..
United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
PB93-964109
EPAIROD/R05-921216
September 1992
-----
. Hazardous Waste Colfection
Information Resource Center
US EPA Region 3
Philodelphio,. PA 191Q7
U.S. EnV\r~~~
ReQio.,'!'. Ha1af maUon CentQ! .
TectVJlCl'~ Street t 9th Floor
841 ~7PA 19107
&EPA
Superfund
Record of Decision:
Hagen Farm, WI
J
-------
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.
-------
50272-1 01
REPORT DOCUMENTATION 11. REPORT NO.
PAGE EPA/ROD/R05-92/216
I 2.
3. Reclpienr. A_Ion No.
4. Tille and Subtille
SUPERFUND RECORD OF DECISION
Hagen Farm, WI
Second Remedial Action - Final
7. Aulhor(.)
5. Report Date
09/30/92
6.
8. Performing Organization Rapt No.
9. PerformIng Orgalnlzatlon Name and Addr-
10. Profec1lTaskIWork Unit No.
11. Con1rac1(C) or GranI(G) No.
(C)
(G)
12. Spon.or\ng Organization Name and Addr-
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type 01 Report " PerIod Covered
800/000
14.
15. Supplementary Notee
PB93-964109
16. Abelract (Umlt: 200 w0rd8)
The Hagen Farm site is a former waste disposal facility approximately 1 mile east of
the City of Stoughton, Dane County, Wisconsin. The site is defined as the area within
the property boundary and the contaminant plume. The property is approximately
28 acres in size, and within the property boundary is a lO-acre area that was used for
waste disposal. The site is located in a rural area that is largely dominated by sand
and gravel mining and agricultural activities. Eleven private wells are located
within 1,000 to 4,000 feet of the site. In addition, a wetland area is located
adjacent to and just south of the site. Prior to the 1950's, the site was operated as
a sand and gravel pit. The gravel pit was then used for disposal of waste materials
from the late 1950's to the mid-1960's. Waste materials were disposed of in three
onsite subareas designated A, B, and C. Waste materials included municipal and
industrial wastes, such as solvents and other various organic materials. From 1980 to
1986, state investigations revealed organic compounds in nearby private water supply
wells. A 1990 ROD addressed contaminated soil in the three disposal areas as OU1 and
provided for excavation of soil in subareas Band C with consolidation in disposal
area Ai construction of a landfill cover at disposal area A; and implementation of a
(See Attached Page)
17. Document AnaIyaI8 & DescrlplDn
Record of Decision - Hagen Farm, WI
Second Remedial Action - Final
Contaminated Medium: GW
Key Contaminants: VOCs (benzene, toluene, xylenes); metals (arsenic, lead)
b. IdenUftenrlOpen-Encled Term.
c. COSA TI F1eId'Group
8. Availability Statement
19. Security CIa8s (This Report)
None
20. Security CIa8s (ThIs Page)
Nonp
21. No.oIPagee
46
I
22. PrIce
(See ANSI-Z39.18
See Instruc1JolJ$ on Reverse
OP
272T4-77)
(Formerty N11S-35)
Oepartmeftt 01 Commerce
-------
EPA/ROD/R05-92/216
Hagen Farm, WI
Second Remedial Action - Final
Abstract (Continued)
soil vapor extraction system in sub-waste soil under disposal area A. This ROD provides
a final remedy for the ground water control on the property and off the property, as OU2.
The ROD defines on-property ground water as contaminated ground water in the immediate
vicinity of the main disposal area and off-property ground water at any location within
the plume other than in the area defined as on-property ground water. The primary
contaminants of concern affecting the ground water are VOCs, including benzene,
1,1-dichloroethene, ethylbenzene, tetrahydrofuran (THF), toluene, vinyl chloride,
xylenesi and metals, including arsenic and lead.
The selected remedial action for this site includes ground water pump and treat. The
major components of the selected remedy include extraction and treatment of ground water,
pre-treatment of extracted on- and off-property ground water to remove metals and
inorganic solids, treatment of on-property ground water using an activated biological
sludge treatment system, treatment of off-property groUnd water using a treatment
technology to be determined during the design stage, discharge of the treated ground
water to the wetlands or the Yahara River; treatment and disposal of sludge generated
from the ground water treatment and treatment of off-gas emitted from the treatment
processi and implementation of a bench-scale study to determine the effect of nutrients
and/or oxygen on contaminated ground water. If the bench-scale study shows positive
results, a pilot study would be conducted, with the ultimate goal of enhancing the
selected remedy with an in-situ ground water bioremediation system. All private wells
located around the site will be monitored. The estimated present worth cost for this
remedial action (depending on the treatment selected for the off-property ground water)
ranges from $13,612,000 to $24,163,000, which includes an annual O&M coSt for the first
yearof $550,000 to $1,062,000.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific ground water clean-up goals are based
on the State of Wisconsin Preventive Action Limits (PALs) and include benzene 0.067 ug/l,
1,1-dichloroethene 0.024 ug/l, ethylbenzene 272 ug/l, tetrahydrofuran 10 ug/l, toluene
68.6 ug/l, vinyl chloride 0.0015 ug/l, xylenes 124 ug/l, arsenic 5 ug/l, and lead 5 ug/l.
-------
HAGEN FARK SITE, WI
GROUNDWATER CONTROL OPERABLE UNIT
DECLARA~ION FOR THE RECORD OF DECISION
Site"Name and Location
Hagen Farm Site, Groundwater Control Operable Unit
Dane County, Wisconsin
Statement of Basis and Purcose
This decision document represents the selected remedial action for
the Hagen Farm Site (the "Site"), in Dane County, Wisconsin,
Groundwater Control Operable Unit, which was chosen in accordance
with the Comprehensive Environmental Response Compensation, and
Liability Act of 1980 (CERCLA), as amended by" the Superfund
Amendments and" Reauthorization Act" of 1986 (SARA) and, to the
extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP).
This decision is based on the Administrative Record for the Hagen
Farm site.
The state of Wisconsin concurs with the selected remedy on the
condition that, at the time that the proposed treatment design is
finalized, the State determines that the proposed effluent
discharge limits and discharge location are acceptable to the
state.
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.
DescriDtion of Remedy
- --'
This Groundwater Control Operable Unit is the second of two
operable units for the Site. For purposes of this ROD, the "Site"
is defined as the area within the Hagen Farm property boundary and
the contaminant plume. The selected remedial action for this
operable unit addresses the groundwater contamination by
remediation of contaminated groundwater. For" purposes of this ROD,
"on-property groundwater" is defined as contaminated groundwater on
and in the immediate vicinity of the main waste disposal area and
"off-property groundwater" is defined as contaminated groundwater
-------
-
2
at any location within the plume other than in the area defined as
on-property groundwater.
The major components of the selected remedy include:
*
Monitoring of all private wells located around the
site;
*
Pre-treatment of extracted on- and off-property
groundwater;
*
Extraction and treatment of groundwater;
. .
* Treatment of on-property groundwater using Activated sludge
. Biological Treatmept; .
*
Treatment of off-property g~undwater using a treatment
technology to be determinedpuring the design phase;
Discharge of treated groundwater to wetlands or
the Yahara River; ,
*
*
, '.
Treatment and disposal of sludges generated from the
groundwater treatment and treatment of off-gas emitted from
the treatment process; .
Deed and access restrictions to prevent installation of
drinking water wells within the vicinity of the disposal
areas and off-property; and.,
*
*
Implementation of a bench scale studYfto determine the
effect of nutrients and/or oxygen on contaminated
groundwater. If the bench scale study shows positive
results, a pilot study would be conducted, with the
ultimate goal of enhancing the selecte~remedy with an in-
situ grou~dwater bioremediation system.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State environmental
requirements that are legally ~plicable or r~levant and
appropriate to the remedial action, and is cost effective. This
remedy utilizes permanent solutionS and alternative treatment
technologies to the maximum extent practicable and satisfies the
statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as a principal element.
-------
3
Because this remedy will result in hazardous substances remaining
on-site, a review will be conducted within five years after
commencement of the remedial action to ensure that the remedy
continues to provide adequate protection of human health and the
environment. .
~~t/d ~.L
;; Valdas V. Adamkus
['- Regional Administrator
...~ji
. ,Ii
'I'
~.
----
~Al-
ate'
-------
RECORD OF DECISION
DECISION SUMMARY
HAGEN PARK SJ:TE
GROUNDWATER CONTROL OPERABLE UNJ:T
DANE COUNTY, WJ:SCONSJ:N
.Prepared "By:
u.S. Environmental Protection Aqency
ReqioD V
chie~qo, J:llinois
September, 1992
-------
"
I.
II.
III.
IV
V.
VI.
VII.
VIII.
IX.
X.
XI.
ROD SUMMARY
HAGEN FARM SUPERFUND SITE
GROUNDWATER CONTROL OPERABLE UNIT
DANE COUNTY, WISCONSIN
TABLE OF CONTENTS
SITE NAME, LOCATION, AND DESCRIPTION
. . . . . . . . .
SITE HISTORY AND ENFORCEMENT ACTIVITIES. . . . . . .
COMMUNITY RELATIONS ACTIVITIES. . . . . . . . . . . .
SCOPE AND ROLE OF RESPONSE ACTION.
. . . . . . .
. . . 10
SUMMARY OF SITE CHARACTERISTICS.
. . . . . . . . .
SUMMARY OF SITE RISKS. . . . .
............
DOCUMENTATION OF SIGNIFICANT CHANGES
. . . . . . . . . 20
DESCRIPTION OF REMEDIAL ALTERNATIVES
........
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES. .
THE SELECTED REMEDY. . . . . . . . . .
. . . .
STATUTORY DETERMINATIONS SUMMARY
. . . . . . .
. . . . 35
--"""
3
5
9
11
12
20
26
33
-------
ROD StJMXARY
HAGEN FARK SUPERFUND SITE
GROUNDWATER CONTROL OPERABLE UNIT
DANE COUNTY, WISCONSIN
I.
SITE LOCATION AND DESCRIPTION
The Hagen Farm Site (the Site) is located at 2318 County Highway
A, approximately one mile east of the 'City of Stoughton, Dane
County, wisconsin. The site is defined as the area within the
Hagen Farm property boundary and the contaminant plume. The
property is approximately 28 acres in size and is located in the
northeast quarter of the southeast quarter of Section 10,
Township 5 North, Range 11 East. ' Within the property boundary
is approximately 10 acres of disposal area. The Site, as a
whole, is situated in a rural surrounding that is dominated
largely by sand and gravel mining and agriculture. Sand and
grayel mining operations are located northwest, northeast, and
south of the site. The Stoughton Airfield is located adjacent
to the northwest corner of the site. County Highway "A" passes
just south of the property boundary (See Figure 1).
