United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
PB93-964111
EPA/ROOJReS-92J206
March 1992
&EPA
Superfund
Record of Decision:
Kohler Landfill, WI
~
EPA Report Collection
Information Resource Center
US EPA Region 3
Philadelphia, PA 19107
Hazardous Waste Correction
Information Resource Center
US EPA Region 3
Phlladelphia~ PA 191Q7
u. S. £nV~1t."''-'~At9AiAl\
ReaiOft'lJ Hazardous -. ~ ~r
TeChnica' ~tion Center ~~
841~St,eet. 9th~. .
: ~ PA 18101 -."
-,--

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NOTICE.
The appendices listed in the index that are not found in this document have been removed at the request of
the issuing agency. They contain material which supplement. but adds no further applicable information to
the content of the document. All supplemental material is. however, contained in the administrative record
for this site.

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50272-101
REPORT DOCUMENTATION  11. REPORT NO.      I ~     3. RecIpient'. AcaJ88lan No.   
 PAGE:    EPA/ROD/R05-92/206             
4. TItIII end SubtII8                  5. Report 0818      
SUPERFUND RECORD OF DECISION             03/30/92    
Kohler Landfill, WI                      
               6.       
First Remedial Action - Subsequent to follow             
7. AuthOt(.)                  8. IWfonnlng OrglUliZlltion II8pI. No.  
8. Pltrfonnlng Org8lnlZlltion N8m8 end Add....              10. Proj8ctlT-*JWork Unit No.   
                   11. CantreC1(C) Of Grent(G) No.   
                   (C)       
                   (G)       
1~ Spaneorlng Org8lliutlan N8m8 end Addre88              13. Type of Report & PerIod Covered  
U.S. Environmental Protection Agency         800/000    
401 M StJ=eet, S.W.                      
Washington, D.C. 20460              14.       
15. Suppl8m8nl8ry N"..                        
PB93-964111                        
16. Abetr.c1 (Umlt: 2110 wolde)                      
The 40-acre Kohler Company Landfill site is an operating landfill at the Kohler  
manufacturing facility in KOhler, Sheboygan County, Wisconsin. Land use in the area is
a mixture of business and residential, and an BOO-acre wildlife reserve owned by Kohler
Company surrounds the site. Wetlands are located along the landfill's edge. The sHe
lies within, but rises above, the 100-year floodplain of the Sheboygan River, which is
located east and south of the plant. The estimated 57,000 people who reside within 
3 miles of the site use the Sheboygan municipal system from Lake Michigan as their 
drinking water supply. Two residences located 1/4 mile from the site share a private
well as their drinking water supply. From the early 1950's to the present, the Kohler
Company has used the landfill as the primary location for disposing of manufacturing 
and foundry wastes generated at the Kohler manufacturing facilities. The majority of
the wastes disposed of in the landfill is non-RCRA hazardous waste, including sand, 
cores, molds, clarifier wastes, slag, clay, and pottery, and dust collector wastes. 
Between 1950 and the mid-1970's, several waste disposal pits were constructed in the 
landfill for disposal of hydraulic oils, solvents, paint wastes, enamel powder, lint 
from brass polishing, and chrome-plating sludge. By 1975, these pits were closed and
(See Attached Page)                      
17. Doc......t An8Jy8I. L DHcrlpto18                      
Record of Decision - Kohler Landfill, WI               
First Ren~dial Action - Subsequent to follow             
Contaminated Media: soil                     
Key Contaminants: VOCs (benzene, TCE, toluene, xylenes), other organics, metals  
     (arsenic, chromium, lead)               
b. Identillet8/0pe....- Tenne                      
c. COSATI AeIdIGroup                        
18. Av8l1.blUty St8l8mem            18. Security CI... (Thi. Re.....,)  21. No. 01 P.II8.  
                  None     94   
             20. SecurIty CI... (Thl. "'118)  n Price   
                  None        
(See ANSl-Z38.18)
See Instrueuons on Reverse
(Formetly NTlS-35)
Oep8t1ment 01 Co"""",ce

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EPA/ROD/R05-92/206
Kohler Landfill, WI
First Remedial Action - Subsequent to follow
Abstract (Continued)
covered with nonhazardous fill. Beginning in 1975, all RCRA hazardous liquids were
disposed of offsite. Disposal of solid RCRA hazardous wastes ceased prior to 1980,
however solid non-hazardous wastes have continued to be disposed of in the landfill. In
1983, EPA detected contaminated surface-water runoff at the landfill. Studies have
revealed that ground water is contaminated due to leaching of chemical constituents from
the landfill. This ROD addresses source contamination through containment of the waste
mass as th,~ first of two remedial actions planned for this site. A future ROD will
address th,~ contaminated ground water. The primary contaminants of concern affecting the
waste mass and ground water are VOCs, including benzene, toluene, TCE, and xylenes; other
organics including phenolic compounds; and metals, including arsenic, chromium, and lead.
The select,~d remedial action for this site includes closing the landfill according to
state regulations; constructing a cap over the fill material to reduce infiltration into
the waste Jnass; collecting and treating leachate onsite using air stripping, prior to
discharge to the Sheboygan River through installation of leachate collection system; and
implementing operation and surface controls for the remaining period of landfill
operations and implementing institutional controls including site access and land use
restrictions. The estimated total present worth cost for this remedial action is
$4,700,000 and includes an annual O&M cost of $1,000,000.
PERFORMANCE STANDARDS OR GOALS: Clean-up goals will be met in accordance with state
landfill closure codes, and discharge codes. Chemical-specific ground water clean-up
goals will be addressed in a future ROD.

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DECLARATION OF THE RECORD OF DECISION
site Name and Location
Kohler Company Landfill
Kohler, Wisconsin
statement of Basis and PurDose
Thi:s decision document presents the selected remedial action for
the Kohler Company Landfill (KCL) in Kohler, Wisconsin, which was
cho:sen in accordance with CERCLA, as amended by SARA, and, to the
extl~nt practicable, the National oil and Hazardous Substances
Pollution Contingency Plan (NCP). This decision is based on the
administrative record for the site.
The State of Wisconsin concurs with the selected remedy.
Assessment of the site
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action selected
in this Record of Decision (ROD), may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
DeseriDtion of the Selected Remedv

Thi~; remedy is the first operable unit for the KCL site and
addresses the source of contamination through containment of the
. was1:e mass. The primary goal of the remedial action at this site
is:
to reduce infiltration into the landfill which is the source
of ground water contamination and to reduce the risks
associated with exposure to contaminated materials.
The KCL Remedial Investigation identified contaminated ground water
as the principal threat, with the waste materials acting as the
source of that contamination due to infiltration and the contact
between portions of the waste mass and the ground water.
The major components of the selected remedy consist of:
Closure of the landfill and placement of a clay/soil cap over
the fill material to reduce infiltration into the waste mass.
(Constructed in accordance with NR 504 Wis. Adm. Code).
Collection and treatment of leachate prior to discharge to the
Sheboygan River through the installation of a perimeter
leachate collection drain and treatment system.

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Impose access and use restrictions.
Implement operational and surface controls for remaining
period of landfill operation.
Declaration of Statutorv Determinations
The selected remedy ,is protective of human health and the
environment, complies with Federal and state requirements that are
legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. This remedy utilizes permanent
solutions and alternative treatment technologies, to the maximum
extent practicable for this site. However, because treatment of
the principal threats of this site was not found to be practicable
nor within the limited scope of this action, this remedy does not
satisfy the statutory preference for treatment as a principal
element.
Subsequent actions are planned to address fully the principal
threats posed by the conditions at this site. As required by SARA,
when hazardous substances are left on site, a review will be
conducted within 5 years after commencement of remedial action to
ensure that the remedy continues to provide adequate protection of
human health and the environment.
~s v. damkus, Regional Administrator
~~ u.s. Environmental Protection Agency, Region V
3ft;Yf>
/
Date

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RECORD OF DECISION
DECISION SUMMARY
KOBLER COMPANY LANDFILL
SOURCE CONTROL OPERABLE UNIT
KOBLER, WISCONSIN
prepared .By:
U.S. Environmental Protection Aqency
Reqion V
Chicaqo, Illinois
March 1992

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V.
VI.
VII.
VIII.
IX.
X.
XI.
XII.
I.
II.
III.
IV
j
SUMMARy OF REMEDIAL ALTERNATIVE SELECTION
KOBLER COMPANY LANDFILL SITE, SOURCE CONTROL OPERABLE UNIT
KOBLER, WISCONSIN
TABLE OF CONTENTS
SITE NAME, .LOCA'«'ION, AND DESCRIPTION
.........
4
SITE HISTORY AND ENFORCEMENT ACTIVITIES.
. . . . .
. . 6
HIGHLIGHTS OF COMMUNITY PARTICIPATION
.......
. . 7
SCOPE AND ROLE OF RESPONSE ACTION.
. . . . .
. . 8
SUMMARY OF SITE CHARACTERISTICS.
. . . .
9
SUMMARy OF SITE RISKS. . . . . . .
. . . . . .
11
DOCUMENTATION OF SIGNIFICANT CHANGES. . . . . . . . . . 19
DESCRIPTION OF ALTERNATIVES. . . .
.........
20
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES. . 23
THE SELECTED REMEDY. . . . . . . .
. . . . . . . . . .27
STATUTORY DETERMINATIONS.
. . . . . .
. . . 28
. . . . .
RESPONSIVENESS SUMMARY.
. . . .
. . . .
. . . 34
. . . .

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3
PIGURES
l.
2.
3.
4.
5.
6.
7.
8.
Site Location Map
Kohler Company Landfill Site
Geologic Cross Section Location Map
Geologic Cross Section A-A
Geologic Cross\Section B-B
Geologic Cross Section B-C
Geologic Cross Section E-A
Phase III VOCs in Soil Borings
Phase III Semi-Volatile Compounds in Soil Borings
Phase III Inorganics in Soil Borings
Magnitude of Total Chlorinated VOCs Present in Soil Vapor
Samples
Magnitude of Total Aromatic VOCs Present in Soil Vapor
Samples
Conceptual site Model for Potential Exposure
Source Control Alternatives
9.
10.
11.
1:Z.
1:3 .
14.
TABLES
1..
Summary of Organic Chemical Constituents Detected in
Ground Water Samples
Detected Constituents From Phase I Leachate Samples
Toxicity Summaries for Constituents of Concern
Risk Estimation Summary
Adult Resident Risk Scenarios, Unconsolidated Unit,
Hypothetical Future Potable Ground Water Use
Adult Resident Risk Scenario, Shallow Bedrock,
Hypothetical Future Potable Ground Water Use
Adult Resident Risk Scenario, Deep Bedrock Unit,
Hypothetical Future Potable Ground Water Use
Estimated Sheboygan River Surface Water Concentrations for
Constituents of Concern
Comparison of Constituents of Concern in Ground Water with
Water Quality Criteria
Comparison of Constituents of Concern Estimated in
Sheboygan River Surface Water with Water Quality Criteria
20'
30
40
5.
6.
7.
8.
9.
10.

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..
ROD SUMMARY
KOBLER COMPARY LANDPILL SUPERFUND
KOBLER, WISCONSIN
SOURCE CONTROL OPERABLE tJHIT
SITE
I.
\
SITE LOCATION AND DESCRIPTION
The Kohler Company Landfill Site (the "Site"), comprised of
about 40 acres, is located about one-half mile southeast of the
Kohler Company manufacturing plant in the Village of Kohler,
Sheboygan County. The site is bounded on the north by County
Highway PP, on the south and east by the Sheboygan River, and on
the west by County Highway A. The Village of Kohler is located
approximately four miles west of Lake Michigan, halfway between
the cities of Sheboygan Falls to the west and Sheboygan to the
east. The Site is located in the NE 1/4 of the SE 1/4 of
Section 29, T15N, R22. See Figure 1.

The site is a State-licensed landfill for the disposal of
industrial wastes generated by the Kohler Company and continues
to operate today. (See Figure 2) Most of the area immediately
surrounding the site is undeveloped and is part of the Kohler
Company's aOO-acre River Wildlife Reserve. In the immediate
vicinity of the Site, the principal demographic feature is the
Village of Kohler and the Kohler Company operations. The plant
employs approximately 6,400 persons. County Highway PP is a
frequently used transportation artery between the Village of
Kohler and Cities of Sheboygan and Sheboygan Falls.
It is estimated that 57,000 people live within three miles of
the site. The neares.t private homes (two residences) are
located approximately one-quarter mile south of the landfill on
the opposite side of the Sheboygan River. The nearest private
well is situated near these two homes and is used by the
. residents for drinking and non-drinking purposes. Drinking
water for the Village of Kohler and the Kohler manufacturing
facility is supplied by the Sheboygan municipal system from Lake
Michigan. There are no water supply intakes in the Sheboygan
River downstream of the Site. There are several non-potable
water supply wells located on Kohler Company property including
two on the plant's premises, but none of these are located on
nor have been impacted by contamination from the Site.

The landfill site is located in an area which originally
consisted of a sloping plateau and the historical Sheboygan
River floodplain. Presently, the surface elevation of the
majority of the fill area is at approximately 660 ft. above mean
sea level (msl). The base of the landfill along its eastern

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5
edge marks the Sheboygan River 100-year flood plain. The site
lies above the 100-year floodplain. The surface of the
landfilled area slopes between three and five percent on
average, and the side slopes of the waste disposal mound range
=rom a 3:1 (33 percent) to a 4:1 (25 percent)
horizontal:vertical slope.
The landfill material thickness varies from 6 to 15.5 ft in the
WE!stern portion of 'the fill to 44 to 58 ft in the central to
eClstern portions of' the fill. The most abundant material
identified in landfill borings is black foundry sand, pottery
cull, clay slurry and other non-hazardous foundry wastes.
BE!tween 1950 and the mid-1970s, at least four pits were
cc)nstructed for the disposal of waste solvents, hydraulic oils,
chrome plating sludges, and paint wastes. Figure 2 shows the
landfill boundaries and approximate locations of the disposal
pits.
The Sheboygan River is a principal surface feature in the
vicinity of the Site and has a mean annual discharge of 258
cubic feet per second (cfs) at the united states Geological
Survey gaging station which is situated immediately downstream
f:r'om the Site. The river flows 178 stream-miles from the
headwaters in eastern Fond du Lac County through the Sheboygan
Ma.rsh and toward Lake Michigan while draining a 432 square mile
watershed. Major tributaries include the Onion River and Mullet
River. The Sheboygan River flows over a series of bedrock
outcrops forming the falls and rapids at Sheboygan Falls. Near
the landfill, the river flows in a series of incised meanders
and several oxbow lakes are present. The Sheboygan Ri ver
watershed has been identified as one of the 43 "Areas of
Concern" on the Great Lakes. An Area of Concern, as defined in
the Great Lakes Water Quality Agreement between the United
States and Canada, is a geographic area that fails to meet the
general or specific objectives of the Agreement where such
failure has caused or is likely to cause impairment of
beneficial use or of the area's ability to support aquatic life.
The Sheboygan River and Harbor comprise another Superfund site
and is, therefore, not an explicit part of the Kohler Company
Landfill Remedial Investigation/Feasibility Study (RI/FS),
except to the extent that the river and harbor have been or may
be affected by the landfill. The Kohler Company has been
identified as one of the potentially responsible parties for the
Sheboygan River and Harbor site.

The geologic setting at the Site consists of up to 100 ft. of
unconsolidated sediments of glacial and alluvial origin
underlain by Niagara Dolomite of Silurian-age. The
unconsolidated material can be divided into four units: the
upper, middle, and lower units of glacial origin, and the
alluvium unit.

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6
Two aquifers have been identified at the Site, within the
unconsolidated and bedrock units. Ground water at the site,
derived from local recharge, typically flows through the upper
unconsolidated units. Steep downward gradients present in the
shallower units cause a portion of the local recharge to
percolate into the lower bedrock aquifer prior to discharge to
the river. Due to the highly permeable nature of the landfill
materials (more permeable than the upper till units), the
landfill materials' act as the source of contaminants to the
ground water. Ground water and precipitation that has
percolated downward flow through the landfill materials picking
up the contaminants. Data gathered during the RI indicated that
the landfill has affected ground water in both aquifers, that
the affected ground water is discharging into the Sheboygan
Ri ver , and that the potential exists for movement of the
contaminants under the river to the east. Additional monitoring
activities planned for the Ground Water Operable Unit (GWOU)
will further address the concern for contaminant migration under
the Sheboygan River.
II.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Kohler Company Landfill has been in operation since the
early 1950s, primarily for the disposal of foundry and
manufacturing wastes produced by the Kohler Company
manufacturing facilities. The landfill is owned and operated by
the Kohler Company. In 1969, Kohler obtained a landfill license
from the Wisconsin Department of Natural Resources (WDNR) for
the operation of the landfill, which continues today under that
license. The majority of the wastes disposed of in the landfill
consist of foundry wastes including sand, cores, dust collector
waste, slag, and pottery wastes including cull, clay, molds, and
clarifier waste. These waste streams are not considered listed
or characteristic waste pursuant to the Resource Conservation
and Recovery Act (RCRA)..

General landfill practices between the 1950s and mid-1970s
consisted of the construction. of cells for waste disposal and
other standard filling practices. During this period, practices
also included the construction of waste disposal pits, including
the Old Waste Pit, the Northern Burn Pit, the Southern Burn Pit,
the Non-Flammable Pit (which was located in a portion of the
Northern Burn Pit), and the Suspected Pit. The location of the
pits, the approximate limits of the fill, and the approximate
boundary of the landfill are presented in Figure 2. Waste
streams which were disposed of in these pits included hydraulic
oils, solvents, paint wastes, enamel powder (containing lead and
cadmium), lint from brass polishing, and chrome plating sludges.
Most of these waste streams would be defined as hazardous waste
under RCRA. These cells were closed by 1975 and were
subsequently filled over with non-hazardous wastes.

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7
Beginning in 1975, all hazardous waste liquids (by definition
under RCRA) were shipped for off-site disposal. Disposal of all
solid hazardous waste (by definition under RCRA) in the landfill
c:eased prior to 1980. Since implementation of the hazardous
waste requirements under RCRA in November 1980, all RCRA-
regulated wastes have been shipped off site for disposal.

As the western half of the landfilled area reached capacity, new
disposal cells weJS:e developed to the east. This continued
t:hrough the 1970s and 1980s. By May 1989, a single disposal
c:ell was in use in the northern portion of the eastern half of
the site. Since 1990, solid wastes have been placed along the
western slope of the landfill, while waste slurries have been
placed in shallow trenches in the northern portion of the
eastern half of the Site.
Contaminated surface-water runoff was detected at the landfill
i.n 1983. The following year, the site was placed on the
National Priorities List. Kohler Company was identified as the
only potentially responsible party (PRP) for the site. RIfFS
activities began in 1985 with the signing of an Administrative
Order by Consent (U.S. EPA Docket Number V-W-85-C-018, dated
September 30, 1985) whereby Kohler Company, U.S. EPA and WDHR
agreed that Kohler Company would conduct an RIfFS for the site.
Following three phases of investigatory work, the RI including
t.he Baseline Risk Assessment was completed in August 1991. In
May 1991, U.S. EPA directed Kohler Company to assess site
r'emedial options as two separate operable units, the first
covering source control and the second covering ground water
management. These two operable units together will comprise the
final remedy for the site. The Source Control Operable Unit
Feasibility study (SCOUFS) was completed in September 1991.
Currently, additional ground-water monitoring efforts are
underway for polychlorinated biphenyls (PCBs). Additional
studies are planned tor the GWOU including an ecological
assessment and additional ground-water monitoring.
III.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
A Community Relations Plan for the Site was finalized in April
1987. This document lists contacts and interested parties
throughout the local and government community. It also
establishes communication pathways to ensure timely
dissemination of pertinent information.
The RI, SCOUFS, and the Proposed Plan were released to the
pUblic in October 1991. All of these documents were made
available in the information repository maintained at the Kohler
Public Library. An administrative record file containing these
documents and other site-related documents are located at the
Kohler Public Library. The notice of availability of these
documents was published in the ~heboygan Press on October 10,

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8
1991. Press releases were also sent to all local media. A
public comment period was held from October 14, 1991 to January
6, 1992. Notices of two comment period extensions were placed
in the November 11 and December 14, 1991 editions of the
Sheboygan Press. In addition, a public meeting was held on
October 15, 1991 to present the results of the RIfFS and the
recommended alternative as presented in the Proposed Plan for
the site. All comments are addressed in the Responsiveness
Summary which is the final section of this ROD.
Two fact sheets were developed, in June 1991 and October 1991,
to explain the findings of the RI. These fact sheets were sent
to everyone on u.s. EPA's mailing list for the Kohler site.

