PB94-964143
EP AIRODIR05-94/270
April 1995
EP A Superfund
Record of Decision:
Lemberger Transport and Recycling
Site (O.V. 2), Franklin Township, WI
9/29/1994
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Hazardous Waste Collection EP A Report Collection
Information Resource Center Information Resource Center
US EPA Region 3 US EP A Region 3
Philadelphia, PA 19107 Philadelphia, PA 19107
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Lemberger Transpon and Recycling, Inc. Site, Manitowoc County, Wisconsin.
ST A TEMENT OF BASIS
This decision document presents the selected remedial action for the Second Operable Unit
(OU2) at the Lemberger Transpon and Recycling Inc. Site, in Manitowoc County, Wisconsin,
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 is consistent with the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP) to the extent practicable. This decision is based
upon the contents of the Administrative Record for the site.
DESCRIPTION OF THE SELECTED REMEDY
U.S. Environmental Protection Agency (EPA) has selected "No Further Action."
DECLARATION STATEMENT
EPA has determined that once the provisions of the July 15, 1993 Administrative Order on
Consent have been implemented, the conditions at the site will pose no current or potential threat
to human health or the environment. Accordingly. no further remedial action will be undenaken
at this site.
Although this is a decision for "No Further Action." the statutory requirement of CERCLA
Section 121 for a five-year review will be undenaken. The five-year review will be performed
because waste will be left in place at the site.
. The State of Wisconsin concurs conditionally with this decision from a technical standpoint.
;jlltt
, DATE
~~~/I /I. tifiW
/'-., Valdas V. Adamkus
. Regional Administrator
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T ABLE OF CONTENTS
I.
Site Descripti.:>n ........... ..........................,..... .. ..............................., 1
II.
Site History and Enforcement Activities............... .. . ... .. .. .... .. .. ........... .. 1
III.
Highlights of Community Panicipation ................................................ 3
IV.
Scope & Role of Operable Unit[[[ 4
V.
Site Characteristics........................ ............................................... 4
VI.
Summary of Site Risks[[[ 8
VII.
Explanation of Significant Changes[[[ 10
VIII. State Concurrence[[[ 10
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LEMBERGER TRANSPORT AND RECYCLING INC.
MANITOWOC COUNTY, WISCONSIN
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
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DECISION SUMMARY
J. SITE DESCRIPTION
The Lemberger Transpon and. Recycling, Inc. (LTR) site consists of a former land disposal
facility located in Manitow.oc County. Wisconsin. The study area is bounded approximately by
Haas Road to the nonh. San Road to the south, Madson Road to the east and Korinek Road to
the west. Figure 1 shows the location of the site. The site is located near the intersection of
Hempton Lake and Sunny Slope Roads. The Branch River. which drains into Lake Michigan,
is located less than one mile west of the site. The river is used for fishing and canoeing and as
a potable water supply. The entire Branch River system is managed as a s.mallmouth bass
stream. The LTR site occupies approximately 45 acres. with 16 acres used for industrial
landfilling. The site is unlined and it occupies an area previously used to mine gravel. Land
in the vicinity of the site is rural and agricultural. with dairy farms in the area. Most residences
are located along Reifs Mills Road. Four residences are located within 1,000 feet of the site.
The groundwater is used by residents as a drinking water supply and for agricultural activities.
.
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
The LTR site operated between January 1970 and September 1976 under the same license issued
by the Wisconsin Department of Natural Resources (WDNR) for the Lemberger Landfill (LL)
Superfund site. The site ceased operations in 1976 when the WDNR did not renew the license.
The wastes were deposited in trenches excavated to an approximate depth of five feet. Records
of the types and quantities of wastes were maintained, but no specific records were kept to
indicate what types of wastes were deposited in each trench. No engineered liner or leachate
collection systems were ever installed at the LTR site.
The LTR site is documented as receiving industrial waste and a variety of liquids, sludges, and
slurries between 1969 and 1977. Industrial wastes, including wood tar distillates, aluminum
dust, and oil and water mixtures were disposed at the site.
The WDNR had expressed concern that the site had not been covered properly, as indicated by
wastes exposed at the landfill's surface. SubseCiluently, in 1982, the WDNR entered into a
consent order with Lemberger Landfills Inc., which operated the LL and LTR sites, to
investigate the extent of contamination at the site. WDNR also issued a notice of violation in
August 1982 to Lemberger Landfills, Inc. regarding failure to implement groundwater
monitoring requirements at the LTR site. In September 1984, the LTR site was added to the
National Priorities List (NPL), and EPA became the lead regulatory agency.