The City of Stoughton's municipal wells are located
approximately two miles to the west. Three private wells are
located approximately 1000 feet west of the Site, and eight
private wells are located within 4,000 feet downgradient from
the Site based on hydrogeology information obtained during
investigation at the site' (See section V below). The private
wells located at the Site were abandoned in accordance with NR
112 and are no longer in use. Approximately 350 people reside
within one mile of the Site.
~
The site is located in the Yahara River watershed, in an area of
flat to gently rolling topography. The Yahara River is located
approximately, 1.3 miles to the west and flows in a southerly
direction. The Site does not lie within the 100-year flood
plain. The land surface generally slopes toward the Yahara
River from topographically high areas located to the northeast
and east. Surface-water drainage in the area is generally
poorly developed, apparentiy due to permeable surface soils.
The only substantial surface water bodies in the area are
Sundby's pond located approximately 1/2 mile south of the site
and the Yahara River. An on-Site ditch is located at the
southeast corner of the property which flows to a wetland. This
wetland' is located dire_ctly ,south of the Site. There is no
designated Wisconsin State significant habitat, or historic
landmark site directly or potentially affected. No endangered
species are known to inhabit the Site.
The, site is located in an area dominated by glacial outwash
deposits, which extend approximately one-half mile to the
northeast. These deposits are dominated by sand and gravel.
Beyond this, ground moraine and occasional drumlins are
encountered. Lacustrine deposits associated with Glacial Lake
-------
[ij]
-."
~ ;
:f'a
eD e:
!=&
0CJ'
00<
me..
:I .
ts
:I CJ'
3 ::w
eD :I
.:1 C)
[:r
."eD
'" CD
O ::!.
- :I
CDfD
&Q
o 0
:I C
~'a
. -
:I :I
C') ~
~ 0
~:!:
~!
CD 0
o
00
:OJ;
~~.
i
i~
Figure 1
Site Location Map
Hagen Farm Site
Dunkirk Township, Wisconsin
-------
5
Yahara are located approximately one-eighth of a mile south.
Bedrock, primarily sandstone and dolomite, underlie the glacial
deposits in this area. Bedrock generally slopes from the west
to southwest, toward a preglacial valley associated with the
Yahara River. The depth to bedrock ranges from 50 to 80 feet
near the site. Groundwater is present approximately 10 to 40
feet below ground surface near the Site. Groundwater flow is
predominantly to the south-southwest, toward the Yahara River,
a regional groundwater discharge zone. Estimated groundwater
velocities ranged from 1.2 ft/yr to 145 ft/yr.
The current site topog~aphy is the result of sand and gravel
mining and waste disposal activities. Prior to these
activities, the ground surface probably sloped from the existing
topographically high area located west and northwest toward the
southeast and east. The excavated area in the northwest corner
. of the property is flat. This flat area is separated by a ridge
from the water-filled depression located to the northeast.
within the Site's "area of contamination" (AOC) , waste disposal
took place wi thin three subareas. These subareas are A (6
acres, located in the southern portion of the property), Band
C ( 1. 5 acres each, located in the' northeastern portion) (See
Figure 2). All three subareas reside within the Site's formally
defined AOC. Subareas Band C have been consolidated into the
disposal area A. Disposal area A has been capped and vegetated.
These consolid~t.ion and capping activities were conducted as
part of the Sou~oe Control Operable Unit (see ROD in this matter
dated September 17, 1990).
.' ,Iii.
II.
i
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Site was operated as a sand and gravel pit prior to the late
1950s. Observations suggest gravel operations encompassed an
area bounded by ~he current access road to the east, the former
Schroeter pro~y bounda~y to the west, and the current
property boundary to the north (See Figure 2). Mining
operations reportedly terminated approximately 14 to 18 feet
below qround surface. Excavation may have ceased at this depth
due to the presence of groundwater, more fine grained materials,
or a change in sand and gravel quality.
The gravel pit was the~-~sed for disposal of waste materials
from the late 1950s to the mid-1960s. During the period that
the Site was operated as a disposal facility, the property was
owned by Nora Sundby, since deceased. The property was then
purchased from Nora Sundby by Orrin Hagen in November 1977. The
Site is currently owned by Waste Management of Wisconsin,
Incorporated (W,MWI). The site was operated by City Disposal
Corporation. City Disposal Corporation was subsequently
purchased by WMWI. City Disposal was also the transporter of
much of the waste that was deposited at the Site. It is known
-------
Figure 2
Site Diagram
Hagen Farm Site
Dunkirk Township, 'Wisconsin
( Not To Scale)
1---------------------
,-~-----~-----------._----------- -
II : ! limit of Area of
I :~
11 ! C~ntamination
I.: ,: ICD
: I C
I: I::J
1 i 1 i
____I : / I g.
" . ~
, / Disposal I a..
" Areas I
: IIB&C" I
: I
: I
,
: 1
: I
: I
I
I
.
I
I
I
I
I
I
I
I
I
I
I
,
I
I
,
I
I
,
I
I
,
I
I
:CD
:0
'C
'CD
:u.
I
'CD
,-
:0
,
I
"'''''''''''''''''
"'........
"''''........
--
~...'.:~
~~~.
Gravel Pit
Airfield
I~--
,.
I
I
I
I
I
I
I
COv,
"Jty IYJ
~~
ei: ::;
-'~. ..'.~.""..'~".' 0..
, ..::~~..,. ~'.
Ponds J;j,;:'
Disposal
Area 8A8
Sundby Sand
and Gravel
.
. K-Way
Insulation
..-
IJ E I Prepared by Jacobs Engineering Group Inc. Chicago
for the U.S. Envlronmentai Protection Agency, 7/22/90.
Drawn
Checked
AH
DS
-------
7
that Uniroyal, Incorporated (Uniroyal) generated industrial
waste, some of which was deposited at the site beginning
sometime in 1962 and continuing through August 1966.
Waste solvents and other various organic. materials, in addition
to the municipal wastes, were disposed of at the Site, including
acetone, butyl acetate, 1-2-dichloroethylene, tetrahydrofuran,
solid vinyl, sludge material containing methyl ethyl ketone and
xylenes, and toluene. In a 103(c) Notifica~ion submitted to the
United states Environmental Protection Agency (U. S. EPA) by
Uniroyal, in June 1981, Uniroyal indicated that F003 and FOOS
wastes (spent non-halogenated solvents) ,which are hazardous
wastes wi thin the meaning of the Resource Conservation and
Recovery Act (RCRA), 42 U.S.C. 6901, also were disposed of at
the Site. This site stopped accepting waste in 1966, prior to
regulation of hazardous waste disposal by RCRA'Subtitle C. .
Beginning in November 1980, in response to complaints received
from local residents, the Wisconsin Department of Natural
Resources (WDNR) began conducting groundwater sampling at nearby
private water supply wells. Sampling of the on-Site monitoring
wells during the period 1980-1986 indicated certain organic
compounds were present in the groundwater, including benzene,
ethylbenzene, tetrahydrofuran (THF), xylenes, and toluene.
In addition, nearby private water supplies on adjacent
properties also contained detectable levels of volatile organic
compounds (VOCs). The private wells located on adjacent
properties had been impacted by acetone, THF, vinyl chloride,
xylene, trans-1,2-dichlorethene.' and trichloroet!:lylene.
- .
In 1983, the state of Wisconsin brought an enforcement action
for abatement of a public nuisance against WMWI and Uniroyal.
At the same time, nearby residents to the Site brought a civil
action against WMWI and Uniroyal,' seeking civil damages for
reduced property values and potential health hazards resulting
from groundwater and well contamination. The state of Wisconsin
obtained a dismissal of its 1983 enforcement action against WMWI
and Uniroyal after the site was listed on the National
Priorities List (NPL). In 1986, the parties to civil litigation
brought by the nearby residents to the Site against WMWI and
Uniroyal reached a settlement. The exact terms of the
settlement are confiden~ial. It is known, however, that one of
the terms of the settlement required WMWI to purchase the Site
property from Orrin Hagen, as well as other property located
adjacent to the site. Upon acquiring these properties, WMWI
razed the structures constructed thereon.
The site was proposed for inclusion on the NPL on September 18,
1985. The Site was placed on the NPL in July 1987.
Subsequently, WMWI and Uniroyal, the two potentially responsible
parties (PRPs) named by U.s. EPA in connection with the site to
-------
8
date, entered into an Administrative Order by Consent (U.S. EPA
Docket No. VW 87-C-016, dated September 14, 1987) (the Consent
Order) with U.S. EPA and WDNR. In the Consent Order, WMWI and
Uniroyal agreed to conduct a Remedial Investigation and
Feasibility Study (RI/FS) at the site. Accordingly, in July
1988, upon U.S. EPA approval, in consultation with the WDNR, of
the required Work Plans, fieldwork at the Site commenced.
Two operable units (OUs) have been defined for the site. OU I,
which is the Source Control Operable Unit (SCOU), is intended to
address waste refuse and sub-surface soils (Waste/sub-Soils) at
disposal area A and the two smaller disposal areas Band C. OU
II, which is the Groundwater Control Operable Unit (GCOU), is
intended to address the contami~ated on- and off-property
groundwater at the site. For purposes of this ROD, "on-property
groundwater" is defined as contaminated groundwater on and in
the immediate vicinity of the main waste disposal area and "off-
property groundwater" is defined as contaminated groundwater at
any location within the plume other than in the area defined as
on-property groundwater. TheOU approach was agreed upon after
discussions among u.S. EPA, WDNR, and the PRPs during the early
phase of the implementation of the Work Plan for theRI. This
ROD is developed for the GCOU, which is OU II.
The RI for the SCOU was comple~ed in early 1989, and the ROD was
signed on September 17, 1990. . An Explanation of significant
Differences was issued in April of 1991. ,. Subareas Band C were
consolidated into the disposal area A and the construction of
the Landfill Cover over the main dJsposal area A, which is one
of the components of the selected remedy for the SCOU, was
completed in May 1992. Prior to the implementation of the
Landfill Cover, wastes from areas Band C were consolidated into
the main disposal area A. The implementation of In-situ Vapor
Extraction, which is also part of the selected remedy for the
SCOU, was initiated in May 1992.. The RI for the GCOU was
initiated in July 1989 and the final RI report was submitted in.
November 1991. An Alternative Array was prepared in July 1991,
which provided a preliminary description of the technical
methods under consideration for cleaning up the groundwater.
Based on the evaluation and screening of technical methods
available for addressing the groundwater contamination in the
Alternative Array, a draft Feasibility Study (FS) report was
submitted in October 1991-- The draft FS was revised in order to
include off-property contaminated groundwater in January 1992,
and finalized in April 1992. The FS. Report for the GCOU
outlines the final alternatives under consideration for
correcting contamination problems found in the groundwater, and
provides a thorough evaluation of each alternative.
-------
9
III.
COMMUNITY RELATIONS ACTIVITIES
Upon the signing of the Consent Order in July 1987, U.S. EPA
held a 30-day public comment period. A press release was sent
to all local media and advertisements were placed.