An RI "kickoff" meeting wa's held on July 22, 1986 to explain the
RI process. A fact sheet was developed in conjunction with this
meeting. An advertisement was placed in the July 18, 1986
edition of the Sheboygan Press and a press release was sent to
all local media. u.S. EPA representatives attended a Kohler
Company-sponsored briefing on Superfund on January 4, 1986.
Upon the signing of the Consent Order in September 1985, u.S.
EPA held a 30-day public comment period. A press release was
sent to all local media and advertisements were placed.
IV.
SCOPE AND ROLE OF RESPONSE ACTION
As with many Superfund sites, the conditions at the Kohler
Company Landfill site 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
activities or operable units at the site. This ROD addresses
the source of ground-water contamination, namely, the waste
material in the landfill. This source control operable unit
(SCOU) is consistent to.the maximum extent practicable with the
National contingency Plan ("NCP"), and is being implemented to
protect human health and the environment by controlling the
migration of contaminants from the waste to the ground water.
This source control action, by controlling the migration of
contaminants, is fully consistent with all future site work. In
addition, this action will positively affect the cost of the
final ground-water remedy by limiting the amount of additional
ground water that becomes contaminated by this source.

The area that poses the greatest risk is considered to be the
ground water contaminant plume. The contaminated waste in the
landfill is considered to be a long-term threat to human health
and the environment, primarily as a principal source of ground-
water contamination. The volatile organic compounds (VOCs),
semi-volatile organic compounds (SVOCs), and metals in the waste
are considered to be the principa~ threats for this SCOU.

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9
The selected remedy involves the closure of the landfill,
placement of a cap, and installation of a leachate collection
arid treatment system. More specifically, the SCOU response
action encompasses the following activities:
- Closure of the landfill;

- Installation of a WAC NR 504 multi-layer cap over the
landfill; '.
- Installation of a perimeter leachate collection drain;
- Treatment of the leachate prior to discharge to the
Sheboygan River;
- Institutional/operational and surface controls;
- Zoning and deed restrictions; and
- Effective security control measures.
The selected remedy is protecti ve of human heal th and the
environment, complies with Federal and state requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost effective. This remedy utilizes
permanent solutions and alternative treatment technologies, to
the maximum extent practicable for this site. However, because
treatment of the principal threats of the site was not found to
be practicable within the limited scope of this action, this
remedy does not satisfy the statutory preference for treatment
as a principal element.
v.
SUMMARY OF SITE CHARACTERISTICS
In August 1991, the RI. for the site was completed by Kohler
Company under the guidance and oversight of u.s. EPA and WDNR.
An extensive database of information was developed to define the
physical and chemical conditions at the site. The main
objective of the RI was to determine the nature and extent of
contamination at the site.
The following is a summary of the RI results:

Geoloqy: The site is underlain by 20 to 100 ft of
unconsolidated sediments of glacial and alluvial origin
underlain by Niagara Dolomite of Silurian-age. The
unconsolidated material can be divided into four units: the
upper, middle, and lower units of glacial origin, and the
alluvium unit. Figures 3 - 7 represent geologic cross-sections
through the site. These units have been identified consistently
across the site; in places these units have been eroded, or
deposited, by the Sheboygan River.

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10
The uppermost geologic unit, identified as glacial till, is
comprised of poorly sorted silt, clay, and fine sand. The
average thickness of this unit, except where eroded, is
approximately 25 ft.
The middle unit is also glacial till; however, this unit is
comprised primarily of clay to silty-clay material with zones of
gravel and fine sand. This unit is up to 55 ft thick at the
site and averages -approximately 20 ft thick. This unit is
absent in the northeast portion of the site, presumably eroded
by the Sheboygan River. The lower glacial unit is a basal till
and contains compacted gravel, sand, silt, and clay. This unit
is thinner than the two upper units; it averages approximately
15 ft thick.
The fourth geologic unit is the alluvium deposited by the
Sheboygan River. The alluvium primarily overlies the middle
till unit and consists of well-sorted interbedded gravel, sand,
silt, and clay. Where the middle till has been eroded near the
river, the alluvium overlies the lower till. The alluvium is
up to 12 ft thick where it exists along the Sheboygan River.

The unconsolidated sediments overlie dolomite bedrock. The
bedrock in the vicinity of the site is fractured. In addition,
distinct zones of weathering have been noted. . The presence and
extent of the weathering is very irregular. The landfill
materials have been deposited in the Sheboygan River valley. As
such, the landfill materials overlie the alluvium, and the
glacial deposits on the hillsides.
Waste Characterization: Landfill borings indicate that the
majority of wastes in the landfill consist of foundry wastes
including foundry sand, cores, and slag; and pottery wastes
including cull, clay, and molds. These materials are over 50 ft
thick in places. Chemical analysis of the landfill materials
show it to contain significant concentrations of VOCs including
1,2-dichloroethene (DCE) and trichloroethene (TCE); SVOCs
including polynuclear aromatic hydrocarbons (PAHs), phenolic
compounds, and polychlorinated biphenyls (PCBs); and inorganic
compounds including chromium, cadmium, lead, copper, antimony,
and zinc. Portions of the landfill waste materials are below
the water table, most notably the central to western portions of
the landfill. The maximum thickness of the saturated wastes is
about 8 feet. The landfill mass has been and continues to be
the primary source of contamination to the ground water.
Figures 8, 9, and 10 provide a pictorial representation of the
spatial extent of chemical compounds found in the landfill
materials.
Vapors within the landfill contain a variety of VOCs including
vinyl chloride, TCE, and DCE. Figures 11 and 12 can be
referenced for information on co.ncentrations of VOCs in the

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11
li:indfill vapors.
Ground Water: The main source of ground water at the site is
the local infiltration of precipitation into the subsurface.
The water table lies fairly close to the surface (about 2-12
feet below the surface). Lateral ground-water flow is generally
west to east. Shallow ground water, though, is affected by the
steep topography of the site. As a result, shallow ground-water
flow is generally radially away from the center of the landfill
and toward the Sheb'Oygan Ri ver which surrounds it on three
sides.
The bedrock beneath the site and a portion of all the glacially
deposited till units are saturated, as are a portion of the
river deposits and the landfill materials. The middle till unit
tends to impede downward flow of ground water, but steep
dCJwnward gradients in the upper unconsolidated units and in the
landfill have resulted in the migration of landfill contaminants
into the lower glacial 'unit and bedrock. Lateral ground-water
flow through the saturated portions of the waste material may
also be a contributing factor. As a result of the site
hydraulics, a plume of contaminated ground water migrates
tc)wards and discharges into the Sheboygan River. The plume
e]ctends from the Site to the Sheboygan River on the east and
sc)uth sides. The question of whether contaminants are migrating
under the river to the east has not been satisfactorily
al1swered. Long-term monitoring will determine whether the
contaminant plume may also be migrating under the river to
impact wells located on the other side.
Ground water beneath and adjacent to the site is contaminated
with the same chemical constituents found in landfill wastes and
vapors, including VOCs, SVOCs, and inorganic compounds. Many of
these chemicals are at levels exceeding NR 140 (Wisconsin ground
wciter) Enforcement Standards (ESs) or Safe Drinking Water Act
Maximum Contaminant Levels (MCLs). Table 1 provides a summary
of the chemical constituents detected in the ground water and
highlights those which exceed the MCLs or ESs, whichever is most
st:ringent for each constituent.
LE~achate :
..::c)mpounds.
The leachate contains primarily VOCs and inorganic
Table 2 presents the data available on leachate.
Surface-water runoff and sediment: The surface-water runoff and
SE~~ iment contain SVOCs and inorganic compounds. Surface runoff
pa~~erns have been altered since this data was collected.
Runoff channels were utilized for much of the Site's operating
history. Sheet flow drainage has been established with the
placement and grading of cover soils.
WE~tlands: A preliminary wetlands assessment of the site
concluded that several small stands of hydrophilic vegetation

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12
were observed along the toe of the fill on the east and
southeast sides of the Site, and northeast of the Site. Shallow
test pits indicated that hydric soils are present in these areas
and a wetlands hydrology exists. These small stands have been
classified as wetlands.
VI.
SUMMARY OF SITE RISKS
A Baseline Risk Assessment was completed pursuant to the NCP to
determine whether the contaminants of concern identified at the
site pose a current or potential risk to human health and the
environment in the absence of any remedial action. It provides
information used in determining whether remedial action is
necessary and is one justification for performing remedial
actions. The Superfund Baseline Risk Assessment process may be
viewed as consisting of an exposure assessment component and a
toxicity assessment component, the results of which are combined
to develop an overall characterization of risk. These
assessments are site specific and, therefore, may vary widely in
the extent to which qualitative and quantitative analyses are
utilized. .
The Baseline Risk Assessment for the Site was completed to
evaluate public health and environmental risks associated with
the chemical constituents detected in ground water, leachate,
and surface water. A number of scenarios were evaluated and
estimated risks calculated. Two of the scenarios exceeded U.S.
EPA's health-based guidelines of 1 X 10-4 to 1 X 10-6 for excess
lifetime cancer risk and 1.0 for the hazard index (HI). Potable
use of ground water by hypothetical future residents (both
adults and children) resulted in risk estimates that exceed the
guidelines. Exposure to VOCs while showering by hypothetical
future adults using water drawn from the unconsolidated unit
resulted in an HI exceeding 1.0. Table 4 provides the risk
summary.

Excess lifetime cancer risks are determined by multiplying the
intake level with a cancer potency factor. These risks are
probabilities that are generally expressed in scientific
notation (e.g., 1 X 10-6 means that an individual has an
additional one in one million chance of developing cancer as a
result of site-related exposure to a carcinogen over a 70-year
lifetime under the specific exposure conditions at a site).
Potential concern for noncarcinogenic effects of a single
contaminant in a single medium is expressed as the hazard
quotient (HQ) (or the ratio of the estimated intake derived from
the contaminant concentration in a given medium to the
contaminant's reference dose). By adding the HQs for all
contaminants wi thin a medium or across all media to which a
given population may reasonably be exposed, the HI can be
generated. The HI provides a useful reference point for gauging

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"
13
the potential significance of multiple contaminant exposures
within a single medium or across media.
~onstituent Characterization
Based on
<::omparison
<::riteria,
developed.
the occurrence of specific constituents and a
of the constituent concentrations to standards and
a listing of chemicals of concern (COCs) was
The COCs are as follow:
benzene
2-butanone
carbon disulfide
chlorobenzene
chloroethane
l,l-dichloroethane
1,2-dichloroethane
l,l-dichloroethene
1,2-dichloroethene (total)
ethylbenzene
4-methyl-2-pentanone
toluene
I, 1, I-trichloroethane
trichloroethene
vinyl chloride
xylene
butylbenzylphthalate
4-chloro-3-methylphenol
2,4-dimethylphenol
di-n-octyl phthalate
2-methylphenol
4-methylphenol
phenanthrene
phenol
pyrene
aluminum
antimony
arsenic
barium
beryllium
cadmium
chromium
cobalt
copper
fluoride
iron
lead
magnesium
manganese
nickel
nitrate-nitrite
selenium
silver
sulfate
vanadium
zinc
Tuble I provides a summary of the concentrations of the COCs
detected in the ground water at the site and highlights those
which exceed either the MCLs or ESs whichever is most stringent
fc)r each constituent. As shown in this table, the levels of
ccmtaminants found in Site wells far exceed Federal and State
st:andards. The data clearly indicates that the landfill
materials are acting as a source of ground-water contamination.
Wlth the discharge of the contaminated ground water into the
Sheboygan River, additional loading of persistent toxic
chemicals into Lake Michigan lend toward the potential for toxic
effects to be felt by the aquatic environment. This source will
continue to load contaminants to the ground water and the
Sheboygan River unless addressed by a remedial action.

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14
Toxicitv Assessment
Cancer potency factors (CPFs) have been developed by U.S. 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/day) -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. CPFs are derived from the results of
huma~ epidemioloqical studies or chronic animal bioassays to
which animal-to-human extrapolation and uncertainty factors have
been applied (e.q." to account for the use of animal data to
predict effects on. humans).

Reference doses (RfDs) have been developed by U.S. EPA for
indicatinq the potential for adverse health effects from
exposure to chemicals exhibitinq noncarcinoqenic effects. RfDs,
which are expressed in units of mq/kq/day, are estimates of
lifetime daily exposure levels for humans, includinq sensitive
individuals. Estimated intakes of chemicals from environmental
media (e.q., the amount of a chemical inqested from contaminated
drinkinq water) can be compared to the RfD. RfDs are derived
from human epidemioloqical studies or animal studies to which
uncertainty factors have been applied (e.q., 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 noncarcinoqenic effects
to occur.
Based on the list of COCs, the physical and chemical properties
as they relate to fate and transport in the environment were
developed. The followinq properties were considered: molecular
weiqht, water solubility, specific qravity, vapor pressure,
Henry's Law constant, orqanic carbon parti tion coeff icient,
octanol-water coefficient, fish bioconcentration factor, and
half-life in water. A summary of toxicoloqical properties was
also developed for the COCs. This included RfDs for non-
carcinoqenic effects and cancer classification and cancer slope
factors (CSFs) for carcinogenic effects.

Constituents were also classified accordinq to their
carcinoqenic and non-carcinoqenic toxicity effects. For
carcinoqenic compounds, the excess lifetime cancer risk provides
an estimate of the increased risk of cancer which results from
lifetime exposure, at specified averaqe daily dosaqes, to
constituents detected in media at the site. For non-
carcinoqenic compounds, the HQ is used to define the ratio of
the estimated exposure dose to the reference dose (based upon a

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15
dc)se which elicits no effect when evaluating the most sensitive
response). Because of these differing approaches to calculating
risk, the risks associated with carcinogenic effects are
gElnerally much higher than those associated with non-
carcinogenic effects, particularly at the low-dose levels
as:sociated with environmental exposures. Table 3 summarizes the
rElcognized toxic responses associated with the site-specific
COCs.
E~~osure Characterization
The exposure characterization completed in the Risk Assessment
included a release/source analysis, an evaluation of exposure
pathways, exposure points and receptors; and calculation of
exposure point levels and exposure doses for ground water,
leachate, and surface water. Figure 13 provides a summary model
for potential exposure at the site. The landfill material
constitutes the source area for VOCs, SVOCs, and inorganic
compounds.' Leaching of the source area is the primary release
mechanism. Leachate seeps and ground water discharged to the
Sheboygan Ri ver are also release mechanisms. There is no
evidence that on-going erosional runoff is an important release
source from the landfill.
Exposure scenarios were developed to describe potential human
exposures via these pathways under current site conditions and
future potential site uses. Potential effects on the
environment were also evaluated in a qualitative manner.

Risk Characterization
The risk characterization for the Kohler Company Landfill site
provides a quantitative risk estimate for human exposure to
ground water, leachate, and surface water. The estimated risks
were quantified by calculating an excess lifetime cancer risk
and HI for each reasonable maximum exposure scenario. Excess
lifetime cancer risks are determined by multiplying the intake
level with the CPF. These risks are probabilities that are
geJr1erally expressed in scientific notation (e. g., 1 X 10-6). An
excess lifetime cancer risk of 1 X 10-6 indicates that, as a
plausible upper bound, an individual has a one in one million
chance of developing cancer as a result of site-related exposure
to a carcinogen over a 70-year lifetime under the specific
exposure conditions at a site.
Potential concern for noncarcinogenic effects of a single
contaminant in a single medium is expressed as the hazard
quc)tient (HQ). By adding the HQs for all contaminants within a
medium or across all media to which a gi ven population may
reasonably be exposed, the HI can be generated.
Three hypothetical
future ground~water
exposures
(equipment

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1&
washing by a future worker, and potable use by a future resident
at the site, via ingestion and via showering); two potentially
eXisting leachate exposures (site worker and trespasser); two
hypothetical future leachate exposures (adult and child
residents); and two potentially existing surface-water exposures
(swimming and fish consumption) were evaluated. Table 4
provides a summary of these risks.
EauiDment washina 'bv future worker: A hypothetical future
scenario involving workers using site ground water for equipment
washing activities over a 25-year period was developed. These
risks were calculated for hypothetical non-potable water supply
wells in each of the three water units. Excess lifetime cancer
risks ranged from 1 x 10-7 for wells completed in the deep
bedrock to 6 x 10-6 for wells in the unconsolidated deposits and
shallow bedrock unit. The HIs ranged from 0.030 for the deep
bedrock and shallow bedrock units to 0.10 for the unconsolidated
unit. These values are below or within the range of acceptable
health guidelines.
Potable use bv a future resident: Risks for a reasonable
maximum exposure scenario (30-year residence period) for a
hypothetical future adult resident using potable water from a
well completed at the site were calculated in the Baseline Risk
Assessment. Excess lifetime cancer risk estimates ranged from
1 x 10-4 for a well completed in the deep bedrock to 5 x 10-3
for a well completed in the shallow bedrock. The HIs ranged
from 30 for the unconsolidated deposits to 60 for the deep
bedrock. Tables 5, 6, and 7 provide a summary of these risk
estim~tes. Risks from ingestion of ground water by a future
child resident (age 0 to 6 years) were evaluated. The excess
lifetime cancer risks ranged from 6 x 10-5 in the deep bedrock
unit to 2 x 10-3 in the shallow bedrock and unconsolidated
units. The HIs ranged from 60 for the unconsolidated deposit to
100 for the deep bedrock.

Risks to a hypothetical future adult resident from inhalation of
vapors released during showering were also calculated separately
for each of the three hydrogeological units. Excess lifetime
cancer risk estimates range from 3 x 10-6 (deep bedrock unit) to
1 x 10-4 (unconsolidated and shallow bedrock units). The HIs
range from 0.020 (deep bedrock unit) to 2.0 (unconsolidated
unit) .
Values for both ingestion and showering are shown to exceed the
acceptable health guidelines.
Leachate exoosure bv site worker or tresDasser:
Leachate seeps occur at the site and exposure to this media was
evaluated for the potentially existing pathways (site worker and
trespasser) and for the hypothetical future pathways (adult and
child residents). The excess lifetime cancer risk was 2 x 10-6

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17
:for a current worker and 3 x 10 -6 for a trespasser. The HIs
were 0.0060 and 0.20 for the current worker and the trespasser,
respectively. The excess lifetime cancer risk for the future
resident exposure to leachate was 6 X 10-6 for an adult and 2 X
10-5 for a child. The HIs were 0.020 for an adult and 0.20 for
il child. These values lie within the acceptable health
cJUidelines.
l3urface-water exoosures (swimmina and fish inaestion):
Estimates of potential constituent concentrations in the
Sheboyqan River based on levels observed in the qround water
were evaluated in lieu of river water data. The hiqhest 95
percent upper confidence limit (UCL) on the arithmetic averaqe
c:oncentrations for COCs from the three qround-water units were
used to estimate a surface-water exposure point concentration.
Several simplifying assumptions were made: (1) the aquifer is
homogenous and isotropic; (2) the constituents are distributed
equally over the entire site as 95 percent UCL concentrations of
each constituent; (3) the ground water acts as a continuous
source; and (4) no dispersion, biodegradation, or adsorption
occurs along the flow path from the site to the river. Table 8
provides the estimated Sheboygan River surface water
concentrations.
The excess lifetime cancer risk for adults swimminq in the
Sheboygan River (for this site alone) was 1 x 10-12 and the HI
was 0.0020. Consuming fish caught in the Sheboygan River (for
this site alone) was calculated to produce an excess lifetime
cancer risk in adults of 2 x 10-11 and an HI of 0.30. Risks for
children enqaging in these activities were calculated, and were
similar to the values for adults. These values for potential
recreational use of the Sheboyqan River under these assumptions
are below or within health-based guidelines.

Cumulative site risk: A cumulative site risk can be derived by
the summation of excess lifetime cancer risks and HIs across
exposure routes for all media at the site. CUrrent total site
risk was estimated by assuminq that a site worker could, in
addition to leachate exposure, be exposed to constituents
estimated in the Sheboyqan River durinq recreational activities.
The combined risk for the on-site leachate exposure pathway and
the surface water pathways results in an excess lifetime cancer
risk of 4 x 10-6 and an HI of 0.30.
The hypothetical future total site risk values are based upon a
future resident living on site, using the ground water for
drinkinq and showering, swimming in the river, and eating fish
c.!ught from the river. These values are 5 x 10-3 and 60 for the
excess lifetime cancer risk and HI values, respectively. The
total site risk for a future child resident results in an excess
lifetime cancer risk and HI of 2 x 10-3 and 100, respectively.
These. two scenarios are outside of U.S. EPA's health-based

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18
guidelines of 1 X 10-4 to 1 X 10-6 for excess lifetime cancer
risk and 1.0 for the HI. Table 5 provides the risk estimation
summary for the site.

