United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPAIRODIROS-91/187
September 1991
. Cory ("
p3?,2. - t(64 12..'-f
oEPA
Superfund
Record of Decision:
Lemberger Transport &
Recycling, WI
u . ~ . Environmenta' Protection Agencv>
Reglo~ III Hazardous Waste I
Technrca' Information Center
841 Chestnut Street 9th Floor
Philadelphia. PA 19107
Hazardous W<:JSte.~..' .'
information. Resouce>C:' . .
US EPARegiOn 3 .
PhHodelphia. PA 19107
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110272 101
.
REPORT DOCUMENTATION \" REPORT NO. . \ ~ 3. RecIpient. Accesalon No.
PAGE EPA/ROD/R05-91/187 -
4. 11IIe and 8ubtI1Ie 5. Report Date
SUPERFUND RECORD OF DECISION 09/23/91
Lemberger Transport & Recycling, WI
8.
First Remedial Action
7. Aulhor(.) 8. Perfonnlng Organization Repl No.
II. P8rf0nning OrgalnlDtlon Name and Add- 10. ProjedlT88k/Work Unit No.
11. Contract(C) or Gr8nt(G) No.
(C)
(G)
1~ IIpon8orIng Org8nlz8tlon Name and AcI$na 13. Type of Report & Period Covered
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. Supplem8nl8ly No..
18. Abatract (Umlt: 200 _rda)
The 45-acre Lemberger Transport and Recycling (LTR» site is a former land disposal
facility in Manitowoc County, Wisconsin. The site is located within one-quarter mile
of the 45-acre Lemberger Landfill (LL) site. Land use in the area is predominantly
agricultural, with four residences within 1,000 feet of the site. 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 1970 to 1976, the LTR site received industrial waste
and a variety of liquids, sludge, and slurries, which were deposited in unlined
trenches. 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. All industrial waste was diverted to
the nearby LTR site. Reports of contaminated material seeping onto local properties
prompted State investigations that revealed VOCs in residential wells in excess of
State standards. Affected residences received deeper replacement wells that have not
shown contamination. Because of the similarity of contamination and proximity of the
sites, the LTR and LL sites will be addressed concurrently. This Record of Decision
(ROD) provides a final remedy for ground water contamination at both the LTR and LL
(See Attached Page)
17. ~t Analyala .. De8crlpIo18
Record of Decision - Lemberger Transport & Recycling, WI
First Remedial Action
Contaminated Medium: gw
Key Contaminants: VOCs (PCE, TCE, toluene, xylenes), other organics (PCBs,
pesticides), metals (arsenic, chromium, lead)
b. IdentlflerslOpen..Ended Tenna
Co COSA TI FIeIdIGr......
18. Av8l'abllty SI-..nt 111. SecurIty CI... (Thla Report) 21. No. of Pagea
None 76
20. SecurIty CI..a (Thla Page) n PrIce
NnnQ
See ANSl-Z3II.18) See /Mtrucfi- on Re- Of' 7)
(Formerly NTlS-35)
Department of Commerce
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EPA/ROD/R05-91/187
Lemberger Transport & Recycling, WI
First Remedial Action
~stract (Continued)
sites, as the first Operable Unit (OU1). A future ROD will address the landfill
contents at the LTR site, as OU2. The primary contaminants of concern affecting the
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 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 to be
constructed at the LL site with ground water extracted for remediation, and treating it
onsite at the treatment facility; temporarily storing residual sludge onsite, then
treating and disposing of the 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 into 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
general accessibility to the facility and the potential for public exposure. The
estimated present worth cost for this remedial action is $19,200,000, which includes
the source control remedy for the LL site and an annual O&M cost of $731,000 for years
0-1 and $596,000 for years 2-30.
2ERFORMANCE 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 PCE 0.1 ug/l (State), TCE 0.18 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 TRANSPORT & RECYCLING, INC.
~ITOWOC COUNTY; WISCONSIN
SITE
Statement of Basis and Purpose
This decision document presents the selected remedial action for
the Lemberger Transport & Recycling 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.
DescriDtion of the Selected Remedv
The selected remedial action is the first operable unit at the
site. Operable units are discrete actions that comprise
incremental steps toward the final remedy. A second and final
operable unit will address the landfill contents. The selected
remedy addresses the greatest risks posed by conditions at the
Site, exposure by ingestion or direct. contact with contaminants in
the ground water. The remedy will achieve substantial risk
reduction through extraction and treatment of the contaminated
ground water at the site. '
The major components of the selected remedy for this first operable
unit include:
Installation of ground-water extraction wells;
Extraction of contaminated ground water to actively
restore the aquifer to Federal and ~tate of Wisconsin
ground-water quality standards;
Construction of a ground-water treatment system;
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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" complies with Federal and State requirements that are
legally applicable or relevant and appropriate to the remedial
action, and is cost, effective. This remedy utilizes permanent
solutions and alter~ative 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. with the selected remedy.
Letter of Concurrence is attached to this ROD.
The
ff;4
,AS a te
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State of Wisconsin \ DEPARTMENT OR NATURAL RESOURCES
Carroll D. Bc:saday
Scm:\.ary
101 Soulb Webster Slrccl
nox 7921
Madisoa, W' 1SCCas:in 53707
50110 WASTE 11?l.FPAX 608-267-2768
.. TElEPAX 608-267-3579
roD 608-267~
September 5, 1991
IN REPLY REFER TO:
FID #3601679
Manitowoc Co.
ER/SFND
Mr. Valdas V. Adamkus,
U.S. EPA Region V
230 S. Dearborn St.
Ch i cago, 111 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
fo 11 owi ng:
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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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
Lemberge~ 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:
source of
of co~tamination 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 cont~ibute 10%
of all other O&M costs for the fi~st year and provide for all O&M after that.
We provide this assurance on the assumption tr~t 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 reluired to be managed off-site as part of
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Mr. Valdas V. Adamkus, Administrator - September 5, 1991
3
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 wlth 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 ~ur staff will continue to work in close consultation
with your staff during the pre-design, design and construction pnases of the
remedy.
Thank you for your support and cooperation in addressing the contamination
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/S
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/ll
SW/3
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RECORD OF DECISION
Lemberger Landfill, Inc.
Lemberger Transport & Recycling, Inc.
Manitowoc County, Wisconsin.
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TABLE OF CONTENTS
A.
Site Location and Description. . . . . . . . . . .
. . 1
B.
Site History and Enforcement Activities.
community Relations.
. . 3
. . . .
. . . 2
C.
. . . .
. . . . .
D.
Scope of the Selected Remedy.
........
. . 4
E.
Summary of Current Site Conditions.
. . . . 5
F.
Summary of site Risks
.......
. . . 8
. . . . . .
G.
Environmental Standards not met at the Site.
. .13
H.
I.
Description of Remedial Alternativess . . . . . . . . .14
Summary of Comparative Analysis of Alternatives. . . .23
J.
The Selected Remedy. . . . .
Statutory Determinations
. .29
. . . . . .
. . . . .
K.
. . . .
. . .33
........
Responsiveness Summary
. . . .
. . .40
.......
. . . .
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FIGURES AND TABLES
Ficrures
L
Location
Map. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 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 Desiqn for Source Control Alternative 5.........22
12. Recommended Cleanup ActivitY.......................".......29
Tables
L
Chemicals
of Potential Concern..............................9
2.
Toxicity Data for Chemicals of Concern.....................11
Classification System for CarcinoqenicitY..................11
3.
4.
Risk Characterization Summary for Land Use Scenarios.......11
5.
Source of Federal and State Ground Cleanup Standards.......13
Cost Estimates for each Alternative........................28
6.
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
Lemberqer Landfill, Inc.
Lemberqer Tran8port , R.eyelinq, Inc.
The Lemberqer Landfill, Inc. (LL) Site and the Lemberqer Transport
& Recyclinq, Inc (LTR) Site are listed separately on the National
Priorities List (NPL), but were studied toqether resultinq in one
Remedial Investiqation (RI) and one Feasibility Study (FS) that
addresses both sites. The proximity of the sites to each other,
operation of both sites by Lemberqer Landfills, Inc., and the
initiation of the RI for each site at the same time, made it
feasible and cost effective to study the sites simultaneously.