A Community Relations Plan for the Site was finalized in July
1988. This document lists contacts in the government and
interested parties throughout the local communities. It also
establishes communication pathways to ensure timely
dissemination of pertinent information.
An RI "Kickoff" meeting was held on July 14, 1988 to explain the
RI process. A fact sheet was developed in conjunction with this
meeting. Advertisements were placed in the Madison Capital
Times and Stoughton Courier-Hub and a press release was sent to
all local media. .
A press release was sent to local media on March 27, 1989 to
update the community on the progress of Dane County, Wisconsin
Superfund sites, including Hagen Farm.
A public meeting was held on July 27, 1989 to explain the
findings of the RI and the operable unit approach. A fact sheet
was developed in conjunction with this meeting. Advertisements
were placed to announce the meeting and a press release was sent
to all local media. Prior to the public meeting, u.S. EPA
representatives held a separate briefing for Town officials.
A public meeting was held on August 2, 1990, to present the
recommended remedy for the SCOU. Advertisements were placed to
announce the meeting and a press release was sent to all local
media. A public comment period was held from July 11, 1990, to
August 10, 1990. All comments received by u.S. EPA during the
public comment period and at. the public meeting were addressed.
in the Responsiveness Summary of the SCOUROD.
A public meeting was held on August 29, 1991, to provide the
pUblic with an update on the progress for the SCOU and the GCOU
at the site. A fact sheet was developed in conjunction with
this meeting. . Advertisements were placed to announce the
meeting and a press release was sent to all local media.
- ......-.
The RIfFS and the Proposed Plan "for the GCOU were released to
the public in May 1992. All of these documents were made
available in the information repositories maintained at the
stoughton Public Library and Klongland Realty. An
administrative record file containing these documents and other
site-related documents was placed at the. Stoughton Public
Library. The notice of availability of these documents was
published in the Stoughton courier-Hub, Wisconsin State Journal,
and Madison Capital Times on May 27, 1992. Press releases were
-------
10
also sent to all local media. A public comment period was held
from June 1, 1992 to July 1, 1992. The request for an extension
of the comment period was made and the public comment period was
extended until July 31, 1992. In addition, a public meeting was
held on June 11, 1992 to present the results of the RIfFS and
the preferred alternative as presented in the Proposed Plan for
the site. All comments received by U.S. EPA during the public
comment period are addressed in the Responsiveness Summary which
is the third section of this ROD.
As sampling results from private wells became available, u.s.
EPA wrote letters to the property owners to inform them of these
results. These letters were mailed in September 1989 and
December 1990. .
IV.
SCOPE AND ROLE OF RESPONSE ACTION
As discussed in Section II above, U.S. EPA has divided the site
into two operable units. The SCOU addresses waste refuse and
sub-surface soils at disposal area A and the two smaller
disposal areas Band C. The GCOU, which is the subject of this
ROD, is intended to address the contaminated on-and off-property
groundwater at the Site.
U. S. EPA identified contaminated on- and off-property
groundwater as posing potential risks to human health and the
environment. To address these risks, U.S. EPA developed the
following remedial objectives for the GCOU based on the data
obtained during the RI:
1)
Restore groundwater so that contamination levels meet
appropriate Federal and State groundwater quality
standards;
2)
stop the flow of contaminated groundwater
downgradient of the Site and to the Yahara River; and
Prevent the flow of contaminated groundwater to
residential wells. .
3 ).
This ROD was developed to meet these objectives and it addresses
the contamination problems identified in the GCOU, namely the
on- . and off-property groundwater contamination at the site.
This response action is being implemented to protect human
health and the environment from risks posed by the contamination
problems.
This present response action, by addressing contaminated on- and
off-property groundwater, is fully consistent with all future
site work, including the on-going Remedial Design and Remedial
Action (RD/RA) for the SCOU at the Site.
-------
11
v.
SUMMARY OF SITE CHARACTERISTICS
In November 1991, an RI Report for the GCOU was completed under
the guidance and oversight of u.S. EPA and WDNR. The RI for the
GCOU was to determine the nature and extent of contamination in
the groundwater, and evaluate possible exposure pathways. The
report summarized all soil-boring, surface water, on- and off-
property groundwater, private well, pump test, and treatability
study analytical data that had been collected. The RI report
should be consulted for a more thorough description of the Site
characteristics.
The following are the results of the RI at the Site:
The uppermost aquifer at the Site is the glacial sand and
gravel aquifer. This aquifer is unconfined with
groundwater present approximately 10 to 40 feet below
ground surface near the Site. The sandstone bedrock
aquifer is located below the glacial sand and gravel
aquifer. The saturated thickness of the unconsolidated
sand and gravel aquifer generally ranges from 30 to 40 feet
on site and 50 to 100 feet off site. The thickness of the
bedrock aquifer is unknown. Based on the contact of the
sand and gravel aquifer with the bedrock aquifer and the
insignificant difference between water levels in the sand
and gravel and bedrock wells, it appears that the two
aquifers are hydraulically connected.
Groundwater flow immediately beneath the main disposal area
(Area A) is predominantly toward the southeast, but then
rotates to a southerly and southwesterly direction
immediately downgradient of disposal area A. Groundwater
flow south of County Highway A appears to be generally
southerly to southwesterly, with fairly uniform horizontal
gradients. Groundwater velocities ranged from 1.2 to 145
feet per year.
It does not appear that Sundby's pond functions as a local
qroundwater discharqeareai qroundwater flow appears to be
horizontal or slightly downward beneath the pond. Data
also indicate that the nearby drainage ditch is probably
not a potential groundwater discharge point.
- ---'
The constant rate pumping test was run for 33 hours.
During this test, 119,000 gallons were pumped from the
aquifer resulting in a cone of depression extending out
approximately 400 feet. This test indicates that the
aquifer behaves as an unconfined aquifer with some degree
of connection to the sandstone bedrock. Results showed an
average transmissivity of 24,000 gallons per day per foot.
-------
12
The contaminants causing the most concern are VOCs. The
elevated levels of VOCs detected in groundwater were
THF (630,000 parts per billion (ppb», ethylbenzene (4,400
ppb), toluene (2,700 ppb), and xylenes (37,000 ppb).
Benzene (8 ppb), 1,1-dichloroethene (1 ppb), and vinyl
chloride (77 ppb) were also detected in the groundwater.
Inorganic compounds such as arsenic (25.2 ppb), barium
(1,570 ppb), iron (17,000 ppb), lead (6 ppb), manganese
(3,300 ppb), and mercury (6.5 ppb) were also found in the
groundwater. Aroclor-1242 (0.25 ppb), arsenic (31.9 ppb),
lead (997 ppb), cadmium (35.6 ppb), chromium (109 ppb), and
mercury (1.0 ppb) were detected in the leachate from the
landf i 11.
The occurrence, concentration, and .distribution of THF
suggest there is a THF plume originating in the south-
central section of disposal area A which extends
downgradient (south) approximately 3,600 feet to between
test boring #1 and well nest #34 (See figure 3).
Private wells determined to be potential receptors were
sampled in September 1989, August 1990 and September 1991.
VOCs were not detected in private well samples collected
during this investigation.
A treatability study was conducted during the on-property
pump test. The results of the treatability study indicate
that air stripping can attain removal levels as high as 40
percent of the THF concentration in the sample tested. It
is estimated that a cascade aeration system will remove up
to 30 percent of the THF, with higher removal efficiencies
for other VOC contaminants. Granular activated carbon
(GAC) is an effective technology to remove VOCs by itself
and also in combination with biological treatment.
However, two of the contaminants, THF and 2-butanone, are
not readily adsorbable. An activated sludge system can
remove up to 99 percent of the THF and other organic
compounds in the groundwater. UV-chemical oxidation should
remove up to 99 percent of the contaminants.
VI.
SUMMARY OF SITE RISKS
The baseline risk asses~nt was conducted to characterize the
current and potential future threat to public health and the
environment posed by chemicals in the groundwater originating
at, or migrating from the site. Both current and potential
future-use conditions were examined in the baseline risk
assessment. Under current conditions, the site was assessed in
the absence of remedial action for groundwater.
-------
Plume Diagram
Figure 3
1-- - - 48 - - .. - ...... - - - ~-.
Disposal Area
( capped)
.
...
.r",,\
x
Ground-Water
Plume
.
'."
.-.
.0
.-g
:~
I ~
.:;
.(1)
I
.
.
.
.
.. Ditch :
.
.
.
.
.
.
.
.
.
.
...
..
.
.
-x- X X
KEY
N X Soil Boring
6 ... . Monitoring Well
. . Private Well
Not to Scale
-------
14
A risk assessment consists of four primary parts: identifying
chemicals and other contaminants of concern; assessing pathways
through which humans, plants, and animals could be exposed to
contamination; assessing the toxicity of the contaminants; and
character izing cancerous and non-cancerous health effects on
humans.
a.
Human Health Risks
1.
Contaminant Identification
The first step of the risk assessment was to select chemicals
and other contaminants of potential concern for detailed
evaluation. This was conducted by summar'1.zing and evaluating RI
data, including a consideration of naturally occurring
background levels and the presence of chemicals in blank
samples. Based on this evaluation, 56 chemicals of potential
concern were selected for detailed assessment. These chemicals
were considered most likely to be of concern to human health and
the environment. The following compounds were selected as the
chemicals and other contaminants of potential concern:
orqanic Compounds
Acetone
Benzoic acid
2-Butanone
Chloromethane
1,4-Dichlorobenzene
4,4'-DDE
Diethylphthlalate
Ethylbenzene
Naphthlalene
Phenol
Toluene
Vinyl chloride
Metals
Benzene
Benzyl alcohol
Chlorobenzene
l,1-Dichloroethene
l,2-Dichloroethene
Dieldrin'
2,4-Dimethylphenol
4-Methylphenol
Di-n-octylphthalate
Tetrahydrofuran
Vinyl acetate
Xylenes (total)
Arsenic
Barium
Copper
Manganese
Mercury
Nickel
Vanadium
Zinc
These qontaminants were detected in both on- and off-property
groundwater. Table 1 identifies the maximum concentration of
contaminants in groundwater.