Residential Wells
In 1985, after receiving complaints from people living northwest of the Lemberger sites, the
WDNR sampled residential wells in the area. Sample test results indicated volatile organic
compounds (VOCs) were present in seven residential wells near the sites and the groundwater
under the sites in amounts that exceeded Wisconsin groundwater standards. Affected residents
received replacement wells. which were drilled 160 to 220 feet deeper than their original wells.
Later, from 1985 through 1987, the new wells were sampled and no contamination was found.
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Figure 1
LEMBERGER TRANSPORT AND RECYCLING SITE LOCATION
MAP
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III. HIGHLIGHTS OF COMMUNITY PARTICIPATION
EPA hosted a "kick off" public meeting on March 29, 1989, at St. Patrick/Maple Grove School,
Reedsville, Wisconsin. The purpose of the meeting was to inform the local residents of the
Superfund process and the work to be conducted under the Remedial Investigation (RI). RI
update fact sheets were issued in April 1990 and January 1991.
The RI Repon for the first operable unit at the Lemberger sites was released to the public for
review in January 1991. The Feasibility StUdy (FS) and Proposed Plan were released on May
20, 1991. Information repositories have been established at the following three locations: The
Manitowoc Public Library, 808 Hamilton Street, Manitowoc, Wisconsin: the Whitelaw Village
Hall, 232 East Menasha A venue, Whitelaw, Wisconsin; and the Franklin Town Chainnan, Steve
Brooks, Home Office, Route 1, Box 293A, Whitelaw, Wisconsin. The Administrative Record
for the sites has been made available to the public at the EP A Docket Room in Region V and
at the Manitowoc Public Library.
A public meeting was held on May 22, 1991 at the Franklin Town Hall, Cato, Wisconsin to
discuss the FS and the Proposed Plan for the first operable unit. The meeting was chaired by
representatives from the EP A, WDNR, the Wisconsin Department of Health and attended by
approximately 60 residents.
A public meeting was' held on November 5, 1992 to update the community on the investigation
and cleanup activities at the LTR site. More than 50 people attended. A fact sheet was also
distributed.
The FS and Proposed Plan for the first operable unit were available for public comment from
May 20, through July 29, 1991. The Record of Decision (ROD) for the first operable unit at
the Lemberger sites was signed on September 23, 1991.
A site tour for local media and officials was held in December 1993 when the LTR drum
removal began. Update letters were also sent to everyone on the site mailing list in January
1992, April 1993, and November 1993.
The Proposed Plan for the second operable unit was available for public comment from July 18,
through August 17, 1994. A public meeting to discuss the Proposed Plan was held on August
3, 1994 at the Franklin Town Hall in Cato, Wisconsin.
Display advenisements were placed in the Manitowoc Herald Times to announce all public
meetings and comment periods as well as the availability of the administrative record. Press
releases were also sent to other local newspapers, television, and radio stations.
The public panicipation requirements of CERCLA sections 113 (k)(2)(i-v) and 117 of CERCLA
have been met in the remedy selection process. This decision document presents the selected
remedial action for the Lemberger sites in Wisconsin, chosen in accordance with CERCLA, as
amended by SARA and, to the extent practicable, the National Contingency Plan (NCP). The
decision for this site is based on the administrative record.
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IV. SCOPE AND ROLE OF OPERABLE UNIT
As with many Superfund sites. the conditions at the LL and L TR sites were complex. As a
result, EPA organized the work into two planned activities. The remedial action selected in the
September 1991 ROD addressed the first of these two planned activities or operable units at the
sites. The September 1991 ROD addressed groundwater contamination at the LL and LTR sites,
and source contamination at the LL site. This response action was scoped to treat the
groundwater in the shallow and deep aquifers and install a slurry wall around the waste in the
LL site and place a cap on the LL site. The remedy utilized pennanent solutions and alternative
treatment or resource recovery technology to the maximum extent practicable for each site, and
satisfied the statutory preference for remedies that employ treatment that reduces toxicity,
mobility, or volume as a principal element.
The second and final action which is the scope of this ROD addresses the source of
contamination at the LTR site. The LTR landfill contains hot spots which needed to be further
characterized. The October 1992 RI for OU2 found buried drummed wastes and further
delineated and identified hot spots present at the site. As a result, EP A detennined that the
conditions at the site warranted the undertaking of emergency removal activities to abate
conditions which may have presented an imminent and substantial endangennent to the public.
As pan of these activities, EPA entered into an Administrative Order on Consent (AOC) on
July 15, 1993 with a group of Potentially Responsible Parties (PRPs) to implement the removal
action components at the site. The AOC requires' the PRPs to fence the landfill, excavate and
remove buried drums, install a soil vapor extraction system, and cap the landfill.
