PB94-964125
EP AIRODIR05-94/251
September 1994 .
EP A Superfund
Record of Decision:
Land and Gas Reclamation
Landfill Site, Williamstown, WI
1/13/1994
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RECORD OF DECISION
SOURCE CONTROL OPERABLE UNIT INTERIM REMEDY
Site Name and Location
Land and Gas Reclamation LandfIll
(Listed on the NPL as the Hechimovich Sanitary Landfill)
Located in the Town of Williamstown, Dodge County, Wisconsin (approximately 3.5 miles
east of the City of Horicon and approximately 2 miles south of the City of Mayville)
Statement of Basis and Pul1'ose
This document presents the decision of the Wisconsin Department of Natural Resources
("WDNR") that no further source control interim action is necessary at the Land and Gas
Reclamation Landf1l1 site in the Town of Williamstown, Dodge County, Wisconsin, which
was chosen in accordance with the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 ("CERCLA"), as amended by SARA, and to the extent practicable,
the National Oil and Hazardous Substances Pollution Contingency Plan ("NCP"). This
record of decision also presents information on source control action that has been
implemented at this site by the defendants subject to a Dodge County Circuit Court Order. It
is likely that actual or threatened releases of hazardous substances from this site would have
presented an imminent and substantial danger to public health, welfare or the environment, if
the Dodge County Circuit Court Order had not been implemented. The attached Desision
Summary identifies the information contained in the administrative record for this site upon
which the decision that no further source control interim action is necessary was based.
The United States Environmental Protection Agency ("U.S. EPA") concurs with the selected
source control operable unit interim remedy.
Description of the Selected Remedv/Rationale for No Action
The WDNR has determined that no further source control interim action is necessary at this
site for this first operable unit. The reason for this determination is that the source control
action which was implemented under the Dodge County Circuit Court Order has eliminated
potential exposure to source related contaminants, except for contaminants in the
groundwater, which will be addressed in the second operable unit. The Court-ordered source
control action that was implemented at this site met the solid waste disposal facility closure
requirements in chs. NR 500 to 520, Wisconsin Administrative Code, and consisted of:
*
Installation of an improved landfill cap which met the requirements of ss. NR
504.07 and 506.08, Wisconsin Administrative Code;

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*
Installation of an active gas collection and flaring system which met the
requirements of cbs. NR 445 and 508, and ss. NR 504.05(7), 504.07(3), and
- 506.08(6), Wisconsin Administrative Code; and
*
Monitoring and maintenance of the landfill cap and gas collection and flaring
system.
Declaration Statement
The WDNR has detennined that landfill waste and source-related contaminants pose no
current or potential threat to human health or the environment because the Court-ordered
source control action taken at this site eliminated the need to conduct further source control
interim action for this first operable unit. Exposure to waste and contaminated soil has been
eliminated and the potential release of contaminants from the landf1l1 waste to the
groundwater has been minimized with the installation of an improved landf1l1 cap. Potential
exposure to methane and volatile organic compounds in the landf1l1 gas has been eliminated
with the installation of an active gas collection system. The remedy selected in this record of
decision does not constitute the final remedy for this site. Subsequent actions will address
fully the threats posed by conditions at this site. Because hazardous substances remain on
site, a review will be conducted, within five years after the implementation of the Court-
ordered source control action began, to ensure that the implemented source control action
continues to provide adequate protection of human health and the environment. Review of
this site and of the implemented source control action will be ongoing as the settling potential
responsible parties who signed a State environmental repair contract complete a remedial
investigation and feasibility study to develop fmal remedial alternatives for this site.
~W!.a n {'i'7'1
() Date /