2. , Exposure Assessment
_.-
An exposure assessment was conducted to identify potential
pathways of exposure under current and future site and
surrounding land-use conditions. The following pathways were
selected for detailed evaluation under current use conditions
(AI though no current pri vate wells located around and
downgradient of the site are impacted by the contaminated
groundwater, the assumptions were made that the private wells
located in the near and far downgradient of the site might be
impacted due to the potential for groundwater flow changes~):
-------
TABLE 1
Hagen Farm Site
Groundwater Contamination
Maximum Levels Detected/Groundwater Cleanup Standards
Maximum Concentration Standards
Compounds (ugll) (ug/L) BD
On-Property Off-Property ES PAL MCL
OrlZanic
Benzene 8 ND 5 0.067 5 ND
1,I-Dichloroethene 1 ND 7 0.024 7 ND
Ethylbenzene 4,400 ND 1,360 272 700 ND
Tetrahydrofuran 630,000 1,200 50 10 NA ND
-
Toluene 2,700 ND 343 68.6 1,000 ND
Xylenes 37,000 ND 620 124 ' 10,000 ND
Vinyl Chloride 77 5 0.2 0.0015 2 ND
lnorlZanic
Arsenic 25.2 ND 50 5 50 ND
Barium 1,570 ND J,OOO 200 2,000 37
Iron 17,000 ND 300 150 3001 ND
Lead 6 5.6 50 5 I? ND
Manganese 3,330 ND 50 2S NA ND
Mercury 6.5 ND 2 0.2 2 ND
ES: Enforcement Standard, NR 140, WAC
PAL: Preventive Action Limit, NR 140, WAC
MCL: Maximum Contaminant Level, Safe Drinking Water Act
BD: Background Level - -,-
ND: Not-Detected
NA: Not Available
1 Secondary MCL
2 Action Level value
-------
16
Ingestion of groundwater; and
Inhalation of VOCs by residents located near and
far downgrdient of the Site while showering.
Under future-use conditions,
selected for evaluation:
Ingestion of groundwater by a future resident on
the Site; and
the
following
pathways
were
Inhalation of VOCs while showering by a future
residents on the Site..
For the ingestion of groundwater by current and future
residents, adult residents were assumed to weigh 70 kg and
ingest two liters of water per day, 350 days per year and to
live in the same location for 30 years of their 70-year expected
lifetime. For the inhalation of VOCs while' showering, an
exposure time of 17 minutes, a frequency of exposure of 350 days
per year, and a duration of exposure of 30 years were assumed.
The maximum concentration of contaminants of concern was used
for groundwater to calculate the risk. For the inhalation
exposures while showering, the exposure point concentrations
were calculated using a shower model.
0"
3 . '~oxici ty Assessment
The harmful effects, or toxicity, of a chemical in terms of its
potential cancerous and non-cancerous health effects were
evaluated. Research was conducted to determine the toxicity of
chemicals, and the results and conclusions of this research were
used in the evaluation of the toxicity of Site-related
contamination. In the research of a chemical's toxicity, the
effects of lo~evels of chemical exposure on people in the
workplace are -studied over long periods of time, and test
animals are studied in laboratories., where animals are exposed
to varying levels of chemicals over different lengths of time.
Cancer slope factors have been developed by U.S. EPA's
Carcinogen Assessment Group for estimating excess lifetime
cancer risks associated with exposure to potentially
carcinogenic chemicals. Slope factors, which are expressed in
units of (mg/kg-day)-l, are multiplied by the estimated intake of
a potential carcinogen, in mg/kg-day, to provide an upper-bound
estimate of the excess lifetime cancer risk associated with
exposure at that intake level. The term "upper bound" reflects
the conservatiye estimate of the risks calculated from the
cancer slope factor. Use of this approach makes underestimation
of the actual cancer risk highly unlikely. Cancer slope factors
-------
17
are derived from the results of human epidemiological studies or
chronic animal bioassays to which animal-to-human extrapolation
and uncertainty factors have been applied. Table 2 contains the
cancer slope factors for carcinogenic contaminants of concern at
the site.
Reference doses (RfDs) have been developed by u.s. EPA for
indicating the potential for adverse health effects from
exposure to chemicals exhibiting noncarcinogenic effects. RfDs,
which are expressed in units of mg/kg-day, are estimates of the
daily exposure to the human population (including sensitive
subpopulations) that is likely to be without an appreciable risk
of deleterious effects during a lifetime. RfDs are derived from
human epidemiological studies - or animal studies to which
uncertainty factors help ensure that the RfDs will not
underestimate the potential for adverse noncarcinogenic effects
to occur. The reference doses for contaminants of concern at
the'Site are specified in Table 2. -
4.
Risk Characterization
Using the maximum levels of each contaminant detected in the
groundwater for each respective calculation, the excess cancer
risk and non-cancerous effects were calculated for current and
future scenarios. Under current-use conditions, the
groundwater data used was from monitoring wells located near and
far downgradient from the Site. The cancer risk due - to the
ingestion of groundwater near downgradient is 2 X 10~.
The cancer risk due to the inhalation of VOCs from showering is
2 X 10~. The hazard index for ingestion of near downgradient
groundwater is 3, and far downgradient groundwater is 10. The
higher hazard index for far downgradient groundwater (10) is the
result of higher contaminant concentrations detected in far
downgradient wells. Higher contaminant concentrations in far
downgradient - wells may possibly be due to downward vertical
gradients of the plume. The hazard index numbers indicate that
exposure to contaminants may produce harmful, non-cancerous
effects.
Accordingly, under future-use conditions, it is assumed that
residential housing would be developed around the Site. The-
groundwater data collected from on-property wells were used to
calculate the risk for the future-use scenario. The cancer risk
through the ingestion of groundwater in shallow wells is 2 X 10-3.
The hazard index from shallow wells located on site is 6,000.
U.S. EPA considers these risks unacceptable. Table 3 contains
the cancer risk and hazard index for current and future cases.
-------
TABLE 2
Hagen Farm Landfill Site
ORAL TOXICITY CRITERIA FOR CHEMICALS OF POTENTIAL CONCERN
Chemical Chronic Reference Dose Slope Factor
(mglkg - day)"1 (mglkg - day)"l
Dreanic Chemicals
Acetone -- l.00E-OI
Benzene 2.90E-02 -
Benzoic Acid -- 4.00E+OO
Benzyl alcohol -- 3.00E-OI
2-Butanone (methyl ethyl ketone) -- S.OOE-02
Chlorobenzene - 2.00E-02
--
Chloromethane 1.30E-02 -
4,4'-DDE 3.40E-Ol -
Di-n-octylphthalate - 2.00E-02
1,4-Dichlorobenzene 2.40E-02 l.00E-ol
l,l-Dichloroethene 6.00E'{) 1 9.00E.oo
1,2-Dichloroethene - 2.00E-m
Dieldrin l.60E+Ol S.OOE-05
Diethylphthalate - 8.00E-Ol
2,4-Dimethylphenol -- 2.00E-02
Ethylbenzene - l.00E-Ol
4-Methylphenol (p-<:resol) --- S.OOE-02
Naphthalene -- 4.00E-03
Phenol - 6.00E-Ol
Tetrahydrofuran -- 2.00E-03
Toluene - 2.00E-Ol
Vinyl Acetate - l.00E+OO
Vinyl Chloride 1.90E+OO -
Xylenes (total) --- 2.00E+OO
Inor2anic -Chemicals
Arsenic 1.80E+OO l.OOE-03
Barium -- 7.00E-02
Copper - 3. 70E-02
Manganese - --- - l.00E-Ol
Mercury - 3.00E-04
Nickel - 2.00E-02
Vanadium - 7.00E-03
Zinc and compounds - 2.00E-Ol
-------
TABLE 3
Hagen Farm Landfill Site
SUMMARY OF POTENTIAL HEALTH RISKS ASSOCIATED WITH
CURRENT AND FUTURE LAND USE CONDmONS
Upper Bound Hazard Index for
Exposure Pathway Excess Lifetime Noncarcinogenic
Cancer Risk" Effects b
Current Residents
Ingestion of Groundwater (Off-property Shallow Wells)
.'
Downgradient - Near 2E-04 >1 (3)
Downgradient - Far - > 1 (10)
Inhalation of Volatiles from Sowering with Groundwater
(Off-Property Shallow Wells)
Downgradient - Near 2E-OS <1
Downgradient - Far 8E-07 <1
Future Residents
Ingestion of Groundwater
Hypothetical Resident on Property
(Shallow wells) 2E-03 > 1 (6,000)
(Shallow wells - On Property Data) - > 1 (30)
(Deep wells) 2E-OS > 1 (300)
Inhalation of Volatiles from Showering with
On-Site Groundwater
Hyptothetical Resident
(Shallow wells) 2E-04 > 1 (300)
(Shallow wells - On Property Data) - =lc
(Deep wells) SE-06 >1 (9)
a The upper bound individual excess lifetime cancer risk represents the additional probability
that an individual may develop cancer over a 70-year lifetime as a result of exposure
conditions evaluated. .
b The hazard index indicates whether or-flot exposure to mixtures of noncarcinogenic chemicals
may result in adverse health effects. A hazard index less than one indicates that adverse
human health effects are unlikely to occur.
C When recalculated by target organ or effect, all hazard index values were less than one.
-------
20
b.
Environmental Risks
An ecological risk assessment was conducted to
potential impacts on nonhuman receptors associated
site. An evaluation of selected terrestrial plants
organisms (earthworms) to chemicals of potential
indicated that neither plant nor earthworm populations
adversely affected.
evaluate
with the
and soil
concern
would be
VII.
DOCUMENTATION OF SIGNIFICANT CHANGES
No significant changes have been made
publication of the FS and Proposed Plan.
since
the May
1992
VIII.
DESCRIPTION OF ALTERNATIVES
Based on the results of the RI and risk assessment, an FS was
conducted to identify and evaluate a variety of alternatives for
protecting human heal th and the environment from the
contamination associated with the groundwater contamination at
the site. After identifying and screening potential remedial
technologies for the Site, two alternatives were selected for
further evaluation. The selection of these two alternatives
from various remedial technologies was based on the screening
process considering the remediation goal, the results of the
treatability study, volume of groundwater to be treated,
contaminant levels, and the merit of the technology. Each of
the alternatives is evaluated using a set of nine criteria.
These criteria reflect the goals of< the Superfund program. They
are used by u.S. EPA to compare the merits of each alternative.
These criteria are explained in Section IX.
Descriptions of the two alternatives considered by u.S. EPA are
provided below, including costs, estimated in terms of capital
cost and annual operation and maintenance cost. Together, these
dollar amounts are converted to net present worth. u.S. EPA's
evaluation of each remedial alternative using the evaluation
criteria is summarized in section IX.
Due to the relatively low concentration levels of contaminants
detected off-property and lack of information collected for the
off-property aquifer, th~_._groundwater contamination at the site
was separated into on- and off-property groundwater
contaminatipn. The terms "on-property" and "off-property" are
defined in Section II. More studies will be conducted off-
property as part of the RD/RA Phase to characterize the off-
property aquifer and to gather other necessary information.
-------
21
The alternatives considered for the GCOU are:
Alternative 1:
No Action.
Alternative 2:
Groundwater extraction and treatment;
Discharge of treated groundwater to the wetlands
or Yahara River.
A description of each of these alternatives follows:
Alternative 1:
No Action
Under this alternative, the site would be left in its present
condition and no action would be taken to reduce the risk of
exposure to contamination. u.s. EPA requires consideration of
a no-action alternative to serve as a basis against which other
remedial alternatives can be compared. Under this alternative,
groundwater-quality monitoring of selected on-property, off-
property, and all private wells located on and around the Site
will be continued.