As a result of these response actions, EP A has determined that no further action is required at
this site. However, because hazardous substances will remain at the site, a five-year review will
be conducted to assure human health and the environment continue to be protected by the
response activities conducted at the site as pan of the July 15, 1993 AOC.
V. SITE CHARACTERISTICS
The RIs involved sampling and analysis of groundwater, air, surface water, .sediment, leachate,
subsurface soil, and surface soil to determine site conditions. Water samples were collected
from numerous residential and monitoring wells around the site. A geophysical investigation
consisting of a magnetic survey, an electromagnetic survey and a seismic survey was conducted.
Site geology, landfill characteristics, and groundwater flow patterns were also examined.
Based on the results of the RIs, EP A detennined that the threats to human health and the
environment are through exposure by ingestion or direct contact with VOCs, semi-volatile
organic compounds (SVOCs), and inorganic compounds found in the groundwater near the site
and in landfill contents on the site. The following conditions were observed at the. site:
1. Topography
The Branch River, which drains into Lake Michigan, is less than one mile west and northwest
of the site. The area consists of rolling to hilly terrain and numerous wetlands. The area is
generally characterized by glacial deposits and variable bedrock. The L TR site slopes to the
west/northwest with steeper slopes in the east. Elevations on the LTR site range from870 feet
A
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to 852 feet above Mean Sea Level (MSL). There are four. general geologic units present at the
study area, the upper granular unit (UGU), the cohesive unit (CU), the lower granular unit
(LGU) and the bedrock. The UGU is composed of sandy, gravelly deposits at or close to the
ground surface. It does not cover the whole study area. The CU. or clay layer, is composed
of silty, clayey deposits and has low hydraulic conductivity. The LGU is composed of sandy,
gravelly deposits underlying the clay layer and rests on the bedrock.
2. Hydrogeology
There are two groundwater systems at the site. Within the upper granular unit is a localized
perched aquifer. The clay layer separates it from the lower aquifer in the lower granular unit
and bedrock. A groundwater divide as a result of a bedrock ridge runs northeast-southwest on
the southeast side of the study area. The water flows away from the divide in all directions but
primarily to the nonhwest and the southeast.
a.
The upper aquifer is within the upper granular unit and is localized in the area of
the LL site, apparently extending east into Ridgeview Landfill, south into the
LTR site, and north at least as far as monitoring well RM-4. The upper aquifer
may be a single perched system or there may be more than one independent
perched water table system in the area. Groundwater in the upper aquifer appears
to flow to the west through the waste disposed at the LL site. The average depth
of the upper aquifer is thirteen feet.
b.
The cohesive or clay layer, underlies the upper aquifer and is interbedded with
granular material at the interface. The thickness of the clay layer varies
considerably across the study area, ranging from one to three feet thick over the
bedrock ridge to almost 50 feet thick at several locations where the bedrock
surface is lower in the north, northwest, and west ponions of the Lemberger sites
study area.
c.
The lower aquifer is venically and laterally continuous west of the L TR site. It
is composed of well-graded, dense sandy gravel and gravely sand and is
hydraulically connected with the underlying bedrock. The thickness and depth
of the aquifer increases away from the bedrock ridge, ranging from one to three
feet thick at the bedrock ridge to 25 feet thick northwest of the Lemberger sites
between monitoring wells RM-4 and RM-2.
d.
The bedrock, under the consolidated deposits is a dolomitic limestone that ranges
from a highly weathered condition in its upper surface to a highly fractured and
then unfractured bedrock below. The lower water system is in the limestone
bedrock and has a regional direction of groundwater flow to the east, toward
Lake Michigan. Locally, however, the groundwater flows to the northwest,
toward the Branch River. An area of local recharge of the lower aquifer runs
northeast-southwest on the southeast side of the Lemberger sites study area. The
recharge area functions as a groundwater divide, with flow moving away from the
divide in all directions but primarily to the northwest or the southeast.
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3. Contamination
a. Source
The source of contamination from the LTR site is the landfilled waste. The source of
contamination at the L TR site is contributing to groundwater contamination. Based on
infonnation derived from the RIs perfonned at the LTR site, available aerial
photographs, the Final Public Comment FS report for the first operable unit for the LL
and LTR sites, and past disposal practices. the soil and waste contamination at the LTR
site is delineated as follows:
.
Hot Spots - Areas that contain buried drums, concentrated amounts of
hazardous constituents. and high contaminant concentrations.
.
Area. of Low to Moderate Contamination - All locations where hazardous
constituents were detected at low to moderate concentrations based on the
OU2 LTR RI analytical results.
.
Area of Low/Probable Contamination - The area where hazardous
constituents were detected (regardless of concentration) and all locations
with high probability of having been used for disposal of waste materials
in the past.
