site
residents may also be exposed through direct contact wi th
contaminated soil.
Actual or threatened releases of hazardous substances from.
these sites, 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.
G.
Environmental standards not met at the site
In addition to posinq unacceptable risks to humans, the Lemberqer
sites do not meet certain applicable or relevant and appropriate
Federal or state environmental standards at this time.
1.
Groundwater
Table 5 lists the representati ve chemicals found in the
contaminated groundwater plumes and the corresponding Federal
and state groundwater cleanup standards which EPA believes to
be adequately protective. The groundwater contaminant plumes
contain concentrations of hazardous substances which exceed
most of these groundwater cleanup standards.
2.
Groundwater Protection Goals and the National Contingency
Plan
u.s. EPA's groundwater protection goal has been set forth in
the NCP as follows:
The National goal of the remedy selection process is to select
remedies that are protective of human health and the
environment, that maintain protection over time, and that
minimize untreated waste. Title 40 of the Code of Federal
Regulation (40 CFR) Part 300.430(a) (1) (i).
The NCP states that U. S. EPA expects to return usable
groundwaters to their beneficial uses, wherever practicable,
within a time frame that is reasonable given the particular
13
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Contaminanta of Concern
Methylene Chloride
Acetone
I,I-Diehloroethene
I,I-Diehloroethane
1.2-Diehloroctbene
2-Butanone
I,I,I-Triehloroethane
Triehloroethene
4-Methyl-2-pcntanone
Tctrachloroethcne
Toluene
Xylene
Bia(2-ethylhexyl)pbthalltO
Heptachlor
Aldrin
Dieldrin
4,4-DDT
Arochlor-I248
Arochlor-l254
Barium
Cadmium
Chromium
Lead
Zinc
Anenie
Beryllium
Manganae
Mercury
Selenium
Silver
Chloroform
Carbon Tetrachloride
Vinyl Cbroride
Table 5
GROUND WATER CLEANUP STANDARDS
Risk-Bued
Cleanup
Goal,
ugIL
Cleanup Standards
USEPA Max. USEPA Max. WuconsiD
Contaminant Contaminant Enforcement
Level (a) Level Goal (a) Standard (b)
uglL uglL uglL
S (c) 0 (c) ISO
WuconsiD

Preventive
\"',<'200.,}
(a) Code of Federal Regulation., Chapter 40, Part 241.
(b) Chapter NR 140, WISCODIiD Adminiastrative Code
(c) Propoaod Standard.
(d) Theae ltalldards are bued only on public welfare, not public health.
- indicates that no ItaIIdard ia provided. .
1::(:::::'...,}:::liadicates cleanup ltalldard for UK for Lemberger lites remedial action
s
rliOOO?
0.06
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200

,.",500.::.,

900
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7
7
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850
100
70 (c)
200
S
200
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200
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10,000 (c)
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1
343
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'.:.:.;.;
o (c)
.:,'.:.:.;.,,:
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0.005
0.9
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.... .... .. -
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-------
circumstances of the site. Whenever restoration of
groundwaters is not practicable, U.S.EPA expects to prevent
further migration of the plume, prevent exposure to the
contaminated groundwater, and evaluate further risk reduction.
(40 CFR Section 300.430(a) (1) (iii) (F».

Also,the NCP considers the use of institutional controls to
limit exposures to hazardous substances in the groundwater:
u.S. EPA expects to use institutional controls such as water
use and deed restrictions to supplement engineering controls
as appropriate for short-and long-term management to prevent
or limi t exposure to hazardous substances, pollutants, or.
contaminants.... The use of institutional controls shall not
substitute for active response measures as the sole remedy
unless such response measures are determined not to be
practicable. . . . (40 CFR Part 300.430 (a) (1) (iii) (D).
H.
DESCRIPTION OF REMEDIAL ALTERNATIVES
As with many Superfund sites, the conditions at the LL and LTR
Sites are complex. As a result, u.S. EPA organized the work into
two planned activities for effective evaluation of remedial
alternatives designed to reduce site risks to acceptable levels.
The remedial action selected in this ROD addresses the first of
these two planned activities or operable units at the sites. This
ROD addresses groundwater contamination at both the LL and LTR
sites, and source contamination at the LL site only.

The groundwater alternatives and the LL site source containment
(soil, and waste) al ternati ves have been developed separately. The
groundwater alternatives do not include any source control measures
or means of mitigating contaminant migration from the soil and
wastes into the groundwater. without source containment for the LL
Site, the contaminated soil, leachate and wastes may continue to
contaminate the groundwater and increase the time required to
cleanup the aquifers; therefore, both a source control alternative
for the LL Site and a groundwater alternative were evaluated
together for the Lemberger sites.
Source contamination at the LTR site will be further characterized
and a remedy will be selected for the second operable unit when
additional work is completed. At that time a subsequent ROD will
be prepared to address source control at the LTR site.
1.
Landfill site
Although the NCP reaffirms u.S. EPA's preference for permanent
solutions to Superfund site problems through the use of
treatm~nt technologies, the preamble to the NCP contemplates
that many remedial alternatives may be impractical for certain
14
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sites due to severe implementability problems or prohibitive
costs (e. g., treatment of the entire contents of a large
landfill). Since the LL site is a 45 acre landfill containing
homogeneous wastes where no hot spots of contamination were
found, u.s. EPA believes that treatment of the landfill
contents is impracticable because of severe implementability
problems, danger to workers and nearby residents, and
prohibitive costs; therefore, the FS was directed at the
evaluation of containment rather than treatment of the LL
source material. Source control alternatives range from no
action to capping and slurry wall.
2.
Groundwater
The objective of the ground remedial action unit is to achieve
Federal drinking-water standards under the Safe Drinking Water
Act and the State of Wisconsin groundwater Rule, Chapter NR
140. Groundwater alternatives range from no action to
groundwater extraction and treatment.
Groundwater Alternative.
The alternatives considered for detailed analysis in the FS are:
1.
4.
5.
No Action
Groundwater
Groundwater
Restoration
containment by Hydraulic Controls
Extraction and Treatment for Active
(Note: The National contingency Plan (NCP) requires that
al ternati ves be subj ected to an ini tial screening to eliminate
those alternatives that have adverse impacts on public health and
the environment, are not applicable to the contaminants and media
at the site, or are much more expensive to implement than other
alternatives that provide essentially the same level of risk
reduction. Based on this initial screening, two groundwater
alternatives were rejected before final screening. Alternative 2,
Limited Action, consists of institutional controls, groundwater
monitoring, and deed restrictions. This alternative was rejected
because it would not meet remedial action objectives. Alternative
3, Groundwater Containment by Vertical Barrier consists of
groundwater containment by a slurry wall, treatment of extracted
groundwater, monitoring and deed restrictions. This alternative
was rejected because it would not meet remedial action objectives).
Groundwater Alternative 1:
No Action
15
-------
A No Action alternative was evaluated to serve as a baseline for
comparison against the other cleanup alternatives. It assumes that
no corrective action will be taken at the site. No reduction of
toxicity, mobility, or volume through treatment or of the rate of
leaching of contaminants to the groundwater would be provided by
this alternative; therefore, no risk reduction would result from
this action. The No Action alternative would not meet Federal or
state drinking water standards for groundwater and is not
protective. There are no costs associated with this alternative.
GroUD4wa~.r Al~.rna~iv. 4:
GroUD4wa~.r Con~aiDm.n~ by By4raulic
controls
Groundwater Al ternati ve 4 includes pumping and treating groundwater
in the vicinity of the LL and LTR Sites to contain the contaminated
groundwater. The purpose of this alternative is to control the
movement of contaminated groundwater rather than achieve
groundwater cleanup goals. The approximate extent of the plume in
the upper aquifer is 189 acres and the lower aquifer plume covers
approximately 1,000 acres.
Groundwater Extraction Svstem
Approximately six extraction wells would be installed in the upper
and lower aquifer to extract the groundwater plumes. The wells in
the upper aquifer would be installed so that they terminate at the
top of the clay layer. The extraction wells would be used to
change the groundwater flow pattern to control the migration of the
contaminate plume. The exact number of extraction wells, well
locations and pumping rates in gallons per minute (gpm) would be
evaluated and selected during the design phase of the remedy. It
is estimated that the wells would be pumped at a combined rate of
110 gpm (1. 7 billion gallons of groundwater) for 30 years. An
. estimate of 30 years was used for costing purposes only; however,
it is expected the pumps will run perpetually.
Treatment Facilitv
An on-site treatment facility would be built at the LL site to
treat the contaminated groundwater. Treatment processes (Figure 5)
include electrochemical precipitation to remove inorganic
contaminants and granular activated carbon (GAC) to remove organic
contaminants, unless treatability studies show other technologies
to be more effective. The design of the actual process flow train
and the sizing of the treatment processes would be completed
following completion of a treatability study to evaluate the
performance of the systems. A 6-foot-high chain link security
fence would be constructed around the treatment facility to limit
general accessibility to the facility and the potential for public
exposure. Deed restrictions would be placed on properties over the
16
-------
nECTROCHEHI CN...
~
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CROtMJ NInER
EXTRftCTlON
NELlS
..
u
rc-
.
--
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Z~
...~
"0
~~
BRCKWRSH RETURN
LRIo£IIA
SE IlLER
OXIOANT
RCID/BRSE
RECYCLE RETURN
~
,.~'
SDLJ..DS
THICICENINQ
~
,.
BRCKHRSH
WtilHG
F'lLTER PRESS
" SUJJCE "
SPENT
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BRRNCH
RIVER
SRMPlINQ PORT
~
lMK
COMPRESSED
RIR
CRC COLUMNS
#
Flc:URE 5
CONCEPTUftl. F'LOH DIRCR,," OF'
CROUNO HATER TREATMENT PROCESS
-------
contaminant plume to prevent contaminated groundwater from being
used.
Treated effluent from the groundwater treatment system would be
discharged into the Branch River. A Wisconsin Pollutant Discharge
Elimination System (WPDES) permit would not be required for on-site
discharge to the Branch Ri veri however, the substanti ve State
requirements for effluent discharge limitations would be met before
discharge.
Monitorina Proaram
A monitoring program would be developed to evaluate the
effectiveness of the extraction system. Selected residential wells
(including the Denor well) would be identified during design and
included in the monitoring program.
Manaaement of Treatment Residuals
Treatment of the contaminated groundwater will result in the
generation of residual sludge containing metals and other
contaminants. The sludge would be stored temporarily in 55-gallon
drums. Approximately seven cubic yards (21 drums) of waste would
be generated every month.
The contaminated groundwater contains organic constitutents which
originated from listed waste at the LTR Site. It may be possible
to remove the organics from the groundwater to below health base
levels, prior to generating a metal bearing sludge from the
chemical precipitation treatment. If the groundwater has been
successfully treated, then the organic contaminants will not make
the sludge a listed hazardous waste and will not trigger Land
Disposal Restrictions (LDRs). In the event that the groundwater
cannot be treated to remove all organics above health based levels,
or the sludge does contain detectable levels of organic
contaminants, the sludge will be managed as a listed hazardous
waste. If the sludge is a listed hazardous waste, it may, if
possible, be disposed of as part of the LTR source control remedy.
Alternatively, it may be treated and disposed of offsite at a RCRA
Subsitle C landfill.
The sludge is not expected to contain metals at concentrations
above characteristic levels. If, after testing by the TCLP, it is
determined that the sludge is characteristic for metals, it will be
treated below characteristic levels. Sludge which does not contain
organics and is not characteristic for metals may be disposed of as
a solid waste.
If the sludge is a listed hazardous waste, it may, if possible, be
disposed of as part of the LTR source control remedy.
Alternatively, it may be treated and disposed of offsite at a RCRA
Subtitle C landfill. If organics are successfully removed prior to
17
-------
the electrochemical precipitation, the sludge containing metals
would not be a listed hazardous waste.
If the sludge is neither a characteristic nor a listed waste, it
will be disposed of as a solid waste, and Land Disposal
Restrictions would not be applicable. If the sludge must be
managed as a listed hazardous waste, then the sludge would be
treated to appropriate LDR standards prior to on- or off-site
disposal. It is expected that the spent carbon from the treatment
system would be recycled in a unit in compliance with 40 CFR 264
(Subpart X).
Wetlands