Chemical constituents contained in the landfill materials have
affected ground water in the vicinity of the site. Data
obtained from on-site ground water monitoring wells indicate
that substantial amounts of chemical constituents have been and
continue to be released from the landfill materials to the
ground water. Potential future risks from use of the ground
water are unacceptable. As shown in Table 9 (and also referring
to Table 1), the levels of the COCs in the ground water exceed
Federal and state standards. Continued leaching of these COCs
from the landfill materials to the ground water will result in
continued unacceptable risks. Should these COCs migrate under
the Sheboygan River to existing private wells, or in the event
of future site development involving the installation of a water
supply well, contaminant exposure via ground-water use and
consumption may occur.
Based on the Baseline Risk Assessment and RI, it is concluded
that actual and/or threatened releases of hazardous substances
from the Site, if not addressed by implementing the response
action selected in this ROD, may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
Environmental Assessment
The potential environmental risks of affected ground water on
the aquatic and terrestrial ecosystems around the site were
assessed qualitatively. The calculated constituent
concentratiops in the Sheboygan River are at least one order of
magnitude below the Wisconsin surface-water criteria or the
Federal Ambient Water Quality Criteria. Table 10 provides a
comparison of the COCs estimated in the Sheboygan River water to
the applicable or relevant and appropriate water-quality
criteria.
The bioaccumulation potential for the majority of the COCs by
aquatic organisms is relatively low, based on a comparison of
fish bioaccumulation factors (BCFs) with the value of 1,000 L/kg
which was used in the Baseline Risk Assessment. The BCF relates
the concentration of a chemical in plant and animal tissues to
the concentration of the chemical in the water in which they
live. Fish BCFs greater than 1,000 L/kg are believed to
bioaccumulate significantly. Two COCs have BCFs exceeding 1,000
L/kg: silver and di-n-octyl phthalate.
The presence of PCBs in the landfill has been documented through
chemical analysis of samples of the landfill materials during
the final phase of investigative_activities. Ground water was

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19
not investigated for the presence of PCBs during the three
phases of the RI. The extent of any PCB-contamination in the
ground water is being investigated as part of the ground-water
operable unit. Further investigation is needed to determine
whether PCBs may be migrating from the landfill via the ground
water and discharging into the Sheboygan River. PCBs have a
high BCF and numerous studies have documented their toxic
impacts on both aquatic life and human health. The
concentrations and extent of PCB contamination in the Sheboygan
River and Sheboygam River fish and water fowl has been well
documented in the Remedial Investigation/Enhanced Screening
Report and Alternative Specific Remedial Investigation under the
on-going Sheboygan River and Harbor RI/FS. Should PCBs be
detected in the ground water, conclusions made in the Baseline
Risk Assessment regarding human health and environmental impacts
will need to be re-evaluated.
A comparison of the 95 percent UCL ground-water concentrations
to the appropriate water-quality criteria was conducted to
evaluate the potential ground-water discharge might have on
bE!nthic dwelling organisms. This comparison is presented in
Table 10. This qualitative evaluation suggests that the
potential exists for the ground water to affect sediment
d",'elling organisms.

Risks to terrestrial organisms associated with the Site were not
quantitatively evaluated. The Site has not been identified as
a critical habitat for any species, and no state nor Federal
endangered species that have been reported as migrating through
the Wildlife Reserves are known to reside in the immediate
vicinity of the Site. Terrestrial animals could be exposed via
ingestion of surface water or aquatic life. The level of
exposure to constituents in the leachate is unknown and
difficult to quantify.
Without a more comprehensive assessment of the potential or
actual impacts of the Site on aquatic and terrestrial
ecosystems, final conclusions regarding environmental risk
cannot be made. As a result, an ecological assessment has been
initiated to provide a more definitive answer to this question.
The results of the ecological assessment will be available for
the GWOU remedy selection process.
Y..LI .
DOCUMENTATION OF SIGNIFICANT CHANGES
A significant change has been made in the remedy selected for
the SCOU since the PUblication of the FS and Proposed Plan in
October 1991. The remedy recommended in the Proposed Plan was
Alternative Number 5, Solid Waste Cap with Soil Vapor Extraction
(SVE) Treatment. The remedy selected in this ROD is Alternative
NwDber 3, Solid Waste Cap. This change is a logical outgrowth
baf3ed on the information availabJ.e during the public comment

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20

period and the comments submitted. Alternative Number 3, Solid
Waste Cap, has been determined to provide the most appropriate
balance of tradeoffs among al ternati ves, with respect to the
nine criteria, in light of public comment.
The primary means for protection of human health and the
environment in this al ternati ve is the Solid Waste Cap and
associated institutional controls which preclude direct exposure
to the waste material. The cap provides a substantial reduction
in infiltration of, ,precipitation through the landfill. The
primary means of contaminant transport from the landfill is from
infiltration, although the potential for lateral ground-water
flow affecting contaminant migration exists. This will be
further addressed in the GWOU.
PUblic comments have correctly pointed out that the SVE system
is tied directly to ground-water quality since its primary
objective is to significantly reduce the source of VOCs to the
ground water. The goal of the SVE system would be to achieve a
level of VOCs in the waste and vapors necessary to achieve
protective levels of VOCs in the ground water. A determination
of these levels cannot take place until ground-water cleanup
levels are in place. In addition, to meet the remedial action
objectives set forth in Section VIII, the SVE system must be
designed and implemented to remove VOCs from both the vadose and
saturated zones of the landfill materials, perhaps necessitating
a need to dewater the landfill. Therefore, based on pUblic
comment, the remedy selected in this ROD for the SCOU has been
changed from that presented in the Proposed Plan.
VIII.
DESCRIPTION OF ALTERNATIVES
The FS identified five remedial action objectives for this
operable unit based on the information gathered during the RI
and potential exposure routes and risks identified in the
Baseline Risk Assessment. The objectives identified in the
SCOUFS are:
(1) Reduce and control the movement of contaminants from the
waste material to ground water, surface water, and air;
(2) Prevent exposure to waste materials and leachate seeps
through direct contact, ingestion, or inhalation;
(3) Manage leachate seeps to protect surface water
resources;
(4) Remove and treat VOC-contaminated vapors within the
waste to the extent practical; and

(5) Minimize long-term site management and maintenance.

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21
A comprehensive list of appropriate remedial technologies was
identified for source control. These technologies were screened
based on their cost, implementability, and effectiveness,
e:haracteristics of the Site and the characteristics of the
e:ontaminants. Technologies which satisfied the ini tial
slcreening were ref ined to form remedial action al ternati ves. A
summary of the five alternatives, including the no action
alternative, is provided in Figure 14. A narrative description
elf these options follows:
bLTERNATIVE 1: NO ACTION
'I'his al ternati ve is evaluated as required by the NCP to
dletermine the public health, public welfare and environmental
c:onsequences of taking no further action. Under this
alternative, nothing would be done at the site regarding the
waste mass. The site would continue to operate under its
operating license.
Capital Cost:
'I'otal Present Worth Cost:
Time to Implement:
$0
$0
None
ALTERNATIVE 2: LIMITED ACTION
The Limited-Action alternative would consist of several remedial
activities that would be implemented to provide for the
protection of human health and the environment. Institutional
controls in the form of access and deed restrictions would be
used to prevent access to the site, to limit future land use of
the Site, and-to prohibit placement of ground-water extraction
wells within the contaminated portion of the aquifer. This is
in conformance with NR 112, wis. Adm. Code which requires that
no drinking water wells be located within 1,200 feet of a
landfill unless a var.iance is obtained from the WDNR. In
addition, NR 504 and NR 514 Wis. Adm. Code address final uses of
landfill sites and prohibit certain activities on landfill sites
including the construction of buildings. Operational controls
would provide for the continued acceptable and safe operation of
the landfill. Operational controls are also addressed under
State regulations NR 500-520 wis. Adm. Code.
Access restrictions would be provided in the form of the
installation of a fence surrounding the landfill area. A
sufficient number of warning signs would be placed along the
perimeter fence and security measures would be implemented to
deter unauthorized entry. Deed and zoning restrictions would be
initiated through the local authorities. Deed restrictions
would preclude future development of the Site for residential
construction and prohibit the placement of ground-water wells
within the affected portion of the aquifer for potable or non-
potable use.

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22
Operational controls would include an investigation of waste
minimization procedures at the manufacturing plant that could
reduce total waste quantities, a reduction in the quantity of
high moisture content wastes, and continued management of waste
deposition to maintain proper slope stability. Surface controls
would be continued, to improve the topography of the site,
increase slope stability, and control precipitation runon and
runoff.
Capital Cost:
Total Present Worth Cost:
$70,500
$89,000
ALTERNATIVE 3: SOLID WASTE CAP
The major. elements of this alternative are closure of the
landfill in conformance with Wisconsin Administration Code (WAC)
NR 500 through 520, and the installation of an NR 504 Wis. Adm.
Code solid waste cap over the entire landfill (which is in
conformance with a RCRA Subtitle D cap). This alternative also
includes the use of institutional/operational controls and
surface controls similar to Alternative 2 with the exception
that a perimeter fence is not included since the cap will
provide a suitable barrier against exposure. In addition,
shallow interceptor trenches are included in this alternative as
part of the cap design to collect leachate seepage from the
fill. Based on data collected during the RI, treatment via air
stripping is also included. Discharge of the treated leachate
to the Sheboygan River will meet the requirements of WAC NR 102,
104, 105, 106, and 207, and as such, WDNR will determine the
final treatment and discharge option during the remedial design
when leachate quality and technology-based treatment standards
are finalized.
The cap will provide a barrier to direct exposure to the waste
material as well as limiting water infiltration into the
landfill. The institutional controls will limit future site
usage in order to maintain cap integrity and prevent exposure to
affected ground water.
Capital Cost:
Total Present Worth Cost:
Time to Implement:
$3.7 million
$4.7 million
8 - 12 months
ALTERNATIVE 4: HAZARDOUS WASTE CAP
This alternative is essentially the same as the previous
al ternati ve except that a RCRA Subtitle C cap in conformance
with WAC NR 181 would be used instead of a WDNR solid waste cap.
The RCRA Subtitle C cap would provide additional layers of
material over that of the solid waste cap to reduce the amount
of infiltration and provide additional protection against
subsidence and cap damage. This al ternati ve includes the use of

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23
institutional and operational controls as described under
Alternative 2, with the exception that a fence will not be
.included because of the effective barrier provided by the cap.
Shallow interceptor trenches are also included in this
al ternati ve as part of the cap design to collect leachate
seepage from the fill. This alternative limits future site
uses, limits exposure, and controls contaminant migration as in
Alternative 3. Leachate treatment, similar to that described in
Alternative 3, is also included to ensure compliance with the
identified ARARs p~ior to discharge -of the effluent to the
Sheboygan River.
Capital Cost:
Total Present Worth Cost:
Time to Implement:
$6 million
$7.1 million
12 - 15 months
l\.LTERNATIVE 5: SOLID WASTE CAP WITH SOIL VAPOR EXTRACTION (SVE)
TREATMENT
Alternative 5 includes the implementation of the components of
Alternative 3, and combines it with treatment of VOC source
areas. The treatment component would consist of an SVE system
with treatment of the collected vapors prior to emission. SVE
refers to the practice of inducing an air flow through the soil
or waste matrix to remove volatile contaminants. As a result,
not only is the infiltration of water through the waste material
reduced but most of the VOCs, which contribute significantly to
s:ite risks, are also reduced.
The SVE system would consist of vapor-extraction wells placed
strategically at the Site, and an air-treatment system would be
e.mployed as needed to meet Wisconsin air-quality standards. The
vapor-extraction wells draw air containing VOCs to the surface
where it is treated as necessary to meet wisconsin air-quality
standards (WAC NR 400 through 484) prior to discharge to the
atmosphere. Catalytic oxidation has been identified as the most
effective technology for treating the air emissions. WDNR would
make the final determination of treatment standards -during the
remedial design when adequate data regarding emission quality
and rates is available.
Capital Cost:
Total Present Worth Cost:
Time to Implement:
$4.3 million
$6 million
12 - 16 months to place the cap and
SVE system; 3 - 5 years SVE
operation
Phasina of the Remedv
The "Time to Implement" information provided for each of the
alternatives refers to the implementation period beginning with
landfill closure. This is not necessarily representative at the
Kohler site because it is an operating landfill. Operations at

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24
the landfill will continue for the time specified in the Final
Closure Plan pursuant to the Operating Permit. This will allow
the site to be filled to a final grade that ensures proper
drainage and construction of the cap in accordance with state
requirements. This will most likely add approximately 2 years
to the "Time to Implement" estimates provided. Elements of the
selected response action, such as institutional/operational
controls, surface controls, grading of the fill materials,
zoning and deed restrictions, and security control measures will
be implemented prioE to final closure of the site. In addition,
it is anticipated that the placement of the cap will be
accomplished in phases as each section of the site achieves
final grade.
IX.
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
The alternatives are evaluated against the nine criteria
contained in the NCP [40 CFR 300.430(e)(9)(iii»), by balancing
long-term effectiveness and permanence, reduction of toxicity,
mobility, or volume through treatment, short-term effectiveness
and implementability with the cost of the remedy. This
evaluation determines the most protective and cost-effective
alternative that will meet the remedial action objectives at the
Kohler Company Landfill site. The nine criteria are:
( 1)
Overall Protection of Human Health and the Environment
U.S. EPA measures each alternative by how effectively risks
posed by each exposure pathway are elimin~ted, reduced, or
controlled through treatment, engineering controls, or
institutional controls.
(2)
ComDliance with ADDlicable or Relevant and ADDroDriate
Reauirements (ARARs)
The alternatives are evaluated for compliance with State and
Federal ARARs determined to be applicable, or relevant and
appropriate to the site or provide grounds for invoking a
waiver.
(3)
Lona-Term Effectiveness and Permanence
This criterion relates to the degree of residual risk and
the ability of a remedy to maintain reliable protection of
human health and the environment over time, once cleanup
goals have been met.
(4)
Reduction of Toxicitv. Mobilitv.or Volume throuah
Treatment
This criterion relates to the anticipated performance of the
treatment technologies a reme~y may employ.

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25
(5)
Short-Term Effectiveness
This criterion addresses the period of time needed to
achieve protection against any adverse impacts on human
health and the environment that may be posed during the
remedy's construction and implementation period, until
cleanup requirements are achieved.
(6)
ImDlementabilitv
This criterion addresses the technical and administrative
feasibility of a remedy, including the availability of
materials and services needed to implement a particular
option.
(7)
Cost
This criterion includes estimated capital costs, operation
and maintenance costs, and present net worth costs.
(8)
State AcceDtance
This criterion addresses the State's comments on the
proposed remedial action.
(9)
Community AcceDtance
This criterion summarizes the public's general response
to the alternatives described in the Proposed Plan and FS.
1.
OVerall Protection of Human Health and the Environment
Alternatives 3, 4, and 5 are protective of human health and the
environment since each would minimize the risks posed by direct
contact, inhalation, or ingestion of site-related contaminants
in the waste through containment of the waste. Containment of
the waste would limit exposure to the waste material and reduce
the potential for contaminant movement from the waste mass into
the ground-water by reducing infiltration. The institutional
controls, by minimizing site access and controlling land and
ground water use, would add to the protectiveness. Collection
and treatment of leachate will reduce potential exposure and the
discharge of leachate into the Sheboygan River. The SVE system
in Alternative 5 would provide some additional protectiveness
through the removal and treatment of VOCs from the waste mass,
but would not affect the SVOCs nor inorganic compounds. The
solid waste cap and SVE system would be implemented to ensure
that the remedy is effective in meeting the ground-water cleanup
standards to be determined in the ground-water operable unit.
Alternative
2
would
reduce
human
exposure
to
contaminants

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26
through institutional controls, but would not be as protective
as the previously listed alternatives since they employ a cap.
Alternative 1 will not provide protection from risks associated
with the site contaminants. Ground water will continue to
degrade due to release from the source. Therefore, Alternative
1 will not be included for further consideration.
2. Compliance with Applicable or Relevant and Appropriate
Requirements CARARS)
Alternatives 3, 4, and 5 will comply with state and Federal
ARARs for this operable unit. state solid waste regulations, NR
500 through 520 wis. Adm. Code, for existing landfills are
applicable for this site because it is a licensed solid waste
landfill. The landfill caps described in Alternatives 3 and 4,
and used in Alternative 5, meet current Wisconsin requirements
for solid waste and hazardous waste landfill closures. The
closure plan required pursuant to NR 514.07 wis. Adm. Code must
address long term care of the site (operation and maintenance)
and include a final use plan. NR 504.07 wis. Adm. Code requires
that final use of the site must be compatible with the final
cover system and prohibits the establishment or construction of
buildings on the site or excavation into the cover. NR' 112 wis.
Adm. Code prohibits the placement of water wells within 1,200
feet of the site. These are applicable requirements and will be
addressed in the site closure plan. Water from the leachate
collection drain in Alternatives 3, 4, and 5 would be treated
prior to discharge to the Sheboygan River in accordance with
state requirements for treatment and discharge to a surface
water, WAC NR 102, 104, 105, 106, and 207. contaminants
extracted from the waste material by the SVE system pursuant to
Al ternati ve 5 would be monitored and treated as necessary to
ensure that wisconsin Air-quality standards, WAC NR 400 through
484 are met.
In addition, Alternatives 3, 4, and 5 will reduce infiltration
of rain water into the landfill, thereby reducing the migration
of additional contaminants into the ground water. Alternative
2 fails to meet the Wisconsin ARAR which requires the use of a
cap at the site (WAC NR 500 through 520). Alternative 2
therefore will not be included for further consideration.
3.
Lonq-Term Effectiveness and Permanence
The long-term effectiveness of those alternatives which employ
a cap as a barrier to exposure and a means of reducing
infiltration through the fill (Alternatives 3, 4, and 5) are
roughly equal since the cap and associated institutional
controls provide for permanent protection. Alternative 5
reduces risk by removing from the waste material some of the
more volatile and mobile compounds. This reduction is judged
marginal since infiltration through the unsaturated zone of the

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27
landfill will be substantially reduced by the cap.. Leachate
c:ollection and treatment (in alternatives 3, 4, and 5) will add
t:o the permanence of the site by contributing to the cap
integrity and by removing an additional source to the river.
~~hese technologies are considered reliable and proven and can be
E!asily maintained. Thus, the source control alternatives 3, 4,
and 5 are determined to provide roughly equal long-term
protection.
<4, .
Reduction of Toxicity, MObility, or Voluae throuqh Treatment
'I'he alternatives which include a cap (Alternatives 3, 4, and 5) ,
while not reducing mobility directly through treatment, offer a
r'eduction in the migration of the hazardous constituents in the
fill by reducing infiltration and therefore decreasing the
potential for leaching of contaminants into the ground water.
A.lternative 5, by incorporating the collection and treatment of
VOCs in the SVE system, reduces the toxicity, mobili ty , and
volume of VOCs by removing and treating them. The SVE system is
not effecti ve in reducing toxicity, mobili ty , nor volume of
SVOCs and inorganic compounds since they are not affected by the
system.

The collection of the leachate in the perimeter collection drain
(.Alternatives 3, 4, and 5) will result in a small reduction of
the contaminant discharge into the Sheboygan River, and will
result in a minor reduction in toxicity, mobility, and volume
through treatment of the contaminants. The perimeter collection
drain will not affect the discharge of contaminants to the
Sheboygan River via ground water. Further reductions of
contaminant discharge through ground water will be addressed in
the GWOU.
s.
Short-Term Effectiveness
Alternatives 3, 4, and' 5 offer similar degrees of short-term
effectiveness because the major factors influencing short-term
effectiveness involve closure of the landfill and construction
of the cap, which is a main component of each of these
alternatives. Because construction activities of the selected
remedy will not be initiated for about 2 years while the Site is
bJC'ought to final grade (see Section VIII, Phasing of the
Remedy), protection to the community would be addressed through
the implementation of institutional and operational/surface
cc:mtrols, and access and deed restrictions immediately. In
addition, the use of operational and surface controls will help
tC) minimize infiltration until the cap is in place. The
construction of the cap will be accomplished in stages as
st!ctions of the landfill reach final grade, which will also
reduce infiltration.
The potential for site personnel. to be exposed through direct

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28
contact with waste materials during the closure and capping
activities is considered minimal or nonexistent and was not
considered in the Baseline Risk Assessment, The landfill
accepts only non-hazardous wastes and the potential risk
associated with handling and disposal activities was determined
to be a health and safety issue addressed as part of employment.