The probable area of soil contamination, as shown on Figure 2, is estimated to cover an area
of approximately 1.2 million square feet (approximately twenty seven acres).
b. Groundwater
The presence of hazardous constituents in the landfill is indicated by the chemical
composition of the groundwater. VOCs and SVOCs, and inorganic compounds were
detected in the groundwater including 1-1 dichloroethane, trichloroethelene, 1,2
dichloroethene, acetone, toluene, ethylbenzene, xylene, 4-methyl-2-pentanone,
chloroethane, I-I-trichloroethane barium, chromium, methylene chloride, 2-butanone and
cadmium. Contamination above Maximum Contaminant Levels (MCL) was found at a
depth of 95.4 feet.
The upper aquifer contained high concentrations (3,000 to 5,000 ug/L) of acetone and
2-butanone, and high concentrations (41,800 to 1.3 million ug/L) of calcium, iron,
magnesium, potassium and sodium. Moderate concentrations (100 to 220 ug/L)of
methylene chloride, 1,2-dichloroethene, and tetrachloroethene were detected. Three
semivolatile phenols were also identified.
Extensive VOCs (greater than 1,000 ug/L) were found in the lower aquifer including
chloroethane, methylene chloride, 1, 1-dichloroethane, 1,2-dichloroethene, and 1, 1,1-
trichloroethane. Phenols, phthalates, pesticides and Polychlorinated Biphenyls (PCBs)
were also detected in the lower aquifer. Concentrations begin to decrease north of the
LTR Site and toward the Branch River. The September 23, 1991 Record Of Decision
selected groundwater pump and treat to actively restore the aquifer to Federal and State
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of Wisconsin groundwater quality standards as one of the components of the remedial
action for the first operable unit at the LTR site.
c. Soils
At the LTR site. surface soils contain VOCs at concentrations ranging from 230 to 2.000
ug/kg, SVOCs ranging from 94 to 2,000 ug/kg and pesticides including Aldrin at
concentrations of 240 ug/kg and Dieldrin at concentrations of 200 ug/kg. Subsurface
soils at the LTR site had lower concentrations of VOCs than the surface soils. ranging
from 3 to 620 ug/kg. SVOCs, pesticides, and PCBs were not found in the LTR
subsurface soils. The risks from the soils from the LTR site were further assessed in
the OU2 RI.
d. Sediment, Surface Water and Leachate
Sediment and surface water samples were collected at and near the LL and L TR Sites,
including the wetland area. Sediment samples showed low concentrations of VOCs;
however, one sample south of the LL site contained acetone detected at 510 ug/kg.
Surface water samples contained phthalates, methylene chloride and acetone at low
levels. Of the four leachate sample locations planned, leachate was found at only one
location, in the northwest comer of the LL site. Organics were not detected in this
sample.
VI. SUMMARY OF SITE RISKS
The RI for OU2 at the L TR site revealed potential sources of contamination at most test borings
and test pit investigative locations across the site. Fill soils intermixed with solid wastes, drums
containing liquid and semi-solid wastes, and naroral soils were encountered at the site. A total
of four drums were encountered during the OU2 RI at L TR.
Founeen VOCs were detected in the test pits, and six VOCs were detected in the borings.
Tetrachloroethylene, acetone, methylene chloride, toluene, ethylbenzene, and xylenes (total)
were detected at concentrations ranging from 1lLg/kg to 380,000 ILg/kg.
Semivolatile organic compounds were most notably present in the test pit samples. Polynuclear
Aromatic Hydrocarbons (P AHs) were also encountered in most fill samples.
A red-pink liquid, clear liquid, and white semi-solid were revealed in two of the drums
encountered during the OU2 RI activities at L TR. The red-pink liquid ponion was sampled and
the analytical data revealed high levels of VOCs and metals, a flash point of 54 degrees
Fahrenheit, and a pH of 4.5.
The baseline risk assessment conducted in 1991 by EPA for OUI RI at LTR was not
quantitatively revised by the RI for OU2. Under the furore residential scenario, potential risks
for new contaminants of concern were qualitatively assessed. The 1991 risk assessment
determined that repeated exposure over many years to the site's contaminated soil increased an
o
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individual's risk of developing cancer to one in 100.000.. The risk assessment concluded that
direct contact with contaminated soils at the site constitutes a health and environmental threat.
Based on the results from the analysis of the drummed wastes, it was detennined that the high
levels of VOCs and the low flash point of these wastes constituted an actual or threatened release
and that this presented an imminent and substantial endangennent to the public health, welfare,
or the environment.