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DECISION SUMMARY
SOURCE CONTROL OPERABLE UNIT INTERIM REMEDY
LAND AND GAS RECLAMATION LANDFILL
Findings Of Fact
The following fIndings of fact summarize the infonnation contained in the administrative
record for the Land and Gas Reclamation Landfill site. The selection of the source control
interim action for this site was based upon the information in the site's administrative record.
The Wisconsin Department of Natural Resources ("WDNR") fmds that:
1. Site Name. Location And Description
The Hechimovich Sanitary LandfIll was listed 'on the National Priorities List by the U. S.
Environmental Protection Agency in March of 1989. This site, now known as the Land and
Gas Reclamation LandfIll, does not include the active landfill (lithe new Hechimovich
Sanitary Landfill") which is located immediately to the north of the closed Land and Gas
Reclamation LandfIll.
The Land and Gas Reclamation LandfIll site is located in a rural area in the Town of
Williamstown, approximately 2 miles south of the City of Mayville, and approximately 3.5
miles east of the City of Horicon, Wisconsin. (See Figure A.) This 24.3 acre, closed
landfIll is located in the east one-half of the southwest quarter of Section 35, Township 12
North, Range 16 East, Town of Williamstown, Dodge County, Wisconsin. This site is
unfenced and access is not controlled.
II. Site Historv And Enforcement Activities
The Land and Gas Reclamation Landfill was a commercial landfIll, municipally operated
from 1959 to 1970 and privately operated from 1970 to October, 1986 when it ceased
accepting waste. Paint sludges and cutting oils, from local industries, possibly containing
lead, chromium and solvents, were disposed of in lagoons on-site. It is estimated that 53,000
gallons of liquid hazardous wastes were disposed of at this site. The landfIll does not have a
liner. An initial cover, consisting of 2 to 4 feet of local till soils and 6 inches of topsoil, was
placed in 1987.
In July, 1987, the Land and Gas Reclamation Landfill site was the subject of a WDNR
enforcement action, resulting in a Stipulation and Order signed by the Dodge County Circuit
Coun, which directed George Hechimovich, Hechimovich Sanitary LandfIll, Inc. and Land
and Gas Reclamation, Inc. (lithe Defendants") to undertake certain actions at the landfIll,
including the installation of a clay cap and a gas collection system.

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The WDNR nominated the site for listing on the National Priorities List ("NPL") in 1988.
The site was listed on the NPL, as the Hechimovich Sanitary Landfill, in March of 1989.
Based on the information obtained from landfill records in the possession of Daniel and
George Hechimovich, the WDNR issued special notice letters to fourteen potentially
responsible parties ("PRPs") on August 15, 1990 and special notice letters to two additional
PRPs on September 20, 1990.
The Defendants and other potentially responsible parties entered into an environmental repair
contract with the WDNR, which became effective on September 28, 1990, to perform a
remedial investigation/feasibility study ("RIfFS") pursuant to s. 144.442, Wisconsin Statutes,
and the Comprehensive Environmental Response, Compensation and Liability Act
(CERCLA). After the environmental repair contract was signed, the WDNR decided that,
due to the complexity of the site, and because the Defendants had been previously ordered to
improve the landfill cap and install a gas collection system at the site, remediation at the site
should be divided into two operable units: a source control (landfIll closure) operable unit
and a groundwater operable unit.
During 1991 and 1992, the Defendants installed a cap, in compliance with the requirements
of ss. NR 504.07 and 506.08, Wis. Adm. Code, consisting of a 6 inch thick grading layer
over the waste material; a minimum of 2 feet of low permeability soil (clay) placed on top of
the grading layer; a 2-foot thick soil cover layer; and 6 inches of topsoil. In addition, the
Defendants installed an active gas collection and flaring system, in compliance with the
requirements of chs. NR 445 and 508, and ss. 504.05(7), 504.07(3) and 506.08(6), Wis.
Adm. Code.
m. Highlights Of CommunitY Particiuation
An information repository has been established at the Mayville Public Library, 111 North
Main Street, Mayville, Wisconsin. The administrative record for this site has been made
available to the public at the Horicon Free Public Library, 404 East Lake Street, Horicon,
Wisconsin.
In September 1991, a Superfund Fact Sheet on the 4md and Gas Reclamation LandfIll was
issued by the WDNR. On September 25, 1991, representatives of WDNR, U.S. EPA, and
the Wisconsin Department of Health and Social Services held a public information meeting at
7:00 p.m. at the Senior Center located at 330 N. Walnut Street in Mayville, Wisconsin, and
discussed the Land and Gas Reclamation LandfIll and the landfIll closure and groundwater
investigation work that was being conducted at this site. Approximately 50 residents of the
area attended the public meeting.
A proposed ROD which selected the implemented source control interim action for the Land
and Gas Reclamation Landfill was made available for public comment from December 3,
1992 through January 6, 1993. Since that time, the WDNR has decided, after consultation
with the U.S. EPA, that the best approach to conclude the interim remedy for the first
operable unit would be to document the source control action that has been implemented and
to evaluate existing site conditions. The result of this evaluation is that because of the