An investigation would be conducted during remedial design to
determine the extent of the wetlands on the Lemberger sites and the
impact that pumping groundwater from the upper aquifer would have
on these wetlands. Measures would be implemented to avoid damage
to these wetlands. Potential impacts on wetlands would be avoided
or mitigated in accordance with Chs. NR 1.95 and NR 103, Wis. Adm.
Code. If damage occurs, the impact on the wetlands will be
mitigated.
Capital Costs
Annual O&M 1st year
Each year thereafter
Present Worth
Time to implement
$ 2,800,000
442,000
343,000
8,200,000
12 Months
Groundwater Alternative 5:
Groundwater Extraction and Treatment
for Active Restoration
- Groundwater Al ternati ve 5 involves pumping and treating groundwater
in the vicinity of the LL and LTR sites to actively and
aggressively remove the contaminants-and restore the aquifer to
meet cleanup standards at the waste management boundary. The major
difference between Groundwater Alternative 4 and 5 is that the
purpose of Al ternati ve 4 is only to contain the contaminated
groundwater to prevent it from moving off-site and purpose of this
Alternative is to remove contamination from the groundwater and
actively restore the aquifer. The description of this alternative
is the same as for groundwater alternative 4, but because a greater
volume (flow rate) of groundwater would be removed from the aquifer
(at a much faster rate) and treated, the operation and maintenance
~f the system would be greater and a larger volume of sludge
r~quiring disposal would be generated from the treatment process.
Approximately 40 drums of waste would be generated each month. It
is estimated 210 gpm of groundwater (1.7 billion gallons) would be
pumped and treated for 16 years. The target area and extraction
18
-------
well placement for groundwater alternative 5 is illustrated in
figure 6.
Treated effluent from the groundwater treatment system would be
discharged into the Branch River. A wisconsin Pollutant Discharge
Elimination System (WPDES) permit would not be required for an on-
site discharge to the Branch River; however, the substantive state
requirements for effluent discharge limitations would be met before
discharge. .
Management of treatment residuals would be the
groundwater alternative 4.
same
as
for
Monitorina proaram
A monitoring program would be developed to evaluate. the
effectiveness of the extraction system. Selected residential wells
(including the Denor well) would be identified during design and
included in the monitoring program.
Groundwater CleanUD Standards
Groundwater will be pumped and treated until contaminants do not
exceed Federal Maximum contaminant Levels (MCLs) or more stringent
state standards, notably the Wisconsin Preventive Action Limits
(PALS). Collectively, the cleanup levels will comply with the 10~
to 10~ risk range as required by the National contingency Plan
(NCP). If there is a contaminant for which an MCL, MCLG or PAL
does not exist, but for which health-based data is available, then
the risk based number will be used. A health-based risk level of
10 ~ was used for carcinogens and an HI level .of 1 (HI=l) was used
for non-carcinogens. The groundwater standards are presented in
Table 6. .
Wetlands

t CONCEPTUAL DESIGN FOR GW ALTERNATIVE 5-
GROUND WATER EXTRACTION AND
TREATMENT FOR ACTIVE RESTORATION
ICAU
10acr
~.
o
+
+
~...I
...1«
~Z
-;:;.. :~
w \,J
-
u:a:
00
a
0.'
Figure 6
-------
Source control Alternatives
The alternatives considered for detailed analysis in the FS are:
1.
3.0
4.
5.
No Action
Solid Waste Cap
Multilayer Cap
Solid Waste Cap
and Slurry Wall
(Note: The National contingency Plan (NCP) requires that
alternatives be subjected to an initial screening to eliminate
those alternatives that have adverse impacts on public health and
the environment, are not applicable to the contaminants and media
at the site, or are much more expensive to implement than other
alternatives that provide essentially the same level of risk
reduction. Based on this screening, Source Control Alternative 2,
was rejected because it would not meet all Remedial Action
Objectives, Alternative 6 was rejected because it is essentially
the same as Source Control Al ternati ve 5 at a higher cost and
Alternative 7 was rejected because it would be difficult to
implement, would create dangers for workers and nearby residents,
and would have extremely high costs. These alternatives were not
evaluated in detail in the FS).
Source Control Alternative 1:
No Action
The description for this alternative is the same as for Groundwater
No Action.
Source control Alternative 3:
Soli4 Waste Cap
This alternative involves capping the known extent of the wastes at
the LL site with a solid waste cap to reduce potential contact with
contaminated material and reduce water infiltration into waste
areas. Drainage controls, vegetation, and a 6-foot high security
fence would be provided to minimize erosion and limit disturbances
to the cap. Deed restrictions may be placed on the site to prevent
future uses of the land. A cross section of the solid waste cap is
shown on figure 7.
CaD Construction
The waste area would be cleared and regraded to smooth out the
existinq cap. Borrow soil would be used as necessary on the
existinq cap. The cap layers include from bottom to top: A
grading layer (existinq cover may be used, if adequate) a compacted
clay layer, a drainaqe layer an optional geotextile fabric, a
compacted native soil layer, topsoil, and a veqetative cover. A
conceptual design is presented in fiqure 8.
20
-------
cno OHG NO:COOOOaS1\P
ORTE:3-6-91 TlR
PLOT SCALE: 1\4"=1'
NATIVE SOIL
TOPSOIL
I N IT I AL COVER
RNO NATIVE SOIL
GEOTEXTILE
SRND DRAINAGE LAYER
"""""""
""""""'"
""""""""
. .. """""
.."",
""". ,...
UPPER GRANULRR UNIT
.-t
,..
COHESIVE UNIT
"
///, .
/ / / ,.. LONER GRRNULAR UNIT
all/ ,,////////,.
all///////////////,
////////////
.-t ////////// .
,,//////"
.,""""" """
NOT TO SCALE
NOTE: THE ACTIVE INTERIOR GAS COLLECTION
SYSTEM HOULO BE LOCATED HITHIN THE HASTES.
. ....eo _.a
.----.---...... . . ,..
6"
t
2'-0"
S"
2'-0"
S" HIN
FIGURE 7
CROSS SECTION OF
, CLAY CAP
-------
/
LEGEND
NOTES:
~~.. "-;;::
-: .>-
'\ I
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,-,
.\
\ .
\ "
,
-
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.-
'-
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._-
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.,(
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.........~"
APPROXIMATE SCALE
0'
178'
J