Installation of the cap would potentially increase particulate
emissions. Dust suppression techniques are available and would
be used as warranted. by the conditions. Construction of the cap
could also potentially increase traffic accidents in the area
surrounding the site due to the large number of trucks required
to haul clay and soil. The risks to site construction personnel
would be mitigated through use of Occupational Health and Safety
(OSHA) standards and proper safety procedures for the work
performed. While the risks to the community may be slightly
increased during implementation, the short period of time for
construction of the cap should still have a moderate degree of
short-term effectiveness.
6.
Impl..entability
No major implementability problems are anticipated for
Al ternati ves 3, 4, or 5. The technologies included in each
alternative are technically feasible, readily available, easily
implemented, and are considered reliable. The hazardous waste
cap in Alternative 4 would take longer to install than the solid
waste cap in Alternative 3 since it is more complex (8 months
vs. 12 months). Alternative 5 offers some added complexity over
a solid waste cap alone (Alternative 3) since the SVE system
would have to be integrated with the cap design and construction
schedule. The need to conduct pilot and treatability studies
before the system is fully implemented could cause some delay.
7.
Cost
Alt.
3
4
5
capital Cost
$3.7 million
$6 million
$4.3 million
0'11 Cost
$1 million
$1.1 million
$1.6 million
Total Present
Worth Cost
$4.7 million
$7.1 million
$6 million
Note:
O&M = Annual Operation and Maintenance Cost
8.
state Acceptance
The State of Wisconsin is in agreement with the selection of
Alternative 3 for remediation of the Kohler Company Landfill
site and has provided U.S. EPA with a letter of concurrence.
9.
comaunity Acceptance
Based on the comments received by. U.S. EPA, the selected remedy

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29
i.s acceptable to the community. u. S. EPA responses to the
c:omments are found in the attached Responsiveness Summary.
x.
THE SELECTED REMEDY
As provided in CERCLA and the NCP, and based upon the evaluation
of the RIfFS and the nine criteria, u.S. EPA, in consultation
with the WDNR, has identified Alternative 3 as the selected
remedial alternative for the source control remedial action at
the Kohler Company Landfill Site. Alternative 3 represents the
best balance among evaluation criteria and satisfies the
statutory requirements for protectiveness, compliance with
ARARs, cost effectiveness, and the use of permanent solutions
and treatment to the maximum extent practicable.
Alternative 3: Solid Waste Cap
Time to Implement:
Capital Cost:
Annual O&M Cost:
Total Present Worth
8 - 12 months
$3.7 million
$1 million
$4.7 million
Cost:
Major components of the selected remedy are the following:
*
*
*
*
*
*
*
20:.
Closure of the Kohler Company Landfill;
Installation of a multi-layer solid waste cap over the
landfill;
Installation of a perimeter leachate collection drain;
Collection and treatment of leachate with discharge to
the Sheboygan River;

Institutionalfop-erational and surface controls;
Zoning and deed restrictions; and,
Effective security control measures.
STATUTORY DETERMINATIONS
Under its legal authorities, the primary responsibility of U.S.
EJ?A at Superfund sites is to undertake remedial actions that
achieve adequate protection of human health and the environment.
In addition, Section 121 of CERCLA, establishes several other
s1:atutory requirements and preferences. Section 121 requires
that the selected remedy must:
a.
b.
Protect human health and environment;
Comply with ARARs;

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30
c.
d.
Be cost effective;
Utilize permanent solutions and alternate treatment
technologies to the maximum extent practicable; and
Satisfy the preference for treatment as a principal
element of the remedy or document in the ROD why the
preference for treatment was not satisfied.
e.
The following sections discuss how the
(Alternative 3) meets these requirements.
selected
remedy
a.
Protection of Human Health and the Environment
Implementation of the selected alternative will
control potential risks to human health and the
posed by exposure to contaminated waste 'by closure
of the landfill.
reduce and
environment
and capping
Capping the landfill, in addition to reducing any potential
risks that may be posed by direct exposure to contaminated
waste, will reduce the infiltration of precipitation through the
landfill, thereby reducing the ground water contaminant loading.
No unacceptable short-term risks will be caused by
implementation of the remedy. The site workers may be exposed
to noise and dust nuisances during construction of the cap. A
standard health and safety program will manage any short-term
risks. Dust control measures would reduce those risks as well.
b.
Comnliance 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: .

Solid Waste Can/Landfill Closure
State solid waste regulations, NR 500 through 520 wis. Adm.
Code, for existing landfills are applicable for this site
because it is a licensed operating solid waste landfill. NR
504.07 Wis. Adm. Code contains the requirements for the solid
waste cap that is included in the selected alternative. While
both solid and hazardous waste requirements were reviewed as
potential ARARs, the hazardous waste requirements (including
RCRA) were not found to be relevant and appropriate because the
state solid waste requirements provide adequate protection. In
addition, the Site did not receive RCRA listed wastes after
November 19, 1980. Therefore, it was determined that an NR
504.07 cap, in conjunction with a perimeter leachate collection
drain, provides adequate protection. NR 504.07 seeks to
minimize infiltration by specifying clay type, slope, and
topsoil requirements for a final cover for the Site. Although
state regulations may require a gas venting system to relieve

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31
gas buildup beneath the cap (NR 445, NR 504.07, NR 506, NR 508,
NR 514.07 wis. Adm. Code), the site is an industrial (as opposed
to municipal) landfill and buildup of methane and other gases
resulting from the anaerobic decomposition of waste is not a
primary concern. Therefore, the requirements for a gas venting
system are not appropriate.

The Closure Plan required pursuant to NR 514.07 wis. Adm. Code
will address long term care including an inspection/maintenance
schedule. A Final Use Plan is also required. NR 504.07 Wis.
Adm. Code requires the final use of a landfill site to be
compatible with the final cover system and specifically
prohibits the establishment or construction of buildings on the
site or excavation into the cover.
Leachate Collection and Treatment
The selected remedy will achieve state ARARs for discharge to
surface water through discharge of treated leachate to the
Sheboygan River. Wisconsin effluent levels for discharge to the
Sheboygan River will be established in accordance with NR 102,
NR 104, NR 106, NR 108, and NR 207 wis. Adm. Code. The
requirements of NR 220 wis. Adm. Code must also be satisfied.
Effluent limitations based on the use of best available control
technology economically available (BAT), or best practicable
control technology currently available, will be determined by
the WDNR during the remedial design phase of the project.

Additional ARARs which will be met follow: NR 112, wis. Adm.
Code requiring that no drinking water wells be located within
1,200 feet of a landfill unless a variance is obtained from the
WDNR; NR 116 Wis. Adm. Code, Wisconsin's floodplain management
program which governs all activities taking place in a
floodplain; NR 112 and NR 141.25 wis. Adm. Code, which specify
abandonment requirements for monitoring wells and boreholes;
Clean Water Act (CWA) , Ambient Water Quality Criteria for
protection of aquatic life; 40 CFR Part 268, Land Disposal
Restrictions, would be applicable if residuals generated through
leachate treatment exhibit hazardous characteristics.
Wetlands
Construction activities involved with the placement of a solid
waste cap and installation of a leachate collection/treatment
system may impact small areas located at the toe of the fill and
to the northeast which are currently classified as wetlands.
The selected alternative through the reduction of infiltration
and collection of the leachate seeps may result in drying up
these wetlands areas. CWA, section 404 requlates the disposal
of fill materials in waters of the United states including
wetlands. 40 CFR Part 6 contains requlations requiring Federal
agency actions (such as fill activities) to avoid or minimize
adverse impacts on wetlands, and to preserve and enhance the
natural values of wetlands. The~e are applicable at this site

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32
and will be met through one of the following responses: Kohler
Company may be required to pay into a national fund for wetlands
restoration an amount commensurate with the damage incurred to
wetlands at the Site; Kohler Company may be required to create
wetlands similar in scope and nature to those damaged in a
nearby area; or if the overall wetlands impact is negligible,
then no response may be deemed necessary. The determination of
wetland impact and the required response will be made by u.S.
EPA during the remedial design stage.
Following completion of this ROD, the site will become State
enforcement lead. The State will therefore ensure that
compliance with the identified ground-water ARAR, Wisconsin
statute, Chapter 160 and NR 140, WAC, is achieved through the
selection and implementation of the final remedy for addressing
ground water.
c.
Cost Effectiveness
Cost effectiveness compares the effectiveness of an alternative
in proportion to its cost of providing its environmental
benefits. Alternative 3 is a cost-effective alternative
providing for protection of human health and the environment and
long-term effectiveness. Alternative 2 is somewhat less
expensive than the selected remedy, but attains a lesser degree
of long-term effectiveness because the landfill continues to
operate and no cap is placed. Because there is no cap, there is
a greater risk of contaminants continuing to affect the ground
water with Alternative 2 over the long term. Alternative 4 is
the most expensive alternative without providing proportional
increased effectiveness. Alternative 5 is more costly than
Alternative 3 and provides no proportional increase in
effectiveness.
d.
utilization of Permanent Solutions and Alternative Treatment
Technoloaies or Recoverv Technoloaies to the Maximum Extent
Practicable
u.S. EPA and the State of Wisconsin believe the selected remedy
represents the maximum extent to which permanent solutions and
treatment technologies can be utilized in a cost-effecti ve
manner for the SCOU remedy at the Kohler Company Landfill site.
Of the alternatives that are protective of human health and the
environment and comply with ARARs, u.S. EPA and the State have
determined that the selected remedy provides the best balance of
tradeoffs in terms of long-term effectiveness and permanence,
reduction of toxicity, mobility or volume achieved through
treatment, short-term effectiveness, implementability, cost, the
statutory preference for treatment as a principal element, and
State and community acceptance.
Alternative
3
complies
with
ARARs;
provides
long-term

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33
E~ffectiveness; and protects human health and the environment
E~qually as well as Alternatives 4 and 5. The major tradeoffs
t:hat provide the basis for this selection decision are short-
t:erm effectiveness, implementability, and cost. In terms of
short-term effectiveness, Alternative 3 takes the shortest time
t:o implement because there are no substanti ve permi t
requirements, as needed for Alternative 5. Alternative 3 also
poses minimal risk to remediation workers and the community
during the implementation period. Alternative 3 will be easier
t:o implement technically because it requires less construction,
and administratively because it will require less coordination
within the WDNR and u.s. EPA. Finally, Alternative 3 is the
least costly alternative that affords the protection of closing
a.nd capping the site. The selected remedy is more reliable and
can be implemented more quickly, with less difficulty and at
less cost than the other treatment alternative and is therefore
d.etermined to be the most appropriate solution for source
control at the Kohler Company Landfill site.
The state of Wisconsin is in concurrence with the selected
remedy. Public comments are fuily addressed in the
Responsiveness Summary.
e.
Preference for treatment as a nrincinal element
The selected response action does not satisfy the statutory
preference for remedies that employ treatment as a principal
element. Treatment of the waste mass (i. e., SVE system) to
permanently and significantly reduce toxicity, mobility, or
volume of the contaminants (VOCs) was not found to be
practicable nor cost effective for this operable unit.

The goal of theSVE system is to achieve a level of VOCs in the
waste and vapors necessary to achieve a protective level of VOCs
in the ground water, thus tying the design of the SVE system
directly to ground water-quality. This determination of
acceptable levels of VOCs in the waste and vapors cannot occur
until the ground-water cleanup levels are in place. Thus, the
SVE system is considered an integral part of the ground-water
remedy at this site and this treatment element will be
considered when the ground-water alternatives are evaluated.

-------
FIGURES

-------
'0-
-~v

c::::; . f (,;2
o
4000
SITE LOC FIGURE 1
KOHLER COM' A TION MAP
PANY
KOHLER LANDFILL
. WISCONSIN
L,
~~
A.,&GERAGHTY
AYEII..;~ILLER INC
"",,,"'.1 ' .
Ser"icel

-------
Kohler Company Landfill Site
Kohler, Wisconsin
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KOHLER COMPANY LANDFll
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-------
- 620
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- - - PRE-DEVELOPMENT
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.
.
.
.
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FIGURE ~
GEOLOGIC CROSS SECTION A-A'
KOliLER CO'APANY LANI)F Ill.

-------
8
10
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ASSUMED 5 FT SCREEN AND
FIGURE 15
GEOLOGIC CROSS SECTION 8-8'
KOHlER COIAPANY lANDFill
. ,.."".-...... .. h""_",.. ~~-

-------
B
10
IC?
640-
UPPER UNIT
------------
iij 620 .
>
~
c
'"
III
~ 600-
!,
III'
>
o
01
C
...
UI 580 -
~
Z
o
~
c
>
~
'" 560
MIDDLE UNIT
-------------
LOWER UNIT
-------------
540 ..
520
100
200
HCIU2ONTAI. SCAlE IN fEET
VERTICAL EXAOOERATlON. lOX
~!"GERAGIITY
_Fe MILLER.INC.
41'c..".....,., s.,,,~..
DOLOMITE BEDROCK
400
.
.
.
6SR
6DR
LEGEND
- - - PRE.DEVELOPMENf
TOPOGRAPHY
.
.
.
.
PROJECTED WELL
OR BORING
Q8SR
SCREEN & SAND PACK
INTERVAL
C'
LOWER UNIT
"
"
"
"
'.
. "
. "
. "
:.. ::
:. FILL::
'. II
"-.:o6 ~ PRE.DEVELOPMENT : :
-....1 TOPOGRAPHY : '
, A.:"
" ::
'-::------.... 8::.
..........., A.:.
"""....', ::
............ ......------...--::
"""....... .:-:-"""'--.....
.................. ~ ----"""--.....
MIDDLE UNIT ........... -- '" ALLUVIUM

-"" ". """ -"'...!t

.
.
14
DOLOMITE BEDROCK
t4SR
.
SAND PACK AND SCREEN
PROJECTED AND SHIFTED VERTICALL Y
.
GEOTECHNICAL SAMPLE
.
CHEMICAL SAMPLE
.
SHELBY TUBE SAMPLE
FIGURE 6
GEOLOGIC CROSS SECTION B-C'
KOIfLER COI,fPANY lANDFILL
KOHLER, wise OilS IN
?
UNKNOWN CONSTRUCTION
ASSUMED 5 FT SCREEN AND
LOCA 1I0N AT BorrOM OF BORING

-------
Gi 620
i:i
-I
:I
'"
Z
;600
III
i
..

m580

Z
~
5560-
o
660
E
640 -
12D
---------
540
520
'00
2IXI
HORIZONTAl SCAlf IN FEET
VERTICAL EXAGGERATION - '0'
AA!"GERAGIITY
r& MILLER,INe.
~E.IJI"...'.'.' .s."IJ'I.,
400
I I
I I
I I 3SR
II
II
. DOLOMITE BEDROCK I : J
UNCONSOliDATED I I 3R
~m%~~S~~ JDR -~
I
I
I
2DR
ALLUVIUM
27
.
LOWER UNIT
2SR
2DR
LEGEND
- - - PRE-DEVELOPMENT
TCi'CGRAPHr
,
,
,
,
,
PROJECTED WELL
OR BORING
~8SR
SCREEN' SAND PACK
INTERVAL
14SR
.
.
3DR
13C2
13SR2 13DR
.
I.
----
13C
14SR
13SR2
13SR
13R'
13DR
3DR
.
SAND PACK AND SCREEN
PROJECTED AlID SHIFTED VERTICALL Y
.
GEOTECHNICAL SAMPLE
....
CHEMICAL SAMPLE
.
SHELBY TUBE SAMPLE
7
UNKNOWN CONSTRUCTION
IISSUUED 5 FTSCREEN AND
LOCATION AT BOTTOM OF BORING
A'
16SR
13A'
ROAD
UPPER
UNIT
13
 . WDDL E .
  UNIT
 . 
ALLUVIUM  
MIDDLE UNIT . 16
LOWER UNIT  
DOLOMITE BEDROCK
16SR
FIGURE ..,
GEOLOGIC CROSS SECTION E-A'
KOHLER COMPANY LANDFIU
KOHLER. W,SCOIISIN

-------
13/4-6
230 Oic:n_-
120 Tncn_-
350 TOTAL VOCI.

'3/6-8101
24.000 Triclllof_-
'2.000 1.2.0ic_n-
36.000 TOTAL voc.

13/8-8102
62.500 1.2.0icll_-
46.000 Trcll_-
21 Vinyl en.......
a 1.1.0icll_-
110.529 TOTAL VOC.
o~/~


/'
/
,
I
\
3/4-6
a T,icll_-
3/12.14
12.000 x.-
230 E,"y-
46 To--.
12.276 TOTAL voc.
I
I
I
I ,
I I .
I
I
,
9/2-4
9TricII-
1 T-
7 E,IIy-
6 X.-
23 TOTAL vae.
, 0/36-38
NO voc.
10142-44
9 T,ich-
6 x~
1~ TOTAL VOCa
1015..56
NO voc.
\
, \
\ \

\ \
SSg
\
\
I
I
1210.2
NO voc.
7116.18
9T~
10 To"-
19 TOTAL voc.
, 1136-38
NO voc.

11'''2044
23 X-
14/4-6
NO voc.
51..6-50
170 Vinyl-
~30 ToI-
260 T..,II_-
270 X~
1.250 TOTAL voCe
\
\
6128.28
200 1.2.0ich_-
100 T~-
300 TOTAL voc.
613C-36
g T.~~_-
10 T-
12 eu.y--...
4~ Xy-
76 TOTAL voc.
\ \

\ I
I I

I I
, I
I I
41..6-48
42.000 Tr~-
1.500 ToI-
1.500 T.._-
1.100 X~
46. 100 TOTAL voCe
8/......8
NO Voc.
-
/
/
\
\
, I
, I
" '- 1/
\ " J I
, ' I I

'"',, II
'~~~ II
""" O}'~, I I
"~''-, II
- , ,,- '- I I
, ,-tf~.t;-.... I I
~~, ----, ,//
""....~ ---''',,'''
-----
N
LEGEND
SOIL BORINGS
.
o
200
400
800
SCALE IN FEET
AWGERAGHTY
All., & Mll..LER, INC.

~E..i'o....'tJl S.,.i~.,
FIGURE 8
PHASE III VOCS (ug/kg) IN SOIL BORING
KOHLER COMPANY LANDFII
FEASIBILITY STU[
KOHLER, WISCONS
WI1...o1 . O:WI

-------
~
~
~
\
\
\
\ \

\ I
\ I

j I
I I
I
/
\
\
\ \
\ \
\ "-
,
,
o
~
NO
NO
NO
II
1
1 ,
I
/'
I
,
o~o
~\,~
~!>'
~~~
~~':J'\
t;.'\>(.
~O
'!.
V~r:P
1
,
: ,
10136-38
TCL Q£.
11.0:10 13.470 p-Cocla.
30.810 NA PAHt
NO NA PC8a
10/42-44
~ f&.
1.510 13.570 P-CocIa.
5.140 NA PAHI
NO NA PCB.
I I .
I I
,
I
~
NO
8110
NO

~ f&. 1316-8

850 1.450 P- CocIa.
NO NA PAHI
NO NA PCB.
TeL GC 11136-38
2'i&O"2O.5iO P-eoc
8.240 NA PAHI
NO NA PCB.

TC 11/42-44
.....b. Q£.
3.550 15.180 p_ea:
2.530 NA PAHI
NO NA PCB.
~ Q£. 13113.16
NO 2:3.2110
NO NA
NO NA
1414-8
.!£!:. 9£
140 72R ""-CocIa.
250 NA PAHII
NO NA PCBa
~ Q£ 4/8-10

2.180 '3.030 p-eo.
700 NA PAHt
ND NA PCBs

TCL GC 4/~8

8:iiOii 87.iiij "'- eo.
2.250 NA P-
10.000 NA PCBa
14/8.10
9£
170 "-~
NA P-
NA PCB.
m. mo. 314-6
130 1.510 "'-CGda.
3JIOO NA PAHa
NO NA PC8a
19.. mo. 3112.14
1.880 27.300 PI18IIIIiio CGda.
1.050 NA PAHa
NO NA PCb
~ 9£ 8/24.26

6110 4.100 P-CGdL
4.283 NA PAHI
NO NA pea.
Q£
1/4-6
.IE:. 9£ 8/28-28
530 1.970 P"'" CodI.
110 NA PAN.
NO NA PC84
Jn !& 6134-36
8.580 20.600 Ph- CocIL
1.5'0 NA PAN.
54G.000 "'A PCB.
---
------ --
--
TC 8/48-48
......!:. 9£
.,0 550 P-CocIL
1.500 NA PAHI
530 NA PCB.
!Eo.
NO
NO
NO
110 P~Coda.
NA PAHI
NA PCb
!!:1. GC 2/4-6

'.150 7.5110 Ph-cCoclL
820 NA PAHI
2110 NA PCBa
/
1
I 1
II
I I
I I
II
I I
I I
II
LE~ND

. SOIL BORINGS
,
,
",
"~~ ..
....C~'........
""" .. ..
-,-........ II

.. 'f2te"........ - I 1
".. --- ,//
............. .........."" --~ "
-...~--~.,.
N
TCl
TARGET COMPOUND LIST (GClMS)
GAS CHROMATOGRAPHY
200
BOO
400
GC
SCALE IN FEET
AGURE 9
PHASE III SEMI-VOLA Till
COMPOUNDS (ug/kg) IN SOIL BORING!
KOHLER COMPANY LANDFIL
FEASIBILITY S; ",J'
KOHLER. WISCONSII
WlI8401 . 0348.1
A8'GERAGHTY
A"& Mll...LER, INC.

AI £."ir.....,.' S.r.i~.'

-------
0",0
'!......~
~~
~~~
~~c:,"\
f?"\~
~o
r::P~
U~\U~
5B131W
13 "'*-"
2.11 C8dnium
3QJI a.-.m
".2 e.-
112 L-
1,010 ~
5B1316-812
e33.~R "'*-"
c2. I C8dnium
11.1 CNwIun
.1.0 e.-
51.1 L-
T7.3 ~
5BI8
5B7124.26
17 IV-.,
SA c:.-.
21.3 Ch-.
2.480 e.-
~ L-
U20 &c
5B11
5BII26-28
au "-
~ CMrMn
108 CIvamoum
1.0150 e-
z.ooo ~
1.1130 Zinc
5B8I34036
«1.1 "-
1~.' CMrMn
1011 CIvamoum
~85 e-
2.no L-
.eo Zinc
5B12.
8
SB14
\
5B6
5B4I30.32
e7.1 IV-.,
1.~ c:--.m
21.1 CNwIun
au e.-
m L88
2!IO ~
SB~4"'8
301.1 "'*-"
1J1 c:--.m
... a.-.m
:153 e.-
U10 L88
573 ~
\ I
\ ,

I I

I ,
I ,
I
/
SB2IM
cU "'*-"
1.7 CMrMn
38.2 0.-
155 e.-
1. L88
113 ~
SB2IW12
5U "'*-"
~.o c:--.m
2M CNwIun
I. e.-
.a2 L88
3111 Zinc
---------.....-....- -'
,""" ."....--------- --
'" "'. -------""
/ .-
, /
I
I

f/
\ \ " "
" \ II
\ " "
, ' I ,

',', II
.. ...r~~.. : :
""~"'.. II

-','............ , I
........~.... I,
""'~..... - - - //
.... .... - '
......... ............ "'""-, ,
--...---._---,,'
LEGEND
. SOIL BORINGS
N
o
200
800
400
SCALE IN FEET
/"
I
,

f "

, ,

/ !