Althouqh 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 divided into two operable units. This ROD
addresses the first operable unit, which includes a treatment
system for contaminated qround 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. Fiqure 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 Michiqan, is located less than one
mile west of both sites. The river is used for fishinq and
canoeinq and as a potable water supply. The entire Branch River
system is manaqed as a smallmouth bass stream. The LL site
occupies approximately 4S acres. Twenty one of those acres were
used for waste disposal. The LTR site also occupies approximately
4S acres, with 16 acres used for industrial landfillinq. Both
sites were unlined and portions' of both sites cover areas that
contained qravel quarries. Land in the vicinity of the sites is
rural and aqricultural, with dairy farms in the area. Most
residences are located alonq Reifs Mills Road. Four residences are
located within 1,000 feet of the sites. The qround water is used
by residents as a drinkinq water supply and for aqricultural
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 Landfill, 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
diverted 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.
2
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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
additional 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,
3
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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 meetin,g 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 si tes, 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 the LL 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
4
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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, a 5-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 qroundwater, air, surface
water, sediment, leachate, subsurface soil, and surface soil in
order to determine site conditions. Wate~ 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 geoloqy, landfill characteristics, and groundwater flow
patterns were also examined.
Based on the resul ts 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 units present at the study area, the upper
granular unit (UGU), the cohesive unit (CD), the lower granular
unit (LGU) and the bedrock. The UGU is composed of sandy, qravelly
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.
Hydrogeoloqy
There are two groundwater systems at the sites.
granular unit is a localized perched aquifer.
Within the upper
The clay layer
5
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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-~outhwest 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.
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.
b.
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 2S feet thick northwest of the Lemberger sites
between monitoring wells RM-4 and RM-2.
d.
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.
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
divide, with flow moving away from the divide in all
directions but primarily to the northwest or the
southeast.
6
-------
wwm
..... -- fI'OTlNT\AI. UMrT o,r ~'JII GROUND WATt.. 1't8TIM(S)
....10 ON USDA 800~ ~"-.
,,:. we... ~TON AHO D_'-
aT ca_WA,,"aulU'..clIUYA'-.DlCIM.... ...
~. -
. -. . "--,
IDUIICa; ... ~...
--.
--.....
,..---
ICALI
-
POTENTIAL UMITS OF UPPERGROUND WATER
SYSTEM AND WATER SURFACE ELEVATIONS.
DECEMBER ,.8.
.-
..
~
--l ...J
«2
OC!:)
a:c:
8°
Q..
Figure 2
-------
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 wast~ 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 SQils 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 MCLls
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
-------
-
-
~~.'.....
.""
+
..., .'
--I: ....~....
...,.............
---
,......". --
H
i
CONTAMINANT PLUME IN
uppeR GROUND WATER SYSTEM
ICAL8
.r
-
-
~
- .....
....1«
-
O~
a: a:
00
o
a..
Figure 3
-------
~
- - - EXTENT OF
CONTAMINANT P~UME
----
-..._"
---
<-
~---
~.~w.
WIICONIIH CII..-IGLa
7"~-
.
t
CONTAMINANT PLUME IN
LOWER GROUNO WATER SYSTEM
~
218'
,--
J,.
;'
(
+
~..J
-1«
-
O~
c: a:
00
o
a..
Figure 4
-------
Surface and subsurface soil samples at the LL Site indicate
the presence of volatile compounds ranqinq from 1 to 12 uq/kq
and semivolatileorqanic compounds ranqinq from 71 to 3,800
uq/kq. Pesticides includinq 4,4-DDE, 4,4-DDD and 4,4-DDT were
found at concentrations of 70 uq/kq, 190 uq/kq, and 42 uq/kq
respectively.
At the LTR site, surface soils contain volatile orqanic
compounds at concentrations ranqinq from 230 to 2,000 uq/kq,
semivolatile compounds ranqinq from 94 to 2,000 uq/kq and
pesticides includinq Aldrin at concentrations of 240 uq/kq and
Deildrin at concentrations of 200 uq/kq. Subsurface soils at
the LTR site had lower concentrations of volatile compounds
than the surface soils, ranqinq from 3 to 620 uq/kq.
Semivolatiles, 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 hear
the LL and LTR Sites, includinq the wetland area. Sediment
samples showed low concentrations of volatile compounds;
however, one sample south of the LL Site contained acetone
detected at 510 uq/kq. 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.
Orqanics were not detected in this sample.
F.
SummarY of Site Risks
The analytical data collected durinq 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 fencinq, qroundwater 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 qroundwater and soils on the LL
Site included the followinq assumptions: .
No direct air emissions were occurrinq, and the soil will not
be disturbed by plowinq or excavation which cause siqnificant
air emissions in the future;
8
-------
current land use includes approximately 2,700 residents wi thin
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
-------
Me';hylene Chloride
Acc.tone
1,1-DiS;hl()wcthene
1,1 -Dichlorocthane
1,2- Dichlol oClbcne
2-ButKnullc
1,1.1- Trichloroethane
TrJI;hloroethene
4-MethyJ-~pc:ntanolle
TetraCh]oroethene '
Toluene
Xylene
Bis ~2-cthyJhcxyI)phthaJatc
Heptachlor
Aldrin
Dfe:ldrin
4,4--DDT
Arc)chlor-1248
Arc)chIor-1254
Blirium
Ca.;1mium
Chromjum
Lertd
Zinc
Ar:ienic
BeryJJi~m
Mzmgancsc
Mc:rcury
Selenium
SU-/er
"rp.
//
TABLE 1
Chemicals of Potential Concern
JI
ff
-------
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
-------
b.
Carcinoqenic Health Risks
Cancer potency factors (CPFs) have been developed by EPA's
Carcinoqenic Assessment Group for estimatinq excess lifetime
cancer risks associated with exposure to potentially
carcinoqenic chemicals. CPFs, which are expressed in units of
(mq/kq-~ay) -1, are multiplied by the estimated intake of a
potential carcinoqen, in mq/kq-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 hiqhly unlikely. Cancer potency
factors are derived from the results of human epidemioloqical
studies or chronic animal bioassays. The excess lifetime
cancer risks are the sum of all excess cancer lifetime risks
for all contaminants of a qiven scenario.
Excess Lifetime Cancer Risks are determined by multiplyinq the
intake level'with the cancer potency factor for each contaminant of
concern. These risks are probabilities that are qenerally
expressed in scientific notation (e.q. 1 X 10~). An' excess
lifetime cancer risk of 1 x 10~ indicates that a person's chance
of contractinq 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 qenerally attempts to reduce the excess lifetime cancer
risk at Superfund sites to a ranqe ot 1 x 10~ to 1 x 10~ (1 in
10,000 to 1 in one million), with an emphasis on the lower end (1
x 10~) of the scale. Table 2 describes the acceptable intakes and
carcinoqen potency factors for chemicals of concern at the
Lemberqer Sites. Table 3 lists the weiqht of evidence cateqories
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 lO's.