352'
N

+
FIGURE 8
TOPOaRAPHIC MAP PREPARED 8Y: MARTINEZ CORP.
--..----... .
..-. --- -- . ---
-------
The minimum design requirements of the cap would meet the state of
Wisconsin NR 504.07(1)-(7), Wis. Adm. Code Solid Waste regulations.
The compacted clay layer would be 2 feet thick and would have a
permeability of less than 1 x 10-7 cm/sec. The clay layer would be
placed in maximum 6 inch thick lifts. The drainage layer would be
placed on top of the clay layer to minimize hydraulic pressure and
would be a 6-inch-thick sand layer. A geotextile fabric may be
placed over the sand to prevent clogging. A minimum 2-foot-thick
native soil layer and a minimum 6-inch-thick layer of topsoil would
compose the top layers of the cap. The drainage layer and
overlying soil would provide protection for the compacted clay and
reduce the potential for damage from freeze-thaw cycles'and other
environmental factors. The final layer of the cap would be graded
to a minimum of 3 to 5 percent and a maximum of 25 percent. A
vegetative cover of native grass would be established to minimize
cap erosion. Earthen drainage channels would be located around the
perimeter of the cap to collect surface runoff and water from the
drainage layer. The collected water would eventually drain into
the wetlands west of the landfill. Documentation of the cover
construction shall be in accordance with substantive requirements
of NR 516, Wis. Adm. Code.
Gas Collection Svstem
An active gas collection and combustion system would be installed
if required to meet state regulations unless it could be
demonstrated through adequate testing that the performance criteria
of NR 504.04(4)(f), Wis. Adm. Code, could be achieved without
implementing such a system. The collected landfill gases would be
treated by combustion. It is assumed that supplemental fuel would
be required to provide combustion. Gas monitoring should be
conducted to enable adequate design of the gas collection and
treatment system. The active gas collection system shall be
designed to meet the requirements of SSe NR 504.05(7), NR 504.07(3)
and NR 506.08(6), Wis. Adm. Code. Documentation of the system
construction shall be in accordance with Ch. NR 516, wis. Adm.
Code.
Monitorina
Monthly site monitoring would be performed to provide cap
maintenance. Long-term groundwater monitoring would be associated
with the cap operation. .
Wetlands
An investigation would be conducted during remedial design to
determine the extent of the wetlands on the Lemberger sites and the
impact that pumping groundwater from the upper aquifer would have
on these wetlands. Measures would be implemented to avoid damage
to these wetlands. Potential impacts on wetlands would be avoided
21
-------
or minimized in accordance with Chs. NR 1.95 and NR 103, Wis. Adm.
Code. If damage occurs, the impact on the wetlands will be
mitigated.
capital Costs
Annual O&M 1st year
Each year thereafter
Present Worth
Time to implement
$8,500,000
79,000
43,000
9,200,000
16 Months
source control Alternative 4:
Multilayer Cap
This alternative is the same as source control alternative 3
except, the cap includes a synthetic membrane with a minimum 60-mil
thickness. The multilayer cap construction would be in compliance
with the Resource Conservation and Recovery Act (RCRA) and would
comply with WDNR NR 600 requlations.

In addition to the multilayer or hazardous waste cap, vegetation
would be planted and surface water would drain into trenches
constructed at the edge of the cap. A security fence would be
installed around the site to prevent access. Deed restrictions
would be placed on the site to prevent future uses of the land.
The gas collection system would have the same requirements as in
source control Alternative 3. A cross section for alternative 4 is
illustrated in fiqure9.
capital Costs
Annual O&M 1st year
Every year thereafter
Present Worth Cost
Time to implement
$10,100,000
79,000
43,000
10,800,000
16 Months
Source Control Alternative 5:
Solid Waste cap and Slurry Wall
The solid waste cap portion of this alternative is the 'same as
Alternative 3. In addition to the solid waste cap, a slurry wall
would be constructed around the perimeter of the wastes at the LL
site to control the amount of groundwater infiltration into the
wastes and the amount of contaminant migration from the waste
areas.
Slurry Wall Construction

The slurry wall would be keyed into the clay layer. A trench would
be excavated and backfilled with a slurry consisting of bentonite,
water, and soil or cement to form a low-permeability containment
wall. Figure 10 shows a cross section of the cap and slurry wall.
Fiqure 11 shows the conceptual design for source control
alternative 5. At least one small volume extraction well would be
installed in the upper aquifer to collect groundwater from within
the slurry wall. The exact number of small volume extraction
22
-------
CAD DHG NO:C0000833/P
DATE: 3-7-91 1IA
PLOT SCALE: 1\4N=I'
rLEXIBLE MEMBRANE LINER
NATIVE SOIL
TOPSOIL
SAND DRAINAGE LAYER
6"
2'-6"
1 ' -0"
6N
2'-0"
,"'"
'"",.,..
, """"'"
,', """"'"
""""'"
.. , , ,.
6" MIN
FLEXIBLE MEMBRANE
ANCHOR TRENCH. FILLED
WITH NATIVE SOIL
UPPER GRANULAR UNIT
..
,..
COHESIVE UNIT
..
,/
/ / /,
/ / / ,.. LOWER GRANULAR UN IT
'//,/. ,/ ////////".
'/////////////////,
..
.""'""""""
NOT TO SCALE
)
ITE: THE ACTIVE INTERIOR GAS COLLECTION
SYSTEM HOULD BE LOCATED HI THIN THE HASTES.
FIGURE 9
CROSS SECTION OP
MUl TIlAYER CAP
SC AlT~RNAT{VE 4
-------- _..
-------
NATIVE SOIL
SAND DRAINAGE LAYER
~VEL
"""""
"""""
"""""'"
, " , ,
.,""
, , , , , , ' S.
''II
COHESIVE UNIT
/ / / ,
/ / / ,... LOHER GRANULAR UNI T ~
"/// //////////.
'/////////////////,
"""""""""
INIT I AL COVER
AND NATIVE SOIL
"'"
."",
"""
""'"
SLURRY HALD-
"'"
////////////
////////// .
/////// "
CROSS SECTION OF SLURRY WALL AND CLAY CAP
Figure 10
-------
~
APPROXIMATE EXTENT OF WASTE
~ APPROXIMATE LIMIT OF SLURRY WALL
- ( - APPROXIMATE LIMIT OF CAP
--... - DIRECTION OF PROPOSED DRAINAGE
SECURITY FENCE
PROPOSED EXTRACTION WEll
WITHIN SLURRY WAll
'l / / / // BOUNDARY REOUIRING A
RET ~INING STRUCTURE
~
()
1. ACTUALLOCA TlON AND NUMBER OF EXTRACTION
WELLS WITHIN SLURRY WALL WOULD BE
DETERMINED DURING REMEDIAL DESIGN.
2. TRANSMISSION PIPING TO GROUND WATER
TREATMENT SYSTEM IS NOT SHOWN. FIGURES
6-1 AND 6-3 SHOW THE LOCATION OF THE
GROUND WATER TREATMENT SYSTEM.
3. RETAINING STRUCTURE WILL BE
LOCATED OUTSIDE WASTE EXTENTS.

4. GAS EXTRACTION WEll LOCATIONS Will BE ....
DETERMINED DURING REMEDIAL DESIGN
AND THUS ARE NOT DEPICTED.
.. .~''''";:::::' . ~
.
~
"'+
..'
APPROXIMATE S~
cr
17..
.
:ISZ'
.

t
FIGUI'IE 11
Tc.oo"'A""IC "'A~ .AC8'ACI"\ ay. UID""'I"r"P "'''''etl'''l
-------
wells, well locations, and pumping rates would be selected during
the remedial design. The design for the number and locations of
internal extraction wells must provide for adequate inward
groundwater gradients at all points within and at the edges of the
entire waste mass. Water extracted from this welles) would be
blended with the water being extracted for groundwater remediation
and would be treated at the groundwater treatment facility. The
extraction welles) would be operated for as long as contaminated
groundwater within the wall is generated. For costing purposes,
the wells are assumed to operate for 30 years.
Capital Cost
Annual O&M 1st year
Every year thereafter
Present worth
Time to implement
$9,200,000
80,000
44,000
9,900,000
19 Months
I.
summary of comparative Analysis of Alternatives
In accordance with the NCP, the relative performance of each
alternative is evaluated using the nine criteria (40 CFR 300.430)
(e) (9) (iii», as a basis of comparison. This evaluation
determines the remedy that provides the best balance of the nine
criteria. Except for the No Action alternatives, the Groundwater
Alternatives are compatible with each of the Source Control
Alternatives to develop a remedial action. Both a Groundwater
Alternative and a Source Control Alternative for the LL Site were
evaluated in order to decrease the continued contamination of the
groundwater from the wastes and the length of time required to
clean the aquifers to water quality standards. The nine criteria
evaluation is as follows:
Threshold criteria
1.
Overall Protection of Human Health and the Environment
Overall protection of human health and the environment addresses
whether a remedy provides adequate protection and describes how
risks posed by each exposure pathway are eliminated, reduced, or
controlled throuqh treatment, enqineerinq controls, or
institutional controls.
The no action alternatives do not provide protection. Groundwater
Al ternati ve 4 would contain the contamination; however, . a risk
would remain because the groundwater would not be actively
remediated. Groundwater Alternative 5 is more effective over time
and would provide a reductio~ of risk to human health and the
environment because contaminant concentrations greater than the
cleanup standards would be actively removed from the aquifer and
remediated.
23
-------
Source Control Alternatives 3, 4, and 5 would protect human health
by reducing the potential for direct contact with contaminants and
would reduce the migration of contaminants offsite through capping
of the wastes at the LL site. The cap would protect the
environment by reducing contaminant migration to the groundwater.
Source Control Alternative 5 would provide the greatest reduction
in risk by the addition of the slurry wall. The slurry wall and
internal hydraulic controls, including pumping wells, would provide
the greatest benefit because it would prevent clean groundwater
from flowing into the waste from off-site, and would also prevent
contaminated groundwater inside the wall from flowing away from the
si te, further contaminating the. upper aquifer. Source control
Alternatives 3, 4, and 5 would meet remedial action objectives.
2.
Compliance with ARARs
compliance vith Applicable or Relevant and Appropriate Requirements
(ARARs) addresses whether or not a remedy vill meet all of the
applicable or relevant and appropriate requirements of other
Federal and state environmental statutes and/or provide grounds for
invoking a waiver.