The capital cost of this alternative is approximately $179,000,
and annual Operation and Maintenance (O&M) is $50,000. The 30-
year present net worth (PNW) cost is $1,025,000.
Alternative
(a)
2:~1Groundwater extraction and treatment;
'..Discharge of treated groundwater to the wetlands
"or Yahara River.
~.; ! .
. \'
Groundwater Extraction and Treatment
Under this alternative, on-property groundwater will be
extracted and treated using an activated sludge biological
system. The off-property groundwater will be extracted and
treated using ~e treatment technology which will be selected
during the ReBl~dial Design (RD) stage. The off-property
treatment technology will selected during the RD stage because
additional information is needed' concerning the off-property
aquifer. The treated groundwater will be discharged into the
wetlands or Yahara River. The treated on-property groundwater
may also be reinjected to the on-property aquifer with nutrients
and/or oxygen to enhance-- biodegradation. The private wells
located around the site will be monitored. It is anticipated
that aquifer restoration under this alternative may require a 30
year period.' .
Groundwater extraction will be performed by a series of
groundwater extraction wells placed at strategic locations
downgradient of the source of contamination. The precise
location, number, and depth of these wells will be established
in the RD phase. preliminary aquifer flow analysis indicates
-------
22
that wells extracting 100 to 180 gallons per minute (GPM) should
contain and significantly reduce the contamination within the
plume.
The extracted groundwater from on-property will be treated using
an activated sludge biological system. In a biological
treatment process, the contaminants act as an energy source for
biological microorganisms. If, over time, the contaminant
concentrations become too low to support biological growth,
additional materials (e.g., milk whey) may be added to maintain
optimum biological activity for contaminant degradation. When
influent contaminant concentrations in the biological process
decrease to a level insufficient to support biological activity
without large additions of substrate, a more cost-effective
option may be to switch. to a physical or chemical treatment
process, such as Granular Activated Carbon (GAC). The
biological system should remove up to 99 percent of the
contaminants in the groundwater. Prior to the biological
treatment, the extracted on-property groundwater would be passed
through the pretreatment facility to remove metals and inorganic
solids.
In addition, the treated on-property groundwater may be enhanced
with nutrients and/or oxygen and reinjected into the aquifer to
promote in-situ contaminant biodegradation in groundwater and
saturated soils, potentially decreasing the time necessary for
extraction and treatment. The reinjected water may also help
flush additional contaminants from the aquifer. Preliminary
groundwater flow analysis indicated that approximately 30
percent of the total on-property extraction volume will be
treated to NR 140 Preventive Action Limits (PALsf by biological
treatment and reinjected into the aquifer. Because the
effectiveness of this enhancement is uncertain, full
implementation should be preceded by a testing and evaluation
phase to determine the feasibility of performing long-term in-
situ bioremediation treatment. A bench scale study would be
implemented first to determine the effect of nutrients and
oxygen on contaminated groundwater. If the bench scale study
shows positive results, a pilot study would be conducted with
the ultimate goal of enhancing the selected remedy with an in-
situ groundwater bioremediation system.
For the treatment of ext-racted off-property groundwater, the
. following five technologies will be evaluated:
Option 2A:
Option 2B:
Option 2C:
Option 2D:
Option 2F;:
Cascade Aeration
Biological Treatment
Air Strippir:tg
Granular Activated Carbon
Ultraviolet (UV)-Chemical
(GAC)
Oxidation
-------
23
option 2A: Cascade Aeration
The cascade aeration system utilizes a modified pipeline with an
open channel gravity flow section in order to strip the VOCs in
the groundwater. This flow section would create turbulence in
the water and enhance air-water contact prior to discharge to
the Yahara River. This open channel segment would promote the
transfer of volatile contaminants to the air. It is expected
that the cascade aeration system is "not as efficient as the air
stripping process evaluated in the treatability study, and would
remove less than 40 percent of the THF in the off-property
groundwater. Pretreatment for met"als and inorganic solids would
be necessary prior to cascade aeration. Since cascade aeration
has a low removal rate for THF, the treated groundwater using
cascade aeration will not .be discharged into the wetlands.
option 2B: Bioloqical Treatment
Off-property groundwater would be combined with more highly
contaminated groundwater from on site, pretreated to remove
metals and inorganic solids, and then biologically treated to
remove the organic compounds. If combined groundwater
contamination concentrations from both. on- and off-property
become too low to support biological growth, additional
substrate material may be added to maintain optimum biological
activity for contaminant degradation.
Option 2C: Air Strippinq
Off-property groundwater would first be pretreated to remove
metals and inorganic solids, and then conveyed to a packed-tower
air stripper which uses countercurrent aeration, in which
influent water flows into the top of the tower and cascades
through a packing media, while air is forced upward through the
tower. This allows a transfer of contaminants in the liquid
phase to the gas phase by providing a larger contact surface and
void volume for phase tr~nsfer of the contaminants and a
sufficient residence time for the transfer to occur. The air
stripping could reduce THF contamination by up to 40 percent and
remove other less soluble VOCs by greater amounts. The treated
groundwater using air stripping will not be discharged to
wetlands due to the low removal rate.
-. -....'
Option 2D: Granular Activated Carbon (GAC)
Off-property groundwater would first be pretreated to remove
metals and inorganic solids, and then conveyed to the GAC bed,
where contaminants are adsorbed on the carbon. When the
capacity of the carbon is exhausted, the bed is taken out of
service and the spent carbon either regenerated or disposed of
in an off-site landfill to meet the Land Disposal Restriction
requirements. Based on the treatability study, the GAC would
;.
-------
24
remove up to 99 percent of the contaminants in the groundwater.
However, the main contaminant in the off-property groundwater,
THF, is not readily adsorbable, and will require large
quantities of GAC for complete adsorption.
Option 2E: Ultraviolet (UV)-Chemical Oxidation
Chemical oxidation and UV light would be used to destroy VOCs in
the contaminated off-property groundwater. Chemical oxidation
uses strong oxidizing agents to react and destroy organics in
groundwater. UV light would be used in conjunction with the
oxidizing agents (such as hydrogen peroxide and ozone) to
improve the oxidation process efficiency. The treatability
study for on-property groundwater indicated that data from
vendors show that UV/peroxide oxidation with pre-filtration was
able to remove THF concentrations as high as 57,000 ug/l. This
technology should remove up to 99 percent of the contaminants
from the extracted off-property groundwater. consequently, this
process will need to be preceded by an inorganics removal
pretreatment process such as air oxidation/precipitation or pH
adjustment to remove metals which could cause scaling on
ultraviolet lamps.
lb) Selection
Teehnoloqy
of
Off-Propertv
Groundwater
Treatment
U. s. EPA, in consultation with WDNR, will select the off-
property groundwater treatment "technology from the five
technologies described above. The selection of the technology
will be based on design information including, but not limited
to, an off-property pump test, off-property treatability study,
and bio-assay test. U.s. EPA will consider the off-property
aquifer characteristics, the surface water discharge limits for
the contaminants of concern for discharge to the Yahara River,
groundwater discharge limits for the contaminants of concern for
discharge to wetlands, and the ability of these technologies to
meet ARARs. After selection of the off-property groundwater
treatment technology, the U.S. EPA will issue an explanation of
significant differences (ESD) to inform the public of U.s. EPA's
decision.
" (c)
Discharqe of Treated Groundwater
The treated on- and off-property groundwater could be discharged
to the Yahara River through an 11,000-foot force main water line
which must, at some point, tunnel beneath the Chicago,
Milwaukee, st. Paul, and Pacific Railroad line which lies
between the Site and the Yahara River. The cascade aeration
treatment system would replace a segment of the force main if
that treatment system is selected for off-property groundwater.
The treated groundwater could also be discharged into wetlands.
-------
25
The discharge location will be determined after a Site specific
evaluation including an evaluation of the impact of ARARs on the
design of the groundwater extraction and treatment system and
effluent discharge limits.
(~)
Groundwater Cleanup and Discharqe Standards
Groundwater will be extracted until the groundwater no longer
attains or exceeds Wisconsin NR 140 PAL standards at the point
of compliance and beyond. Consistent with the exemption
criteria of NR 140.28, WAC, an alternative concentration limit
(WACL) may be established if it is determined that it is not
technically or economically feasible to achieve the PAL for a
specific substance. The point of compliance shall be the waste
management boundary.
Discharge of treated groundwater to the Yahara River will be
required to comply with the requirements set forth in a WPDES
permit, since discharge to the Yahara River would be considered
an off-site discharge.
Discharge of treated groundwater into the wetlands via the
drainage ditch near the southeast corner of the Site or directly
to the wetlands will be required to meet the substantive
requirements of a WPDES permit and::shall comply with NR 140, PAL
standards. In addition, the state of Wisconsin also has
policies on protection of wetlands which shall be complied with
for actions affecting wetlands including NR 1.95 and 103 Wis.
Adm. Code. Impacts to the wetlands will be considered and
minimized to the extent possible during the design phase of this
remedial action as directed in Executive Order 11990.
(e)
Air Emission Treatment
The emitted gases produced by waste water treatment system will
be treated to meet state air-quality standards in accordance
with the Clean Air Act (CAA) and NR 400 through 499, WAC.
(f)
Sludae Manaaement
All residue, sludge, and/or spent coagulants/agents from the
treatment of groundwater shall be treated to meet the Land
Disposal Restriction (LDR}" standards for F003-F005 wastes prior
to disposal in a Resource Conservation and Recovery Act (RCRA)
landfill in accordance with the requirements of 40 CFR 268.41.
Spent carbon will be regenerated or treated to meet the LDR
requirements.
-------
26
(q)
Cost
Depending on the selection of off-property groundwater treatment
options and the location of discharge of treated groundwater,
the cost of this alternative will vary. The detailed cost
information is contained in Table 4. The capital costs range
from $4,396,000 to $6,288,000, annual O&M costs range from
$550,000 to $1,027;000~ and 30-year total PNW cost ranges from
$13,612,000 to $24,163,000.
IX.
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
A detailed analysis was performed on the two alternatives using
the nine evaluation criteria in order to select a groundwater
control' remedy. The following is a summary of the comparison of
eachal ternati ve' s strength and weakness with respect to the
nine evaluation criteria. These nine criteria are:
1)
2)
3)
4)
overall Protection of Human Health and the Environment
Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
Long-Term Effectiveness and Permanence
Reduction of Toxicity, Kobility, or Volume through
Treatment
Sbort-Term Effectiveness
%mp1ementability
Cost
state Acceptance
Community Acceptance
5)
6)
7)
8)
9)
h
1.
Overall Protection of Human Health and the Environment
Alternative 1, No Action, will not provide adequate protection
from risks associated with contaminated groundwater. The
private wells located downgradient of the site might be exposed
in the future. Theref ore, it will not be discussed any further,
since it is not protective and, thus, not an acceptable
alternative. Additional contaminant loading into the aquifer
will, however, be reduced by implementation of the cap and ISVE
system determined in the ROD of the SCOU.