, I

\ \

, ,

'" \
5B11/36038
I"" "'*-"
30.1 c:--.m
30 a-
~. e.-
2.130 ~
- Zinc
SB11/42-"
8. I AnIin8ny
1.1 C8dnium
45.8 a-
m ~
1.. ~
- Zinc
I /
,
I ,
'/
/,
/,
S81124-26
R ......
"7~
aa a--
1"10 e.-
2117 ~
1,.100 ~
5B1141048
R AnIin8ny
e18.7 c:--.m
!ilIA a-
3010 e-
.1. L.-
101 Zinc
FIGURE 1 C
PHASE IIIINORGANICS (mgJkg) IN SOIL BORINGS
KOHLER COMPANY LAND FlU
KOHLER. WISCONSIf\
~"GERAGHTY
~r& Mll..LER_. INC.
u_...-- _.~

-------
I"
"
'"
'"
",
/
......
...,,---
_.- "
,
,
/
f
w""'...~ of
ri~\ -1
! I
  SGZ4 .   \    5GZ7      
     dGir   .        
          SGZB .    
      SGZ60     SGZ9  
      )        0  
     I"            
   -         SGZZ.    
  ,/             
 ,/              SGZJ  
               0 
 V SG1B.  SGj9 SGZO . . 5G27      
I      .        
    k)w-z    SG1SC. 0.SC168. . '.6 ~G178  
,     3   SG1SB8  
 SG720    OSG13 0 SG14      
 "   .SG73C      . "Sl:16A ..   
 \       .'0'.    5G7 7A  
          . . SG15A      
 ,       SGOBS 500gB'. '. SGO~A      
 SG~6 .     .  SG108 . SC11A  
    SC07B   0..... .   
  \    .        . 5G119  '
   S~!,7A.'. .  0 SCOBA   SGOSC   
  \      .      I
   '. ';G07;0'.          I 
  \             I  
  ,  SG02A.'          
   ......  . . .     sccu    I  
      SCOJA  .     
    r--   O .    .0   I  
    ,    SG038    . '?COS   
 SC07            
  .  \           /'  
             ./   
    \         :,..--   
I
I
I
/
i
I
I
I
~LEGENi5- - .

SGZ4. - SOIL VAPOR SAMPLE LOCATION
--~
---
~I'''
SiGOl . .
SG05 0
5GOJB .
5COJA 0
SGC7A.
SG09A °
SG1JC .
5G07C 0
. . J
..)0.000 - 100.000 ug/m

>100.000 ug/m J
FIGURE 11
o
125
250
. 500
MAGNITUDE OF TOTAL
CHLORINATED VOC's PRESENJ
IN SOIL VAPOR SAMPLES
SCALE IN FE:::T
XOHUR u.VDFru
11111UJC. r/scon/II
7f7f Engineering & Science
~~'JQI'II. ,.....
(UOO..OI

-------
/
/'
"-
"
--
'"
" ~
-- .
./
,/
"
(
 SG24.   \      SG27      
    S~S    .        
          SG2B     
    .         .  SG29  
     )    °       .  
        SG26         
    /             
   ./               
  /'           SG22 .    
 /'               SG2J 0 
 / SGtB.  SGtS  SG20   SG2l      
    .   . '      , 
   OW-2     SG1SC . . SCt6e. .~~7.7e 
          ..  
     ~     SG15B .      
\  .    .   SG74 .OSC16A    
SG72     SG1J .        
         ..     
 ,              ..   
 ~   . SG7JC      .    SG17A 
         , . SC1.5A      
 \        SGOBe SG09B.  SCtOe  SGllA I
       .  . . SGOSA  
           .0 .  .   
 SG,'     SG07B     . .     
     .   0 SGOBA      SG118 I 
  ~Cp~A...     SGOSC   .  
 \       .    I 
  . 'SC07C",          
            I 
 '              / 
  \ SGO:O( ,          
  '...   . . .     . SC04    
       SGOJA     
  \    '  .    .0   I  
        SCOJB    . 'SG0.5   
 SGOt  \            
  .             
             'V  
    '            
/
t..a'tn'j+, of I
1;'111---.,1
! ,
I
i \
I
!
J
(
I
,
J
'-" ----
-
.-'
.-'
--
--
SG24 .
LEGEND
MAGNITUDE
SC01. ND - 100 ug/mJ
SCOS 0 100- .300 ug/m J
SC04 . 300 - 1.000 ug/mJ
J
1,000 - 3.000 ug/m
.,
r.rl'
SC16A °
FICURE 12,
o
MAGNITUDE OF TOTAL
AROMATIC VOC's PRESENT
IN SOIL VAPOR SAMPLES
125
250
500
,
I

I
. I
SCALE IN FEET
ICr/BUR /..U{DTru.
mllZ.lJf. r Ut:Jt111$//f
inI' Engineering & Science
$_nanc. ,...,
0400a.,Z

-------
RElEASE
SOURCE
RELEASE
MECHANISM
TRANSPORT
MEDIUM
EXPOSURE
POINT
RECEPTORS
Exposure
Route
Human
Biota
      Future  Ingestion .  .  
  .... Leaching Ground .... On-site ....      
  Water Industrial & Dermal Con. . . .  
      Domestic Wells       -
       Inhalation .    
   1,\   leachate  Ingestion . . . . 
landfill     Seeps       
  ....     Dermal Can. . . . . 
    Surface    Ingestion . . . . .
   Runolf -- Waterl .... Sheboygan .... Dermal Can.     
   River . . . . .
  .... Sediments        
   Erosion     Inhalation     
  -           
 ,            
   Bloaccum\     Ingestion . . . . 
   Fish .... Sheboygan r-- Dermal Con.     
   I   River      
        Inhalation     
.AWGERAGHTY
A..& MILLER, INC.

..,. E",i,o""u,'/J' S",lcu
FIGURE 13
CONCEPTUAL SITE MODEL FOR POTENTIAL EXPOSURE
KOHLER COMPANY LANDFILL
SOURCE CONTROL FEASIBILITY STUDY
KOHLER. WISCONSIN
WI164.01.01!.'.

-------
      Figure I Lf   
     Source Control Alternatives  
    fohler Company landfill. Source Control Feasibility Study 
 ...pons. ActlClfll   Alternatives 
   .  IIA LA IC RC IC/SYE
Mediua Action   'rpe No Action limited lase Cap RCRA Guidance lese Cap with
     Act ion wi th Leachate Cap with SVE and Air
       Treatment leachate E8ilslons
        Treatment Treatment
 lnatltutlonall'  "  " 
 Operational Controls     
    Wllconlln IIR   .  .
    504.07 CaD     
Source Capping        
Ar.a    ICIA Guidance    . 
    CaD     
    Vapor     .
 Treltment  btractlon     
   -      
 ./ '  lYE E.llsl-     .
    traltMnt     
 Collect Ion 'renches   ' " 
leachate         
Seeps Treatment     ' " 
 Discharge  liver   ' " 

-------
TABLES

-------
                 P8J;C I (11".:
Table I Sum miry of ChemicII Consliluenls (lfg/L) Delecled in Ground-WIler SImples, Kuhler Company Landfill, Kohler, Wisconsin.   
  MCL               
Sample ID ES IC-OI 1001 OWISR-OI OWIOR-OI 2-01 2-02 20-01  2SR-01  2DR-01  2DR-02 OW2-01 JOI
VOLA=TILE ORGANIC COMPOUNDS                
Vinyl Chloride 0.2 <10 <10 <10 <10 <10 NA ~~  <10  I ~ I I r;;pJ <10 C]~l
Chloloclhane  <10 <10 <10 <10 <10 NA  <10  
-------
                  "age 1 ..f 4
T.hle I Summery of Chemicll Consliluenls (pg/L) Delecled in Ground-Wiler Simples, Kohler Company Landfill, Kohler, Wisconsin.    
  MCL                
S8mple 10 ES '1 "'1 .,~ n. 3R.OI 3OR.OI 3SR-OI 4.01 40-01  5-01  50-01  6.{)1 60R-01  8(RE).01
~'U" .JLI-VI    
VOLATILE OROANIC COMPOUNDS                 
Vinyl Chloride 0.2 ~J ~ qjgJ J <10 ~~ <10 <10  <10  ~~ <10 <10  <10
Chlorocth.ne  <10 J <10 <10  <10 J <10 J <10  <10
C.rbon Dilulfide  qJ <5 <5 <5 <5 <5 <5  <5  <10  <5 <5  <5
I,I-Dichlorocchcne 7 <5 <5 <5 <5 <5 <5  <5  <10  <5 <5  <5
I,I-Dichlorodh.ne 850 <5 5!fJ ~ <5 ~ <5 <5  <5  ~ <5 <5  <5
1,2.Dichlorodhene (lot8J) 100 r-::J <5 qp ~PJ c;pJ <5 ~PJ <~
Chloroform 6 
-------
               l'II,;c .1 .., 4
Table I Summary of Chemic.1 Constituents (,.g/I..) Delecled in GWllnd-Water Samples, Kohler Company Landfill, Kohler, Wisconsin.   
  MCL             
Sample ID ES 8D(RE)01  BnnOI BR.OI  8SR.OI 8SROIRE 11.01 IID.OI  12.01 13.01 IJR~I IJSROI
VOLATILE OROANIC COMPOUNDS             
Vinyl Chloride 0.2 ~ <10 I~J ~ ClgJ r:--2AP q;gJ  <10 <10 r;,~ ;..1 [IT]
ChlorOdhlne  <10 J l qp qJ ~p~ ~ <5 <5 c;p ~~]
Benzene 5 <5 <5  <5 <5
4-Methyl-2-Pentenone  <10 <10 J <10 J <10 J <10 J if <10 <10 <10 J <10
Toluene 343 <5 <5 <5 J <5 J <5 <5 <5 <5 <5
Chlorobcnzene  <5 <5 ~il <5 J <5 .-nO <5 <5 <5 <5
E'hylbenzcne 1360 <5 <5 <5 J <5 ~ ~J I <5 <5 <5 <5
Xylene ('oCal) 620 <5 <5 <5 J <5 J <5 190  <5. <5 <5 <5
SEMI-VOLATILE OROANICS              
Phenol  <10 <10 <10  <10 NA q~ 
-------
I'nt< 4 or 4
Table I
Summary of Chemical Consliluenls ("g/L) Deleclell in GrOllnd-Waler Samples, Kohler Company Landfill, Kohler, Wisconsin.
 MCl             
Sample ID ES DSR.OIRE 13DROI 14.01  14SR-OI 15.01 ISDR.OI 15SR.01 16.01 16SR.01 16SR.0IDUP t1SR.OI 
VOLA TilE OROANIC COMPOUNDS              
Vinyl Chloride 0.2 
-------
Table I -8. Summary of Inorganic Consliluenls Delecled in Till Wells, Concenlralions are IIg/L, Excepl Flouride and Nilrale-Nilrile almg/L.
5ample ID
Antimony
Arsuic
Barium
Cnd ,ium
Chromium
Copper
Imn
/.ud
Silver
Zinc
,
flouride (Diot)
flouride (Elect)
Nilrate.Nitrite
Background
(Maximum)
96
1.3
361
5.1
12.2.
68.1
223

-------
                    "ol;e 2 
-------
                          r.ce I of 2
Table I -C. Inorganic Consliluents Delecled in Bedrock Wells, Concenlralions are pgll., except Fluuride and Nitrale-Nilrile al mg/L.      
  Background MCL                        
Semple ID (Maximum) ES  2SR  2I>R   3R  3SR   30R  8R   8SR   80R   I3R 
Anlimony 61.4   <32 I ~~  <640 I <32 I  <640 I 40.4 I  <640 I I 778 I J ~J
Arsenic 6.3 SO  <3.0  NR   4.4 I <3.0 R  <30  5.5 I  <3.0   <3.0 J  <30 
Berium 60.1 1,000  43.7 I 56.8 I I 130 J I LE~ I /14 J I I 84.6 J 1 I 288 J I 11.650 J I I 168 J I
Cedmium 3.3 10 I 3.6 UI <2.0  I 50.0 J I 3.3 UJ  <40.0  3.2 U  <40.0   <40.0   <40.0 
Chromium 15.9 50 I 55.3 I I LI63 UJI  <80  <4.0   <80.0  116.0 UJI <80.0  @J   <80.0 
Copper 47.9  I 97.2 RI 48.5   <40.0 J 5.5 U  <40.0 J 43.3 R  <40.0 I  <40.0 J  <40.0 J
Iron 2SJ   112 UJ /18  I 520 I I 23.4 U  <100  75.7 lJI  <100  ~370]   <100 
I.end IS 50  < 1.0  < 1.0 J  < 1.0  < 1.0   < 1.0  I 2.8 U I < 1.0   < 1.0   < 1.0 J
Silver 9.7 50  2.7 I 8.3 lJJ  <40.0 I <2.0  1 126 J I <2.0 I  I 54.0 I I I 122 I I ~~J
Zinc 66.7   53.6 I 37.7   <60.0  5.5 J  <60.0  62.6 I  <60.0  I 154 J I  <60.0 
fluuride (Oist) 0.533 ..  NA  NA   NA  NA   NA  NA   NA   NA   NA 
flouride (Elect) 0.514 4  10.580 I  NS   0.391  0.373   0.456  0.326   0.442   0.416   0.446 
Nitrele-Nitrite 0.187 10  Q!U  0018   0.06'1  0.093   0.074  10.3141   10.1941  10.2891   0.181 
NS = No semple collected.
N A = No anelyais.
NR = Not reported.
Dele qualifier. .re provided in Appcndilt Q.
n Value isabovc background concentrations.
D Velue ellCccda Safe Drinking W.ter Act (42 U.S.C. 3OO(f) d scq.1
Muimum Containment Levels (MCLs) or Enforcemenl SI.ndards (s. NR 140.10 Wise. Admin. Code).
80SK OlllER RI(leblcs)N2/bcdrock. wk I
GERAGIITY & MILLE~.INC.

-------
!'age 2 ..f 2
Table I -C. Inorganic Conslituenls Delecled in Bedrock Wells, Concenlrllions Ire pg/L, excepl Flouride Ind Nilrale-Nilrile II mg/L. 
 B/lckground MCl                  
Semple 10 (Mnimum) ES  13SR IJDR   14SR  ISSR  ISOR   16SR  16SR OliP  17SR 
Anlimony 61.4  <640 I <3.2  <32.0  <640 I SJ.7 U [B~ I~  US UJ
Arsenic 6.3 SO  <3.0 <0.30   <3.0 I <3.0  <3.0 I  <3.0  <3.0  <2.0 I
Barium 60.1 1,000 ~ <0.30  I 96.2 I I I 228 I I ~ I 160 I I C@ I 102 I I
Cedmium 3.3 10 <40.0 <0.20   <2.0  146.0 I I <2.0   <40.0  <40  3.S I
Chromium 15.9 SO <80.0 <0.40   4.4 UJ <80.0  6.8 UJ  <80.0  <80  10.7 UJ
C0l'per 47.9  <40.0 I 0.97 lIJ 23.8 UJ <40.0 J 24.S UJ  <40.0 J <40 Q0 
Iron 253   <100 <0.50 J ~  <100  26.1 UJ  < IlJO  ~  45.9 UJ
I.~d I.S SO  < 1.0 <0.10 J < 1.0 J < 1.0 J <1.0 I  J.J J < 1.0  < 1.0 
Silver 9.7 SO CEO 0.26 UJ 6.4 UI < 70.0 J J.5 U.J 176~ ~  5.7 UI
Zinc 66.7  <60.0 0.94 lIJ 8.9 UI <60.0  6.6 UJ  <60.0  <60.0  40.4 
Flouride (Oilt) O.SH 4 ' NA NA   NA  NA  NA   NA  NA  0.456 
Fluuride (Elecl) 0:514 4 0.449 0.416  10.6481  10.SH I  0.450   0.498  0.413  0.J94 
Nilrete.Nitrite 0.187 10 0.200 0.022  ~  0.075  0.076   0.09  ~  0.098 
NS = No I8mple collected..                   
N A = No Inalyaia.                    
NR = No! reported.                    
Dell qualifiefl Ire provided in Appcndia Q.                 
B Value i. above blcklround concentration..                
Value exceedl Safe Drinking Wiler Ad (42 U.S.C. JOQ(f) d scq.1 Mllimum Contlinment level. (MClI) or Enforcement Siandardl (I. NR 140.10 Wilc. Admin. Code)
805KOlIlERRI(lablca)l2/balrock. wk I                  
                   GERAGHTY c:.1' MILLElt INC.

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Table 2.. Detected ConstitUentS from Pha-se I Leachate Samples.
  Sample Numbers 
Parameter KL-LS01-01 KL-LSOlDP-DUP KL-LS02-01 KL-LS03-Q1
VQCs (/Lgll)    
Vinyl Chloride <10 4 J 31 32
T nms-l ,2 - Dichloroethene <5 7 23 38
T richloroethene <5 3 J 1 J 2
Inor~anic (/LglL)    
Aluminum 2,720 80 1,810 315
..o\ntimony 11 <1.4 <1.4 <1.4
Arsenic 1.9 <1.4 2 2.1
Barium 91 31 62 40
Cadmium 2 <1.9 <1.9 <1.9
Calcium 397,000 159,000 627,000 587,000
Chromium 11 <4.4 8 5
Copper 53 <12 23 17
Iron 4,760 137 21.500 14,000
Lead 57 <1.1 36 12
Magnesium 62,900 42,400 50,200 46,900
Manganese 448 7S 1,040 966
Nickel 18 <18 <18 <18
Potassium 28,000 17 ,000 22,000 24,000
Silver 6.7 <6.7 <6.7 <6.7
Sodium 256,000 127,000 26,600 230,000
Zinc 92 <4.3 235 120
Hardness (mg CaC031L) 1,250 572 1,772 1,659
J - Estimated Value.    
1000000Cl'llcacharc. wit!    
   \ 

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Table ~.
Acute Toxicily SlIInlll"ry
TOlicity Summaries for Constituents of Co!!cern, Koh!er Cumj}:my Landfill, Kohler, Wiscunsin.
Constituent
Chronic Toxicity
Summary
Other
Cnllcer "otential
Page I of t8
~
Benzene
2-Butanone
Carbon disulfide
Central nervous system
(CNS) depression marlced
by dizziness, nausea,
headache, staggering,
narcosis, coma, and death.
Nonlethal effects are
reversible.
Irritation of eyes and
relpiratory rassages,
headaches, dizziness, and
vomiting.
" Acute elposure resllils in
dizziness, headaches, poor
sleep, fatigue, nervousness,
anorelia, weight loss,
psychosis, polyneuritis,
Parkinson-like symrtoms,
ocular changes, IInti cardio-
vascular and gastrointestinal
abnonnalities.
Chronic elposurcs aff«t the
hematological and immune
systems. Aplastic anemia,
increased susceptihility to
inf«linn, and bone marrow
depression reported.
Chronic data are lacking.
Suhchronic data indicate low
tnxicity: liver enzyme
changes, organ weight
changes, body weight
changes, nerve conduction
velocity changes at high
doses in rats.
Chronic elposure resulls in
polyneuritis including lower
eltremity weaJc:ness and
paresthesill!!. In dogs,
lesions of the corpor-
atslriatll, Purkinje cells of
the cerebellum, and loss of
anlerinr hum cells of the
srinal cnrd have heen
demonstrated. Chronic
eJlposure 10 fumes resnlled
in damage to the optic
nerve.
Benzene inhalation has been
associated with leukemia.
Benzene has rroduced both
solid tUlllors and leulcemiu
in rals dosed orally.
No evidence.
NCI carcinogenicity study
resulls inconclusive.
Benzene (and metabolites)
cause chromosome
aberrations in humans IIId
animals but ra,-ely ruull in
gene mutations.
One study cnncludod th~t 2-
bulanone is embryotoJlic,
felotoJlic, and potentially
teratogenic in high doses in
rats. 2-Butllllonc pntentialCS
hepatol ic cHects of
halOilkanes IInd halolllkcnes.
Teratogenic in mts and mice
dosed by inhalation.