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implementation of the Court-ordered source control action (an improved landfill cap and an
active gas collection and flaring system), no further source control interim action is necessary
at this sit~, This determination is reflected in a new proposed ROD that was made available
for public comment, from October 15, 1991 to November 15, 1993. Comments received
during both the present and the earlier public comment periods and WDNR's responses to
those comments are included in the attached Responsiveness Summary, which is a part of
this ROD. A notice announcing the availability of the new proposed ROD and the start of
the latest public comment period was published in the Mavville News on October 21, 1993.
The public participation requirements of s. 144.442(6)(f), Wisconsin Statutes, and the
community relations requirements of Sections 117 and 113(k)(2)(B)(i-v) of CERCLA were
met in the source control interim remedy selection process. This decision document presents
the decision of the WDNR that no further source control interim action is necessary for the
Land and Gas Reclamation LandfIll Site in the Town of Williamstown, Dodge County,
Wisconsin, which was chosen in accordance with CERCLA, as amended by SARA and to
the extent practicable, the NCP. The decision is based on the administrative record.
IV. Scope And Role Of Operable Unit
As with many Superfund sites, the conditions at the Land and Gas Reclamation Landfill site
are complex. As a result, WDNR decided to organize the work into two activities or
"operable units." The first of these operable units, which this Record of Decision is a part
of, addresses source control. The second operable unit will address groundwater
CODt~min~tion at this site. The settling potentially responsible parties who signed a State
environmental repair contract for this site have continued to conduct the RIfFS for the site,
while the Conn-ordered source control action was being implemented, in order to develop
and evaluate final remedial alternatives for the site. The WDNR has detennined that the
implemented source control action will be consistent with the final remedy that is likely to be
selected for this site.
No further source control interim action is necessary at this site because the landfill waste
and source-related contaminants pose no current or potential threat to human health or the
environment with the expedited implementation of the Conn-ordered source control action.
Taking action immediately rather than waiting for the final remedial action to be selected for
this site considerably shortened the time required to eliminate or minimize the potential
source related threats to human health and the environment.
V. Site Characteristics
A.
Topography
The Land and Gas Reclamation Landf1l1 site occupies the northern portion of a drumlin (a
glacial landform consisting of a long, narrow hill) in a drumlin field. There are two wetland
areas adjacent to the Land and Gas Reclamation Landf1l1 site, one west and one north and
east of the site.

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B.
Geology/Hydrogeology
The geology in the area of the Land and Gas Reclamation Landfill consists of 50 to 100 feet
of glacial till over Ordovician shale, sandstone and dolomite. The glacial till in this area is
predominately ground moraine. The landfill site is situated on a drumlin. The
unconsolidated materials on the site are characterized by silty gray sand and a sandy gray till
with up to 45 feet of peat and organic silts north and east of the site. The bedrock beneath
the site is believed to be Maquoketa Shale.
Groundwater flow from the site is to the northeast, eventually discharging to the East Branch
of the Rock River. Leachate heads within the landfIll are generally zero to a few feet above
the original base grade. The water table is at or near the ground surface in the wetland area
around the drumlin. Local groundwater discharge appears to occur in the wetlands west, and
north and east of the site. Past studies have indicated that the steepest horizontal gradient is
to the north at 0.049 ft/ft.
C.
Groundwater Contamination
Based on currently available information, there appear to be two separate plumes of
groundwater contamination leaving the site. The boundaries and the exact characteristics of
these plumes are generally known. One plume moving northward from the site is
characterized by high concentrations of dichloroethylene and vinyl chloride. The second
plume initially moves westward, then to the north, from the site and is characterized by
elevated concentrations of trichloroethylene, vinyl chloride and other contaminants.
VI. Summary Of Site Risks
The risks associated with the source control operable unit for the Land and Gas Reclamation
Landfill were evaluated qualitatively. A baseline risk assessment for the entire site
(including both source control and groundwater operable units) is required to be performed
and documented under the environmental repair contract that was signed by the WDNR, the
Defendants and other potentially responsible parties in September of 1990. The fmal
baseline risk assessment will ensure that the final remedy that is selected for the site
addresses all significant threats to human health or the environment.,
A.
Chemicals of Potential Concern
The contaminants identified in groundwater in the vicinity of this site include, but may not be
limited to, benzene, ethylbenzene, 1,1-dichloroethane, 1,2-dichloroethylene,
trichloroethylene, vinyl chloride and xylenes. Additional hazardous substances have been
tentatively identified in leachate generated at the site. Lead, chromium and solvents may
have been present in paint sludges and cutting oils which were disposed of in lagoons on-site.
Landfill gas which is being generated by waste decomposition at the site (largely methane)
may contain elevated levels of other volatile organic compounds.