On July 15. 1993, EPA signed an AOC with eleven PRPs to do removal activities at the LTR
site. The AOC required the PRPs to perform a land survey to better define the boundaries of
the site, construct a fence around the perimeter of the site, perfonn a geophysical study to
delineate areas that could contain buried drums, excavate these areas and remove all drums
encountered, dispose of the excavated drums and their contents, use soil vapor extraction to treat
the contaminated soil adjacent to the excavated drums and "hot spot" areas identified in the RI
Technical Memorandum. and provide site closure by constructing at a minimum a solid waste
cover over the landfill in accordance with NR 504.07, Wis. Adm. Code.
Activities pursuant to the AOC staned in August 1993. The PRPs perfonned a boundary survey
for the site and a geophysical survey. In October 1993, a repon was submitted by the PRPs
presenting the results of the geophysical survey.
A work plan for the excavation and removal of drums from the L TR site was approved by EP A
in November 1993. On November 22, 1993, field activities related to the excavation and
removal of drums started at the LTR site. The excavation and classification of drums were
completed by April 1994. During excavation activities, a total of 1,380 buried drums were
excavated and put into overpacks. Additionally, 180 laboratory-type jars and 226 gas cylinders
were found during excavation activities. All drums will be classified and disposed of at an EPA-
approved facility.
Finally, as pan of the work required by the AOC, the PRPs will submit a work plan for the
design and construction of a soil vapor extraction system and at a minimum a landf1l1 cap in
accordance with NR 504.07, Wis. Adm. Code. In the event U.S. EPA, in consultation with
WDNR, detennines, prior to cover construction, that the soil vapor extraction system would not
be effective in removing VOCs from the source, U.S. EPA will require as. NR 504.07, Wis.
Adm. Code, composite cover system to be constructed to provide for a grater reduction of
infiltration through the source. As pan of the implementation of the AOC, U.S. EPA in
consultation with WDNR, will develop effectiveness criteria for the soil vapor extraction system.
Compliance with Wisconsin Statute, Chapter 160 and NR 140, WAC, will be achieved through
the implementation of the final remedy selected for groundwater as discussed in the September.
1991 ROD for OUI at the site.
The construction of a landfill cap will reduce the risk of direct contact and ingestion of waste.
The infiltration of water through the waste will be reduced too. Furthennore, the removal of
drums in conjunction with the construction of a soil vapor extraction system at the site will
reduce the toxicity, mobility and volume of the contaminants by treating the waste. Pursuant
to 40 CFR Section 300.415, the activities required by the AOC will meet Federal and State
ARARs to the extent practicable. The removal of drums and the treannent of waste by using
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a soil vapor extraction system will reduce the risk to human health and the environment over the
long tenn.
EP A believes that once all the activities required by the AGe are implemented, there will be no
risk. therefore, no further action will be needed at the site.
VII. EXPLANA TION OF SIGNIFICANT CHANGES
There are no significant changes from the recommended alternative described in the proposed
plan.
VIII. STATE CONCURRENCE
The State of Wisconsin concurs conditionally with the action from a technical standpoint.
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RESPONSIVENESS SUMMARY
LEMBERGER TRANSPORT AND RECYCLING SITE
SOURCE CONTROL OPERABLE UNIT
MANITOWOC, WISCONSIN
PURPOSE
This responsiveness summary has been prepared to meet the requirements of Sections 113 (k)
(2) (B) (iv) and 117(b) of the Comprehensive Environmental Response. Compensation, and
Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), which requires the United States Environmental
Protection Agency (U.S. EPA) to respond to each of the significant comments, criticisms,
and new data submitted in written or oral presentations on a proposed plan for remedial
action. The responsiveness summary provides a summary of citizen's comments and
concerns identified and received during the public comment period, and U.S. EPA's
responses to those comments and concerns. All comments received by U.S. EPA during the
public comment period will be considered in the selection of the remedial alternative for the
Site. The responsiveness summary serves two purposes: It provides U.S. EPA with
information about community preferences and concerns regarding the remedial alternatives,
and it shows members of the community how their comments were incorporated into the
decision-making process.
This document summarizes written and oral comments received during the public comment
period of July 18 to August 17, 1994. The public meeting was held at 7:00 p.m. on August
3, 1994 at Franklin Town Hall, Cato, Wisconsin. Comments were submitted during the
public meeting by the Wisconsin Department of Natural Resources (WDNR) and two
residents. Two comments were mailed to U. S. EP A.
OVERVIEW
The proposed remedial action for the source control operable unit (OU) at the Lemberger
Transport and Recycling (L TR) Site was announced to the public just prior to the beginning
of the public comment period. U.S. EPA proposed "No Further Action."
State Comments
1.