Arsenic was associated with risks of 1 x 10.5 and
benzo(a)pyrene accounted for 2 x 10~. 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
-------
Table 2
TOXICITY DATA FOR CHEMICALS OF CONCERN
ACCEPTASLEINTAKE CARCINOGEN POTENCY FACTORS
INHALATION INGESTON INHALATION INGESTON WEIGHT
CHEMICAL (mgJlcg/dayj (mgJlcg/dayj AEFERENCE (mgJIcg/dayj'-1 (mgJlcg/dayj:-1 OF REFERENCE
AID RID SOURCE SLOPE FACTOR SLOPE FACTOR EVIDENCE SOUACE
METHYLENE CHLORIDE 0.08 IRIS 0.014 0.0075 B2 IRIS
ACETONE 0.1 IAIS
1.1-oICHLOROETHENE 0.008 IAIS 1.2 0.8
1.1-oICHLOAOETHANE 0.1 0.1 HEAST o.cKIt B2
1.2-DICHLOROETHENE 0.02 HEAST
2-8UTANONE 0.08 0.05 HEASTIIAIS
1.1.1- TRICHLOROETHANE 0.3 0.08 HEASTIIRIS
TAICHLOAOETHENE 0.00735 HEALTH ADV. 0.013 0.011 B2 IAIS
'-METHYL-2-PENT ANONE 0.02 0.05 HEASTIIRlS
TETAACHLOROETHENE 0.01 IAIS 0.0033 0.051 B2 HEAST
TOLUENE 0.3 IAIS 0
XYLENE 0.2 2 HEASTIIRlI O
BIS (2-ETHYLHEXYL) PHTHALATE 0.02 IRII 0.014 B2 IRIS
BARIUM 0.0001 0.08 HEASTIIRlS
CADMIUM 0.0001 HEAST 8.1 B1
CHROMIUM 0.005 IRIS 41 IRIS
LEAD .0008 (11) B2
ZINC 0.2 HEAST
HEPTACHLOA 0.0001 IRIS 4.8 4.5 B2 IRIS
ALDRIN 0.00003 IAIS 17 17 B2 IRIS
DIELDRIN . O.ooooa IRIS 18 18 B2 IRIS
4.4-00T 0.0001 IRIS 0.34 0.34 B2 IRIS
AROCLOR-1248 7.7 B2 IAIS
AROCLOR-1254 7.7 B2 IAIS
ARSENIC 0.001 HEAST 10 1.75 A HEASTn
BERYLLIUM 0.001 HEAST U B2 HEAST
MANGANEse 0.0003 0.2 HEAST
MERCURY 0.0003 HEAST
SELENIUM 0.003 HEAST
SIL VEA 0.001 HEAST
NOTES:
IRII -INTEGRATED AElEARCH INFORMATION SYSTEM (WO)
HEAST - HEALTH EFFECTS ASSESSMENT SUMMARY TABLES (4th QUARTER. FY 1888)
NAPH - NAPHTHALENE AID VALUE. THIS IS NOT A USEPA VERIFIED AID.
(a) EST. RID CALC. FROM THE PROPOSED DAINKING WATER STANO. OF 1.3 mOIL BY BVWST.
(11) AID CALC. BY BVWST FOA THIS ASSESSMENT BASED ON PREVIOUS PROPOSED MCLG
OF 0.02 mono THIS 18 NOT A U8EPA VEAlFlB:) AID.
RID - REFERENCE DOSE
-------
Table 3
USEPA WEIGHT-Of-EVIDENCE
CLASSIFICATION SYSTEM fOR
CARCINOGENICITY
GROUP DESCRIPTION
A Human carcinogen
B1 or B2 Probable human carcinogen
B1 indicates that limited
human data are available.
B2 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 6-1 1 1 1-18 18-70 UFETlME
CURRENT <0.1 <0.1 <0.1 <0.1 <0.1 ttt':itm::'tEi;;S::ittFt:t)
FUTURE-LL SITE 0.8 ::N>:1.~1.:''::'?'i 0.2 0.1 <0.1 :;:q:::/\U'::'tta;fS}Wtktmt
NOTE: Expoeur.. includ. Ing.lllon 01 and d.rmat contact with IUrfac. .011..
Shaded ar... r.pr...nt "lit. >1 Chronic Hazard Ind.. or >10-41 Canc.r Ai..
-------
2.
Future Groundwater Risks
For excess cancer risks, contaminant concentrations in samples
from 29 of the 33 monitorinq wells were associated with risks
qreater than 1 x 10~. Eiqht of the monitorinq wells showed
an excess cancer risk of equal to or qreater than 1 x 10~
risks. The qreatest risk of 2 X 10-2 was found at two
locations beneath the LTR site and risks as hiqh 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 durinq the RI.
All residents on the LL site would be exposed to contaminants
throuqh inqestion and. dermal contact with surface soils.
These soils exposures would result in an excess cancer risk of
1 X 10~ and, for children aqe 1 throuqh 6, a chronic health
hazard index of 1.1.
Future residents on the LL site who installed a well into the
upper qroundwater system would also be exposed to contaminants
throuqh inqestion, dermal shower contact, and inhalation of
chemicals when showerinq. Based on concentrations .of
compounds identified in monitorinq wells on the LL site, this
could result in an excess cancer risk of 9 X 10~ and, for
children aqe 1 throuqh 6, a chronic health hazard index of
28.8. Utilization of the lower qroundwater system would
result in an excess cancer risk of 3 X 10~ and, for children
aqe 1 throuqh 6, a chronic health hazard index of 1.5.
All residents on the LTR site would be exposed to contaminants
throuqh inqestion and dermal contact with surface soils.
These soils exposures would result in an excess cancer risk of
2 X 10~ and, for children aqe 1 throuqh 6, a chronic health
hazard index of 3.3.
Future residents on the LTR site who installed a well into the
upper qroundwater system would also be exposed to contaminants
throuqh inqestion, dermal shower contact, and inhalation of
chemicals when showerinq. Based on concentrations of
compounds identified in monitorinq wells on the LTR site, this
could result in an excess cancer risk of 3 X 10~. Utilization
of the lower qroundwater system would result in an excess
cancer risk of 2 X 10~ and, for children aqe 1 throuqh 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 those using
the groundwater at the sites as a potable water source and
farmers, hunters and trespassers entering the sites. If the
si tes are further developed, construction workers or site
residents may also be exposed through direct contact with
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 posing unacceptable risks to humans, the Lemberger
Sites do not meet certain applicable or relevant and appropriate
Federal or State environmental standards at this time.
1.
Groundwater
Table 5 lists the representative 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 qroundwater cleanup standards.
2.
Groundwater Protection Goals and the National Contingency
Plan
u.s. EPAls 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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Contaminantl o( Conc:em
Methylene Chloride
Ac:etone
I,I-Dichloroetbene
1,l-Dichloroethane
1,2-Dichloroetbene
2.Butanone
1,1.1- Trichloroethane
Trichloroetbeae
4.Mcthyl.2-pentanone
Tctrachloroetbeae
Toluene
Xylene
Bia(2«hylbayl)phtb8lato
Heptachlor
AldriD
Dieldrin
4,4-DDT
Arochlor-1248
ArochJor-l2.S4
Barium
Cadmium
Chromium
Load
Zinc
AneaUc
Beryllium
Manguae
Mercury
Selenium
Silver .
ChiorofOl'E
Carbon T eti"8Chloride
Vinyl C~ride
RiIIt-Bued
cieanup
Goal.
uglL
5
,,/,.., .1jOQO:':':')::):
0.06
0.4
200
,.'500
900
3
, '.' ,tOO:::,\'f'
0.7
3,000
1.000
0.008
'::0,_",(::::(:(",:
"'0;'002":., . ..
.:,0,1:",,::.""
0.005
0.005
0.9
0.01
0.002
6
2.000
0.001
0.01
2
3
30
30
1.1
0.3
0.017
Table 5
GROUND WATER CLEANUP STANDARDS
USEPA Max.
Contaminant
Level (a)
ugIL
5 (c)
-
7
-
70 (c)
-
200.
5
-
5 (c)
2,000 (c)
10,000 (c)
-
....oAte)
-
-
-
0;5(0)
'0;5(0) .
1,000
10
SO
SO
-
SO
-
2
10
SO
100
S
2
Cleanup Standards
USEPA Max.
Contaminant
Level GoIIl (a)
ugIL
o (c)
-
7
-
-
-
200
o
-
o (c)
2,000 (c)
10,000 (c)
-
. .
o (c)
WIICOIIIiD
Enfoft:ement
Standard (b)
uglL
ISO
-
7
ISO
100
-
200
5
-
1
343
620
-
-
-
-
-
-
-
1.000
10
SO
SO
5,OOO(d)
SO
-
O.OS(d)
2
10
SO
6
S
0.2
WIICOIIIiD
Preventive
Action Limit (b)
ugIL
/15/
-
.. -,:,:,:0:024:<':.