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B.
Exposure Assessment
_.
This site is located in a rural area of Dodge County. Surrounding land use is primarily
agricultural. The nearest population center is the City of Mayville, 2 miles to the north.
The City of Horicon lies 3.5 miles to the west. (Well logs indicate that 16 wells exist within
a half-mile radius of this site. However, the qualitative risk assessment that was done for the
source control interim action did not attempt to evaluate the risks associated with exposure to
contaminated groundwater.)
The site is unfenced and access is not controlled. Trespassers (hunters, hikers, children,
etc.) could have been exposed to landfill gases and could have come into contact with
exposed waste or contaminated soil if a new clay cap had not been installed.
Because of the Court-ordered source control action that was implemented at this site,
potential exposure to waste and source-related contaminants has been eliminated or
significantly minimized. Direct contact is no longer possible following completion of the
improved cap (Le. waste and contaminated soils are covered by at least five feet of cover
material). Gas migration is now controlled by the gas collection and flaring system. An
additional benefit of the implemented source control interim action is that the improved
landfill cap significantly reduces leachate production within the landfill because the
infiltration of rain and snow melt is minimized by the low permeability clay layer within the
improved cap.
c.
Human Health and Environmental Risk Characterization
Prior to the installation of a new landfIll cap and an active gas collection and flaring system
at the Land and Gas Reclamation Landfill site, human health and environmental receptors in
the vicinity of the landfIll were threatened by the potential for direct contact with waste and
contaminated soil, the inhalation of hazardous air pollutants and the buildup of explosive
levels of methane gas.
Since the exposure pathways associated with the source control operable unit have been
eliminated or significantly minimized by the new landfIll cap and the active gas collection
and flaring system, no further source control interim action is necessary to ensure protection
of human health and the environment.
VII. StatutOry Authoritv Finding and Conclusions Of Law
The WDNR has determined that landfill waste and source-related contaminants pose no
current or potential threat to human health or the environment and that no further source
control interim action is necessary at this site. The reason for this determination is that the
source control action which was implemented under the Dodge County Circuit Court Order
has eliminated actual and potential exposure to waste and source-related contaminants, except
for contaminants in the groundwater which will be addressed in the second operable unit.
The improved landfill cap eliminates the potential for exposure to direct contact with waste
or contaminated soils. The gas collection and flaring system eliminates exposure to methane

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and volatile organic compounds which may have migrated from the landfill through the soil
or the air. An additional benefit of the implemented source control interim action is that the
improved landfill cap significantly reduces leachate production within the landfill by
minimizing the infiltration of rain and snow melt.
Because this is a decision for" no action," none of the statutory detenninations relating to
remedy selection required by Section 121 of CERCLA are necessary in this Record of
Decision. However, because hazardous substances will remain on-site, five year reviews
will be conducted at this site.

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RESPONSIVENESS SUMMARY
Comments Received During the Initial Comment Period (Dec. 3. 1992 to Jan. 6. 1993):
(1) COMMENT:
Section IV of the ROD (Scope of the Selected Interim Remedy) should be revised to specify
that while the cap and gas system do not constitute a fInal remedial action for the entire site,
they do satisfy the statutory preference for final remedies for this operable unit. (Comment
from Peter Ruud, DAVIS & KUELTHAU, S.C., representing the Land & Gas Reclamation
Landfill PRP Steering Committee)
RESPONSE:
This suggested change was not made. Because this record of decision is for "no action,"
none of the statutory determinations relating to remedy selection required by Section 121 of
CERCLA are necessary in the ROD.
(2) COMMENT:
The word "potential" should be inserted into Section VI (Environmental Standards Previously
Not Met at the Site) before the phrase "unacceptable risks." (PRP Steering Committee)
RESPONSE:
The section on environmental standards that were not met prior to the placement of the new
landfill cap and the gas collection and flaring system was removed before the proposed ROD
was made available for public comment from October 15, 1993 to November 15, 1993.
However, the wording that the PRP Steering Committee asked us to insert is now found in
Section VI, C (Human health and environmental risk characterization) of the final ROD.
(3) COMMENT:
It is our understanding that under the Memorandum of Agreement between WDNR and U.S.
EP A, Region V, Region V is required to formally concur with the Interim ROD. Please
indicate in the Interim ROD that U.S. EPA has formally concurred. (PRP Steering
Committee)
RESPONSE:
This change has been made. A reference to U.S. EPA's concurrence has been added to the
Statement of Basis and Purpose Section of the Declaration that is to be signed by Secretary
Meyer.