The major groundwater ARARs include the requirements of the Federal
Safe Drinking Water and Clean Water Acts and State Groundwater
Quality standards, NR 140. The major Landfill Closure ARARs
include the Resource Conservation and Recovery Act (RCRA) , and
Wisconsin Solid Waste Landfill Closure Requirements of Chapters NR
445, NR 500 series and NR 600 series of the Wis. Adm. Code.
Groundwater and Source Control No Action Alternatives 1 are not
expected to meet Federal and State ARARs. Groundwater Alternative
4 is for the purpose of containment only, not aquifer restoration,
and may never meet water quality standards. All other groundwater
and source control alternatives are expected to meet all ARARs.
Addi tional information on ARARs may be found in the section on
Statutory Determinations.
Primary Balancing Criteria
3.
Long-Term Effectiveness and Permanence.
Long-Term Effectiveness and Permanence refers to expected residual
risk and the ability of a remedy to maintain reliable protection of
human health and the environment over time once cleanup goals have
been met.
Groundwater Alternatives 4 and 5 would reduce risk to human health
and the environment over the long term by treating the groundwater.
Groundwater Alternative 5 has a greater reduction in risk because
it restores the aquifer to cleanup goals. A long-term risk would
remain for Groundwater Alternative 4, since the contaminated
groundwater would remain in the aquifer for a long period of time.
24
-------
A risk may exist from the sludge generated during the electro- ,
chemical precipitation process if it contains hazardous
constituents in sufficient quantities to make it a hazardous waste.
If the sludge is classified as a listed hazardous waste, it would
be treated to meet LDRs before disposal at a hazardous waste
facility. Spent carbon is expected to be regenerated, so it would
not exhibit a long-term residual risk.
A long-term risk would remain from the source control alternatives
because the material would not undergo treatment. The cap would,
however, reduce infiltration and subsequent leaching of
contaminants into the groundwater. The slurry wall and internal
hydraulic controls (internal pumping wells) combined with the cap
would have added benefit by minimizing contaminant movement than
would a cap alone and would allow restoration of the aquifer at a
much faster rate. The slurry wall would prevent clean groundwater
from flowing into the waste from off-site, and would also prevent
contaminated groundwater inside the wall from flowing away from the
site, further contaminating the upper aquifer. The cap, slurry
wall, fencing and deed restrictions in the source control
'alternatives would also minimize human contact with the wastes.
4 . Reduction
Treatment.
of
Toxicity,
Mobility
or
Volume
through
Reduction of Toxicity, MoJ:dlity, or Volume is the anticipated
performance of the treatment technologies a remedy may employ.

Treatment in Groundwater Alternatives 4 and 5 would reduce toxicity
through electrochemical precipitation and carbon adsorption;
however, a treatment sludge would remain and may require further
treatment. No treatment would be conducted to reduce toxicity,
mobility or volume in Source Control Alternatives 3, 4, and 5, but
Source Control Alternative 5 would indirectly reduce contaminant
mobility because the remedy involves a slurry wall placed around
the perimeter of the wastes with internal hydraulic controls
(internal pumping wells) which would prevent clean groundwater from
flowing into the waste from off-site, and would also prevent
contaminated groundwater inside the wall from flowing away from the
site. In addition, Source Control Alternative 5 would treat the
extracted groundwater from within the slurry wall along with the
groundwater from the pump and treat system in either Groundwater
Alternatives 4 or 5 and would, therefore, undergo a reduction in
toxicity, mobility, and volume of contaminants.
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
25
-------
environment that may be posed during the construction
implementation period until cleanup goals are achieved.

Groundwater Al ternati ves 4 and 5 would involve installation of
extraction wells and a groundwater treatment facility. Risks to
the community would be low, but could be greater for workers
because of the potential for direct contact with contaminants.
Protection for site workers during implementation of Groundwater
Alternatives 4 and 5 would be addressed by site safety plans.
During the operation of the extraction/treatment system,
institutional controls would be used to minimize the potential for
exposure to contaminated groundwater.
and
Risks to the community during implementation of Source Control
Alternative 5 (cap and slurry wall) would be minimal but greater
than Source Control Alternatives 3 and 4 (capping). Workers in all
source control alternatives may be exposed to contaminants during
various construction activities associated with capping and slurry
wall installation. Site safety measures would be taken to protect
the community and site workers. Health and safety plans would be
developed before cleanup activities begin. Workers would wear
protective clothing and be in compliance with Occupational Safety
and Health Act (OSHA) requirements. Air contaminants could be
emitted during construction for all alternatives. Air monitoring
would be conducted to determine if air contaminants were being
emitted and the appropriate safety measures would be taken.

Short-term environmental impacts resulting from all alternatives
would include noise pollution and dust during construction. , The
source control al ternati ves may have surface-water runoff resul tinq
from construction of the caps. Measures would be taken to avoid
impacts on the wetlands. Again, protection of site workers and the
community during the implementation of all alternatives would be
addressed by site safety plans.
The estimated time until remedial action goals are achieved for
Groundwater Alternative 5 is 16 years. Groundwater Alternative 4
is intended for containment only and will take'a least 30 years to
meet groundwater cleanup goals.
6.
Implementability
Xmplementability is the technical and admi~i.trative feasibility of
a remedy, including the availability of materials and services
needed to implement a particular option.

All the alternatives considered are technically feasible. The
treatment processes in Groundwater Alternatives 4 and 5 have been
used at other Superfund sites and are familiar in the construction
industry. The construction techniques for the landfill cover,
slurry wall and groundwater extraction wells are also proven
technologies. Source Control Alternative 5 would be more labor
26
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intensive to construct because of the slurry wall. If wells were
required in the cap area from the groundwater alternatives,
watertight connections between the membrane and the well casings
would be required for Source Control Alternative 4. Access may be
difficult as a few residents have been reluctant to allow access
during the RIfFS.
7.
Co~t
Estimated cost includes estimated capital,
maintenance, and present net worth costs.

The estimated costs for remedial action alternatives, listed in the
fOllowing table, are order-of-magnitude estimates with an intended
accuracy range of +50 percent and -30 percent for the identified
remedy. The estimated cost of the selected remedy will be further
refined in the final design. capital costs are the direct and"
indirect costs required to initiate and install a remedial action.
Annual operation and maintenance costs (O&M) includes the annual
operating cost for a remedial action incurred and paid on a yearly
basis following implementation of the remedial action. Present
worth analysis provides a method for evaluating and comparing costs
that occur over different time periods by discounting future
expenditures to the present year. .
operation
and
Each groundwater alternative (except no action) was combined with
each source control al ternati ve (except no action) to estimate
costs. They must be combined to meet remedial action goals. Table
6 shows the costs for Groundwater Alternative 4, Containment by
Hydraulic Controls, combined with each of the source control
alternatives and Groundwater Alternative 5, Extraction and
Treatment for Active Restoration, also combined with each of the
source control alternatives. All alternatives are similar in cost.
Groundwater containment by hydraulic controls combined with a cap
is the least expensive, with a present net worth cost of $17.4
million. The groundwater hydraulic controls alternative combined
with the multilayer cap alternative costs $19 million. The
groundwater active restoration alternative combined with the cap
and slurry wall al ternati ve costs $19.2 million and is less
expensive than active restoration combined with the multilayer cap
alternative which costs $20.1 million. Groundwater hydraulic
controls combined with the cap and slurry wall are less costly at
$18.1 million.
27
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Table 6
COST ESTIMATES FOR EACH ALTERNATIVE
Groundwater Alternative 4 Capital Cost OiM. Present Net
containment by Hydraulic Worth
Controls with:
Source Control 3 .- Solid $11.3 million $521,000 $17.4 million
Waste Cap $386,000
Source Control 4 - Hazardous $12.9 million $521,000 $19.0 million
Waste Cap $386,000
Source Control 5 - Solid Waste $12 million $522,000 $18.1 million
Cap & Slurry $387,000
Wall
Groundwater Alternative 5 capital Cost OiM. Present Net.
Extraction and Treatment Worth
for Active Restoration with:
Source Control 3 - Solid Waste $11. 5 million $730,000 $18.5 million
Cap $595,000
Source Control 4 - Hazardous $13.1 million $730,000 $20.1 million
Waste Cap $595,000
Source Control 5 - Solid Waste $12.2 million $731,000 $19.2 million
Cap & Slurry $596,000 II
Wall
*
First O&M figure is first year of implementation
Second O&M figure is second year to cleanup
Modi~yinq criteria
8.
state Acceptance
The State of Wisconsin is in agreement wi th the selection of
Groundwater Alternative 5 and Source Control Alternative 5 for
remediation of the Lemberger Landfill, Inc and the Lemberger
Transport & Recycling Site and has provided U.S. EPA with a letter
of concurrence.
9.
Community Acceptance.
Based on the comments received by U.S. EPA, the selected
al ternati ve is acceptable to the community. Communi ty concerns are
addressed in the attached Responsiveness Summary.
28
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J.
The Selected Remedv
Before noting the maj or components and costs of the selected
remedy, it is appropriate to discuss remediation goals for
groundwater at the site. The goal of this remedial action is to
restore all portions of the aquifer to the waste management
boundary, so.that it may serve as a drinking water resource. Some
studies suggest: however, that not all groundwater extraction and
treatment programs are completely successful in reducing
contaminant concentrations to health-based levels throughout an
aquifer. u. S. EPA therefore recognizes that review of future
operating data may indicate the technical impracticability of
attaining health-based groundwater quality standards throughout the
aquifer. If, at any of the subsequent five-year reviews, it
becomes apparent that unsatisfactory progress is being made in
attaining groundwater goals, the remedy may be reevaluated. If the
remedy is reevaluated, any change in remedy shall be accomplished
by reopening and amendment of the ROD, to include an explanation
and documentation of all findings, in accordance with 42 U.S.C.
9261(d) (4), and 9617.
Based on the findings of the RIfFS, and the evaluation of the nine
criteria, u.S. EPA and the State of Wisconsin have identified
Groundwater Alternative 5 and Source Control Alternative 5 as the
final remedy for the Lemberger Landfill, Inc. site and the first
operable unit for the Lemberger Transport & Recycling site. This
combination of alternatives represents the best balance among the
evaluation criteria and satisfies the statutory requirements for
protectiveness, compliance with ARARs, cost effectiveness, and the
use of permanent solutions and alternative treatment technologies
or resource recovery technologies, to the maximum extent
practicable. See figure 12 for the conceptual design.
Groundwater Alternative 5
Source Control Alternative 5
Time to Implement:
Total Present Worth cost:
capital Cost:
Annual O&M Cost: First Year
Second Year to Cleanup
19 Months
$19,200,000
$12,200,000
$ 731,000
$ 596,000
Major components of the selected remedy are the following:
Groundwater Extraction System
Approximately six extraction wells would be installed in the upper
and lower aquifer to extract the groundwater plume. Groundwater
shall be extracted until the groundwater cleanup standards in Table
6 are achieved at the waste management boundary, in this case, the
edge of the slurry wall. Any disruption of residential water
29
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LEMBERGER LANDFILL
GROUNO HATER
TREATMENT
SYSTEM
SLURRY
HALL
SLURRY
HALL
EXTRACTION
HELL
EXISTING CLAY LAYER
CONTAMINATEO
GROUND HATER
RECOMMENDED CLEANUP ACTIVITY
Figure 12
-------
supply due to the operation of the groundwater extraction system
must be compensated for through an alternative supply of water.
The exact number of extraction wells, well locations and pumping
rates (total gallons per minute (gpm) shall be evaluated and
selected during the engineering design phase of the remedy. It is
estimated that the wells would be pumped at a combined rate of 210
gpm for 16 years. Any impact from the Ridgeview site will be
addressed in the design.
Treatment Facilitv
An on-site treatment facility would be built at the LL site to
treat the contaminated groundwater. Treatment processes (figure 3)
include electrochemical precipitation to remove inorganic
contaminants and granular activated carbon (GAC) to remove organic
contaminants unless treatability studies show other technologies to
be more effective. The design of the actual process flow train and
the sizing of the treatment processes shall be completed following
completion of a treatability study to evaluate the performance of
the systems. Sludge will be generated from the processes and will
require disposal according to Federal .and State regulations. If
possible, spent carbon will be recycled. Treated effluent from the
groundwater treatment system will be discharged into the Branch
River according to applicable Federal and State regulations. A 6-
foot-high chain link security fence would be constructed around the
treatment facility to limit general accessibility to the facility
and the potential for public exposure. Deed restrictions may be
used to limit the use of contaminated groundwater.
Monitorina Proaram
New and existing monitoring wells would be used to verify the
hydraulic performance of the extraction wells, to determine the
extent of the cones of depression around the extraction wells.
Selected residential wells, including the Denor well, will be
included in the monitoring program.
Manaaement of Treatment Residuals
Treatment of the contaminated groundwater will result in the
generation of residual sludge containing metals and other
contaminants. The sludge would be stored temporarily in 55-gallon
drums. Approximately seven cubic yards (21 drums) of waste would
be generated every month.