'...,.,.'.:'" .'.'.
.'. ,'.,,, '''85/,:'..
.:,: \' "'. ':10':',.. .
-
.. ...,.40,:::.
::':':':\)':::0;18":
-
...
<:<~~'6,\>:'<
')24::""'"
-
-
-
o (e)
o (e)
-
5 (e)
-
o (e)
-
o (e)
o (e)
-
2 (e)
SO (e)
-
-
o
o
...
. .
-
-
-
-
-
-
-
200:..
"'. :'.1..,::'
...5.::.
.5
2,5OO(d)
. . '''5':<'
-
?,:,,: J:MJ25(d):(': .....
::.6:.':::::.'O~"'"
\/::. ."'"
" ':.::0:;6::':,',.:'"
. ,.. :. :0;5'::/::.:.:. ,
: :0:0015>
. ,
(a) Code of Fedefll Regulati0n8, Chapter 40, Part 241.
(b) Chapter NR 140, WIICOIIIiD AdllliDiatrative Code
(e) Propo8ed Standard.
(d) Thae ItaDdard. are baled only on public welfare, not public health.
- indicatel that no ltandard iI provided.
J '. '." ..:..:..:" ,:,.,'Iindicatel cleanup IWldard (or UK (or Lemberger litel remedial action
Maximum Cone.
Detected in
Groundwater
uglL
:o'.'.'.':'
5,000
14,000
200
2.200
4,000
21.000
3,200
510
2.400
200
400
480
160
0.1
0.46
0.006
0.18
2.7
2.5
1.580
14.9
53.6
8.9
500
10.9
2
3,280
1.9
3.5
69.7
24
82
28
-------
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 limit 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 desiqned 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) alternatives 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 qroundwater. 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 Si te and a groundwater al ternati ve 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
treatment technologies, the preamble to the NCP contemplates
that many remedial al ternati ves may be impractical for certain
14
-------
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
problem~, 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 continqency 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 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 11
No Action
15
-------
A No Action alternative was evaluated to serve as a baseline for
comparison aqainst the other cleanup alternatives. It assumes that
no corrective action will be taken at the site. No reduction of
toxicity, mobility, or volume throuqh treatment or of the rate of
leachinq of contaminants to the qroundwater 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 drinkinq water standards for qroundwater and is not
protective. There are no costs associated with this alternative.
Groundwater Alternative 4:
Groundwater Containment ~y Hydraulic
Controls .
Groundwater Alternative 4 includes pumping and treating groundwater
in the vicinity of the LL and LTR sites to contain the contaminated
qroundwater. The purpose of this alternative is to control the
movement of contaminated qroundwater rather than achieve
qroundwater 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 qroundwater 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
chanqe the qroundwater flow pattern to control the migration of the
contaminate plume. The exact number of extraction wells, well
locations and pumpinq rates in gallons per minute (qpm) would be
evaluated and selected durinq the desiqn phase of the remedy. It
is estimated that the wells would be pumped at a combined rate of
110 qpm (1.7 billion qallons of qroundwater) 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 qroundwater. Treatment processes (Figure 5)
include electrochemical precipitation to remove inorqanic
contaminants and qranular activated carbon (GAC) to remove organic
contaminants, unless treatability studies show other technologies
to be more effective. The desiqn of the actual process flow train
and the sizinq of the treatment processes would be completed
followinq completion of a treatability study to evaluate the
performance of the systems. A 6-foot-hiqh chain link security
fence would be constructed around the treatment facility to limit
qeneral accessibility to the facility and the potential for public
exposure. Deed restrictions would be placed on properties over the
16
-------
CD.
LI
"'-
-.!.
"'-
'w
CD..
Z~
.....
'-0
~~
8AClCWIISH RETURN
FROM
CROUICJ WIITER
EX TRIICTI ON
NEllS
TURN
~
,~~
fIIŁ1JG
IJK
FILTER PRESS
BftCKImSU
Wt:llIIi
IICIO
KUJUSTNENT
~
~
,"
" SlaIICE ~
TO
BRI\NCH
RIVER
.
SPENT
CARBON
SIIt4PlINC PORT
COMPRESSED
RIR
CAC COllHlS
FI C\Jt[ 5
COHCEPrUlll FLON DIReR"" or "
CROUND IUlTER TREATMENT PROCESS
-------
contaminant plume to prevent contaminated qroundwater from beinq
used.
Treated effluent from the qroundwater treatment system would be
discharqed into the Branch River. A Wisconsin Pollutant Discharqe
Elimination System (WPDES) permit would not be required for on-site
discharqe to the Branch River; however, the substantive State
requirements for effluent discharqe limitations would be met before
discharqe.
Monitorina Proaram
A monitorinq proqram would be developed to evaluate the
effectiveness of the extraction system. Selected residential wells
(includinq the Denor well) would be identified durinq desiqn and
included in the monitorinq proqram.
Manaaement of Treatment Residuals
Treatment of the. contaminated qroundwater will result in the
qeneration of residual sludqe. containinq metals and other
contaminants. The sludqe would be stored temporarily in 55-qallon
drums. Approximately seven cubic yards (21 drums) of waste would
be qenerated every month.
The contaminated qroundwater contains orqanic constitutents which
oriqinated from listed waste at the LTR Site. It may be possible
to remove the orqanics from the qroundwater to below health base
levels, prior to qeneratinq a metal bearinq sludqe from the
chemical precipitation treatment. If the qroundwater has been
successfully treated, then the orqanic contaminants will not make
the sludqe a listed hazardous waste and will not triqqer Land
Disposal Restrictions (LDRs). In the event that the qroundwater
cannot be treated to remove all orqanics above health based levels,
or the sludqe does contain detectable levels of orqanic
contaminants, the sludqe will be manaqed as a listed hazardous
waste. If the sludqe 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 sludqe is not expected to contain metals at concentrations
above characteristic levels. If, after testinq by the TCLP, it is
determined that the sludqe is characteristic for metals, it will be
treated below characteristic levels. Sludqe which does not contain
orqanics and is not characteristic for metals may be disposed of as
a solid waste.
If the sludqe 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 orqanics are successfully removed p.rior 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 ~o 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 Ch~. 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 51
Groundwater Extraction and Treatment
for Active Re.toration
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 Alternative 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
requiring disposal would be generated from the treatment process.
Approximately 40 drums of waste would be generated each month. It
is estimated 210 qpm 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 ~ystem (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 same as
groundwater alternative 4.
for
"onitorina 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 lO~
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
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.
capital Cost:
Annual O&M 1st year
Each year thereafter
Present Worth
Time to implement
$ 3,000,000
651,000
552,000
9,300,000
12 Months
19
-------
~
~
()
I '-.....!,U .'
, .-
-~ I,=-, ...~
i'"
I.
.
a:o&a
'-'
-'
CONCEPTUAL DESIGN ,,0.. GW AL TERNA TIVE S-
GROUND WATER EXTRACTION AND
TAEA~ENT"o..ACTIVERESTOAATlDN
+
+
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 continqency Plan (NCP) requires that
alternatives be subjected to an initial screeninq 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 screeninq, 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 hiqher cost and
Alternative 7 was rejected because it would be difficult to
implement, would create danqers for workers and nearby residents,
and would have extremely hiqh costs. These alternatives were not
evaluated in detail in the FS).
Source Control Alternative 1:
80 Action
The description for this alternative is the same as for Groundwater
No Action.
Source control Alternative 3:
Soli4 .aate Cap
This al ternati ve involves cappinq 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. Drainaqe controls, veqetation, and a 6-foot hiqh 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 fiqure 7.
Ca~ Construction
The waste area would be cleared and reqraded to smooth out the
existing cap. Borrow soil would be used as necessary on the
existinq cap. The cap layers include from bottom to top: A
qradinq layer (existing cover may be used, if adequate) a compacted
clay layer, a drainage layer an optional qeotextile fabric, a
compacted native soil layer, topsoil, and a veqetative cover. A
conceptual desiqn is presented in figure 8.