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Tlble 3.
Toxicily Summaries ~or Consliluenls of Concern. Kohler Company Landfill, Kohler, Wisconsin.
Constituent
Acute Toxidty Summary
Page 2 of 18
Chronic Toxicity
Slunmnry
CUllcer Potential
Olher
Chlorobenz.ene
'nhaillion caposure. results
in respiralory and eye
irrilltion, IInd CNS
depression (sedation and
nlrcosis), necrosis of the
liver, interference wilh
porphyrin meubolism. and
IWeIling of I~bular and
glomendar epithelill.
Chloroetbane
CNS Ind cardiac
depression, and nausea al
higb inhalalion doses
(>20,000 ppm). Has
clused death in hUlllans
when used IS IIn anesthelic.
MIY 1180 iniule eyes and
skin. . Kidney and liver
effecls reported in animals.
I,I-Dichloroelbane
HiSb elposure resulls in
C,",S depression (drowsi-
ncss, unconsciousness, elc.)
and skin irriulion. Oral
LD. (rals) of 72S mgllcg.
Chronic elposure 10 vapors
may cause hlood dyscrasia,
hyperlipidemil, and cardiac
dysfunction in humans.
Liver and kidney damage
have been observed in
. laboralory animals.
No non-cancer effecls
~ported in 2-year Itudy of
rals exposaJlo IS,OOO ppm.
Mild kidney effecls and
hyperaclivity reported in
mice elposed 10 tS,OOO ppm
for 2 years. One report of
narcolic use. in humans
indica led cerebellar
dysfunclion whicll was
reversible.
Kidney and liver damage
observed in animals exposed
10 high concenlralions.
Some evidence of
hepalotolicily in hUmans.
Statislically significant
increase in Ihe incidence of
ncoplastic nodules of the
liver in high dosed (120
109/kg/day) male rals. No
increlsed incidence })f'
hepntocellular carcinomas
were observed in Ihe male
rals.
Recently compleled
inhalation atudy rcputed
significant increase in
ulerine Cltrcinomas and
bepalocellular carcinomas in
female mice. Equivocal
evidence in rats for
carcinogen icily . Equivocal
evidence for genololic
effexts. No evidence for
reproductive or develop-
menial effects.
NCI bioassay inconclusive
for laboralory animals. No
epidemiological evidence in
humans.
Nol nlllingenie in Ames
lSSIy, but has shown
reverse mutalions' in
SlrePtococcus !!ntibolj~
and hmiuil!Ui nodulans.
No observed tl~lIIlogenic
effects in high dosed
pregnant rats and IIIhbils.
Not mUlagenic in Ames
assay. Inhalation of high
doses (> 16,000 mg/m)
caused retarded felal
developmenl in 181s.
GERAGBTY c.,f' MILLU( INt'.

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Table 3.
To)(icity Summaries for Consliluenls of Concern, Kohler Company Landfill. Kohler, Wisconsin.
rug!: J of 18
Conslilurnl
Acule Toxicily Summary
Olhl'l'"
Chronic Toxicily
SWlImnry
Canrer Polrnlial
1,2-0ichloroethane
Inhalation causes irrilalion
of I mucous membranes,
headache, diuj~. ~....~.
vomilin~, abdominal paint
and liver and ~idhey
ciYsfunction. E)(pm'ure via
inhalalion for I hour 10
4,000 ppm has' relt1llled in
leukocytosis. Oral LD.
(rail) 670 mglkg.
I,I-Oicbloroelhene
Acute elposure 10 high
dOlel causes CNS
depression. Did nut appear
10 be leralogenic bul caused
embryolo)(icilY and
hlOlo)(icily when
adminislered 10 rals and
rabbill by inhalalion. Oral
LO. (rats) 200 mglkg.
c-I,2-0ichloroelheno
CNS depression, nausea,
rally liver, Ind transienl
renallo)(icily. Also irritales
litia and mucous
membranes.
t-I,2-0ichloroetheno
High concenlralions have
anesthelic properties a8 a
resull of CNS depressiun.
Irritalion of eyes and
respiralory syslem.
Worker elposure for 2 10 5
monlhs resulled in CNS
dep",.,I.~h, "I~!d,. .1~4
vomilin,. however. workera
rccover~ wilen removed
from e)(posure.
Chrunic elposure to oral
doses as low u S mglkg/day
caused liver changes in rals.
Neuroloxicily hu nol been
demonslrated in sludies
involving low-level chronic
elposures.
No data available for
chronic elposures. Liver
and kidney effects likely.
Repealed elposure via
inhalation 10 800 mg/m'
reportedly produced faUy
degeneralion of the liver in
rail. Possible inleraction
with hepatic drug-
metabolizing lIIono-
olygenase liyslem.
Induces a variety of tumors
in rals and mice. No
'f>ide""9.loglc evidence of
cancer in buman..
Caused kidney lumors (in
males only) and leukemia in
one sludy of mice expos«l
by inhalstion, butlhe results
of other liludics were
equivocal or negalive.
lias nol yet been studied for
carcinogenicily.
No dala available.
MUlagenic in haclerial an,1
insect test liyslcms.
/
MUlagenic in
baclerial assays.
several
Mutagenic and genotolic
effecll reported in mice.
Nol mutagenic in assay
using E.... coli. Salmunell.,
or mouse: bone-manuw
cells.

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Table 3.
TOllicity Summaries for Consliluenls of Concern, Kohler Company Landfill, Kohler, Wisconsin.
Constituent
Acute Toxicity Summary
PHgC 4 of 18
Chmnic Toxicity
Summary
Cancer Potentiol
Dlher
Ethylbenr.ene
No effects in humans at
inhalation concentralions of
100 rrm. Ellrosure to
higher level. causes
.'eepiness, faligue,
headache, and mild eye and
respiratory irrila,tion.
4-Melhyl-2-pentanone
Headaches, nausea,
vomiting, and eye irritation
at air concenlralions of 200
to 2,000 mg/m'.
, Toluene
CNS df«'Cls such u:
fati,ue, weakneu,
confusion, euphoria,
dizzineu, headlehe,
in.omnia, muscular
weakne.., and
incOordination have heen
rerorted.
Increases in liver and kidney
weights and cloudiness and
swelling of heratoeyles and
renal lubular epilhelium of
rals orally dosed for 6
monlhs.
Kidney damage observed in
rals e1rosed via inhalalion
al 400 mg/m'. Damage
appeared 10 be reversible.
Chronic eltposure 10 vapor.
at 200 to 800 prm are
assClcialed wilh disturbances
in memory and rsycho-
mol or skills. Cerebral and
cerebellar dysfunclion
rerorted in chronic abusers
of loluene, u well u
hepalic' and renal funclion
changes. Oral
adminislration 10 mice at
doses of 260 mglkg has
increased embryonic
lethalilYi 434 mglkg has
decreased fetal weighti and
861 mglkg bas increased
incidence of cleft palale.
No dilla availahle from NCI
biullSssy.
No dala available.
No evidence
carcinogenicity.
Nol milia genic in assays
using ~~~!
u..JL.hl1!l!!.Li..!uD . n d
Saccharomyces ccrvisiue.
./
of
Not reported as genololtic or
teratogenic 10 humans.

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Table 3.
TOlicily Summaric:a for Consliluenls of Concern. Kohler Company landfill. Kohler, Wisconsin.
Page 5 of 18
Conslituent
Acute Toxicity Summary
Olht.T
Chnmic Toxicity
Summary
CunCtT I'olenlial
1.1.1- Trichloroelhane
Depression of Ihe CNS is
the primary tOlic effect in
humans elposed 10 high
level. via inhalalilln. Acule.
hig~-Ievel elposures can
advenely arrecl Ihe
cardiovllcular syslem.
Accidental ingeslion results
in CNS depression and
gaslrointestinal Upsel. 11 is
irritating 10 skin; liquid ClAn
be absorbed through Ihe
skin. Acule elposures
indicate Ih.t this compound
i. relitively non-tolic. aside
from CNS effecls. TIle oral
LD. (nil) is aoolll 11,000
milk,.
Long-Ienn inhalalion sludies
in animals resulled in liver
chllnges. Occupational
sludies did nol indicale any
slalislically significant
eff.:cls after prolonged
inhalalion elposures. It
appears 10 be no more IOlic
upon long-Ienn elposure
Ihan acule elposure. Large
oral doses given to lesl
animals over a 78-wco:k
period indicated little
apparent histopathological
chango in any organ.
Recenl NTP IIludy
inconclusive. l:vidc:nce IIf
human carcinogen icily.
EClllivocal evidence IIf
mutagenicity from bacterial
assays.
r':n~r""r'" r',."" ,-t, ..1"-''''

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Table 3.
Toxicily Summaries (or Consliluenls of Concern, Kohler Company Landfill, Kohler, Wisconsin.
Pugo: 6 of 18
Consliluenl
Acule Toxicily Summary
Olher
Chronic Toxicily
Summary
Cancer POlenlial
Trichloroethene.
Exposure resullS in CNS
depression which is
demonstrlted by dizziness,
headache, visual
disturbances, incoordination
(iimilar to that induced by
alcobol), tremors,
sleepiness, nausea,. and
vomiting. Cudiac
arrhythmias and dC4lh due
10 ventricular fibrillation and
cardiac arrest rrom acute
cxposurubove IS,OOOppm.
Accidental ingeslion or
aboul I SO ml resulted in
acute kidney failure and
liver and cardiovascular
damase. Local exposure 10
vapon may cause irrilation
10 eyes, nose, and Ihroat.
Oral LD. (rlls) of aOOul
1,200 mgllcg.
Vinyl chloride
AI ~igh levels CNS errt:Cls
occur including dizziness,
headaches, euphoria,
narcosis, and dealh. L.ower
doses hive resullc:d in
alaxia, con (lest ion and
edema in lungs, and
byperemil in Jiver.
I
Prolonged occupalional
uposure 10 vapors (200 10
400 ppm) resulted in CNS
symploms including
headache, dizziness, nausea,
Iremors, slcqtiness, rilligue,
and vomiling. These
symploms were reversible.
Lower elllOsures (100 10
200 ppm) 10 humans
resulted in biochemical
changes in liver funclion.
In test animals, chronic
exposure induces low to
moderlle liver and kidney
loxicity. Prolonged
inhalalion exposures 10 test
animals al levels grealer
IhlD 2,000 mg/m' resulted
in renal 10licity,
hepalololicily, and
neurolmlicily.
Chronic h)licilY symploms
or workers include
hepatotoxicilY,
acroolileolYllis, CNS
disturbances, pulmonary
insufficiency, cardiovascular
toxicity, and gastrointestinal
tOlicily.
IIIIS prodncetl an increase in
heplacellular carcinomas in
mice afler oral
adminislndion. Olher leslS
wilh mice and rals have
produced nc:galive rc:sull{.
Epidemiological duta are
inconclusive.
Livo:r angiosarcomas as well
as tumors of the brlin, lung,
henudopoielic lissues, and
Iymphopoielic lissues have
bc:en associated with
occupalional exposure.
Vinyl chloride is reponed 10
be cllrcinogenic in rl18,
mice, and hamsters.
Mutagenic
assays.
In
hllclerial
MUlagenic in haclerial and
mammalian cellular assays.
Equivocal evidence of
possible lerlllogc:nic or
reproduclive dfo.:ts.
r.r.UI\r.IITV.c...~~" 1 I:D "IF'

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Table 3.
Toxicily Summaries for Consliluenls of Concern, Kohler Company Landfill, Kohler, Wisconsin.
Page: 7 of III
Consliluenl
Olher
Acule Toxicily Summnry
Chronic Toxicily
Summary
Cuncer I"olenlial
Xylcncs
Semi- YOCs
BUlylbcnzylphthalalo
4-cb1oro-J-melhylpheaol
Di-n-OClyl phthalalo
2,4-Dimethylphcnol
CNS dislurbances 8nd
irrilalion of mucoul
membnnes occur following
aculo elposure.
No evidence.
Low aculo lox icily in mice,
wilh oral and inlraperiloneal
LD. "Ilucs of 6.S and 65
mglks, respeclively. Eyo
md din irrilanl.
Chronic inh81alion exposure
of rlls II J,SOO mg/mJ
resulled in slighl ren81
lubular degeneralion.
Xylene ia nol leralogenic,
bUI has Clused felololicily
in Oils ~d mice.
Decreased body weighl in
nisi also lesticular lesions,
and increased liver weighla.
Very liUle loxicily data are
IVlilable. Possible lelhll
dose in Ihe range of 50 10
500 mgllcg.
A chronic lD. value of 1.3
mglks waa determinod for
mice injecled
inlnpcriloneally.
Oral NTP siudy, while nol
finalized, indicaled xylenell
do nol 8ppear 10 be
carcinogenic in rala.
In rals, an increase in
mononuclear cell leukemia
or lymphoma hu been
observed.
Reported .5 non-irritaling 10
Ihe skin 81 0.5 10 1.0
percenl in alcohol.
No evidence.
Possible
carcinogen.
lopical
Nol mulagenic in Ihe Ames
10111 or olher ahorl-lorm in-
vilro 1811YII.
No dala Iv.ilable.
Some evidence of
fololoxicily .nd
Ibnormllilies in nil
following inlr1lterilonelll
injections.
co-
r.r-:o ArlIT" C";J" All' ,.., ... 1,.--

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Table 3.
TOlicity Summaries (or Constituents of Concern, Kohler Company landfill, Kohler, Wisconsin.
Page 8 of 18
Constituent
Acute Toxicity Summury
Chronic Toxicity
Siunmary
Cancer Potential
o liter
2-Methylphenol
4-Melhylphenol
Phenanthrene
Phenol
Tissue hums, followed hy
1058 of feeling. When
absorbed into the body,
tOlie effects may develop in
30 minutes. These effects
include weakneu of
mUlcles, headache,
dizziness, impa;r",1 vision,
npid breathing and possible
death.
Very litlle data aVlillble.
Phenol i. very tOlic. The
probable human oral lethal
d~ is 50 to 500 mglkg.
These lethal amounls may
be absorbed via skin or
. inhaled. Rals, however,
elpOsed 10 780 mg/kg/day
of phenol in the drinking
Wiler have survived I 90-
day elposure period. Skin
elposure may be followed
by Dumbness. Oral
elposure signs include
IOnorotI. brealhing and
(rolhing It Ihe moulh and
DOse.
Skin irritalion, and chronic
poisoning 10 the skin,
mucous membranes, or
respiratory tract. Symploms
of chronic poisoning include
vomiting, difficully in
Iwallowing, ulivalion,
diarrhea, loss of appetite,
fainting, meDtal
dislurbances, and Ikiu r&.sh.
Photosensitization of skin.
Acute toxicity is elpected 10
he low.
lIepalic and kidney diseases
are genenlly aggnvated by
elposure to phenol. Other
symptoms include burning in
the moulh and throllt,
blOOt.ly diarrhea, pallor,
sweating, headache,
diuiness, hhock, ringing in
the ean, and drop in body
lempenture.
No evidence.
Epolide has produced
mUlagenic and lumorigenic
responses.
Under review by USEPA.
Some evidence of
(etotOlicily. Phenol
administered 10 pregnlnt
nts at doses of 120
mg/kg/day causes decrease
in felal botJy weight.
GERAGIITY f.j Mil I t:1~ '1\]('

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Table 3.
TOJdcity Summaries for Constituenls uf Cllncern, Kohler Company Landfill, Kohler, Wiscunsin.
Page 9 o( III
Constituent
Olher-
Acule Toxicity Summury
Chronic Toxicily
Summary
Cant't~r Potential
Pyrene
Inonlanics
Aluminum
Antimony
Arsenic
Very liule data availahle.
Acute tOlicity is elpecled 10
be low.
Bindins of phosphorus in
the ~nteslinal tnct may lead
to phosphate dcpldion and
osteomalacia. Ingestion of
hiSh concentrations may
rcsuJl in constipation.
Vomiting. walery lIi.nhea.
irresular breathing. lowered
body temperature, and death
can occur in humans
foUowinS acute oral
elposure.
Insestion of sufficienl level
can result in bUnling and
dryness of Ihe oral and 118581
cavities, sastrointestinal
dilturbance, vertigo,
delirium. coma. and death.
Fally liver and enlarged
liver.
Relationship between
aluminum and Allheimer's
disease in humans has been
suggested .
Cardiovascular damage has
bten observed in humans
and laboratory animals.
Pnc:umoconiosi. and
dermatitis have occuITCd in
humans following inhal.tion
and dermal exposurc.
respectively.
Occupationlll and ingcstion
cxposure have caused
progressive polyneuropalhy
(OOlh molor and SCllsory) in
humans, cspccililly in Ihe
extremities.
Nil evidence
No evidence.
The Irillxide has been
associated with lung cancer
(in humans and rats), but it
is not classified 18 a
ruh:nlial carcinogen.
Lung Ind skin cancer hive
been IIhserved in humans.
Was not mUhlgc:nic in must
aS5lYs.
/
MUlagenic in sume hlclerilll
test systems. May cause
reproductive effCClu in
females occupatiohlllly
OJ pu5OO.
Chromosomal .hcrralions
have been observed in
humans and laboniliry
animals. CIIUSCS birth
defects anll reproductive
effects in laboratory aniffillis
and pcrhars in humans when
el(JOscd occup8tion.lly.
,......- '"' . ,..... .,........ '''', . ... . . .

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Table 3.
Toxicity Summariea for CODstituents of Concern, Kohler Company Landfill, Kohler, Wisconsin.
Pllge 10 of 18
Conslituenl
Other
Acute Toxicily Summary
Chronic Toxicity
Summary
Cancer Potmtinl
Barium
Beryllium
Raro occurrence hul
inlestion of soluble barium
18118 hili produced
gastroen.eritis, muscular
paralysis, decreased pulse
nto, vascular cons'riction,
aDd ventricular fibrillation.
Potassium deficiency may
also occur. Alkaline
compounds irritate eyes,
nose, thma., and skin.
Inhalalion can cause rhinitis,
pharyngitia, tncheo-
bronchitia, and acute
pneumoni.is. Dennal con-
lact can cause del1l1ll.i.is.
Tho conjunctiva of the eyo
is allO eensitive.
Inhalation of dust may
produce a benign
pneumoconiosis (baritosis)
which is reversible.
Chronic eaposure can calise
granuloma.ous lung inflam-
ma.ion with cough, chest
. pain, and weakneaa. O.her
effec.s include liver and
aplcen enlargement,
cyanosis, digil8l clubbing,
and kidney stones.
No evidence.
RelMlrtcd to cause cancer in
several labora'ory animal
species; may also cause
cancer in hUIDalls.
Evidence: of genetic damage
is equivocal.
GERAGHTY co? MIIJ.FR.INC

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Table 3.
TOllcity Summaries for Conslituenls of Concern, Kohler Company Landfill, Kohler, Wiscons.in.
Pug.: II of 18
Constituent
Oilier
Acute Toxicily Summary
Chronic Toxicily
Summary
Cancer Polenlial
Cadmium
Chromium
Nauaea, vomiling, diarrhea,
muscular cramps, salivalion,
sensory dislurbances, liver
injury, conwlsions, shock,
renal failure, cardio-
pulmonary depression, and
death can occur in humans
following oJtposuro 10
aufficienl quanlilies of
cadmium.
Occupational elposure 10
holtlvalent chromium (Cr
VI) compounds causes
dormalili., haud and
forearm ulcers, and
perfonlion of nasal tiCptum.
Trivalenl chromium (Cr III)
ia much less 10Jtic; Ihe Inain
effect is contacl dermalilis
in lUSCeplible individuals.
Renal dysfunclion has been
observed in both humans
and laboralory animals
following elposure 10
cadmium. Immuno-
.uppression ha. been
observed in laboralory
animals. Anemia,
oSleomalacia, oSleoporosis,
and pulmonary disease have
been observed in bumans
following long-Ierm
elposure 10 cadmium. The
endocrine and lensory
syslems may also be largels
of cadmium 10licity.
t.by damage liver, kidney,
and respiratory system.
Canecr has been observed in
labonlory animals elposed
10 cUllmium by inhalalion
and injeclion. lbis is )Kff
Ihoughl 10 be relevanl to
oral exposure.
Certain salls of Cr VI arc
carcinogenic in rats.
Epidemiologic sludies have
reporled an increlled
incidence in lung cancer in
workers occupalioDally
OJtpClSed 10 Cr VI (u
cbromic acid or chromale).
Cadmium may impair DNA
repair, bUI probably is not
direclly mutagenic.
Reprooudivc irnlJlimll:fl1
has been ohserved in
laboralory Imimals.
Trace amounl of Cr III are
essential for cartlOhydrale
melabolism in mammals.
Cr VI is mutagenic.
Embryolol ic and ler.logenie
effecta OCCur in mice and
bamslers.