The contaminated groundwater contains organic constitutents which
originated from listed waste at the LTR site. It may be possible
to remove the organics from the groundwater to below health base
levels, prior to generating a metal bearing sludge from the
chemical precipitation treatment. If the groundwater has been
successfully treated, then the organic contaminants will not make
the sludge a listed hazardous waste and will not trigger Land
30
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Disposal Restrictions (LDRs). In the event that the groundwater
cannot be treated to remove all organics above health based levels,
or the sludge does contain detectable levels of organic
contaminants, the sludge will be managed as a listed hazardous
waste. If the sludge is a listed hazardous waste, it may, if
possible, be disposed of as part of the LTR source control remedy.
Alternatively, it may be treated and disposed of offsite at a RCRA
Subsitle C landfill.
The sludge is not expected to contain metals at concentrations
above characteristic levels. If, after testing by the TCLP, it is
determined that the sludge is characteristic for metals, it will be
treated below characteristic levels. Sludge which does not contain
organics and is not characteristic for metals may be disposed of as
a solid waste.
If the sludge is a listed hazardous waste, it may, if possible, be
disposed of as part of the LTR source control remedy.
Alternatively, it may be treated and disposed of offsite at a RCRA
Subtitle C landfill. If organics are successfully removed prior to
the electrochemical precipitation, the sludge containing metals
would not be a listed hazardous waste.
If the sludge is neither a characteristic nor a listed waste, it
will be disposed of as a solid waste, and Land Disposal
Restrictions would not be applicable. If the sludge must be
managed as a listed hazardous waste, then the sludge would be
treated to appropriate LDR standards prior to on- or off-site
disposal. It is expected that the spent carbon from the treat~ent
system would be recycled in a unit in compliance with 40 CFR 264
(Subpart X).
Wetlands

An investigation would be conducted during remedial design to
determine the extent of the wetlands on the Lemberger sites and the
impact that pumping groundwater from the upper aquifer would have
on these wetlands. Measures would be implemented to avoid damage
to these wetlands. Potential impacts on wetlands would be avoided
or minimized in accordance with Chs. NR 1.95 and NR 103, Wis. Adm.
Code. If damage occurs, the impact on the wetlands will be
mitigated.
Cap Construction
The waste area would be cleared and regraded to smooth out the
existing cap. Borrow soil would be used as necessary on the
existing cap. The cap layers include from bottom to top: a
grading layer (existing cover may be used, if appropriate) a
compacted clay layer, a drainage layer an optional geotextile
fabric, a c~mpacted native soil layer, topsoil, and a vegetative
cover. A conceptual design is presented in figure 6.
31
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The minimum design requirements of the cap would meet the State of
Wisconsin SSe NR 504.07(1)-(7), Wis. Adm. Code Solid Waste
requlations. The compacted clay layer would be 2 feet thick and
would have a permeability of less than 1 x 10~ em/sec. The clay
layer would be placed in maximum 6 inch thick lifts. The drainage
layer would be placed on top of the clay layer to minimize
hydraulic pressure and would be a 6-inch-thick sand layer. A
geotextile fabric may be placed over the sand to prevent clogging.
A minimum 2-foot-thick native soil layer and a minimum 6-inch-thick
layer of topsoil would compose the top layers of the. cap. The
drainage layer and overlying soil would provide protection for the
compacted clay and reduce the potential for damage from freeze-thaw
cycles and other environmental factors. The final layer of the cap
would be graded to a minimum of 3 to 5 percent and a maximum of 25
percent. A vegetative cover of native grass would be established
to minimize cap erosion. Earthen drainage channels would be
located around the perimeter of the cap to collect surface runoff.
and water from the drainage layer. The collected water would
eventually drain into the wetlands west of the landfill.
Documentation of the cover construction shall be in accordance with
Ch. NR 516, Wis. Adm. Code.
SlurrY Wall Construction
The slurry wall would be keyed into the clay layer. A trench would
be excavated and backfilled with a slurry consisting of bentonite,
water, and soil or cement to form a low-permeability containment
wall. Figure 8 shows a cross section of the cap and slurry wall.
At least one small volume extraction well would be installed in the
upper aquifer to collect groundwater from within the slurry wall.
The exact number of small volume extraction wells, well locations,
and pumping rates would be selected during the remedial design.
The design for the number and locations of internal extraction
wells must provide for adequate inward groundwater gradients at all
points within and at the edges of the entire waste mass. Water
extracted from this welles) would be blended with the water being
extracted for groundwater remediation and would be treated at the
groundwater treatment facility. The extraction welles) would be
operated for as long as contaminated groundwater within the wall is
generated. For costing purposes, the wells are
assumed to operate for 30 years.

Treated effluent from the groundwater treatment system would be
discharged into the Branch River. A National Pollutant Discharge
Elimination System (NPDES) permit would not be required for
discharge; however, the substantive portion of the requirements
would be met before discharge.
other provisions
32
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The Branch River is a habitat for the Greater Redhorse fish,
which was listed as a special concern species. in 1979 and
uplisted to threatened in 1989. The recommended water quality
discharge limitations should provide protection of this
threatened species; however, backgroundwater quality
assumptions must be verified by backgroundwater quality
testing in the Branch River as specified by the WDNR.