20
-------
eno OHG NO:~_~OOBS1'P
Ol\TE: 3-S-91 TlI\
PLOT SCALE: 1'4u=I'
NATIVE SOIL
TOPSOIL
I N IT 1 RL COVlR
ANO NATIVE SOIL
GEOTEXTILE
SANO ORRINAGE LAYER
--
"""""""
""""""'"
""""""""
.."""""
.."",
""".,..
UPPER GRRNULAR UNIT
...
,..
COHESIVE UNIT
"
/ / /, .
/ / / ,.. LOWER GRANULAR UNIT
"/// ,,////////,.
"/////////////////.
////////////
... //////////.
'//////'
. , , , , , , ., , , , , , , , , , ,
NOT TO SCALE
NOTE: THE ACTIVE INTERIOR GAS COLLECTION
SYSTEM HOULD BE LOCATEO HITHIN THE HASTES.
.--..-- __4.'.' .. . . ..
6"
2'-0"
6"
2'-0"
6" HIN
FIGURE 1
CROSS SECTION OF
. CLAY CAP
-------
~
~
1.
RETAINING STRUCTURE WILL BE
LOCATED OUTSIDE WASTE EXTENTS.
'-.---:
APPROXIMATE SCALE
~OO'} -, , . 1 '--'.,
J~ \ t~ L}'u.A~.J / l'
", ORJGINAL
II
+
. -. --- --
O'
,
:152'
178'
FIGURE 8
T()IIOO~I'HIC MAl' I'''!I'A''ED IV: MAIIITINEZ COAP.
--.._--- .
- -.;:
-': ,'"
,~
\\
.
, ,
-,
-
-'
:.:--"-
,.!
" -
""-
.......
....
.~
f
"
/"
/
, ,
-------
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 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 iayer 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 compact~d 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. tonq-term qroundwater monitorinq 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:
Jlultilayer 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 figure 9.
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 qroundwater infiltration into the
wastes an~th. amount of contaminant migration from the waste
areas . ~.-
.~:F;'
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. Fiqure 10 shows a cross section of the cap and slurry wall.
Figure 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
-------
CAO OWG NO:C0000833/P
DATE: 3-7-91 TJA
PLOT SCALE: 1\4-=1'
FLEXIBLE MEMBRANE
ANCHOR TRENCH. FILLEO
WITH NATIVE SOIL
FLEXIBLE MEMBRANE LINER
NATIVE SOIL
TOPSOIL
SANO DRAINAGE LAYER
6"
2'-6"
J '-0"
6"
, """"'"
,', """"'"
""""'"
, , ".
2'-0"
~
6" MIN
UPPER GRANULAR UNIT
...
,...
COHESIVE UNIT
...
/
/ / /,
/ / / ~ lOWER GRANULAR UNIT
all/" / /////////,
"/////////////////,
...
-"'1""1' ""'"
NOT TO SCALE
I( :
TilE ACTIVE INTERIOR GAS COLLECTION --
SYSTEM WOULO BE LOCAIEO HITHIN THE HASTES.
FIGURE 9
CROSS SECTION OF
MUL TlLAYER CAP
SC ALTERNATIVE 4
---
-------
/1-0
0°
~~
90
~~
-f
-<
NATIVE SOil
SAND DRIU
"""""
"""""
"""""
, , , ,
'11
COHESIVE UNIT
/
/ / /,
/ / / ... lONER GRANULAR UN IT --...
/// /////////,."
"/////////////////,
""'1""""""
INIT IAl COVER
AND NATIVE SOIL
---
"',
."",
"""
""'"
SLURRY HAl~
"'"
////////////
////////// "
'////// '
CROSS SECTION OF SLURRY WALL AND CLAY CAP
'., I . ~: .' ,
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
'/ / / / // BOUNDARY REOUIRING A
RETAINING STRUCTURE
~
G
1. ACTUAL LOCATION AND NUMBER OF EXTRACTION
WELLS WITHIN SLURRY WALL WOULD BE
DETERMINED DURING REMEDIAL DESIGN.
2. TRANSMISSION PIPING TO GROUND WATER
TREATMEHT SYSTEM IS HOT SHOWN. FIGURES
1-1 AND 1-3 SHOW THE LOCATION OF THE
GROUND WATER TREATMENT SYSTEM.
3. RETAINING STRUCTURE WILL BE
LOCATED OUTSIDE WASTE EXTENTS.
.. GAS EXTRACTION WELL LOCATIONS WILL BE .....
DETERMINED DURING REMEDIAL DESIGN
AND THUS ARE NOT DEPICTED.
-, .
'.--.... ..
~"';- I
//~,.
.",
I
.,
'- -...-, ,
APPROXIMATE SCALE
.' "
0"
1ft.
.
ar
.
t
FIGUOIE 11
. .
T()8toaIllA~IC U"8 ...8.01:'''''.",
"'O-"~"''''C't...
-------
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 analy.i. of Alternative.
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:
Thre.hold criteria
1.
OVerall Protection of Human. Health and the Environment
overall p~~80~io. of huaan health and the environment addre..e.
whetheZ\~..~dJ' provide. adequate protection and de.cribe. how
ri.k. po .~ each eKpo.ure pathway are elt8inated, reduced, or
controll': tlar01lglt treatment, enqineering control., or'
in.tit1lti...~ oontrol..
d .
The no action alternatives do not provide protection. Groundwater
Alternative 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 reduction of risk to human heal th 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 tea, further contaminating the. upper aquifer. Source control
Alternatives 3, 4, and 5 would meet remedial action objectives.
2.
Compliance with ARARs
Compliance with Applicable or Relevant an4 Appropriate Require.ents
(ABARs) a44re8ses whether or not a re.e4y will .eet all of the
applicable or relevant an4 appropriate require.ents of other
Pe4eral an4 state environmental statutes an4/orprovi4e qroun4s for
invokinq 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.
Lonq-Term Effectiveness and Permanence.
Lonq-Term Effectiveness an4 Permanence refers to expecte4 resi4ua1
risk and the ability of a reme4y to maintain reliable protection of
human health and the environment over time once cleanup qoals have
been met.
Groundwater Alternatives 4 and 5 would reduce risk to human health
and the environment over the lonq term by treating the groundwater.
Groundwater Alternative 5 has a greater reduction in risk because
it restores ~he 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
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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.
rf 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 ~isk 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, Mobility, or Volume is the anticipated
performance of the treatment technoloqies 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
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environment that may be posed during the construction
implementation period until cleanup goals are achieved.
and
Groundwater Alternatives 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 ~he 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.
Risks to the community during implementation of Source Control
Alternative 5 (cap and slurry wall) would be minimal but greater
than Source Control A1 ternati ves 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 alternatives may have surface-water runoff resulting
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
Implementability is the technical and administrative feasibility of
a remedy, including the availability of material. and .ervice.
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.
Cost
E.timated coat include. e.timated capital,
maintenance, and pre.ent net worth coata.
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 alternative 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.
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Table 6
COST ESTIMATES POR EACH ALTERNATIVE
Groundwater Alternative 4 Capital Cost O'H* Present Net
containment ~y 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 O'H* Present Net
Eztraction 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
Wall
*
First O&M figure is first year of implementation
Second O&M fiqure is second year to cleanup
HOdifying Criteria
8.
State Acceptance
The State of Wisconsin is in aqreement with the selection of
Groundwater Alternative 5 and Source Control Alternative 5 for
remediation of the Lemberger Landfill, Inc and the Lemberger
Transport & Recyclinq 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.
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J.
The Selected Remedv
Before notinq the maj or components and costs of the selected
remedy, it is appropriate to discuss remediation qoals for
qroundwater at the site. The qoal of this remedial action is to
restore all. portions of the aquifer to the waste manaqement
boundary, so that it may serve as a drinkinq water resource. Some
studies suqqest; however, that not all qroundwater extraction and
treatment proqrams are completely successful in. reducinq
contaminant concentrations to health-based levels throuqhout an
aquifer. u. S. EPA therefore recoqnizes that review of future
operatinq data may indicate the technical impracticability of
attaininq health-based qroundwater quality standards throuqhout the
aquifer. If, at any of the subsequent five-year reviews, it
becomes apparent that unsatisfactory proqress is beinq made in
attaininq qroundwater qoals, the remedy may be reevaluated. If the
remedy is reevaluated, any chanqe in remedy shall be accomplished
by reopeninq and amendment of the ROD, to include an explanation
and documentation of all findinqs, in accordance with 42 U.S.C.