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Tlblo 3.
TOllicity Summaries ror Constituents of Concern, Kohler Company Landfill, Kohler, Wisconsin.
Cons'ituen.
Acu'e Toxicily Summary
Chnlllic Toxicily
Summary
Pugc 12 of 18
Cancer J'olenlial
Olher
Cobalt
Copper
Therapeutic admillistrution
o( clcessive 111IOIInt8 was
reported to produce
vomiting, dianhea, and 1
SOIsation of wanllth in
humans. Oral LDJO of
I,SOO mglkg in thc rat.
Inhllation of dust CIlII cause
ahort-term chills, (ever,
headache, aching muscles,
and dryness of mouth and
throat. Inhalation of fumes
can cause irritation of the
upper rapiratory tracI, I
metallic t88to, nausea,
metallic fume fever, and
discoloration of skin and
hair. Ingcstion of high
lovel. can causc ClCesS
salivation, nausea, vomiting,
dianhea, and glStritis;
extremely high levels can
CIUse hemolysis, liver
damase, gastrointcstinal
blcediDS, convulsions, and
death.
Children receiving between
I and 6 mg per day IS
trc:JItnh:nt (or anemia have
experienced soiter and
decreased Ihyroid function,
increased heart and
respiration ratcs, and blood
lipid chllngcs.
May result in anemia.
Nil evidence
carcinogenicity
aigni fieant routes
elposure.
Nu evidence of
carcinugenicity in animals or
humans for oral or
inhalation routes of
exposure:.
of
via
of
Limited duta suggest Ih.1
cobalt chloride has
mutagenic aClivity.
No evidence: of mulagenic
effects or birth defcels in
humans or laboratory
animals.
GERAGHTY & MILU:/(.INC

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Table 3.
TOlicily Summaries for Consliluenls of Cuncern, Kohler Company landfill, Kohler, Wiscoosin.
Pa1:e 13 of I H
Constituent
Oliler'
Acute Toxicity Summary
Chronic Toxicity
Summary
Cancer Polential
Fluoride
Iron
Fluoride exhibils cilleillm-
bincliD, effects which elhibil
IYmptoms such IS vomiling,
abdominal pain, nausea, and
di~rrbea. followed by
pareslbesias, hyperaclive
refle.ea, and tonic and
clonic conwlsions. Dealh
from respintory parillysis or
cardiac failure may resull.
Inseation of >0.5 gnms
relulll in tOlicity:
vomilinS, ulceralion of
,lSlrointeslinal Incl, liver
dama.e, and kidney failure.
Cunlrollcd liludics wilh
recommended levels of
added fluoridc have shown
no adverse effecls. Adverse
effocls, clcepl in rare cases,
have not been reporled in
waler conlaining fluoride
unlil Ihe concenlralion is
many limea Ihal
recommended for Irlificilll
fluoridation.
Imn overload can occur
when body iron conlenl is
increased S 10 10 limes due
10 increased ablOrplion or
diclary inlake. Clinical
sians include liver function
and endocrine disturbances,
diabetes, and cardiovascullr
erfocls. Pneumoconiosis
reporlcd in workers elposed
10 > 10 mg/m'.
EquivIlCll1 rc:sulls were
oblainod in a recenl NTP
bioassay using sodium
fluoride in rodenb.
No evidence.
.'
Iron ill an essenlial metal.
rrnAlr'I,m,' {"'.'I' I ,.,-, ,.""

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Tablo 3.
TOlicil, Summaries ,or Constituents of Concern, Kohler Company Landfill, Kohler, Wisconsin.
Plige 14 uf 18
Constituent
Acute TOlicity Summary
I
Chronic Toxicity
Summary
Cancer rotential
Other
Lad
Manganese
Lead is primarily a chronic
lOllia. OrglRolead
compounds are more lCut.:ly
IOllic Ihan inorganic
compounds. A rev.:rsible
renal tubular dysfunction has
beea reported in children
acutely exposed 10 inorganic
lead. Blood lead
concenlrations associaled
with renal effecls and brain
damap range from about 80
10 100 I'g/dLi dc:llh has
boeD reported al
coac:cnlralions > 125 pg/dl.
Blood levels grealer Iban 10
p,felL have been associaled
with premature birth, low
birlb weight, and
aeurobchavioral effects.
Inhalalion exposure 10 high
I
levols of manganese dUSls
can cause mangsnese
pneumonitis, increased
susceptibilily 10 respiratory
disease, and proliferation of
mODoauclear cells in
bUIDIDI.
Chronic exposure via
ingestion or inhalalion can
result in brain
encephalopalhy, permanenl
brain damage, peripheral
neuropalhies, and permanent
kidney damage. Low-level
chronic exposure can resull
in learning disabilities and
anemia duo to a reduclion 10
Ihe life span of cireulilling
r~ bloud cells, and can also
resull in a reduclion of Ihe
biologically aclive .form of
Vilamin D.
Liver dysfunclion and CNS
degeneralion can result from
chronic exposure, causing
emotional dislurbances,
mask-like face, and
Parkinson's-like syndrome
in hUmans.
A dose-dependenl increase
in renal lumors has been
reported in rals dosed al 500
102,000 ppm of lead IC«;lale
in Ihe diel.
No evidence uf
carcinogen icily in hUmans.
Direct injeclions of
manganesc
-------
Table ,.
TOlicity Summaries for Constiluenls or Concern, Kohler Company Landfill, Kohler, Wisconsin.
Page 15 tlf 18
Comlituenl
Acule Toxicily Summary
Other
Chronic Toxicity
Swnmary
Cancer Potenlial
Magnesium
Ma8flcsium olide dusl can
irritate tho eyes and
respiratory tract. Ing~lion
of larse amounts of
mapesium salts results ill a
lualive effect.
Nickel
Acuto effects of nickel
carbonyl inhalalion include
both immediate and delayed
symptoms includinS
chemical pneumonilis. Oral
tOlicily i. low. Dermal
lensitization hIS been
demonstraled.
Nilralc-Nilrite
Methemoglobinemia in
infanll is caused by high
levell of nitrile, or
indirectly from nilrale, in
humlnl. Resulls of
difficulty in oxygen
traDsport have been
reported.
lotolicalion io humans via
ingeslion generally only
occurs in humans wilh
severe kidney disease.
Symptoms include sudden
drop in blood pressure and
respiratory paralysis due 10
CNS depression.
Chronic inhalalion can cause
rhinilis, nasal sinusilis, and
nasal mucosal injury in
hUlRln8. Oral tOlicity is
low.
II his been proposed Ihll
nilrale in waler may be
converted to N-nilrosos
compounds Ihat are
carcinogenic agenls.
No evidence o.r
carcilltlgenicily in laboralory
animals or humans.
Inhaillion of insoluble
nickel compounds is
associalct! wilh lung and
nll8l clvily clncer in
hUmlns and cancer in
laboralory animals.
Uigh concenlralions of
nitrale in Ihe drinkinS waler
have been associaled wilh
stonuch cancer, although
the findings are only
suggcslive.
No evidence of
mutagen icily, birth defoels,
or reproductive effc:ds.
Mutagenicity and chromo-
somal aberrations are caused
by IIC:veral forms of nickel.
Dilia indica Ie Ihal nickel can
cause reproduclive effects in
labohtory animals, bul bilth
defcels have nul beo:n
demonstraled .
GERAGHTY 8 MII.I.UC INC

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Table 3.
Toxicity Summariea for Constituents of Concern, Kohler Compauy landfill, Kohler, Wisconsin.
Constiluent
Page 16 of 18
Acute Toxicily Summary
I
Chronic Toxicily
Swnmary
Cancer POlenlial
Olher
Selenium
Acule effects are similar
acma species and rolltes
(oral, dermal, and
inhalation) and include
degeneralion of liver,
kidney, and myocardia,
di,eslive Iracl
hemOnbaging, . and brain
dama,e. Inhalalion
eXpoNre can 1150 cause eye,
nose, and throal irrililion.
Chronic lox icily is similar
across species and "onns of
selenium. EIJecis include
depression, nervousness,
dennalilis, gaslroinleslinal
disturhances, denial caries
and discoloralion, lassitude,
and loss of hair and nails.
TOlicily is associaled with
ingeslion of high levels of
selenium.
There is no evidence of
carrinngenicily in hUlnllns;
evidence from laboralory
animals lihillies is equivocal.
Recenl evidence suggesls
Ihat appropriale dosages. of
selenium may inhibil Ihe
occurrence of lumors.
Birlh defe:Cls and
repnkluclivc: effecls Ire:
suggesled by anecdotal
evidence from farm anilnllls,
but further Icsling is
necessary. Inadeqnate dala
are available (or predicting
mUlagenic potential.
GERAGI-ITY {,f' Mil I FI~ IN('

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Table 3.
TOlicity SUDUl1lries for Consliluents of Concern, Kohler Company Landfill, Kohler, Wisconsin.
I'lige 17 of 18
Comliluml
Olher
Acute Toxicily Summury
Chronic Toxicily
Summary
Cllnccr Polential
Silver
Sulfate
Largo oral doses call cUllse
violent abdominal Vlin.
vornilin,. convulsions, and
death. I
No chronic or acute adverse
re'ponles have been
reported fur conUlllrlllions
onso to 1.000 mg/L.
Eacessive ahsorption by Ihe
orul or inhalltion roUlei can
CIUse local or generalized
Irgyria (impregnltion of
tissues) in humans.
sometimes resulting in blue-
gray vigmentation of the
skin, hlir. internal orglllls.
and conjunctiva of the eye.
Lesions of the liver. kidney.
bone marrow, and lungs
hive .150 been reported in
humans. Hemorrhaging of
the kidneys, decreased
immunologic resistance.
growth depression. lowered
conditioned reftel activity,
and Vathologic changes in
the morphology of liver.
kidney. stomach. and lmall
intestine have been observed
in laboutory animlls
ellposcd to silver in their
drinking waler.
Silver is not known to CRUS«:
cancer by relevant routes of
elposure.
No evidence.
No significRnl IIIlIlRgenic or
teratogenic effects in
humans or Ilboralory
animals.
GERAGHTY 8 MII.U:n.INC

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T.ble 3.
TOlicily Summaries for Consliluenls of Concern, Kohler Company landfill, Kohler, Wisconsin.
I
I'lige 18 III" 18
Comliluenl
Acule Toxicily Summary
Olher
Chronic Toxicily
Summary .
Cllncer Polenlial
Vanadium
Acule exposure 10 vanadium
vi. bmal.lion can resull in
upper and lower n:spil'ltory
irril.tion with mucous
discbllle and bronchitis,
cOugh, bronchosp.sm, and
chest p.in. Ingestion can
c.ule gAStrointcstin.1
disturbancea and dislocation
of the or.1 mucosa .nd
10n8'"'.
Zinc
Ingestion of excessive
.mounts of zinc can cause
fever, vomiting, slomach
cramps, and diarrhe..
Enzymatic dysfunction is
common with long-Ierm
exposure.
Excessive dietary intake has
caused growth retardation,
hypochromic anemia, and
defective minel'llization of
bone in 18bol'llory animals.
Zinc is not thoughllo cause
cancer by relevant roules of
exposure.
No evidence of
mulagenicity ,tc:ratogenicity,
or reproductive effecls in
humans or anil'DJJls.
/
No data suggesl mutagenic
or teratogenic effects.
Referenc:ea: Constituent-specific docamenta from Asency for Toxic Subslances and Disease Registry (A TSDR), National Toxicology ProSl'lm (NTP) Technical
Reports, USBPA Health Bffecls Assessmenl Documents, Regislry of Toxic Effecls of Chemical Substances (RTECS), and 5.. and uwis (1984).
GERAGIITY {'? Mil I FI~ IN!'

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Table 4 Risk Estimation Summary, Kobler Company I..andfill. Source Control Feasibility 
Study, Kobler. Wiscol1SU1.    
  Excess Lifetime Hazard 
  Cancer Ri,skA In~ 
Non-Potable Ground Water    
Hypothetical Future Worker (Uncoasolidated Unit) 6 x 10--  0.10 
Hypothetical Future Worker (Shallow Bedrock Unit) 6 x 10--  0.030 
Hypothetical Future Worker (Deep Bedroc:k Unit) 1 x 10'1  0.030 
Potable Ground Water    
Imrestion: Amill fJWsI dsbW gu}sI
Hypothetical Future Resident (Unconsolidated Unit) 4 x 10') 2 X 10') 30 60
Hypothetical Future Residen1 (Shallow Bedrock Unit) S x 10') 2 x 10') 40 90
Hypothetical Future Resident (Deep Bedroclc Unit) lxlo-- 6 x 10" 60 100
~~ ~ QliliI ~ fJWsI
Hypothetical Future ResideDt (Ul1CODSOlidated Unit) lxl~ NE 2.0 NE
Hypothetical Future Residen1 (Shallow Bedrock Unit) lxl~ NE 1.0 NE
Hypothetical Future Resident (Deep Bedrock Unit) 3 x 10-- NE 0.020 NE
Leachate    
Current Worker 2 x 104  0.0060 
Current Trespasser 3 x 104  0.020 
Hypothetical Future Adult Resident 6x 1~  0.020 
Hypothetical Future Child Resident 2 x 10"'  0.20 
Surface Water    
  Amill gwa Amill guw
Swimming 1 x 10" S x 104 0.0020 0.0040
Fish Ingestion 2 x 104 2 x 104 0.30 1.0
a
An CXCCII lifetima CIIJIi:U risk nnge above 1 x 1~ is typically deemed "unacceptable" by reguiat.ory
apIICieL In 101IIII lite IpeCific ~ val.. above 1 x 104 are deemeci "UD8CCept&ble".
A Iwani index value Irea&a' tb.m 1 is typically deemeci "uuacc:eptable" by rep1atory ageaciea.
Not evaluated.
b
NE
GERAGHTY & MILLER.INC.

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    Page 1 of 2
Table 5.  Adult Resident RlSk Scenario. Unconsolidated Unit. Hypothetical Future Potable
 Ground-Water Exposure Doses (PGWExDs), Hazard QuotientS, and Excess
 Lifetime Cancer Risks , Kohler Company Landfill, Source Control Feasibility
 Study, Kohler, Wisconsin  
    Cancer Risk and
Constituent C,.. PGWExD Hazard Quotient
CANCER EFFECTS   
~   
Benzene 0.011 1.3E-04 3. 7E..()6
1,1- Dichloroethane 1.0 1.2E-02 NA
1 ,2-Dichloroethane. 0.024 2.8E-04 2.6E-oS
1,I-Dichloroethene 0.0045 S.3E-05 3.2E-05
Trichloroethene 1.7 2.0E-02 2.2E-04
Vinyl chloride 0.14 1. 6E-03 3.1E-03
Semi- VOCs   
Butylbenzylphthalate 0.0093 1.1E-04 NA
2-Methylphenol 0.041 4.8E-04 NA
4-Methylphenol 0.047 S.SE-04 NA
Inol'2anics   
Arsenic 0.0047 S .SE-oS 9. 7E-oS
Beryllium 0.0010 1.2E-05 5.0E-oS
Lead O.OIS 1.8E-04 NA
   ELCR 4E-03
Non-Cancer Effects   
~   
Benzene 0.011 3.0E-04 4.3E-ol
Carbon disulfide 0.0095 2.6E-04 2.6E-03
Chlorobenzene 0.018 4.9E-04 2.5E-02
ChJoroetbaDe 0.052 1.4B-m 3.6E-Q3
1, I-Dich1()1'lV'th!ln~ 1.0 2.7E-02 2.7E-Ql
1,2-Dichloroethane 0.024 6.6E-04 2.6E-03
1,1-Dichloroethene O.OO4S 1.2E-04 1.4E-Q2
1,2-Dichloroethene (total) 0.24 6.6E-03 6.6E-Ql
Ethylbenzene 0.0083 2.3E-04 2.3E-03
4-Methyl-2-penranone 0.012 3.3E-04 6.6E-03
Toluene 0.081 2.2E-03 1.1E-02
1,1,1- Trichloroetbanc 0.051 1.4E-Q3 1. 6E-02
Trichloroethene 1.7 4.7E-Q2 6.3E+00
Vinyl chloride 0.14 3.8E-03 3.0E+00
Xylene 0.029 . 7.9E-04 4.0E-04
GERAGHTY & MILLER. INC.

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Page 2 of 2
Adult Resident Risk Scenario. UncoDSolida~d Unit. Hypothetical Future Potable
Ground-Water Exposure Doses (pGWExDs) , Hazard Quotients. and Excess
Lifetime Cancer Risks. Kohler Company Landfill, Source Control Feasibility
Study, Kohler, Wisconsin
Table 5.
Constituent
PGWExD
C..
Cancer Risk and
Hazard Quotient
S,f,mi- VOCs
Butylbenzylphthalate
4-Chloro-3-methylphenol
2,4-Dimethylphenol
Dii-n-octyl phthalate
2-Methylphenol
4-Methylphenol
Phenol
Pyrene
Inon!anics
Aluminum
Antimony
AJ'senic
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Fluoride
Iron
Lead
M'lgnesium
Manganese
Nickel
Nitrate
Selenium
Silver
Sulfate
Vanadium
Zinc
  0.0093 2.5E-04 1.3E-()3
  0.015 4.1E-04 2.1E-04
  2.0 S .5E-()2 2.7E+OO
  0.0071 1.9E-04 9. 7E-()3
  0.041 1.1E-()3 2.2E-()2
  0.047 1.3E-()3 2.6E-()2
  0.015 4.1E-04 6.8E-04
  0.0030 8.2E-()5 2.7E-()3
  1.1 3. OE-02 NA
  0.14 3.8E-()3 9.6E+00
  0.0047 1.3E-04 1.3E-() 1
  0.065 1. SE-()3 2.5E-()2
  0.0010 2.1£-()5 S .5E-()3
  0.010 2.1£-04 S .5E-() 1
  0.033 9. OE-04 1. 8E-o 1
  0.040 1.1E-()3 NA
  0.066 I.SE-()3 NA
  3.2 8.8E-02 1.5E+00
  0.33 9.0E-03 NA
  0.015 4.1E-04 NA
 62  l.7E+OO NA
 0.35 9. 6E-()3 9.6E-02
 0.073 2.0E-()3 1. OE-() 1
 170  4.1£+00 NA
 0.0020 5.SE~ 1.8E-02
. . 0.016 4.4E-04 1.SE.{)1
 370 1.0E+Ol NA
 0.075 2.1E-()3 2.9E'{) 1 
 0.065 1. 8E-()3 8.9E-()3
   m 3E+Ol
C... Ground-water concentration (mglL).
ELCR Excess lifetime cancer risk (sum of cancer risks [pGWExD x CSF] see Table R-ll).
HI Hazard index (sum of the hazard quotients [pGWExDIRfDJ see Table R-ll).
PGWExD Potable ground water exposme dose -(mglkglday).
NA No USEPA-verified toxicity values available to estimate risk.
GERAGHTY & MILLER.INC.

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    Page ~ of 2
Table 6. Adult Resident Risk Scenario. Shallow Bedrock Unit. Hypothetical Future
 Potable Ground Water Exposure Doses (pGWExDs) , Hazard QuotientS, and
 Excess Lifetime Cancer Risks, Kohler Company Landfill, Source Control
 Feasibility Study, Kohler, Wisconsin  
    Cancer Risk and 
Constituent Cp PGWExD Hazard Quotient 
CANCER EFFECTS    
~    
1,1-Dichlo~~e 0.0094 1.1E-D4 NA 
I, 1-Dichlo~thene 0.0027 3.2E-05 1.9E-05 
Trichloroethene 0.12 1.4E-03 1.5E-05 
Vinyl chloride 0.20 2.3E-03 4.5E-03 
Ino~anics    
Arsenic 0.0032 3.8E-05 6.6E-05 
Beryllium 0.0024 2.8E-05 1.2E-D4 
Lead 0.0012 1.4E-05 NA 
   ELCR SE-03 
NON-CANCER EFFECTS    
~    
Chlorobenzene 0.0020 5.SE-05 2. 7E-03 
Chlo~thane 0.0020 5.5E-05 1.4E-D4 
1,I-Dichloroeth2u1e 0.0094 2.6E-D4 2.6E-03 
I, 1-Dichlo~thene 0.0027 7.4E-05 8.2E-03 
1,2-Dichlo~thene (total) 0.59 1. 6E-02 1.6E+OO 
Trichlo~thene .0.12 3.3E-03 4.4E-01 
Vinyl chloride 0.20 5.5E-03 4.2E+OO 
Semi- VOCs.    
Phenol 0.0015 4~ lE-05 6.8E-05 ---- - -
Pyrene 0.0030 8.2E-05 2. 7E-03 
Inol"2anics    
Aluminum 0.93 2.SE-02 NA 
Antimony 0.41 1.1E-02 2.8E+01 
Arsenic 0.0032 8.8E-05 8.8E-02 
Barium 0.17 4.7E-03 6. 7E-02 
Beryllium 0.0024 6.6E-05 1.3E-02 
Cadmium 0.024 6.6E-04 1.3E+OO 
Chromium 0.040 1.lE-03 2.2E-Ol 
GERAGHTY & MILLER. INC.