Alternative 2 provides protection of human health and the
environment because it - includes an extraction and treatment
system to remove and treat the contaminated groundwater from the
aquifer.
2.
ComDliance with ARARs
Alternative 2 would comply with all applicable'or relevant and
appropriate federal and state environmental laws.
-------
TABLE 4
Summary of Cost Estimates for
Hagen Farm GCOU Feasibility Study Alternatives
Alternatve 1: No Action
Capital Costs
Annual Operating Costs
Total Present Net Worth
$ 179,000
$ 50,000
$ 1,025,000
Alternative 2: Extraction, Treatment, and DN:barge
Alternative
Option 2A:
Activated Sludge
Cascade Aeration
Option 2B:
Activated Sludge
Option 2C:
Activated Sludge
Air-Stripping
Option 2D:
Activated Sludge
GAC
Option 2E:
Activated Sludge
UV -Chem Ox
Dischazge to
Yahara River
Dischazge to
Wetlands
Capital Costs
Annual Operating Costa
Total Present Net Worth
$ 4,396,000
$ 550,000
$13,612,000
N/A
Capital Costs
Annual Operating Costs
Total Present Net Worth
5,217,000
699,000
16,943,000
4,413,000
665,000
15,589,000
Capital Costs
Annual Operating Costs
Total Present Net Worth
5,816,000
765,000
18,645,000
N/A
Capital Costs
Annual Operating Costs
Total Present Net Worth
5.986,000
805,000
19,491,000
5,181,000
770,000
18,119,000
Capital Costs
Annual Operating Costs
Total Present Net Worth
6,288,000
1,062,000
24,163,000
5,482,000
1,007,000
22,790,000
Note:
1. Present net worth assumes 30 years of operation, 9% discount rate, and a 5% inflation rate.
2.
N/A indicates not applicable for the alternative or option.
3. The Alternative 2 costs include in-situ bioremediation.
_.-
-------
28
The major groundwater ARARs include the Federal Safe Drinking
Water Act (SDWA) and State Groundwater Quality Standards, NR
140, WAC.
The major surface water discharge ARARs include Chapter 147
Wisconsin Statutes, NR 102 , 104, 105, 106, 108, 200, 207 , 219,
and 220 of WAC.
The major wetland discharge ARARs include NR 1.95, 103, and 140
(PAL Standards) of WAC, and the substantive requirements of a
WPDES permit (Chapter.147 Wisconsin Statutes, NR 102, 104, 105,
106, 108, 200, 207, 219, and 220 of WAC).
The groundwater wells for the alternatives
according to the standards listed in NR
Wastewater treatment facility standards
according to NR 108, WAC.
will be constructed
112 and 141, WAC.
will be followed
Water used for in-situ bioremediation will be treated to achieve
NR 140, PALs prior to re-injection into the aquifer. Any
proposal to re-inject treated groundwater enhanced with
nutrients and/or oxygen must comply with the substantive
requirements of Ch. NR 112, WAC. Feasibility and evaluation
testing of in-situ bioremediation should be evaluated during
implementation of the remedial action.
NR 445, Control of Hazardous Pollutants, is an ARAR for
Alternative 2. Off-gases generated from the treatment process
should be treated in order to meet NR 445 emission limit
requirements. In general, NR 400 to 499, WAC (Air Quality
Management) is an ARAR for the emission of off-gas.
A more complete list of ARARs is included in Section XI.
3.
Lona-term Effectiveness and Permanence
Cascade aeration and air stripping may require consideration of
the residual risks due to potential exposure to the community.
This exposure may occur through inhalation of volatilized
contaminants from the aeration channel and air stripper,
respectively, if they exceed NR 445 standards. Alternative 2
also has a ri~k component due to the residual contamination in
the water being discharge~.to the Yahara River. The risk due to
the implementation of air stripping may be slightly less than
from cascade aeration because the air stripper is expected to
remove more contaminants than the cascade aeration system.
Potential risks exist for all treatment options due to the
transport, storage, and disposal of pretreatment and treatment
process residuals which may be hazardous waste. The level of
risk is approximately proportional to the quantities of waste
generated. The GAC has greater potential risk because it
-------
29
generates residuals from activated carbon treatment process.
Biological treatment, air stripping, and UV-chemical oxidation
generate slightly less treatment process residuals. Cascade
aeration generates the smallest volume of potentially hazardous
waste because there might be no pretreatment process for the
water, and the cascade aeration treatment process generates no
residuals.
There is no difference between the effectiveness of the
institutional controls or the proposed groundwater monitoring
for any of the treatment options in Alternative 2.
The surface water discharge limits, which.will be established by
u.s. EPA in consultation with WDNR, will determine whether the
contaminant removal levels for off-property groundwater
treatment options, cascade aeration and air stripping, are
adequate. Treatment options such as biological treatment, GAC,
and UV-chemical oxidation should be adequate for treatment to
the required discharge limits.
4.
Reduction in Toxicitv. Mobilitv. or Volume
Alternative 2 uses a groundwater well extraction network to
remove contaminated groundwater from the ground and a biological
treatment process to remove organics from the extracted on-
property groundwater. Pretreatment would be included and would
likely consist of a precipitation process to remove inert solids
and metals.
The amount of hazardous materials extracted from the groundwater
aquifer is the same, regardless of which treatment option in
Alternative 2 is selected. .
The biological treatment system proposed to treat extracted
groundwater from on-property is expected to remove up to 99
percent of the contaminants in the groundwater. Based upon the
treatability study, the cascade aeration system proposed for
off-property groundwater is expected to be less efficient than
air stripping. Cascade aeration is expected to remove less than
40 percent of the THF in the off-property groundwater. It is
also expected to remove the less-soluble VOCs (e.g., vinyl
chloride) in the contaminated off-property groundwater. The
biological treatm.ent is ..expected to remove up to 99 percent of
the contaminants in the off-property groundwater. The air
stripper system is expected to remove up to 40 percent of the
THF and provide even greater reduction of other less-soluble
VOCs in the contaminated groundwater. The GAC treatment system
and the UV-chemical oxidation system is expected to remove up to
99 percent of the contaminants from the extracted off-property
groundwater. Removal efficiencies are based upon the
treatability study, which was conducted using on-property
contaminant concentrations. Actual removal efficiencies' are
-------
30
dependent upon field conditions, and would need to be further
evaluated in the RD phase.
Reduction of hazardous materials through in-situ bioremediation
cannot be estimated at this time. Evaluations of the
effectiveness of in-situ bioremediation will be made in the in-
situ bioremediation pilot testing phase conducted when the GCOU
extraction system has equilibrated. Prior to conducting the in-
situ bioremedial pilot testing phase, groundwater injection
should be performed and the system allowed to reach equilibrium.
An evaluation to assess the incremental benefit attributable to
reinjection without the addition of nutrients and/or oxygen can
then be made.
Alternative 2 will reduce the toxicity and volume of the
contamination in the aquifer, and limit additional contaminant
migration.
In-situ bioremediation may increase the rate of in-situ
biodegradation. This potential for increased biodegradation
will be evaluated by feasibility testing in the RA
implementation phase.
The extraction of contaminated groundwater and subsequent
treatment for all treatment options is irreversible. In-situ
biodegradation reactions for the treatment of organic compounds
is also irreversible.
In-situ bioremediation has the potential to reduce groundwater
concentrations below those achievable by extraction alone.
However, some residual contaminants are expected to remain under
any extraction or in-situ treatment method.
The pretreatment system and biological treatment system for on-
property groundwater treatment will produce an estimated 550
pounds per day of metal and inorganic residuals, which may be
hazardous. The biological treatment system is expected to
produce an estimated 170 pounds per day of potentially hazardous
sludges due to inclusion of the off-property groundwater in the
treatment process. The air stripping system, GAC, and UV-
chemical oxidation are each expected to produce an additional
estimated 200 pounds per day of potentially hazardous sludges.
Sludge generation rates- ..are based on sludge generation data
gathered in the treatability study. GAC is also estimated to
produce 75 "pounds per day of spent carbon from the GAC process.
All Alternative 2 options will reduce the inherent" hazards posed
by the groundwater contamination at the Site to risk levels
considered protective of human health and the environment
through groundwater extraction and treatment.
-------
31
Activated sludge biological treatment would utilize the ability
of certain bacteria to break down organic compounds into carbon
dioxide and water. Cascade aeration and air stripping' involve
the transfer of volatile contaminants to the air. The
contaminants in the off-gas could be adsorbed in the carbon and
treated if spent carbon is regenerated. Regeneration usually
involves heating the carbon to very high temperature in a kiln
to desorb the contaminants. The des orbed contaminants can then
be incinerated. GAC utilizes the adsorption process in which
molecules in an aqueous solution adhere to the surface of a
solid. The contaminants which adhered in the surface of a
carbon bed can be treated through a regeneration process. UV
oxidation involves the use of UV radiation in conjunction with
one or more oxidizing agents, usually ozone or hydrogen
peroxide, to chemically destroy organic contaminants. Ozone and
hydrogen peroxide are both strong oxidizing agents that can
chemically break down organic compounds. In the presence of UV
radiation, ,the effectiveness of these oxidizing agents is
dramatically increased.
5. Short-term Effectiveness
Risks to the community from Alternative 2 are due to the off-
site transport of sludges and treatment residues generated by
the pretreatment and/or treatment processes for each treatment
option. The level of risk is approximately proportional to the
quantities of wastes generated.
Alternative 2 should cause no additional risks to workers beyond
normal risks associated with construction, provided that a
Health and Safety Plan is developed and followed.
The disturbance of the wetlands due to monitoring and extraction
well construction could occur during the construction 'of
Al ternati ve 2, depending upon well locations. Wetlands may also
be damaged during winter months by ice buildup from continual
water discharges to wetlands from the treatment of the
biological system, GAC, or UV-chemical oxidation. Such damage
should not occur if preventative measures such as intermittent
pumping or engineered control systems (e.g., stilling basins)
are employed. Such damage could be avoided entirely if treated
wastewater is discharged to the Yahara River instead of the
wetlands. These potential impacts to the wetlands will be
evaluated during the RD phase and will be minimized.
For Alternative 2, the time required to achieve the RA
objectives is limited by the extraction technology, as described
in Alternative 2. Remediation times are described in terms of
advective flushing times. The effects of retardation and
dispersion are not accounted for in the groundwater remediation
time estimates. Advection flushing time is between 10 and 15
years for Al ternati ve 2. The addition of in-situ bioremediation
-------
o
32
may decrease the remediation time to between 5 and 10 years.
Actual cleanup time will likely be substantially longer due to
the effects of retardation and dispersion, although these
effects may be offset by the degradation stimulated by in-situ
bioremediation.
6.