9261(d}(4}, and 9617.
Based on the findings of the RI/FS, 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 Lemberqer Transport & Recycling site. This
combination of alternatives represents the best balance amonq the
evaluation criteria and satisfies the statutory requirements for
protectiveness, compliance with ARARs, cost effectiveness, and the
use of permanent solutions and alternative treatment technoloqies
or resource recovery technoloqies, to the maximum extent
practicable. See fiqure 12 for the conceptual desiqn.
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 followinq:
Groundwater Extraction System
Approximately six extraction wells would be installed in the upper
and lower aquifer to extract the qroundwater plume. Groundwater
shall be extracted until the qroundwater cleanup standards in Table
6 are achieved at the waste manaqement boundary, in this case, the
edqe of the slurry wall. Any disruption of residential water
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LEMBERGER LANDFILL
GROUND HATER
TREATMENT
SYSTEM
HASTE
SLURRY
HALL
GAS
COLLECTI ON
EXTRACTION
HELL
SLURRY
HALL
EXISTING CLAY LAYER
CONTAMINATED
GROUND HATER
RECOMMENDED CLEANUP ACTIVITY
Figure 12
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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 Facility
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 qroundwater
cannot be treated to remove all orqanics above health based levels,
or the sludqe does contain detectable levels of orqanic
contaminants, the sludqe will be manaqed as a listed hazardous
waste. If the sludqe 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 sludqe is not expected to contain metals at concentrations
above characteristic levels. If, after testinq by the TCLP, it is
determined that the sludqe is characteristic for metals, it will be
treated below characteristic levels. Sludqe which does not contain
orqanics and is not characteristic for metals may be disposed of as
a solid waste. .
If the sludqe 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 orqanics are successfully removed prior to
the electrochemical precipitation, the sludqe containinq metals
would not be a listed hazardous waste.
If the sludqe 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 sludqe must be
manaqed 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 durinq remedial desiqn to
determine the extent of the wetlands on the Lemberger sites and the
impact that pumping qroundwat.r 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 damaqe occurs, the impact on the wetlands will be
mitiqated.
CaD Construction
The waste area would be cleared and reqraded 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
qradinq layer (existinq cover may be. used, if appropriate) a
compacted clay layer, a drainaqe layer an optional qeotextile
fabric, a compacted native soil layer, topsoil, and a veqetative
cover. A conceptual desiqn 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 qraded 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. Fiqure 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 well(s) 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
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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
discharqe limitations should provide protection of this
threatened species; however, backqroundwater quality
assumptions must be verified by backqroundwater quality
testing in the Branch River as specified by the WDHR.
The selected remedy will achieve risk reduction throuqh extraction
of contaminated qroundwater 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 qoals 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:
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 technoloqies to the maximum extent
practicable; and,
Satisfy the preference for treatment as a principal
element or provide an explanation as to why this
preference is not satisfied.
The implementation of 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:
a.
b.
c.
d.
e.
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 combininq source control and
containment, qroundwater treatment measures and short term site
access restrictions, thus siqnificantly reducinq the risks posed by
direct contact, inhalation, or inqestion of site-related
contaminants. Groundwater contaminant loadinq will be reduced due
. to the decreased infiltration of water throuqh the landfill.
~ccess restrictions will prevent direct contact with contaminated
qroundwater until the qroundwater cleanup standards are met.
Collectively, the cleanup levels will comply with the 10 -4 to 10 -
6 risk ranqe for carcinoqens and a risk-based level of HI=l for
non-carcinoqens 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. .
ComDliance with ARARs
The selected alternative 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
Regulations 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
regulations 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 al ternati ve concentration limit, (WACL) may be
established if it is determined that it is not technically and
economically feasible to achieve the PAL for a specific
substance. Except where the background concentration of a
compound 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 asa 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. Al ternati vely , 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
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 substantive 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 discharqe limitations. To verify the
limits, backqround surface water quality testing and an
assessment of the existinq habitat for the State threatened
species, the Greater Redhorse fish, is required durinq the
remedial desiqn phases, in accordance with Attachment A. In
addition, treatability studies must be performed to identify
treatment technoloqies 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 ~ill be 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 requlates filling of
wetlands (40 CFR 230). Impacts to the wetlands will be
considered and minimized to the maximum extent possible during
the desiqn phase of this remedial action as directed in
Executive 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 Endanqered and Threatened
Species protection law (29.415 Wis. Stats. and NR 27 Wis. Adm.
Code) prohibit the "takinq" or harminq of endanqered or
threatened wildlife resources. These laws are ARARS for this
remedial action, as poisoninq of endanqered or threatened
species by site contaminants could be considered a "takinq."
The followinq ARARs are associated with the preferred remedy
chosen in this ROD:
Chemical SDecific
*
Water Quality Criteria (AWQC).
Criteria for Water, 1986.
Surface Water Quality Standards (NR 102, NR 105, NR 106, NR
147, Wis. Adm. Code)
40 CFR Part 131 Quality
*
37
-------
Action SDecific
*
Land Disposal Restrictions (40 CFR Part 268, 261)
National Pollutant Discharqe Elimination (40 CFR Part 125);
includ~s best available technoloqy
*
*
Standards Applicable to Owners and Operators of Hazardous
Waste Treatment, Storaqe and Disposal Facilities (~O CFR Part
264.90)
*
Standards Applicable to Generators of Hazardous Waste (NR 600
~ sea, Wis. Adm. Code)
*
Resource Conservation and Recovery Act
6924(u), (v) and 6928(h».
(42 U.S.C.
(RCRA)
*
Groundwater Monitorinq and Recovery Well Requirements (NR 112,
NR 141,
NR 508, NR 600 et sea, Wis. Adm. Code)
Requirements and Standards for Pollution Discharqe 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 ~ seq, 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 Dredqed 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
-------
.
Protection of Endanqered and Threatened Species (29.415 Wis.
Stats., NR 27, Wis. Adm. Code)
"To Be Considered" Requirements
- CERCLA Off-site Policy. (May 12,1986), Revised November 13,
1987, aSWER DIR. 9834.11.
- Wisconsin "Interim Policy for Promotinq the In-State and On-
Site Manaqement 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
requlations. After treatment, the sludqe, 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 providinq 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 hiqh
deqree of overall effectiveness proportional to its costs, the net
present worth beinq $19,200,000. The estimated cost of the
selected remedy .is comparable wi th the other al ternati ves and
assures a hiqh deqree of certainty that the remedy will be
effective in the lonq-term due to the siqnificant reduction of the
toxicity of the contaminants by one order of maqnitude for metals
and two orders of maqnitude for orqanics, achieved throuqh
treatment of the groundwater and control and containment of the
source material that constitute the principal threat at the Site.
Groundwatar Alternative 5 combined with Source Control Alternative
4 is sliq' :,ly less expensive but does not reduce the risk to public
health an~ the environment or provide effectiveness over the lonq
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
-------
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 alternatives that are protective
of human health and the environment and comply with ~s, U.S. EPA
has determined that the selected remedy provides the best balance
of tradeoffs in terms of long-term effectiveness and permanence,
reduction of toxicity, mobility or volume through treatment, short-
term effectiveness, implementability, cost and State and community
acceptance.
Preference for Treatment as a PrinciDal Element
The selected remedy for the final action for the LL Site and the
first operable uni.t for the LTR site satisfies the statutory
preference for treatment as a principal element through treatment
of the contaminants in the qroundwater in an on-site qroundwater
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
-------
REMEDIAL ACTION
ADMINISTRATIVE RECORD
(Index and Documents)
FOR 'l'BE
LEMBERGER LANDFILL INC. AND
LEMBERGER TRANSPORT' RECYCLING INC. SITE
United
MANITOWOC COUNTY, WISCONSIN
MAY 1"1
States Environmental Protection
Region V
230 South Dearborn Street
Chicago, Illinois 60604
Agency
-------
Paga NO.