The selected remedy will achieve risk reduction through extraction
of contaminated groundwater and treatment to health-based levels
and by construction of a slurry wall and cap to contain the wastes.
These measures will meet the remediation goals outlined in the FS.
A second operable unit will address the source of contamination at
the LTR Site.
K.
Statutorv Determinations
The selected remedy must satisfy the requirements of Section 121
(a-e) of CERCLA, as amended by SARA, to:
a.
b.
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. .
c.
d.
e.
The implementation of Groundwater Alternative 5 and Source Control
Alternative 5 at the LL and LTR Sites satisfies the requirements of
CERCLA, as amended by SARA, as detailed below:
Protection of Human Health and the Environment

Implementation of the selected alternative will reduce and control
potential risks to human heal th and the environment posed by
exposure to site contaminants by cOmbining source control and
containment, groundwater treatment measures and short term site
access restrictions, thus significantly reducing the risks posed by
direct contact, inhalation, or ingestion of site-related
contaminants. Groundwater contaminant loading will be reduced due
to the decreased infiltration of water through the landfill.
~ccess restrictions will prevent direct contact with contaminated
groundwater until the groundwater cleanup standards are met.
COllectively, the cleanup levels will comply with the 10 -4 to 10 -
6 risk range for carcinogens and a risk-based level of HI=1 for
non-carcinogens as required by the NCP.
33
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No unacceptable short-term risks or cross-medial impacts will be
caused by the implementation of the remedy. The community and site
workers may be exposed to dust and noise nuisances during
construction of the cap and slurry wall. Standard safety programs,
such as fencing, use of protective equipment, monitoring and dust
control measures, should mitigate any short-term risks. Mitigative
measures will be taken during remedy construction activities to
minimize impacts of construction upon the surrounding community.
Ambient air monitoring would be conducted and appropriate safety
measures would be taken if contaminants were emitted.
CO~Dliance with ARARs

The selected al ternati ve will meet all Federal and state
ARARs. The following is a description of the environmental
laws which are legally applicable or relevant and appropriate
to different components of the remedy:
clay/Soil Cap

Requlations found in Chapter 504 of the Wisconsin
Administrative Code govern solid waste disposal facilities.
While both solid and hazardous waste regulations are potential
ARARS, it was determined that an NR 504.07 cap, in conjunction
with a slurry wall, provides adequate protection. subtitle C
landfill requirements, while relevant, were determined not to
be appropriate. The Landfill Site did not receive RCRA
wastes, so a subtitle C cap is not applicable, nor would a
Subtitle C cap provide additional benefit from that of a
Subtitle D cap and the cost would be greater; therefore, it is
not appropriate. section 504.07 seeks to minimize
infiltration by specifying clay type, slope and topsoil
requirements for a final cover for the landfill. The
requlations may require a gas venting system, to relieve gas
build-up beneath the cap (NR 445, NR 504.07, NR 506, NR 508,
NR 514.07 Wis. Adm. Code). Wisconsin statute chapter 160 and
NR 140 wis. Adm. Code indicate that for final action one must
prevent the continued release of contaminants to groundwater,
at or above state groundwater quality standards.
Groundwater Extraction and Treatment
The State of Wisconsin is authorized to administer the
implementation of the Federal SDWA. The State has also
promulgated groundwater quality standards in NR 140 Wis. Adm.
Code, which, according to WDNR, is being consistently applied
to all facilities, practices, and activities which are
regulated by WDNR and which may affect groundwater quality in
34
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the state. Chapter 160, Wis. stats., directs WDNR to take
action to prevent the continuing release of contaminants at
levels exceeding standards at the point of standards
application. Preventive action limits (PALs) and enforcement
standards (ESs), have been promulgated in NR 140, Wis. Adm.
Code. PALs are the groundwater cleanup standard under NR 140.
PALs are generally more stringent than corresponding Federal
standards and, therefore, are ARARs for the Lemberger sites.
Consistent with the exemption criteria of NR 140.28, Wis. Adm.
Code, an alternative concentration limit, (WACL) may be
established if it is determined that it is not technically and
economically feasible to achieve the PAL for a specif ic
substance. Except where the background concentration of a
compound exceeds the ES, and consistent with the criteria in
NR 140. 28(4) (B), the WACL that is established may not exceed
the ES for that compound. .

The NCP, 55 Fed. Req. 8753, provides that groundwater cleanup
standards should generally be attained throughout the
contaminant plume or at and beyond the edge of the waste
management area when waste is left in place.
The implementation of the selected remedy at the Lemberger
Sites will be in compliance with NR 140, Wis. Adm. Code, in
that PALs will be met unless WACLs are established pursuant to
the criteria in NR 140.28, Wis. Adm. Code, in which case the
WACLs will be met. These standards will be met in accordance
wi th the NCP at the waste boundary, in the case of the
Landfill site, the edge of the slurry wall, and wherever
groundwater is monitored beyond the point of compliance.
u.s. EPA has no specific documentation that listed hazardous
wastes were disposed of at the LL Site; however, the LL site
may contain characteristic waste. Therefore, the hazardous
waste regulations may be relevant and appropriate to the
design of the selected remedy.

There is specific documentation; however, that listed
hazardous wastes F002 was disposed of at the LTR site.
Therefore, the hazardous waste regulations are applicable to
any wastes or contaminated media originating from that site
which contain constituents of F002. Any contaminated
groundwater that contains constituents above health based
levels from the listed hazardous waste from the LTR Site must
be managed as a hazardous waste. Any sludge or residuals
generated from treatment of groundwater that contains the
listed hazardous waste above detection limits, would itself be
a listed hazardous waste.
Treatment of the contaminated groundwater will result in the
generation of residual sludge containing metals and other
35
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contaminants. The sludge would be stored temporarily in 55-
gallon drums. Approximately seven cubic yards (21 drums) of
waste would be generated every month.
The contaminated groundwater contains organic constitutents
which originated from listed waste at the LTR site. It may be
possible to remove the organics from the groundwater to below
health based levels, prior to generating a metal bearing
sludge from the chemical precipitation treatment. If the
groundwater has been successfully treated, then the organic
contaminants will not make the sludge a listed hazardous waste
and will not trigger Land Disposal Restrictions (LDRs). In
the event that the groundwater cannot be treated to remove all
organics above health based levels, or the sludge does contain
detectable levels of organic contaminants, the sludge will be
managed as a listed hazardous waste. If the sludge is a
listed hazardous waste, it may, if possible, be disposed of as
part of the LTR source control remedy. Alternatively, it may
be treated and disposed of offsite at a RCRA Subsitle C
landfill.
The sludge is not expected to contain metals at concentrations
above characteristic levels. If, after testing by the TCLP,
it is determined that the sludge is characteristic for metals,
it will be treated below characteristic levels. Sludge which
does not contain organics and is not characteristic for metals
may be disposed of as a solid waste.

If the sludge is a listed hazardous waste, it may, if
possible, be disposed of as part of the LTR source control
remedy. Alternatively, it may be treated and disposed of
offsite at a RCRA Subtitle C landfill. If organics are
successfully removed prior to the electrochemical
precipitation, the sludge containing metals would not be a
listed hazardous waste.
If the sludge is neither a characteristic nor a listed waste,
it will be disposed of as a solid waste, and Land Disposal
Restrictions would not be applicable. If the sludge must be
managed as a listed hazardous waste, then the sludge would be
treated to appropriate LDRstandards prior to on- or off-site
disposal. It is expected that the spent carbon from the
treatment system would be recycled in a unit in compliance
with 40 CFR 264 (Subpart X).
Groundwater which is extracted, treated and subsequently
discharged must meet the substanti ve requirements of the
Wisconsin Pollutant Discharge Elimination System (WPDES).
Discharge of treated groundwater to the Branch River should
meet the substantive requirements of section 402 and the Clean
Water Act and shall not exceed discharge limits established by
the state of Wisconsin. .
36
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The selected remedy will achieve state ARARs for discharge to
surface water through discharge to the Branch River.
Wisconsin effluent levels for discharge to the Branch River
will be established in accordance with chs. NR 102, NR 104, NR
106, NR 108 and NR 207, Wis. Adm. Code. Preliminary discharge
effluent limits are outlined in a WDNR memo dated March 13,
1991. These limitations are dependent on receiving water
quality and effluent pH and hardness values. Any deviation
from these assumed values downward for actual effluent
discharge or background concentrations will require a
reassessment of the discharge limitations. To verify the
limits, background surface water quality testihg and an
assessment of the existing habitat for the State threatened
species, the Greater Redhorse fish, is required during the
remedial design phases, in accordance with Attachment A. In
addition, treatability studies must be performed to identify
treatment technologies to prevent whole effluent toxicity as
required under ch. NR 106, Wis. Adm. Code. The requirements
of ch. NR 220, Wis. Adm. Code, must also be satisfied.
Groundwater monitoring wells ~illbe installed in accordance
with NR 141, Wis. Adm. Code. Extraction wells will be
installed and operated in accordance with ch. NR 112, Wis.
Adm. Code. .
Wetlands Policy

u.s. EPA has a wetlands policy which regulates filling of
wetlands (40 CFR 230). Impacts to the wetlands will be
considered and minimized to the maximum extent possible during
the design phase of this remedial action as directed in
Executi ve Order 11990. The State of Wisconsin also has
policies on protection of wetlands (NR 1.95, NR 115, NR 117
Wis. Adm. Code), and protection of lakes and streams (NR 102,
NR 103 Wis. Adm. Code). Wisconsin Endangered and Threatened
Species protection law (29.415 Wis. Stats. and NR 27 Wis. Adm.
Code) prohibit the "taking" or harming of endangered or
threatened wildlife resources. These laws are ARARS for this
remedial action, as poisoning of endangered or threatened
species by site contaminants could be considered a "taking."
The following ARARs are associated with the preferred remedy
chosen in this ROD:
Chemical SDecific
*
Water Quality Criteria (AWQC).
Criteria for Water, 1986.
40 CFR Part 131 Quality
*
Surface Water Quality Standards (NR 102, NR 105, NR 106, NR
147, Wis. Adm. Code)
37
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Action SDecific
*
Land Disposal Restrictions (40 CFR Part 268, 261)

National Pollutant Discharge Elimination (40 CFR Part 125);
includes best available technology
*
*
Standards Applicable to Owners and Operators of Hazardous
Waste Treatment, Storage and Disposal Facilities (40 CFR Part
264.90)
*
Standards Applicable to Generators of Hazardous Waste (NR 600
et ~, Wis. Adm. Code)
*
Resource Conservation and Recovery Act (RCRA)
6924 (u), (v) and 6928 (h) ) .
(42 U.S.C.
*
Groundwater Monitoring and Recovery Well Requirements (NR 112,
NR 141,
NR 508, NR 600 et sea, wis. Adm. Code)

Requirements and Standards for Pollution Discharge Systems (NR
102, 104, 106, 108, 200, 207, 218, 219, 220, Wis. Adm. Code)
*
*
standards for Landfill Cap Design (NR 504, NR 514, NR 516 NR
600 ~ ~, Wis. Adm. Code)

Standards for Emissions Control (NR 400-499, Wis. Adm. Code)
*
*
Requirements for Collection and Control of Landfill Gas (NR
504, NR 506, NR 508, NR 514, NR 516, NR 600 gt sea, Wis. Adm.
Code)
*
National Primary and Secondary Ambient Air Quality Standards
(40 CFR Part 50)

National Emission standards for Hazardous Air Pollutants (40
CFR Part 61)
*
Location SDecific
*
Protection of Wetlands (Exec. Order No. 11990, 40 CFR 6.302(a)
and Appendix A).