Implementability
The extraction well
implementable.
network
for Alternative
2
is
readily
The technologies required to implement the treatment system for
Alternative 2 and its off-site treatment option are readily
.available, although the biological treatment system requires a
start-up period before. it reaches the optimum operating
efficiency. If intermittent pumping is required to reduce
impacts to the wetlands, operation of a biological treatment
system will be difficult to control. However, intermittent
pumping of individual wells should be possible without causing
operational problems. .
A testing and evaluation period is needed to determine if in-
situ bioremediation is technically feasible before full-scale
implementation. The biological treatment system which reduces
contaminant levels to required discharge levels may require
modifications as groundwater contaminant levels decrease over
time. All off~property treatment options may require a pilot
. scale test t6' establish operation parameters of treatment
technology.
I'
Discharge standards to the Yahara
before it will' be known whether
cascade aeration or air stripping,
standards.
River need to be determined
treatment options, such as
meet surface water discharge
Alternative 2~equires additional materials and services.
However, these ~aterials are expected to be readily available.
If shown to be feasible, in-situ bioremediation utilizes
materials and services available from the consulting and
environmental services communities.
7.
Cost
-. --'
The cost of each alternative is summarized in Table 4.
8.
state Acceptance
The WDNR concurs with the. selection of Alternative 2 on the
condition that.:the WDNR determines, at the time the proposed
treatment design is finalized, that the effluent discharge
limits and discharge location (including any reinjection of
enhanced grouridwater which is proposed) are acceptable to the
-------
33
WDNR and are in compliance with the effluent discharge limit
requirements of Chapters NR 102, 104, 105, 106, 108, 200, 207,
219 and 220, WAC, Ch NR 140, WAC, PAL Standards, the wetlands
protection in Ch NR 103 WAC, and the applicable air quality
standards in Chs NR 400 to 499, WAC.
9.
Community Acceotance
The specif ic comments recei ved and u. S. EPA' s responses are
outlined in the attached Responsiveness Summary.
x
THE SELECTED REMEDY
As provided in CERCLA and the NCP, and based upon the evaluation
of the RI/FS and the nine criteria, u.S. EPA, in consultation
with the WDNR, has selected Alternative 2 as the groundwater
control remedial action at the Hagen Farm Site.
.
Institutional controls would include on-property land and
on- and off-property groundwater use restrictions in the
form of existing deed restrictions to the extent necessary
to implement and protect the remedy, and to safeguard human
health and the environment during implementation of the
remedy. The cooperation of local agencies would be
required to limit future off-property use of groundwater if
the Respondents are unable to obtain deed restrictions from
affected property owners. A fence shall be installed
around the treatment facility system in order to prevent
public access. .
Additional monitoring will be conducted in the selected on-
and off-property monitoring wells and all of the private
wells located around the Site, including but not limited
to, the wells located on the properties of Fosdohl, Lee,
Van Deusen, Sundby, Sundby Sand and Gravel, K-Way
Insulation, GUllickson, Quam, Stoughton Conservation Club,
Saqmoen, and Gjertson.
.
.
Extracted groundwater from on- and off-property would be
pretreated for the removal of metals and inorganic solids.
.
On-property qroundwater will be extracted until the
groundwater at the waste management boundary and beyond
(area of attainment) no longer attains or exceeds
Wisconsin NR 140 PAL standards, and treated using an
activated sludqe biological system. All residue and/or
sludge shall be treated. as appropriate to meet the LDR
standards for F003-F005 wastes and. shall be placed in a
RCRA landfill in accordance with the requirement of 40 CFR
268.41.
-------
34
.
Off-property groundwater will be extracted until the
groundwater within the area of attainment no longer attains
or exceeds Wisconsin NR 140 PAL standards and treated
using an appropriate treatment technology. Treatment
technologies such as cascade aeration, activated sludge,
air stripping, GAC, or UV-oxidation shall be evaluated
during the RD stage. Based on the off-property pump test,
bioassay test, BAT requirements, surface water discharge
limits, and other related factors, the technology will be
selected for off-property groundwater treatment. The
emitted gases will be treated to meet State air-quality
standards of NR'" 445, WAC. All residue, sludge, and/or
spent coagulants shall be treated as appropriate to meet
the LDR standards for F003-F005 wastes and shall be placed
in a RCRA landfill in accordance with the requirement of 40
CFR 268.41. The spent carbon could be regenerated or
treated to meet LDR requirements prior to land disposal.
A bench scale study will be conducted to examine the
feasibility of injecting the treated on-property
groundwater into the on-property aquifer in order to
enhance in-situ bioremediation. Nutrients and/or oxygen
would be added in order to promote the natural microbial
degradation of organic compounds. The study will be
designed to determine the optimum amounts of nutrients to
be added to the aquifer, and the amount of groundwater to
, be injected. If determined to be feasible, a pilot study
would be implemented with the ultimate goal of enhancing
the selected remedy with a full scale in-situ groundwater
bioremediation system. The discharge limit of NR 140, PAL
standards shall be met in order to inject treated
groundwater into the on-property aquifer.
.
.
The treated groundwater will be discharged to the Yahara
Ri ver or nearby wetlands. Discharge of treated groundwater
into the wetlands via the drainage ditch near the southeast
corner of the Site or directly to the wetlands should meet
the substantive requirements of a WPDES permit and shall
comply with NR 140, PAL standards. In addition, the State
of Wisconsin also has pOlicies on protection of wetlands
which shall be complied with for actions affecting wetlands
including NR 1.95 and 103, Wis. Adm. Code. Impacts to the
wetlands will be considered and minimized to the extent
possible during the design phase of this remedial action as
directed in Executive Order 11990. Discharge of treated
groundwater to the Yahara River will be required to comply
with the requirements set forth in a WPDES permit, since
discharge to the Yahara River would be considered an off-
site discharge.
-------
35
XI.
STATUTORY DETERMINATIONS
The selected remedy must satisfy the requirements of Section 121
of CERCLA to:
c.
protect human health and environment;
comply with ARARs;
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.
a.
b'.
d.
e.
The implementation of Alternative 2 at the site satisfies the
requirements of CERCLA as detailed below:
a.
Protection of Human Health and the Environment
This selected remedy will provide adequate protection of human
health and the environment through treatment.
Risk posed by groundwater contamination will be reduced and
controlled by the operation of a groundwater extraction and
treatment system. Access restrictions will prevent direct
contact with contaminated groundwater until groundwater cleanup
standards are met. .
No unacceptable short-term risks will be caused by
implementation of the remedy. Standard safety programs, such as
fencing, use of protective equipment, monitoring, and off-gas
treatment, should mitigate any short-term risks. Short-term
risks include exposure of site workers and the community to
VOCs, and to noise nuisance during implementation of the
groundwater remedy. Ambient air monitoring would be conducted
and appropriate safety. measures would be taken if contaminants
were emitted.
b.
compliance with ARARs
The selected remedy complies with all Federal and State
environmental requirements that are legally applicable or
relevant and appropriate. -.- The maj or Federal and State ARARs for
the selected remedial alternative for the GCOU are listed below.
A)
Federal ARARs
1.
Groundwater
Relevant and appropriate requirements for
groundwater include primary drinking water
standards' established by the federal SDWA.
-------
ii.
iii
iv.
36
Several contaminants of concern identified at the
Site have Maximum contaminants Level (MCLs),
proposed MCLs and/ or Maximum Contaminant Level
Goals (MCLGs). MCLs are relevant and appropriate
to circumstances at the Site, since the aquifers
are current and potential sources of drinking
water. MCLGs are relevant and appropriate when
the standard is set at a level greater than zero
(for non-carcinogen).
The NCP 40 C.F.R. 300 et sea. provides that
groundwater cleanup standards should generally be
attained throughout the contaminant plume or at
and beyond the edge of the waste management area
when waste is left in place. At the Hagen Farm
site, groundwater quality Standards shall be
attained at and beyond the edge of the waste
management area (i.e., at the edge of the
landfill cap) since waste has been left in place.
This is considered the area of attainment.
Surface Water Discharge
Surface water quality standards for the
protection of human health and aquatic life were
developed under section 304 of the Clean Water
Act (CWA). The Federal Ambient Water Quality
criteria {AWQC} are nonenforceable guidelines
that set pollutant concentration limits to
protect surface waters that are applicable to
point source discharges, such as from industrial
or municipal wastewater streams.
National Pollutant Discharge Elimination (40 CFR
Part 125); includes best available technology.
Wetlands Discharge
Executive Order 11990,
Protection of Wetlands -
site if the discharge of
to the wetlands.
40 CFR 6.302 (a)
is applicable for this
treated groundwater is
-'~
Sludges
All sludges, residues, spent carbon, and/or spent
coagulants produced from groundwater and off-gas
treatment will be treated to LDR standards for
F003-FOOS waste prior to disposal at a RCRA
landfill in accordance with the requirement of 40
CFR 268.41. If testing determines that waste
sludge generated from the activated sludge
-------
37
biological system is not hazardous, the waste
sludge could be disposed of by on-site
landspreading or off-site landfilling. Residues
such as spent carbon from the treatment ~f
groundwater which are regenerated must be treated
in a unit in compliance with 40 CFR Part 264
Subpart X. Federal ARAR 40 CFR Part 261 - Land
Disposal Restrictions shall also be complied
with.
The sludge is not expected to contain metals at
concentrations above characteristic levels. If,
after testing by the Toxicity Characteristic
Leaching Procedure (TCLP), it is determined that
the sludge is characteristic for metals, it will
be treated to render it non hazardous.
v.
Air Emissions
National Primary and Secondary
Quality Standards (40 CFR Part 50)
Ambient
Air
National Emissions Standards for Hazardous Air
Pollutants (40 CFR Part 61)
B) State ARARs
i.
..itt~i
Groundwater
:":;;~;
. The State of Wisconsin is authorized to
administer the implementation of the Federal
SDWA. The State has also promulgated groundwater
quality standards in NR 140 Wis. Adm. Code,
which, according to WDNR, is being consistently
applied to all facilities, practices, and
~tivities which are regulated by WDNR and which
may affect groundwater quality in the State.
Chapter 160, Wis. Stats., directs WDNR to take
action to prevent the continuing release of
contaminants at levels exceeding standards at the
point of standards application (point of
compliance). PALs and Enforcement Standards
CESs), have' been promulgated in NR 140, Wis. Adm.
Code. PALs are the groundwater cleanup standards
under NR 140. PALs are generally more stringent
than corresponding Federal standards and,
therefore, are ARARs for the Hagen Farm site.
Consistent with the exemption criteria of NR
140.28, Wis. Adm. Code, u.s. EPA may establish a
Wisconsin Alternative Concentration Limit (WACL),
if, based on Site-specific monitoring data
-------
o
ii.
38
gathered before and after implementation of the
selected groundwater remedy, U.S. EPA determines
that it is not technically and economically
feasible to achieve the PALs for a specif ic
substance. Except where the background
concentration of a compound exceeds the ES, and
consistent with the criteria in NR 140.28(4) (B),
the WACL that is established may not exceed the
ES for that compound.
The implementation of the selected remedy at the
Site will be in compliance with NR 140, Wis. Adm.