Comment: The WDNR believes it would be best to delay the final decision on the
type of closure at the LTR Site, e.g., the type of cover or capping system to be
employed, until additional information can be provided by the responsible parties and
additional public input can be obtained. The Department believes that the
postponement of a final decision would not cause any significant delays in the overall
project schedule, and could, in fact, accelerate the overall schedule by avoiding future
design problems.
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ResDonse: It is U.S. EPA's position that the information available at this time is
enough to make a final decision on the type of closure for the LTR site. Two
Remedial Investigations (RI) have already taken place, and the source characterization
performed was very rigorous. The identification of areas of contamination and the
location of drummeti wastes were appropriately identified. During the RI activity for
OUI and aU2, 22 surface soil samples plus three background samples were collected,
18 soil borings were done, and 13 test pits were dug. In addition, the Administrative
Order on Consent (AOC) required the Potentially Responsible Parties (PRPs) to do
additional geophysical investigations and to identify and excavate all anomalies to
determine if drums were buried in such areas. Approximately 1,400 drums were
excavated, eliminating the possibility of drums leaking into the soils. The RI
provided information on soil characteristics at the site. Based on this information,
there is literatUre that shows a soil vapor extraction system can work adequately in
these types of soils. U.S. EPA does not agree with WDNR, because delaying the
final capping decision will cause delays in the project schedule.
2.
Comment: If U. S. EP A must make a final decision now, then the Department would
concur with
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accordance with the State regulations. U.S. EPA does not have authority ro close this
landfill.
4.
Comment: One commenter said he is disappointed with the final proposal. "It
appears to be a Band-Aid type of solution. I fear that simply capping the residues
over will only pur off the complete cleanup for 20-30 years. Let's clean the site
properly the first time! At the very least, dig up the most highly contaminated soil
residues around the trenches, and either package it and ship it off for disposal, or
clean it up, preferably by burning. Who will pay for the cleanup?"
Response: The purpose of the landfill cap is to prevent direct contact with the landfill
waste and reduce water infiltration. Additionally, a soil vapor extraction system will
be installed to treat the most contaminated soils. Excavating the waste from the
landfill and shipping it off-site to be incinerated is not a feasible and cost effective
option. Excavation of most of the contaminated waste will pose risk of high exposure
to contaminants in the shon term for site workers. The cleanup for both operable
units at the Lemberger Sites will be paid by 11 Potentially Responsible Panies that
have entered into a Consent Decree for the implementation of the cleanup plan for the
first operable unit and into an Administrative Order on Consent for the cleanup
activities at the second operable unit.
5.
Comment: The same commenter agreed with WDNR that if the site is to be capped,
it should include a plastic geomembrane, and questioned the effectiveness of the soil
vapor extraction system in soils with a lot of clay.
ResDonse: A composite cap with a plastic geomembrane is not appropriate because
construction of the soil vapor extraction system would impair the integrity of the
composite cap. An NR 504.07 cap will provide an adequate level of protection when
combined with treatment and can easily be repaired after installation of the soil vapor
extraction system. U.S. EPA has initiated cleanups at sites with similar soil
conditions to the L TR site using soil vapor extraction and it has been demonstrated
that the system can work adequately. Additionally, the areas to be treated at L TR,
coincide for the most part with the areas where drums were excavated. The soil in
these excavated areas is not as tight as the soil in undisturbed areas. This situation
provides for improved transmissivity of the injected air, thus, improving the
effectiveness of contaminant removal at the site.
6.
Comment: One commenter noted that at an early-on meeting, a plan for containing
the contamination in one area called for the construction of a slurry wall and had the
following questions: Is the wall deep enough? What's to prevent contaminants from
entering groundwater below the walls? Is the water removal a one time shot, or will
it be repeated ad infinitum? No plans were made to dispose of the contaminated
water. Was it to be purified in an official treatment plant, or casually filtered on site?
What was to be done with the partially treated water? Was it to be drained into the
A-3
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Branch River watershed? What was planned to keep it from entering a groundwater
aquifer?
Response: This comment refers to the cleanup being implemented as pan of the first
operable unit (OUl) for the site. A Record of Decision was signed in September
1991 for aUi. The slurry wall will be constructed around the perimeter of the waste
in the Lemberger Landfill. This wall will be keyed into a clay unit that separates the
upper aquifer from the lower aquifer. This clay unit will serve as a protective barrier
to prevent migration of groundwater under the wall. Additionally extraction wells
will be placed inside the area enclosed by the wall to extract the leachate generated.
These wells will serve as hydraulic controls to prevent the migration of the
groundwater in contact with the waste away from the area enclosed by the wall. U.S.
EPA assumes the "water" the commenter is referring to is the leachate contained
within the wall. Once this leachate is pumped it will be trucked and shipped to a
Publicly Owned Treatment Works (POTW) for its final disposal and treatment. It
will not be drained to the Branch River watershed nor will it be disposed of so it
enters the groundwater.