Guidelines for Specifications of Disposal Sites for Dredged or
Fill Material (40 CFR 230)
*
*
Protection of Wetlands (NR 1.95, NR 103, NR 115, NR 117, Wis.
Adm. Code)
*
'Protection of Lakes and Streams (NR 102, 103, Wis. Adm. Code)
38
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*
Protection of Endangered and Threatened Species (29.415 Wis.
Stats., NR 27, Wis. Adm. Code)
"To Se Considered" Requirements

- CERCLA Off-site Policy. (May 12,1986), Revised November 13,
1987, O~WER DIR. 9834.11.
- Wisconsin "Interim Policy for Promoting the In-State and On-
Site Management of Hazardous Wastes in the State of ,Wisconsin"
provides a prioritization outline for the treatment and
disposal of hazardous wastes and is "to-be-considered" for the
site.
If residual material is considered a characteristic hazardous
waste (TCLP), additional treatment would be necessary to meet
this State policy since treatment would be in compliance with
the substantive requirements of both Federal and State RCRA
regulations. After treatment, the sludge, formerly
characteristic, would be rendered nonhazardous and disposed in
compliance with ARARs.
L.
Cost-Effectiveness
Cost-effectiveness compares the effectiveness of an alternative in
proportion to its cost of providing its environmental benefits.
Table 6 lists the costs associated with the implementation of the
remedies.
The selected remedy is cost-effective because it provides a high
degree of overall effectiveness proportional to its costs, the net
present worth being $19,200,000. The estimated cost of the
selected remedy is comparable with the other al ternati ves and
assures a high degree of certainty that the remedy will be
effective in the long-term due to the significant reduction of the
toxicity of the contaminants by one order of magnitude for metals
and two orders of magnitude for organics, achieved through
treatment of the groundwater and control and containment of the
source material that constitute the principal threat at the site.
Groundwater Alternative 5 combined with Source Control Alternative
4 is slightly less expensive but does not reduce the risk to public
health and the environment or provide effectiveness over the long
term to the extent of the selected remedy.
-
Utilization of Permanent Solutions and Alternative
Treatment Technoloaies or Resource Recoverv Technoloaies
to the Maximum Extent Practicable.
39
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U.S. EPA believes and the state of Wisconsin concurs that the
selected remedy represents the maximum extent to which permanent
solutions and treatment technologies can be utilized in a cost-
effective manner for the remedial action at the LL and LTR Sites.
A combination of treatment, containment and source control will
significantly reduce the hazards posed by the contaminated landfill
waste, soil and groundwater at the Sites. The groundwater will be
restored and groundwater cleanup will occur at a more rapid rate
compared to other options. Of the al ternati ves that are protective
of human health and the environment and comply with~, U.S. EPA
has determined that the selected remedy provides the best balance
of tradeoffs iri 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.
Preference for Treatment as a PrinciDal Element
The selected remedy for the final action for the LL Site and the
first operable unit for the LTR site satisfies the statutory
preference for treatment as a principal element through treatment
of the contaminants in the groundwater in an on-site groundwater
treatment plant. Treatment of the contanimants using GAC and
recycling the spent carbon will result in a significant reduction
of contaminant toxicity. Residuals will be handled as described
under groundwater extraction and treatment in this section.
40
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REMEDIAL AC'1'ION
ADMINIS'1'RA'1'IVE RECORD
(Index and Documents)
FOR '1'HE
LEMBERGER LANDFILL INC. AND
LEMBERGER '1'RANSPOR'1' , RECYCLING INC. SI'1'E
MANI'1'OWOC COUNTY, WISCONSIN
MAY 1991
United
States Environmental Protection
Region V
230 South Dearborn Street
Chicago, Illinois 60604
Agency
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Page No.
05/13/91
"*
ADMINISTRATIVE RECORD INDEX
LEMBERGER LANDFILL INC. AND
LEMBERGER TRANSPORT & RECYCLING INC. SITE
MANITOWOC COUNTY, WISCONSIN
FIC~E/FRAME PAGES DATE
TITLE
AUTHOR
RECIPIENT
DOCUMENT TYPE
DOCNUMBER
16
91/03/04
Letter re: Hazardous
Air Contaminant Control

Guidance
G. Edelstein-~NR
M. Gustafson-USEPA
Correspondence
65
Alternatives Array
Doc_t
S&Y Waste Science and
Technology Corp.
Reports/Studies
2
90/08/14
400
Final Remedial
Investigation Report
Volume I - Report
B&Y waste Science and
Technology Corp. and
USEPA . .
Lemberger Landfill
Inc.
ReportS/Studies
3
91/01/18
484 91/01/18 Final Remedial S&V Wlste Science and Lemberger Landfill Reports/Studies 4
Investigation Report Technology Corp. and Inc-
Volume II - Appendices USEPA
15 91/03/01 Lemberger Landfill Site C. Whitlock-S&Y Waste M. Gustafson-USEPA Reports/Studies 5
Volume Calculations of Science and Technology
Waste Nith cover letter Corp.
attached
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Page No.
05/13/91
TITLE
Soil Survey of Calumet

and Manitowoc Counties,

Wisconsin
User's Guide to the

Contract Laboratory

Progr8111
CERCLA Compliance
with Other Laws Manual:
Part I
Guidance for Conc:tucting
Remedial Investigations
and Feasibility Studies
under CERCLA, Interim
Final
Quality Assurance
Project Plan, Phase I
Remedial Investigation,
Lemberger Landfill, Inc.
and Leneerger Transport
and Recycling, Inc.
Manitowoc County,WI
Guidance on Remedial
Actions for Cont.inated
Ground Water at Superfund
Site.
EPA/540/G-88/003
CERCLA Compliance with
Other Laws Manual:
Part II Clean Air Act
and Other Environmental
Statues and State
ReQUirements
EPA/540/G-89/009
GUIDANCE DOCUMENTS INDEX
LEMBERGER LANDFILL AND LEMBERGER TRANSPORT & RECYCLING SITE
Guidance Documents are available for review at
USEPA Region V-Chicago IL
AUTHOR
DATE
USDA,Soil Conservation Service 80/02/00
USEPA
86/12/00
USEPA,OSWER Directive
9234.1-01
88/08/08
USEPA,OSWER Directive
9355.3-01
88/10/00
USEPA and S&V
88/11/30
USEPA,OSWER Directive 9283.1-2 88/12/00
USEPA,OSWER Directive
9234_1-02
89/08/00
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Page No.
05/13/91
z
~
TITLE
Risk Assessment Guidance
for Superfund Volume I:
Human Health Evaluation
Manual
Final Remedial
Investigation Report
Lemberger Landfill Inc.
and Lemberger Transport
and .ecycling Inc.
GUIDANCE DDCUMENTS INDEX
LEMBERGER LANDFILL AND LEMBERGER TRANSPORT & RECYCLING SITE
Guidance Documents are available for review at
USEPA Region V-Chicago IL
AUTHOR
DATE
USEPA
891 1 ZlOO
USEPA,B&V ~aste Science & Tech 91/01/18
Corp
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Page No.
05/13/91
ACRONYM GUIDE for the Administrative Record
LEMBERGER LANDFILL INC. AND
LEMBERGER TRANSPORT & RECYCLING INC. SITE
MANITOWOC COUNTY, WISCONSIN
ACRONYM
DEFINITION
AR
Administrative Record
ARAR
Applicable or Relevant
and Appropriate Requirements
CERCLA
Comprehensive Environmental