05/13/91
*
ADMINISTRATIVE RECORD INDEX
LEMBERGER LANDFILL INC. AND
LEMBERGER TRANSPORT I RECYCLING INC. SITE
MANITOWOC COUNTY, WISCONSIN
FICHE/FRAME PAGES DATE
TITLE
AUTHOR
RECIPIENT
DOCUMENT TYPE
DOC NUMBER
16
91/03/04
Letter re: Ha&ardoul
Air Cont8llinant Control
Guidance
G. Edelstein-WONR
M. Gustafson-USEPA
Correspondence
65
90/01/14
Alternatives Array
Docu.nt
BIV Wa.te Science and
Tecllnology Corp.
Raporta/Studies
2
400
91/01/18
Final Remedial
Inve.tigation Report
Volume I - Report
BIV Waste Science and
Tecllnology Corp. and
USEPA
Lemberger Landfill
Inc-
Raporta/Studie.
3
484 91/01/18 Final Remedial BIV Waste Sclenca and Lemberger Landfill . Raports/Studies "
Investigation Report Tecllnology Corp. and Inc.
Volume 11 - Appendice' USEPA
15 91/03/01 Lemberger Landfill Site C. Whitlock-SIV Wa.te M. Gustafson-USEPA Reports/Studies 5
Volume Calculations of Science and Tecllnology
Wa.te witll cover letter Corp.
anaclled
-------
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 Conducting
Remedial Inveetigations
and Feasibility Studies
unaer CERCLA, Interim
Final
Qual i ty Assurance
Project Plan, Pha.e I
Remedial Inve.tigation,
Lemcerger Landfill, Inc.
ano LllliMtrger Transport
ano Recycling, Inc.
Manitowoc CountY,WI
Guidance on RlllediaL
Actions for Cont8lllineted
Ground Wlter It Superfund
Site.
EPA/540/G-88/003
CERCLA CompLiance with
Other Laws ManuaL:
Part II Clean Air Act
and Other EnvironmentaL
StltUls Ind Stlte
Rleui r_ts
EPA/540/G-89/009
GUIDANCE DOCUMENTS INDEX
LEMBERGER LANDFILL AND LEMBERGER TRANSPORT I RECYCLING SITE
Guidance Documents are available for review at
USEPA Region V'Chicago IL
AUTHOR
DATE
USDA,Soll Conservation Service 80/02/00
USEPA
86/12100
USEPA,OSWER Directive
9234.1-01
88/08/08
USEPA,OSWER Directive
9355.3-01
88/10/00
USEPA and Slv
88/11/30
USEPA,OSWER Directive 9283.1-2 88/12/00
USEPA,OSWER Olrectlve
9234.1-02
89/08/00
-------
Plge No.
05/13/91
z
TITLE
Rllk AII.lament Guidance
for Superfund Volume I:
Huun H..ltl! EYelUltion
M8nYIIl
FINII R"'lal
Investigation Report
Lemberger Landfill Inc.
and LlllDlrgar Transport
and Recycling Inc.
GUIDANCE DOCUMENTS INDEX
LEMBERGER LANDFILL AND LEMBERGER TRANSPORT & RECYCLING SITE
Guidance Documents are available for review at
USEPA Region Y.Chicago IL
AUTHOR
DATE
USEPA
89/12/00
USEPA,B&Y Wlltl Scienee & Tecl! 91/01/18
Corp
-------
Plge NO.
05/13/91
ACRONYM GUIDE for the Administrltive Record
LEMBERGER LANDFILL INC. AND
LEMBERGER TRANSPORT' RECYCLING INC. SITE
MANITOWOC COUNTY, WISCONSIN
ACRONYM
DEFINITION
AR
Administrltive Record
ARAR
Appliclble or Relevant
Ind Approprilte Requirements
CERCLA
Comprehensive Environmentll
Response, C~ltion, end
Liability Act
NPL
Nltionsl Priority List
QSWER
Qffice of Solid Wlste
Ind Emergency Response
RI
Remedill Investigltion
RI/FS
Remedill Investigltion!
Felsibility Study
RPM
Remedill Project Mlnlger
U.S.EPA
United Stites Environmentll
Protection Agency
WDNR
Wisconsin Department of
Nlturll Resources
-
-------
Pige NO.
01/18/91
ADMINISTRATIVE RECORD INDEX
LEMBERGER LANDFILL SITE UPDATE NO.1
MANATOWAC COUNTY, WISCONSIN
FICHE/FRAME PAGES.DATE TITLE AUTHOR RECIPIENT DOCUMENT TYPE DOCNUMBER
14 91/05/00 Propo.ed Plen for U.S. EPA U.S. EPA Publ i c Conment
Remedial Action
272 81/10/00 Lember Landfill Site Re.idual. Mlnagement Reports/Studie. 2
Inc. Horizontal Expansion Technology, Inc.
Fea.lbility Report
40 82/07128 Envlrllm*'tal Fothe & Ven Dyke Reports/Studies 3
Investigation Report Engineers/Architects
for: Lemberger Landfills,
Inc. Fly Ash Site 80153
39 85/06/07 Prell8lnary'Remedlal Solexploratlon HIllIIIIIrI,T. Reports/Stloldies "
Invest ill8tlon CoqI8nY
FrriL In TOINhlp
36 85/06/07 Appendix A Privata Soil Exploration U.S. EPA Reports/Stloldies 5
..ater well LOlli CoqI8nY
13 89/09/06 Prell.lnary Heelth Dept. of Hellth U.S. EPA Reports/Studies 6
ASleslllllftt State and Social Services
Of Wllconsln Madilon, WI
Lemberger Transport
and Recycle Landfill
14 89lflf/06.. J.""U8tnary Healt" Dept. of Heal t" U.S. EPA Reports/Studies 1
.!!::' '~t Llllberpr and Social Services
n y.AIII Landt III
-------
Pagc No. *
0-/24/91
ADMINISTRATIVE RECORD INDEX - UPDATE NO.2. ~
LEMBERGER LANDFILL INC. AND LEMBERGER TRANSPORT &
RECYCLING INC. SITE
MANIT~C COUNTY, WISCONSIN
riCHE/FRAME PAGES DATE TI TLE AUTHOR RECIPIENT DOCUMENT TYPE DOCNUHBER
89/08/25 Letter re: Monitoring L. Sridh8r8n-WDNR J. Dowden-WMNA,lnc. Correspondence
to be conducted by
U.$.EPA in the
vicinity of the
Ridgeview L8ndflll
15 90/10/16 Letter r8: Abendonment J. Huffmen'WDNR M. Gust8fson'U.S.E~A correspondence 2
Forms end Repl8cements
Well Logs for
Residenti81 Wells,
Lemberger L8ndf!lls
Superfln:t C~lex
2 90/10/29 Memo re: Review of 1(. Bro'WDNR M. Gustlfson'U.S.EPA Correspondence 3
dati on resldentlll
well watlr s~l..
nelr the Lemberger
Tr_port end
Recycling, Inc.. lite
15 90/11/13 Letter re: Altern8tlvel D. Rossbarg'WDNR M. Gustlflon'U.S.EPA Correspondence (,
ArrlY Docunent
3 91/06/06 Letter re: Met It the J. Nuffmen'WDNR S. Brooks Correspondence. 5
meeting on MIV 22
reglrdlng the proposed
cle8rq1, liter
discusled the Itltus
of the Denar Itock
well. AUlched il
8 letter which
indicltel thlt the
wlter frOll the well
II 'Ife
5 91/07103 Letter re: S8Iplfng J. Huf flllln'WNR Mr. & Mr.. Denor Correspondence 6
rtlul t. of prlvete
weter luppl y well
collected on MaV 15,
1991 by WNR per.omel
6 89/03/29 Superfund Study Begl". U.S.EPA'Reglon V Flct Sheets 7
-------
Page No. 2
09/2~/9'
ADMINISTRATIVE RECORD INDEX - UPDATE NO..2
LEMBERGER LANDFILL INC. AND LEMBERGER TRANSPORT &
RECYCLING INC. SITE
MANITOWOC COUNTY, WISCONSIN
FICHE/FRAME PAGES DATE TI TLE AUTHOR RECIPIENT DOCUMENT TYPE DOCNUHBER
et the L~l'gel'.