7.
Comment: The same commenter asked whether the extraction of contaminated water
from a series of wells for the groundwater pump and treat system was to be done
periodically once or periodically over ten, twenty, or fifty years. Treating the water
"on site" is highly inadequate. It needs to go through an established treatment plant.
Response: Again this comment relates to cleanup plan for OUI. The groundwater
pump and treat system will be designed and constructed to operate continuously. It
has been estimated that the cleanup of the groundwater will take approximately fifteen
years. During the Feasibility Study (FS) for OUI various ways of dealing with the
remediation of the groundwater were evaluated. The FS determined that treatment on
site was the most preferable.
8.
Comment: The same commenter asked, " What are the residents of the area to do
while the cleansing process takes place? Residents would live every day with the
ever-present question, 'Is our drinking water contaminated?'"
Response: The PRPs are required to monitor the residential wells during the duration
of the remediation project. If any wells are impacted by the site contamination during
this timeframe, measures will be taken by U.S. EPA to replace the drinking water
wells or provide a safe drinking water supply.
9.
Comment: The same commenter said in the diagram, air was forced down a pipe at
the L TR site and was supposed to move through the contaminated soil and find its
way to an "exit pipe." "I can just hear the gasping air shouting, 'Where is that exit
pipe?'" What if the air found some other exit in a rock layer or underground
A-4
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channel? Would it erupt at some unexpected. undesirable point? Could it be
anywhere?
Response: The diagram presented in the fact sheet for the LTR site was used for
illustration purposes only. U. S. EP A does not intend to install only one air injection
well and one vapor extraction well. The number of air injection and vapor extraction
wells will be determined during predesign activities for the site. Since the site will be
capped in conjunction with the soil vapor extraction system, there will be an
extremely minimal chance of the injected air or vapor gas escaping, except through
the extraction wells. Air will be injected, after which vacuum is applied, forcing the
injected air up the extraction wells.
10.
Comment: A commenter expressed that their water treatment technology using the
"Advanced Oxidation Process" (the NOBIS system) may eliminate the proposed plans'
need for transportation of vast quantities of contaminated wastewater to a POTW.
The commenter proposed that NOBIS technologies be tested for the Lemberger sites.
Response: This comment refers to the cleanup plan for OUI. An FS was prepared
evaluating treatment technologies to address the contamination at the Lemberger sites.
The 1991 ROD selected groundwater pump and treat. The ROD specified that either
carbon adsorption or air stripping could be used as the treatment technologies. A
pump test and treatability study has been performed and a conventional air stripping
process was determined to be an adequate way of treating the groundwater. At this
time the design is 95 % complete.
A-5
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=aqe NO.
:5113/91
ACRONYM GUIDE fc~ tne AdminIstratIve Keco~a
~EMBERGER LANDfiLL INC. AND
LEMBERGER TRANSPORT & RECYCLING INC. SITE
MANITOYOC COUNTY, ~ISCONSIN
ACRONYM
DEfiNITION
AR
Administrative Record
ARAR
Applicable or Relevant
and Appropriate Requirements
CERCLA
Comprehensive Environmental
Response, Compensation, and
Li abil i ty Act
~PL
~atl0nal P~iority List
OSIoIER
Office of Solid loIaste
and Emergency Response
RI
Remedial Investigation
RI/fS
Remedial Investigation/
Feasibility Study
RPM
Remedial P~oject Manager
U.S.EPA
United States Environmental
Protection Agency
'';DNR
~isconsln Department of
Natural Resources
-------
: 3qe NO.
~5/'3/9'
ADMINISTRATIVE RECORD INDEX
LEMBERGER LANDfiLL :NC. AND
"EMBERGER TRANSPORT & RECYCLING INC. SiTE
MANITOYOC COUNTY, YISCONSIN
~ICHE/fRAME PAGES DATE
TITLE
AUTHOR
16 91/03/04 Letter roe: Hazaraous G. Edelstein'WONR
Air- Contaminant Contr-ol
Guidance
65 90/08/'" Alter-natives Ar-r-ay B&V ~aste Science ana
Docunent Technology Cor-po
~oo
91/01118
Final Remeaial
investIgation Recor-t
o&V ~aste Science ana
~echnology Corp. ana
USEPA
Volume 1 - Recor-t
i
-------
:age NO.