Response, 'Compensation, and
Liability Act
NPL
National Priority List
OSWER
Office of Solid Waste
and Emergency Response
RI
Remedial Investigation
RI/FS
Remedial Investigationl
Feasibility Study
RPM
Remedial Project Manager
U.S.EPA
United States Environmental
Protection Agency
WDNR
Wisconsin Department of
Natural Resources
-
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Page No.
07118/91
ADMINISTRATIVE RECORD INDEX
LEMBERGER LANDFILL SITE UPDATE NO.1
0 MANATOWAC COUNTY, WISCONSIN
FICHE/FRAME PAGES DATE TITLE AUTHOR RECIPIENT DOCUMENT TYPE DOCNUMBER
14 91/05/00 Proposed Plan for U.S. EPA U.S. EPA Plbl ic Conment
Remedial Action
272 81/10/00 Lember Landfill Site Residuals Management Reports/Studies 2
Inc. Horizontal Expansion Technology, Inc.
Feasibility Report
40 82/07/28 Environnenul Fothe & Van Dylee Reports/Studies 3
Investigation Report Engineers/Architects
for: Lemberger Landfills,
Inc. Fly Ash Site #0753
39 85/06/07 Preliminary Remedial Solexploration Hegaman,T. Reports/Studies 4
Investigation C~ny
Frankl in Township
36 85/06/07 Appendix A Private Soil Exploration U.S. EPA Reports/Studies 5
Water Well Logs C~ny
13 89/09/06 Preliminary Health Dept. of Health U.S. EPA Reports/Studies 6
Assessment State and Social Services
Of Wisconsin Madison, WI
Lemberger Transport
and Recycle Landfill
1" 89/09/06 Preliminary Health Dept. of Heal th U.S. EPA Reports/Studies 7
Assessment Lemberger and Social Service.
Fly Ash Landfill
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Page No. *
0;1/24/91
ADMINISTRATIVE RECORD INDEX - UPDATE NO.2
LEMBERGER LANDFILL INC. AND LEMBERGER TRANSPORT &
RECYCLING INC. SITE
MANIT~C COUNTY, UISCONSIN
rICHE/FRAME PAGES DATE TITLE AUTHOR RECIPIENT DOCUMENT TYPE DOCNUMBER
89/08/25 Letter re: Monitoring L. Sridheren-WONR J. Dowden-UMNA,lnc. Correspondence
to be conducted by
U.~.EPA in the
vicinity of the
Ridgeview Lendfill
15 90/10/16 Letter re: Abendonment J. Huffman-WONR M. GUSt8f8on-U.S.E~A Correspondence 2
Forms end Replacements
Well Logs for
Residential Wells,
Lemberger Landfills
Superfund Complex
2 90/10/29 Memo re: Review of 1(. Bro-WONR M. Gustafson-U.S.EPA Correspondence 3
date on residential
well water samples
neer the Lemberger
Transport and
Recycling, Inc. site
15 90/11/13 Letter re: Alternatives D. Rossberg-WONR M. Gustafson-U.S.EPA Correspondence 4
Array Docunent
3 91/06/06 Letter re: Met at the J. Huffman-WONR S. Brooks Correspondence 5
meeting on Mev 22
regarding the proposed
clea"""" later
discussed the status
of the Denor stock
well. Attached il
a letter which
indicates that the
water from the well
is lafe
5 91/07/03 Letter re: Sempling J. Huff..,,-WNR Mr- & Mre. Denor Correspondence 6
r..ulte of private
water e'4'Pl V well
collected on Mey 15.
1991 by WONR personnel
6 89/03/29 Superfund Study Begfns U.S.EPA-Regfon V Fect Sheets 7
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Page No. 2
09/24/91
ADMINISTRATIVE RECORD INDEX. UPDATE NO.2
LEMBERGER LANDFILL INC. AND LEMBERGER TRANSPORT &
RECYCLING INC. SITE
MANIT~C COUNTY, ~ISCONSIN
" FICHE/FRAME PAGES DATE TITLE AUTHOR RECIPIENT DOCUMENT TYPE DOCNUMBER
at the Lerri)erger.
Landfill Transport &
Recycling Sites
Public Meeting
Scheduled for:
March 29, 1989
3 90/04/00 Fect Sheet re: U.S.EPA-Reglon V -' Fect Sheets
8
Remedlel Investlgetlon
Update
2 91/01/00 Fact Sheet re: U.S.EPA-Region V Fact Sheets 9
Remedial Investigation
Update
2 90/10/19 Memo re: ARAR Review T. Mulhollend-~NR J. Hufflll8n-~NR MemorencUn 10
of Lemberger Landfill
Superfund She
91/03/10 Memo re: COIIIMnts on R. Hay-~NR ~ater Resources Memorandun 11
the proposed weste
water facility for
the superfund site
on the Branch River
regarding the presence
of the Greater Redhorse
16 91/03/13 Memo re: Projected D. Schuettpelz-~NR D. Rossberg-~NR MemorencUn 12
~ater Quality-Based
Effluent Limits for
the Lemberger Landfill
3 91/03/14 Memo re: Effluent limits D. Hantz-WIfR J. Huffman-WNR Memorandun 13
and Requirements for
Discharge of treeted
Groundwater from the
lemberger Superfund
Sites
22
91/03/14
Memo re: Transmittal
Memo for the -Interim
P. Didier-IIIMR
IIINR Supervisors,
leaders
Memorandun
l'
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Page No.
09/24/91
3
FICHE/FRAME PAGES DATE
TITLE
Policy for Promoting
the On-Site Management
of. Hazardous ~astes in
the State of ~Isconsln"
17
00/00/00
Order of the State of
~isconsln Natural
Resources Board
Renulb!ring, Amending
and Creating Rules
91/05/22 Conments on the
Cleanup Plan
91/05/28 Conments on the
Cleanup Plan
91/05/28 Conments on the
Cleanup Plan
91/05/28 Conments on the
Cleanup Plan
91/05/28 Conments on the
Cleanup Plan
91/05/30 Conments on the
Cleanup Plen
91/06/04
Conant. on the
Cle8fq» PIM
ADMINISTRATIVE RECORD INDEX - UPDATE NO.2
LEMBERGER LANDFILL INC. AND LEMBERGER TRANSPORT &
RECYCLING INC. SITE
MANITOVQC COUNTY, WISCONSIN
AUTHOR
RECIPIENT
DOCUI!ENT TYPE
o
DOC NUMBER
WNR
Pleadings/Orders
15
-'
M. Shavllk-Area Resident S. Pastor-U.S.EPA
Publ i c Conments
16
J. Kalies-Atea Resident
S. Pastor-U.S.EPA
Publ I c Conments
17
L. Denor-Area Resident
S. Pastor-U.S.EPA
Pub I I c Conments
18
D. Preston-Area Resident S. Pastor-U.S.EPA
Plblf c Conments
19
M. Preston-Area Resident S. Pastor-U.S.EPA
PIbUc Conments
20
J. Remiker-Aree
Resident
S- Pestor-U.S.EPA
Plblf c Conments
21
E. KreJclrek-Arel
Resident
S. Plltor-U.S.EPA
Pwl ic Conments
22
91/06/05 Conmentl on the W. & V. Van Ellis- S. Pestor-U.S.EPA Plbl ic Conments 23
Cleanup Plan Aree Residents
1 91/06/18 Ccnnents on the W- Menze-Am Resident S- Pestor-U_S_EPA Plbl i c Conments 24
Cleanup PI en
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Page No.
0,/24/91
"
ADMINISTRATIVE RECORD INDEX - UPDATE NO.2
LEMBERGER LANDFILL INC. AND LEMBERGER TRANSPORT &
RECYCLING INC. SITE
MANIT~C COUNTY, WISCONSIN
"
FICHE/FRAME PAGES DATE
TITLE
AUTHOR
RECIPIENT
DOCUMENT TYPE
DOCNUMBER
55 91/07/00 Manltowoc Public Dames & Moore S. Pastor-U.S.EPA Public Comments 25
Utilities Comments on
RI and FS
Lenilerger Landf HI
Sites
2 91/07/11 Letter re: Request an A. Vogel, Jr. - $. Pestor-U.S.EPA Public coinnents 26
extension to the Quarles & Brady
public comment period
2 91/07/19 letter re: Request E. Doyle-U.$.EPA A. Vogel-Queries & Publl c Comments 27
for additional Bredy
Information to be
placed In the
administrative
record
50 91/07/19 Comments on the Proposed RMT, Inc. S. Pastor-U.S.EPA Publl c Comments 28
Plen for Remedlel Action
91/07/29
Letter re: Comments
on the Lemberger
Landf III Site
L. Chenney-Lester
Cherney Insurance
Agency
S. Pastor-U.S.EPA
Public Comments
29
'2
91/07/29
Letter re: Request for
8n additional 20 days
for public review on
the additional
Information which
would be placed Into
the administrative
record ffte
S. JOhannsen-RMT,lnc.
S. Pastor-U.S.EPA
Public Comments
30
91/07131
Letter re: Request
for 8n additional
extension to the
public coament period
M. Gustafson-U.S.EPA
S. Johannsen-RMY,
Inc.
Public Comments
31
G
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Page No. 5
09/24/91
ADMINISTRATIVE RECORD INDEX - UPDATE NO.2
LEMBERGER LANDFILL INC. AND LEMBERGER TRANSPORT &
RECYCLING INC. SITE
MANIT~C COUNTY, ~ISCONSIN
rICHE/FRAME PAGES DATE TITLE AUTHOR RECIPIENT DOCUMENT TYPE DOCNUMBER
.,
on the Proposed Plan
91/07/31 Letter re: The A. Llbal-Manitowoc S. Pastor-U.S.EPA Publ i c Comnents 32
engineering firm of Public Utilities
Dames & Moore have
subml tted conments on
the proposed RI & FS
reports for the
Lemberger Landfill Site
2 91/08/01 Letter re: Conments S. Brooks-Town of S. Pastor-U.S.EPA Publ Ie Conments 33
to be. added to the Franklin, Town Chairmen
Publ Ie Conment File
for the Phased
Feasibility Study
Report
334 88/01/13 Agency Review Draft CH2M Hill M. Gustafson-U.S.EPA Reports/Studies 34
QAPP Phese 1 Remedial
Investigation
256 88/05/16 Flnel RI/FS ~ork Plan CH2M Hill M. Gustafson-U.S.EPA Reports/Studies 35
118 91/05/22 Transcript from Public C. Kalmerton, Court Transcript 36
Meeting held Ued., May Reporter, Notary
22, 1991 on the Proposed Pubilc-Mallmann &
Plan for Remedial Action Bastyr Court Reporters
d
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