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Table o.
Page 2 of 2
Adult Resident Risk Scenario, Shallow Bedrock Unit, Hypothetical Future
Potable Ground Water Exposure Doses (PGWExDs) , Hazard Quotients, and
Excess Lifetime Cancer Risks, Kohler Company Landfill, Source Control
Feasibility Study, Kohler, Wisconsin.
Constituent
Crr
PGWExD
Cancer Risk and
Hazard Quotient
Inonlanics (cont.)
Cobalt
Copper
Fluoride
Iron
Lead
Magnesium
Manganese
Nickel
Nitrate-Nitrite
Silver
Sulfate
Vanadium
Zinc
\ 0.21 5. 8E-Q3 NA
 O.OSO 1.4E-Q3 NA
 O.Sl 1.4E-Q2 2.3E-o 1
 0.46 1.3E-02 NA
 0.0012 3.3E-oS NA
 60 1.6E+00 NA
 0.14 3. 8E-Q3 3.8E-Q2
 O.lS 4.1E-Q3 2.1E-01
 91 2.SE+OO NA
 0.066 1.8E-03 6.0E-ol
 230 6.3E+OO NA
 0.30 8.2E-03 l.2E+OO
 0.044 1.2E-03 6.0E-03
  m 4E+01
-

C,.. Ground-water concentration (mg/L). .
ELCR Excess lifetime cancer risk (sum of cancer risks [pGWExD x CSF] see Table R-ll).
HI Hazard index (sum of the hazard quotients [pGWExD/RfDJ see Table R-ll).
PGWExD Potable ground water exposure dose (mg/kgIday).
NA No USEPA-verified toxicity values available to estimate risk.
---- --. - --- ..- -..-. -
GERAGHTY & MILLER. INC.

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Page 1 of 2
Adult Resident Risk Scenario, Deep Bedrock Unit, Hypothetical Future Potable
Ground-Water Exposure Doses (PGWExDs) , Hazard QuotientS, and Excess
Lifetime Cancer Risks, Kohler Company Landfill, Source Control Feasibility
Study, Kohler, Wisconsin.
Table 7.
   Cancer Risk and
Constituent Cp PGWExD Hazard Quotient
CANCER EFFECTS   
~   
Vinyl chloride O.OOSO S .9E-QS 1.IE-04
Inonmnics   
Beryllium 0.00022 2.6E-Q6 I. IE-OS 
Nickel 0.3S 4.1E-Q3 NA
  ELCR IE-04
NON-CANCER EFFECTS   
~   
I ,2- Dichloroethene (total) O.OOSO 1.4E-04 1.4E-Q2
Vinyl chloride O.OOSO 1.4E-04 1.1E-Q 1
Semi- VOCs   
Pyrene 0.0030 8.2E-QS 2.7E-Q3
InoNanics   
Aluminum 1.4 3. 8E-Q2 NA
Antimony 0.71 1.9E-Q2 4.9E+Ol
Barium 1.4 3.8E-02 5 .5E-Q 1
Beryllium 0.00022 6.0E-Q6 1.2E-Q3
Chromium 0.34 9.3E-Q3 1.9E+OO
Cobalt 0.33 9.0E-03 NA
Copper 0.045 1.2E-03 NA
Fluoride 0.46 1.3E-02 2.1E-Q 1
Iron 4.5 l.2E-o 1 NA
Magnesium 550 l.SE+Ol NA
Manganese 3.8 1. OE-Q 1  1.0E+OO
Nickel 0.35 9.6E-Q3 4.8E-Ql
Nitrate-Nitrite 0.15 . 6.8E-Q3 NA
GERAGHTY & MILLER.INC.

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Table 7.
Page 2 of 2
Adult Resident Risk Scenario. Depp Bedrock Unit. Hypothetical Future Potable
Ground-Water Exposure Doses (PGWExDs), Hazard QuotientS, and Excess
Lifetime Cancer Risks, Kohler Company Landfill, Source Control Feasibility
Study, Kohler, Wisconsin.
Constituent
Cp
PGWExD
Cancer Risk and
Hazard Quotient
Inonmnics (cont.)
Silver
Sulfate
Vanadium
Zinc
0.13
300
0.53
0.14.
3.6E-Q3
8.2E+00
1.5E-Q2
3.8E-Q3
1.2E+00
NA
2.1E+OO
1.9E-Q2
m
6E+Ol
Cp
ELCR
HI
I'GWExD
NA
Ground-water concentration (mg/L).
Excess lifetime cancer risk (sum of cancer risks [PGWExD x CSF] see Table R-ll).
Hazard index (sum of the hazard quotientS [PGWExD/RfDJ see Table R-ll).
Potable ground water exposure dose (mg/kglday).
No USEP A-verified toxicity values available to estimate risk. .
GERAGHTY & MILLER. INC.

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Page 1 of 2
Concentrations for Constituents of Concern Detected in Ground-V/ater Samples,
and Estimated Sheboygan River Surface-Water Concentrations, Kohler Company
Landfill. Source Control Feasibility Study, Kohler, Wisconsin.
Table B.
Constituent
Highest
UCLa
Ground- Water
Unit
Estimated
Surface Water
Concentrationb
~
Benzene
Carbon disulfide
Chlorobenzene
Chloroethane
l,l-Dichloroetlt!ne
1,2-Dichloroetlt!ne
l,l-Dichloroethene
1,2- Dichloroethene (total)
Ethylbenzene
4-Methyl-2-pentanone
Toluene
1,1,1-Trichloroe~e
Trichloroethene
Vinyl chloride
Xylenes
0.011
0.0095
0.018
0.052
1.0
0.024
0.0045
0.59
0.0083
0.012
0.081
0.051
1.7
0.20
0.029
Unconsolidated
Unconsolidated
Unconsolidated
Unconsolidated
Unconsolidated
Unconsolidated
Unconsolidated
Shallow Bedrock
Unconsolidated
Unconsolidated
Unconsolidated
Unconsolidated
Unconsolidated
Shallow Bedrock
Unconsolidated
Semi- VOCs
Butylbenzylphthalate
4-Chloro-3-methylphenol
2,4-Dimethylphenol
Di-n-octyl phthalate
2-Methylphenol
4-Methylphenol
Phenol
Pyrene
0.0093
0.015
2.0
0.0071
0.041
0.047
0.015
0.003
Unconsolidated
Unconsolidated
UnconsoliclJltM
Unconsolidated
UnconsoliclJltM
Unconsoli
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Table 8.
Page 2 of
Concentrations for ConstitUents of Concern Detected in Ground-Water Samples,
and Estimated Sheboygan River Surface-Water Concentrations, Kohler Company
Landfill, Source Control Feasibility Study, Kohler, Wisconsin.
Constituent
Highest
UCLa
Ground-Water
Unit
Estimated
Surface Water
Concentrationb
Iwtnmnics   
Aluminum 1.4 Deep Bedrock 4.1 x 10-)
Antimony 0.71 Deep Bedrock 2.1 x 10-3
Ar~;enic 0.0047 Unconsolidated 1.4 x 10-5
Bcuium 1.4 Deep Bedrock 4.1 x 10-3
Beryllium 0.0024 Shallow Bedrock 7.0 x l~
Cadmium 0.024 Shallow Bedrock 7.0 x 10-5
Chromium 0.34 Deep Bedrock 9.8 x l~
Cobalt 0.33 Deep Bedrock 9.7x IQ-4
Copper 0.066 Unconsolidated 1.9 x l~
Fluoride 3.2 Shallow Bedrock 9.4 x 10-3
Iron 4.5 Deep Bedrock 1.3 x 10-1
Lead 0.015 Unconsolidated 4.4 x 10-5
Mal~nesium 550 Deep Bedrock 1.6
Manganese 3.8 Deep Bedrock 1.1 x 10-1
Nickel 0.35 Deep Bedrock 1.0 x 10-3
Nitl'ate- Nitrite 91 Shallow Bedrock 2.7 x 10-1
Selenium 0.002 Unconsolidated 5.9 x l~
Silver 0.13 Deep Bedrock 3.8 x lQ-4
Sulfate 370 Deep Bedrock 1.1
Vanadium 0.53 Deep Bedrock 1.5 x 10-3
Zinc 0.14 Deep Bedrock 4.0 x 1~
a
UCL refers to the upper 95 percent confidence limit on the arithmetic average (obtained from Tabl,
4-2, 4-3, or 4-4).
b
Estim~ted by multiplying the highest UCL concentration in ground water by the dilution factor
of ground water discharge flow (Q,.) to river flow (Q.):
02W X Cr- = 5.0 X 10-1 cfs x Cr
Qgw + Qa = 5.0 X 10-1 cfs + 17 cfs
Alll'csults given in mil1igIams per liter (mglL)
GERAGHTY & MILLER. INC.

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    Page 1 of 3
Table 9. Comparison of Constituents of Concern in Ground Water with Available Water-
 Quality Criteria, Kohler Company Landf11l, Kohler, Wisconsin. 
  Highest Surface- Does Water
  Ground- Water Water Concentration
Constituent UCV Criteriab Exceed Criteria?
~   
Benzene 1.1 x 10-2 5.3 X 10-2 c No
Carbon disulfide 9.5 x 10-)  No
Chlorobenzene 1.8 x 10-2 5.0 x 10') 4 Yes
Chloroethane 5.2 x 10-2  No
1,1- Dichloroethane 1.0 x 10°  No
1,2-Dichloroethane 2.4 x 10-2 2.0 x 100. No
I , 1- Dichloroethene 4.5 x 10-) 1.15 X 10-. ( No
1,2-Dichloroethene (total) 5.9 x 10-. 1.15 x 10-1( Yes
Ethylbenzene 8.3 x 10') 3.2 x 100. No
4-~ethyl-2-pentanone 1.2 x 10'2  No
Toluene 8.1 x 10-2 1.75 X 10-. c No
1,1,1-Jrrichloroethane 5.1 x 10.2 1.8 X 10-.' No
Trichloroethene 1.7 x 100  2.19 x 100. Yes
Vinyl chloride 2.0 x 10"1  No
Xylenes 2.9 x 10"2  No
Semi- VOCs   
Butylbenzylphthalate 9.3 x 10-) 3.6 X 10-1 i No
4-Chloro-3-methylphenol 1.5 x 10"2  No
2,4- Dimethylphenol 2.0 x 100 2.12 X 10'2 c Yes.
Di-n-octyl phthalate 7.1 x 10-) 3.6 X 10-. i No
2-Methylphenol 4.1 x 10-2  No
4-~ethylphenol 4.7 x 10"2  No
Phenol 1.5 x 10"2 2.56 X 10"1. No
Pyrene 3.0 x l()'J 1.3 X lO-Zi No
InOr2anics   
. 1.4 X 100 8.7 X 100Zt 
Aluminum Yes
Antimony 7.1 x lO.1 3.0 X lO.2; Yes
Arsenic 4.7x 10"J 1.53 x 10"1 No
Barium 1.4 x 100  No
Beryllium 2.4 x 10"' 5.3 x 1~. Yes
Cadmium 2.4 x 10.2 1.9 X 10-) I Yes
Footnotes appear on pages 2 ai.'; 3.
GERAGHTY & MILLER.INC.

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. d
Table 9.
Page 2 "r' 3
Comparison of Constituents of Concern in Ground Water with Available Water-Quality
Criteria, Kohler Company Landfill, Kohler, Wisconsin. -
Constituent
Highest
Ground-Water
UCL'
Does Water
Concentration
Exceed Criteria?
Surface-
Water
Criteriab
lDol'2anics (cont'd)   
Chromium (+6) 3.4 x 10'1 9.74 X 10-3 Yes
Cobalt 3.3 x 10-1  No
Copper 6.6 X 10-2 3.7 X 10-21 Yes
Fluoride 3.2 x 100  No
Iron 4.5 x 100 1.0 x 100" Yes
Lead 1.5 x 10-2 4.8 X 10-21 No
Magnesium 5.5 x lQ2  No
Manganese 3.8 x 100 1.5 x 100. Yes
Niclccl 3.5 x 10.1 1.9 X 10-11 Yes
Nitrate-Nitrite 9.1 x 10.  No
Selenium 2.0 x 10"3 7.07 X 10"3 No
Silver 1.3 x 10"1 8.4 X 10"31 No
Sulfate 3.7 x 102  No
Vanadium 1.4 x 10"1  No
All concentrations reponed in milligrams per liter (mglL).
No standard or criteria available.
a
b
From T~le R-l7.
Wisconsin Chronic Toxicity Criteria (NRI05.06, WAC) for Warm Water Sponfish, unless
specified otherwise.
Insufficient data to develop Federal Water-Quality Criterion (FWQC). Value presented
is the lowest observed effect level (LOEL) via acute exposure, reduced by a factor of 100
(USEPA, 1986c). . . .
Insufficient data to develop FWQC. Value presented is the LOEL via chronic exposure
to chlorinated benzenes, reduced by a factor of 10 (USEPA, 1986c).
Insufficient data to develop fWQC. Value presented is the LOEL via chronic exposure,
reduced by a factor of 10 (USEPA, 1986c).
Insufficient data to develop fWQC. Value presented is the LOa via acute exposure to
dich1oroethenes, reduced by a factor of 100 (USEPA, 1986c).
c
e
f
GERAGHTY & MIllER. INC.

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Table 9.
Page 3 of 3
Comparison of ConstituentS of Concern in Ground Water with Available Water-
Quality Criteria, Kohler Company Landfill, Kohler, Wisconsin.
g
h
Insufficient data to develop FWQC. Value presented is the LOEL via acute exposure to
trichIorinated ethanes, reduced by a factor of 100 (USEPA, 1986c).
Insufficient data to develop FWQC. Value presented is the LOEL via acute exposure,
reduced by a factor of 100 (IRIS, 1991).
Proposed federal chronic FWQC (55 FR 93).
Proposed chronic FWQC (USEPA, 1988b).
Chronic FWQC (USEP A, 1988c).
Hardness-related Wisconsin criterion. Criterion presented was calculated assuming a
Sheboygan River water hardness of 343 mg/L as CaC~.
Chronic FWQC (USEPA, 1986c). .
Value presented is not a criterion or standard but a threshold concentration below which
no adverse effects to fish would be expected (USEPA, 1986c).
J
k
I
m
n
--..---.'--
GERAGHTY & MJLLER.I~C.

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Table 10.
Page 1 of 3
Comparison of Constituents of Concern Estimated in Sheboygan River Surface
Water with Available Water-Quality Criteria, Kohler Company Landfill, Kohler,
Wisconsin.
  Estimated Surface- Does Water
  Surface- Water Water Concentration
Constituent  Concentration. Criteriab Exceed Criteria?
~     
Benzene  3.2 x lO" 5.3 X lO-2 c  No
Carbon disulfide  2.8 x lO"   No
Chlorobenzene  5.3 x 10-' 5.0 X lO-3 d  No
Chloroethane  1.5 x 10-4   No
1 , 1- Dichloroethane  2.9 x lO-3   No
l,2-Dichloroethane  7.0 x lO-' 2.0 x 10°c  No
1,I-Dichloroethene  1.3 x 10" 1.15 X lO.1I  No
: ,2-Dichloroethene (total) 1.7 x JO-) 1.15 X 10-"  No
Ethylbenzene  2.4 x lO" 3.2 x 10°8  No
4-Methyl-2-pentanone  3.5 x 10"'   No
Toluene  2.4 x J~ 1.75 X JO"' c  No
1,1,I-Trichloroethane  1.5 x 1~ 1.8 X 10""  No
Trichloroethene  5.0 x 10"3 2.19 x 10°8  No
Vinyl chloride  5.9 x 1()'4   No
X ylenes  8.5 x 10"'   No
Semi- VOCs     
Butylbenzylphthalate  2.7 x 10"' 3.6 x 10' i  No
4-Ch1oro-3-methylphenol 4.4 x 10"'   No
2.,4-Dimethylphenol  5.9 x 10"3 2.12 X 1O'2c  No
Di-n-octyl phthalate  2.1 x JO"' 3.6 X J01 i  No
2..Methylphenol  1.2 x 1()'4   No
4'.Methylphenol  1.4 x J()'4   No
PR1cnol -.--.--- - - 4.4 x 10'" - _2.56 x 10"18 -- -- No
Pyrcnc  8.8 x 104 1.3 x J()"2 t  No
IDol"2anic:s     
Aluminum  4.1 x 10"3 8.7 X 10"2&:  No
Aultimony  2.1 x 1()"3 3.0 X 10"2 i  No
AJrSenic  1.4 x 10"' 1.53 x 10"1  No
Barium  4.1 x 10"3   No
BeryJlium  7.0 x 1()'4 5.3 x 1Q-48  No
Footnotes appear on page 2.
GERAGHTY & MILLER.I:"C.

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Table 10.
:'age 2 of 3
Comparison of Constituents of Concern Estimated in Sheboygan River Surface Water
with Available Water-Quality Criteria, Kohler Company Landfill, Kohler, Wisconsin.
Constituent
Estimated
Surface- Water
Concentration.
Does Water
Concentration
Exceed Criteria?
Surface-
Water
Criteriab
Inor2anics (cont'd)
Cadmium
Chromium (+6)
Cobalt
Copper
Fluoride
Iron
Lead
Magnesium
Manganese
Nickel
Nitrate-Nitrite
Selenium
Silver
Sulfate
Vanadium
Zinc
7.0 x 10"" 1.9 x 10"3 I No
9.8 x 1~ 9.74 X 10"3 No
9.7 x 1~  No
1.9 x 1~ 3.7 X 10"21 No
9.4 X 10"3  No
1.3 X 10"2 1. 0 x 100m No
4.4 x 10"' 4.8 x 10-21 No
1.6  No
1.1 x 100z 1.5 x 100. No
1.0 X 10"3 1.9 X 10"11 No
2.7 X 10"1  No
5.9 x 1~ 7.07 X 10"3 No
3.8 x 1~ 8.4 X 10"31 No
1.1  No
1.5 x 10"3  No
4.0 X 10" 1.4 X 10"11 No
All concentrations reponed in milligrams per liter (mg/L).
No standard or criteria available. .
Estimated by multiplying the highest UCL concentration in ground water (Cp) (from
Table R-I7) by the dilution factor of ground-water discharge flow (Q..) to river flow (QJ:
a
0... x Cr
Q.. + Qa
=
5.0 x 1 Q-2cfs x c...-
5.0 x lO"zcfs + 17 cfs
=
b
WisCOnsin-Chronic Toxicity Criteria (NRI05.06, WAC) for Wann Water Sponfisb, unleSs
specified otherwise.
Insufficient data to develop Federal Water Quality Criterion (FWQC). Value presented
is the lowest observed effect level (LOE!..) via acute exposure, reduced by a factor of 100
(USEPA, 1986c).
Insufficient data to develop FWQC. Value presented is the LOEL via chronic exposure
to chlorinated benzenes, reduced by a factor of 10 (USEPA, 1986c).
Insufficient data to develop FWQC. Value presented is the LOE!.. via chronic exposure,
reduced by a factor of 10 (USEPA, 1986c).
Insufficient data to develop FWQC. Value presented is the LOEL via acute exposure to
dich1oroethenes, reduced by a factor of 100 (USEPA, 1986c).
Insufficient data to develop FWQC. Value presented is the LOEL via acute exposure to
trichlorinated ethanes, reduced by a factor of 1~ ,USEPA, 1986c).
c
d
e
f
g
GERAGHTY & MJLLER.INC.

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Table 10.
Page 3 of 3
Comparison of Constituents of Concern Estimated in Sheboygan River Surface
Water with Available Water-Quality Criteria, Kohler Company Landfill, Kohler,
Wisconsin.
It
Insufficient data to develop FWQC. Value presented is the LOEL via acute exposure,
reduced by a factor of 100 (IRIS, 1991).
Proposed federal chronic FWQC (55 FR 93).
Proposed chronic FWQC (USEPA, 1988b).
Chronic FWQC (USEPA, 1986c).
Hardness related Wisconsin criterion. Criterion presented was calculated assuming a
Sheboygan River water hardness of 343 mg/L as CaCQ,.
Chronic FWQC (USEPA, 1 986c).
Value presented is not a criterion or standard but a threshold concentration below which
no adverse effects to fish would be expected (USEPA, 1986c).
J
k
1
m
n
.-- ,-. ~ .
GERAGHTY & MILlER.INC.

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