:'::/13/91
:~ICANCE DCC~MENTS INDEX
~EMBERGER LANDFILL AND LEMBERGER TRANSPORT & RECYCLING S.7E
Guidance uocuments are avallacle ter revIew at
~SEPA Region V-Chicago !L
i I TLE
AUTHOR
:ATE
Soil Survey of Calumet
and Manitowoc Counties,
USDA,Soil Conservation Service 80/02/00
'WisconsIn
User's Guide to the
Contract Laboratory
Program
USEPA
96/12/00
:ERCLA ComcLlance
with Other Laws ManuaL:
Part I
USEPA.OS~ER Directive
9234.1-01
33/08/08
Guidance for Conducting
Remedial Investigations
and Feasibility Studies
under CERCLA, Interim
Final
USEPA,OS~ER Directive
9355.3-01
88/10/00
Quality Assurance
Project Plan, Phase I
Remedial Investigation,
Lemcerger Landfill, Inc.
and Lemcerger Transcort
and RecYCling, Inc.
Manitowoc County,WI
USEPA and 8&11
88/'1/30
Guidance on Remedial
Actions for Contaminated
Grouna Water at Superfund
Sites
EPA/540/G-88/0D3
USEPA,OS~ER Directive 9283.1-2 88/12/00
CERCLA Comcliance with
Other Laws Manual:
Part II Clean Air Act
and Other Environmental
Statues and State
Requirements
EPA/540/G-89/009
USEPA.OS~ER Directive
9234. 1 - 02
99/08/00
-------
~age HO.
J5/13/91
TiTlE
~isk Assessment Guidance
fo~ Supe~tund Volume I:
Human Health Evaluation
Mal'lUlll
Final Remeaial
Investigation ReQO~t
~emce~ge~ Lanatill Inc.
ana Lemce~ge~ T~ansDO~t
ana Recycling Inc.
GUIDANCE DOCUMENTS INDEX
LEMBERGER LANDFILL AND LEMBERGER TRANSPORT & RECYCLING SiTE
Guidance Documents are available tor review at
USEPA Region V-Chicago IL
AUTHOR
DATE
USEPA
89'12/00
USEPA,B&V Waste Science & Tech 91'01'18
Co~
.
-------
. age "0.
.5/21/91
:!CHE/FRAME PAGES DATE
426
91/05'10
726
91/05/10
.
ADMINISTRATIVE RECORD INDEX. REMEDIAL ACTION
LEMBERGER LANDFILL INC. AND
LEMBERGER TRANSPORT & RECYCLING INC. SITE. UPDATE NO.1
MANIT~C COUNTY, ~ISCONSIN
TITLE
Final Public Comment
Phased Feasibility
Study Report for
Lemberger Landfill
Inc. and Lemberger
Transport and
Recycl ing Inc.
Vol~ I: Report
Final Publ ic Comment
Phased Feasibility
Study Report for
Lemberger Landfill Inc.
and Lemberger Transport
and Recycling Inc.
Voluae II: Appendices
AUTHOR
RECIPIENT
USEPA
Lemberger Inc.
USEPA
Lemberger Inc.
DOCUMENT TYPE
Report/Studies
Report/Studies
*
..
DOCNUMBEI
2
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"
u.s. EPA ADMINISTRATIVE RECORD
LEMBERGER TRANSPORT AND RECYCLING SITE
MANITOWOC COUNTY. WISCONSIN
UPDATE #3
09/21/94
~R
JOCI ~~TE ~UTHOR RECIPIENT TiTLE/DESCRIPTION PASES
---- ---- ------ --------- ----------------- -----
--------- -----------------
1)4/00/91 G5WER/U.S. EPA U.S. EPA Quick Reference Fact Sheet: Guide to 5
Develooing Superfund No Action. lnterll
Action. and Contingency ReledY RODs
(Publication 9355.3-02FS-3)
~ 09/23/91 Adalkus. V.. U.S. U.S. EPA Record of Decision 79
EPA
. 10/00/92 B ~ V Waste Science U.S. EPA Reledial Investigation Technical MeloranDum 180
anD Technology for the Site Source Control Operable Unit
Corporation
OS/25/93 ','alentin. P.. U.S. ~einer. E.. U.S. EPA Meiorandul re: Closure Reauirelents .,
i.
EPA
5 07/15/93 U.S. EPA Respondents Adlinistrative Order by Consent 28
b 08/13/93 Malcolm Pirnie, Inc. U.S. EPA Phase 1 Work Plan tor Operable Unit 12 79
7 10/00/93 Malcoll Pirnie, Inc. U.S. EPA Geophysical Survey Results 29
8 11/02/93 Malcolm Pirnie, Inc. U.S. EPA Phase 2 Drul Excavation and Reloval Nark Plan 231
(Final)
9 09/02194 Edelstein, 6., WDNR Valentin, P.. U.S. Letter re: Draft ROD for Operable Unit 12 30
EPA w/Attachients
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