LandfIll Tl'enspol't &
Recycling Sites
Ptbllc Meeting
Scheduled fol':
MIl'ctI 29, 1989
3 90/04/00 Fect Sheet 1'8: U.S.EPA-Reglan V .' Feet Sheets
8
R~fll l_tf8ltfan
Update
2 91/01/00 Fect Sheet I'e: U.S.EPA-Reglan V Feet Sheen 9
Remedlll Investfgltfan
Update
2 90/10/19 M- 1'.: ARAII 1"1811 T. Mulllollend"'W.. J. Huff"'-Wn "-1''''' 10
of Leeberger L8ndffll
SuperfLnt Sit.
91/03/10 .... ...: Cal8lntl on .. Hey-II)" Vattr ...OUtcn Me80rlnlUa 11
tile .,..oposed II8It.
...ter fecH fty for
the luperfund Ifte
an the Innch Ifvet'
regerdlng the """lnCe
of the Greeter ledhol'l.
16 91/03/13 MI8D res Projected D- Schu8Uptlz-Y)II D. lOI8btrt-W" Ml8DrlnCkll 12
"-ter Quail ty-18ItcI
Effluent LI.fta for
the L"" "I' L8ndf f U
._~ .:.-.;.;;.
3 91/03/1 . :.... Ifft- I f.ft. D. I18ntz-W. J - Huft-.-W" Ml8Dr..u. 13
"')~..-.u for
of tN8ttc1
t.. fr08 the
. ~ .! -. . Superfund
"ii_.' .
22
91/03/14
MI8D ...: Tr'" Uel
MI8D for the .Interf.
P- Dfdler-WII
.... .....,..,f80t8,
l....1'1
Ml8DrlnCkll
14
POOR QUALITY
ORIGINAL
-------
Page No.
0?/21./91
3.
FICHE/FRAME PAGES DATE
TITLE
POlicy for Promoting
the On-Site Management
of HaZlrdous Wlstes in
the Stete of Wlseonsln"
17
DO/DO/DO
Order of the Stlte of
Wiseonsin Nlturll
Resourees BOlrd
Renunber lng, Amend I ng
end Crelting Rules
91/05/22 Comnents on the
Cle.~ PIM
91/05/28 Comnents on the
Cte~ pt.n
91/05/28 Camwents on the
Cle...., Plen
91/05/28 Comnenu on the
Cte~ Plen
91/05/28 Comnents on the
CI.~ pten
91/05/30 Comnents on the
Cle~ Plan
91/06104
C-.,t. on the
ct....., ptan
"
ADMINISTRATIVE RECORD INDEX - UPDATE NO. Z
LEMBERGER LANDFILL INC. AND LEMBERGER TRANSPORT & .
RECYCLING INC. SITE
MANITOWOC COUNTY, WISCONSIN
AUTHOR
RECIPIENT
D0ClR!ENT TYPE
DOCNUHBER
WONR
Pleadings/Orders
15
M. Sh.vllk-Are. Resident S. Pistor-U.S.EPA
Plbl fe Comnenu
16
J. Kllfes-At.. Resfdent
s. P.stor-U.S.EPA
PIbUe Comnenu
17
l. Oenor-Ar.. Resident
S. P.stor-U.S.EPA
Plblle Comnents
18
O. Preston-Ar.. R..ldent S. P.stor-U.S.EPA
Plbl Ie Comnents
19
M. Preston-Ar.. R..ldent S. P.stor-U.S.EPA
Plbl i e Comnents
20
J. Remfker-Ar..
Resfdent
S. P.stor-U.S_EPA
Plbt Ie Comnents
21
E. KreJC8rek-Are.
.11 I dint
S. p..tor-U.S.EPA
.Plbtle Comnenu
22
91/06/05 CClDents on the w. & V. Ven Ettls- S. P.stor-U.S.EPA Plbt Ie Comnents 23
ct....., pten Ar.. .lIldlntl
91/06/18 Comnentl on the w. Menz.-Ares all I dint S- p..tor-U_S_EPA Plbt Ie Comnents 21,
Ctelrq) ptan
. ......\ :
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Page No.
0./24/91
4
"
ADMINISTRATIVE RECORD INDEX' UPDATE NO.2
LEMBERGER LANDFILL INC. AND LEMBERGER TRANSPORT ..
RECYCLING INC. SITE
MANITCWOC COUNTY, WISCONSIN
FICHEIFRAME PAGES DATE
TITLE
AUTHOR
RECIPIENT
DOOJMENT TYPE
DOC NUMBER
55 91/07100 Manltowoc Public D8IIIH .. Moore S. Peltor'U.S.EPA Public Comnents 25
Utilities Coa.entl an
RI .nd FS
Lenaerger Landfttl
Sites
2 91/07/11 Letter re: Requalt an A. Vogel, Jr. - S. p..tor-U.S.EPA Public Coimlents 26
extension to the Quarles .. Br8dy
Fdlilc coa.ent period
2 '1/0711' Letter re: Request E. Doyle-U.S.EPA A. Vogel-Quarles" Public Comnent. 27
for additional - 8r8dy
InfonDItlon to be
pieced In the
8dIIlnlltratl-
record
50 91/07/19 C~t. on tII. Propoud RMT, Inc. S. P8Itor-U.S.EPA PWU c COIIIIIInti 28
Plan for II88dI.1 Action
91/07/29
Letter re: Cal8ent1
on the Llllbarpr
Landfttl lite
L. Cherney-L..ter
Charney lnauranca
Agency
S. Pntor.U.S.EPA
Publ Ie COIIIIII!ntl
29
2 "/07/29 Letter re: Request for I. JaIIamI_lIICT, Inc. I. 'ator.U.I.EPA Pubtt e Comnentl 30
en addltl.., zo daya
for ...' Ie revl. an
the eddltl...,
e InfOl'8ltlan .Ia
~,.. p'''' Into
'" - .""nlltntl".
.i!.~,
~~~~~ 1:"'"
.', ':4~":"'.:. .
.'!o{".Jr;... ',. .
J~ :";...: .
91107131 L.tt.r rt: I....t ~. Gult.f~.I.EPA I. Jah8mHn-IIIn, PWU e COIIIIII!ntl 31
for an eddltl..' Inc.
ext_Ion to the
...' Ie ~ period
-------
Page No. 5
0;/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 DOCNUHBER
on the Proposed Plan
91/07/31 Letter re: The A. Llbal-Manltowoc S. Pastor'U.S.EPA Publ I c Comnents 32
e"glneerlng firm of Public Utilities
Dames & Moore have
subml tted coaments on
the proposed RI & FS
reports for the
Lembergar Landfill Sita
2 91/08/01 Letter re: Coaments S. Brooks-Town of S. Pastor-U.S.EPA Publ I c Comnents 33
to be. added to the Franklin, Town Chairmen
Public Coament File
for the Phased
Feasibility Study
Report
334 88/01/13 Agency Ravlw Draft CH2M Nil I M. Gustaf.on-U.S.EPA Reports/Studies 34
GAPP Phase 1 Remedial
I nvea t I geU on
256 88/05/16 Final RI/FS ~ork Plan CN2M Nfl I M. Guatafson-U.S.EPA Reports/Studies 35
118 91/05/22 Tranacrlpt fro. Public C. Kel_rton, Court Tranacrlpt 36
Meeting held Wed., May Reporter, Notery
22, 1991 on the Proposed Publlc-Mellmann &
Plan for Remedial Action Bastyr Court Reporters
------- |