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Comments Received During the Second Public Comment Period (Oct. 15 to Nov. 15. 1993):
(1) COMMENT:
The full title of CERCLA and the NCP should be inserted the fIrst time that they are
referenced in the ROD. (Comment from U.S. EPA, Reg. 5)
RESPONSE:
The requested change was made.
(2) COMMENT:
The fIrst sentence of the Declaration Statement should be amended to more clearly indicate
that the WNDR has determined that there is no current or potential threat posed by landfIll
waste or source-related contaminants at the present time because of the court-ordered
installation of an improved landfIll cap and active gas collection and flaring system. (U.S.
EPA, Reg. 5)
RESPONSE:
This change has been made.
(3) COMMENT:
A site map should be included in Section I. (U.S. EPA, Reg. 5)
RESPONSE:
This change has been made.
(4) COMMENT:
Information on PRP search and special notice activities should be included in Section II.
(U.S. EPA, Reg. 5)

RESPONSE:
This change has been made.

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(5) COMMENT:
The second sentence in the second paragraph of Section III should be revised to change the
words "would be" to "was being." (U.S. EPA, Reg. 5)
RESPONSE:
This change has been made.
(6) COMMENT:
The third paragraph in Section III should be revised to incorporate the information that was
included in the Explanation of Significant Changes Section in the proposed ROD that was
made available for public comment. (U.S. EPA, Reg. 5)
RESPONSE:
This change has been made.
(7) COMMENT:
The fourth paragraph of Section III should be revised to insert a reference to section 113 and
117 of CERCLA in place of the reference to the NCP, and to include statements that the
ROD presents a decision made by WDNR in accordance with CERCLA and, to the extent
practicable, the NCP, and that the decision is based on the administrative record.
(U.S. EPA, Reg. 5)
RESPONSE:
This change has been made.
(8) COMMENT:
The title of Section IV should be changed to read "Scope and Role of Operable Unit." (U.S.
EPA, Reg. 5)
RESPONSE:
This change has been made.

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(9) COMMENT:
The first -sentence of the second paragraph of Section IV should be amended to more clearly
indicate that the WNDR has detennined that there is no current or potential threat posed by
landfill waste or source-related contaminants at the present time because of the court-ordered
installation of an improved landfill cap and active gas collection and flaring system. (U.S.
EPA, Reg. 5)

RESPONSE:
This change has been made.
(10) COMMENT:
The title of Section V should be changed to read "Site Characteristics." (U.S. EPA, Reg. 5)
RESPONSE:
This change has been made.
(11) COMMENT:
The fourth sentence in the third paragraph of Section VI, B should be amended to read: "An
additional benefit of the implemented source control interim action is that . . ." (U.S. EPA,
Reg. 5)
RESPONSE:
This change has been made.
(12) COMMENT:
The first sentence of the first paragraph of Section VII should be amended to more clearly
indicate that the WNDR has determined that there is no current or potential threat posed by
landfill waste or source-related contaminants at the present time because of the court-ordered
installation of an improved landfill cap and active gas collection and flaring system. (U.S.
EPA, Reg. 5)
RESPONSE:
This change has been made.

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(13) COMMENT:
The last sentence of the first paragraph of Section VII should be amended to read: II An
additional benefit of the implemented source control interim action is that . . . II (V. S. EP A,
Reg. 5)
RESPONSE:
This change has been made.
(14) COMMENT:
The Explanation of Significant Changes Section should be deleted since it has been
incorporated into Section III, Highlights of Community Participation. (V.S. EPA, Reg. 5)
RESPONSE:
This change has been made.

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 5
77 WEST JACKSON BOULEVARD
CHICAGO. IL 60604-3590
DEe 3 0 1993
REPLY TO THE ATTENTION OF:
R-19J
Mr. George E. Meyer
Secretary
Wisconsin Department of Natural
101 South Webster Street
Madison, Wisconsin 53707
Resources
Dear Mr. Meyer:
The United States Environmental Protection Agency (U.S. EPA)
hereby concurs with the decision that no further source control
interim action is necessary as identified in the enclosed Record
of Decision (ROD) completed by the Wisconsin Department of
Natural Resources (WDNR) for the Hechimovich Landfill Site. Our
concurrence is in accordance with 40 CFR S300.515(e) (2) (i) and
(ii) and is based on the administrative record, which documents
past actions taken under the State Court Order, i.e.,
installation of an improved landfill cap and an active gas
collection and flaring system. Because of these past actions,
potential exposure to source-related contaminants have been
eliminated (with the exception of contaminated groundwater, which
will be addressed in the second operable unit). Therefore, we
agree that no further action is needed to address the landfill
waste at this time.
U.S. EPA understands that this first operable unit addresses the
source of the contamination and is not the final remedy at the
site. A second operable unit addressing the groundwater
contamination is expected to follow.
We look forward to our continuing involvement on the Hechimovich
Landfill site.
Sincerely yours,
ORIGINAL SIGNED BY
4MV1j)A. UURJCH
Valdas V. Adamkus ~\~
Regional Administrator t I 0 !)\'V
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