Code, in that PALs will be met unless WACLs are
established pursuant to the criteria in NR
140.28, Wis. Adm. Code, in which case the WACLs
will be met. These standards will be met in
accordance with the NCP at and beyond the edge of
the waste management area.
Groundwater Monitoring and Recovery Well
requirements include NR 112, NR 141, NR 508, Wis.
Adm. Code. Groundwater monitoring wells will be
installed in accordance with NR 141, Wis. Adm.
Code. Extraction and injection wells will be
installed and operated in accordance with Ch. NR
112, Wis. Adm. Code.
~"'" ... .
Wastewater. treatment facility
according to NR 10Sh WAC.
In order to reinject the treated groundwater into
the on-property aquifer PALs under NR 140, WAC
shall be achieved.
will
followed
'! '
Surface Water Discharge
A WPDES permit must be obtained before treated
groundwater can be discharged to the Yahara
River. Discharge to the Yahara River would be
considered an off-site discharge.
The substantive requirements of WPDES for
discharg~~f wastewater (treated groundwater) to
the land and/or surface waters; effluent limits;
discharge permits; sampling/testing methods is
regulated by Ch. 147, statutes - Wastewater
Management Programs and Chs. NR 102, 104, 105,
106, 108, 200, 207, 219, and 220, WAC Surface
Water Discharge Regulations (WPDES). These
requirements are all applicable to the discharge
of treated groundwater to the Yahara River. Ch.
NR 220, WAC, requires that the effluent limits be
-------
39
based on the application of best available
technology (BAT) prior to discharge. The state
has promulgated Wisconsin Water Quality standards
and criteria (WWQC) under Chapters NR 102 and
105, WAC, and the procedures for calculating the
toxic effluent limits under Ch. NR 106, WAC,
based on the Federal AWQC developed by u.s. EPA.
NR 102, 104 and 207 WAC also apply in determining
water quality based limits.
Wetlands Discharge
iii
Discharge of treated gro~ndwater to the on-site
ditch or adjacent to the wetlands should meet the
substanti ve requirements of a WPDES perrili t and
shall comply with Ch. NR 140, PAL standards.
In addition, Ch. NR 1.95, WAC Wetlands
Preservation, Protection, and Management and Ch.
NR. 103 - Water Quality standards for Wetlands
are applicable for this site if treated
groundwater is discharged to the wetlands.
vi.
Air Emissions
The emitted gases produced by waste water
treatment system(s) will be treated to meet state
air-quality standards in accordance wit~ the
Clean Air Act (CAA) and NR 400 through 499,.WAC.
v.
Miscellaneous state ARARs
.
Discharge structures or other structures in a
navigable water (Chapter 30, Wis. Adm. Code)
.
Ch. NR 27, WAC, the state Endangered and
Threatened Species Act and Ch. NR 29, WAC, the
State Fish and Game Act are state endangered
resource laws which protect against the
"taking" or harming of endangered or
threatened wildlife resources in the area.
These would be applicable to the remedial
action in that the poisoning of endangered or
threatened species by site contaminants could
be considered by the WDNR to be a "taking".
C) "To be Considered" Requirements
CERCLA Off-site policy. (May 12, 1986), Revised November
13, 1987, OSWER DIR. 9834.11.
"Interim Policy for Promoting the In-state and On-site
Management of Hazardous Wastes in the state of wisconsin"
-------
"
40
provides a prioritization outline for the treatment and
disposal of hazardous wastes and is "to-be-considered" for
the site. If out-of-state treatment and/or disposal for
the generated sludges is determined, the written
documentation of how the waste management strategy and the
eight evaluation criteria were applied shall be submitted
to the WDNR for review and approval.
C.
Cost Effectiveness
Cost effectiveness compares the effectiveness of an alternative
in proportion to its cost of providing environmental benefits.
Table 4 lists the costs associated with the implementation- of
the remedies. .
The selected remedy is cost effective because it provides a high
degree of overall effectiveness proportiona1 to its costs. The
estimated cost of the selected rAmArly is comparable with the
other alternatives and assures-a-high'segree of certainty that
the remedy will be effecti ve in the long-term due to the
significant reduction of the toxicity of the contaminants in
groundwater.
D.
utilization - of Permanent So~ons and - A~ternat~
Treatment Technoloaies or Resource Recoverv Technoloaies to
the Maximum Extent Practicable
. ".. ....
u. S. EPA believes that the selected remedy represents the
maximum extent to which permanent solutions- and treatment
technologies can be utilized in a cost-effective manner for ~he
RA at the Site. Treatment of contaminated groundwater will
significantly reduce the hazards posed. by the contaminated
groundwater at the Site. The groundwater will be restored to
the acceptable level -to protect public health and the
environment. u.S. EPA has determined that the selected remedy
provides the best balance of tradeoffs in terms of long-term
effectiveness and permanence, reduction of toxicity, mobility or
volume through treatment, short-term effectiveness,
implementability, cost, and State and community acceptance.
E.
Preference for Treatment as a Principal Element
The selected remedy f~ the Site satisfies the statutory
preference for treatment as a principal element through
treatment of the contaminants in the groundwater. Treatment of
the on-property groundwater contaminants using an acti vated
biological sludge system will result in a significant reduction
of contaminants in the groundwater. Treatment of the off-
property contaminants using the technology selected during the
RD stage will result in a significant reduction of contaminant
toxicity in the off-property groundwater.
-------
State 01 Wisconsin
\
DEPARTMENT OF NATURAL RESOURCES
101 South Webster Street
. Box 7921
Madison, Wisconsin 53707
Carroll C. Besadny
Secretary
SUPERFUND/SOLID WASTE FAX 6()8..267-2768
TELEPHONE 6()8..266-2621
September 28, 1992
. Mr. Valdas V. Adamkus,
U.S. EPA Region V
77 W. Jackson
Chicago, III 60604
Administrator
SUBJECT:
Concurrence on The Selected Groundwater Control Remedy,
Hagen Farm Site, Town of Dunkirk, Dane Co., WI
. Dear Mr. Adamkus:
The Department is providing you with this letter to document our concurrence
with the remedy selected for the groundwater control operable unit at the
Hagen Farm Superfund site. The proposed groundwater remedy, as outlined in
the June, 1992 Proposed Plan, will address the contaminated groundwater both
on and off site, and is considered the final remedy for the groundwater at the
site. The selected remedy is alternative 2, which includes:
* Groundwater use restrictions in the form of deed restrictions to the extent
necessary to implement and protect the remedy;
z,.
* Installation of a fence around the treatment system;
* Additional monitoring to determine the depth and extent of off-site
contamination;
* A series of groundwater extraction wells both on and off-site designed to
actively restore the groundwater in both areas;
* Pretreatment of all extracted groundwater for the removal of metals and
inorganic solids;
* Treatment of the on-site extracted groundwater in an activated sludge
biological treatment facility constructed at the Hagen farms site;
-.-"."
* A bench scale study examining the feasibility of injecting the treated on-
site groundwater into the aquifer below the site in order to enhance in-situ
bioremediation;
* Treatment of off-site extracted. groundwater using an appropriate treatment
technology. This technology has not yet been determined but options include
cascade aeration, activated sludge, air stripping, granular activated carbon
(GAC) or UV-oxidation;
~
~t..C8d ..
-..:''''
-
-------
Mr. Valdas V. Adamkus, Administrator - September 28, 1992
2
* Treatment of residue, sludge, and/or spent coagulates to meet land disposal
requirements, followed by disposal in a RCRA landfill; and
* Discharge of all treated groundwater to the Yahara River or nearby
wetlands.
. The range of costs for the selected remedy are estimated to be as follows:
Capital Cost $ 4,396,000 - $6,288,000
Annual O&M 1st year $ 550,000 - $ 1,062,000
Total Present Worth $ 13,612,000 - S 24,163,000
Estimated time to implement 30+ Years
Though the Department concurs with the selection of this remedy, WDNR
concurrence is based upon the understanding that at the time the proposed
treatment design is finalized, the effluent discharge limits and discharge
location (including any reinjection of enhanced groundwater which is proposed)
are acceptable to the WDNR and are in compliance with the effluent discharge
limit requirements of Chapters NR 102, 105, 106, 207 and 220, the wetlands
protection in Ch NR 103, and the applicable air quality standards in Chs NR
400 to 499, WAC. Our concurrence is also conditioned on EPA's supplementation
of that portion of the administrative record that pertains to off-site
groundwater extraction and treatment with all documents submitted by the WDNR
in the future dealing with off-site groundwater extraction and treatment, in
accordance with 40 CFR 300.825(a)(I). In addition, the Department recommends
that the potential to discharge to a municipal sewerage system be further
investigated during the remedial design.
We understand that if the potentially responsible parties (P~Ps) do not agree
to fund the remedy, it will be necessary for the State of Wisconsin to
contribute 10% of the remedial action costs associated with the actions and
10% of the O&M costs for the first 10 years of groundwater extraction and
treatment. In addition, if the PRPs do not agree to fund the OiM, the State
of Wisconsin will need to contribute 10% of all other O&M costs for the first
year and provide for all O&M after that, provided that no changes to the'
National Contingency Plan are made .that would require an alternative cost
allocation. . We provide assurance of the State's willingness to provide this
required state cost share on the assumption that U. S. EPA will pursue all
feasible enforcement actions against the PRPs prior to expending the Fund at
the site. .
We understand that if the Fund is-expended to conduct the remedy and if
hazardous waste needing disposal is required to be managed off-site as part of
. the remedy, that the State of Wisconsin will be required to provide the'
assurances for hazardous waste management in i40 CFR 300.S10(d) and (e) of the
National Contingency Plan. The assurances are that a compliant hazardous
waste facility is available, and that facility's use is consistent with our
approved Capacity Assurance Plan. In addition, the"Department recommends that
an analysis and a finding be made during remedial design on whether hazardous
wastes can be managed in-state and on-site, to the extent practicable.
Hazardous waste residuals may be generated by the pretreatment of extracted
-------
Mr. Valdas V. Adamkus, Administrator - September 28, 1992
3
groundwater prior to treatment, and sludge gp.nerated during the treatment of
groundwater may constitute hazardous waste.
We also understand that our staff will continue to work in close consultation
with your staff during the pre-design, design and construction phases of the
remedy. . .
Thank you for your support and cooperation in addressing the contamination
problem at the Hagen Farm site. Should you have any questions regarding this
matter, please contact Jane Lemcke, Superfund Remedial Unit Leader, at (608)
267-0554.
Sincerely,
.~~~
c~7~;ny ]
Secretary .
cc:
Lyman Wyble - AD/5
Linda Meyer - LC/5
Paul Didier - SW/3
Mike Schmoller - SO
Mary Pat Tyson - U. S.
Mark Giesfeldt - SW/3
Jane Lemcke - SW/3
Paul Kozol - SW/3
EPA Region V, SHS/ll
----
------- |