United StatM
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROO/R05-85 019
August 1985
Superfund
Record of Decision:
Schmalz Dump,  Wl

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                                    TECHNICAL REPORT DATA
                            (Pleat read Instructions on the reverse before completing)
1. REPORT NO.
   EPA/ROD/R05-85/019
                                                            3. RECIPIENTS ACCESSION NO.
4. TITLE AND SUBTITLE

   SUPERFUND RECORD OF  DECISION
   Schmalz Dump, WI_rr

7. AUTHORIS)
             5. REPORT DATE
                 August 13, 1985
             6. PERFORMING ORGANIZATION CODE
             8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
                                                            10. PROGRAM ELEMENT NO.
                                                            11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS

  U.S.  Environmental  Protection Agency
  401 M Street, S.W.
  Washington, D.C.  20460
             13. TYPE OF REPORT AND PERIOD COVERED
                 Final ROD Report	
             14. SPONSORING AGENCY CODE

                 800/00
18. SUPPLEMENTARY NOTES
If. ABSTRACT

        The Schmalz Dump  site is located in the  town of Harrison, Wisconsin,  on the
  north shore of Lake Winnebago.  The site occupies approximately five acres of
  wetland in the federally designated Waverly Beach Wetlands area.  According to
  the Wisconsin Department of Natural Resources and court documents, industries
  dumped wastes at various locations along the  north shore of Lake Winnebago for
  several years.  Mr. Gerald Schmalz, site owner,  began filling his property in 1968.
  Records show that the  wastes hauled there consisted of car bodies, stone,  water
  tanks, trees, pulp chips and mash.  Between 1972 and 1973, the site accepted fly
  ash and bottom ash from a local utility, and  in  1978 and 1979 Mr. Schmalz accepted
  the demolition debris  from a building owned by Allis-Chalmers Corporation.

       The selected remedial action includes excavation and offsite disposal of 3,500
  cubic yards of contaminated building debris.   Total capital cost for the selected
  remedial alternative is estimated to be $2,088,300.
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                               b.IDENTIFIERS/OPEN ENDED TERMS  C.  COSATl I ield,Gr, >
   Record of Decision
   Schmalz Dump, WI
   Contaminated Media:   soil,  wetlands
   Key contaminants:  PCBs,  chromium, heavy
   metals
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     25
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                                                                          22. PRICE
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                             RECORD OF DECISION
                OPERABLE UNIT REMEDIAL ALTERNATIVE SELECTION
Site:  Sctmalz Dump. Harrison, Wisconsin

Documents Reviewed

• Phased Feasibility Study, Schmalz Dump

- Summary of Remedial Alternative Selection

• Responsiveness Summary

Description of Selected Remedy

- Excavation of 3500 cubic yards of Polychlorlnated blphenyl  (PCB)  contami-
  nated building debris and off-site disposal 1n an approved landfill
  facility.

Declarations

Consistent with the Comprehensive Environmental Response Compensation  and
Liability Act of 1980, and the National Contingency Plan (40 CFR Part  300),
I have determined that removing the PCB contaminated building debris at
Schmalz Dump as a source control operable unit 1s cost-effective, 1s consistent
with the final goals for the site, and provides adequate protection of public
health, welfare and the environment.  Tiie State of Wisconsin has been
consulted and agrees with the approved remedy.

1 have also determined that the action being taken 1s appropriate when
balanced against the availability of Trust Fund monies for use at other
sites.  In addition, the off-site transport and secure disposition 1s  more
cost-effective than other remedial action, and Is necessary to protect
public health, welfare, and the environment.

The U.S. Environmental Protection Agency (USEPA) will undertake a remedial
Investigation/feasibility study (RI/FS) of the Schmalz Dump to evaluate
potential contamination of pathways and potential contaminants remaining
on- site.  If additional remedial actions are determined to be necessary, a
Record of Decision will be prepared for approval of the future remedial
action.
Date
                                        Valdas V. Adanku
                                                Administrator

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          Summary of Operable Unit Remedial  Alternative Selection
                   Schmalz Dump Site, Harrison, Wisconsin
Site Location and Description

The town of Harrison is located on the north shore of Lake Winnebago in  the
east central section of Wisconsin, about 2 miles east of Menasha,  in Calumet
County (see Figure 1).

The Schmalz Dump, which occupies approximately 5 acres of wetland  in the federally
designated Waverly Beach Wetlands area, has undergone unauthorized dumping.
The property north and west of the site has also been used for waste disposal.
To the south, between the site and the lake, is a moderately populated,
residential area.  Residents have recently been hooked-up to the Menasha
water system, although some have retained wells for auxiliary uses.  The
neighboring city of Appleton, with a population of 59,040, has its drinking
water intake 500 feet from the shore of Lake Winnebago, in close proximity
to the site.

Site History

According to the Wisconsin Department of Natural Resources (WDNR)  and court
documents, industries dumped wastes at various locations along the north
shore of Lake Winnebago for several years.  Mr. Gerald Schmalz, site owner,
began filling his property in 1968.  Records show that the wastes  hauled
there consisted of car bodies, stone, water tanks, trees, pulp chips and
mash.  Between 1972 and 1973 the site accepted fly ash and bottom  ash from
a local utility, and in 1978 and 1979 Schmalz accepted the demolition debris
of a building owned by the Aliis-Chalmers Corporation.

Initial sampling on-site by the State of Wisconsin and the U.S. Army Corps
of Engineers (COE) in early 1979 determined that the area where the Allis-
Chalmers debris was located was contaminated with concentrations of PCBs as
high as 3100 ppm.

In the summer of 1979, the Wisconsin Attorney General filed suit against
Mr. Schmalz, the waste hauler - Weiseler Construction, and All is Chalmers
Corporation, alleging Illegal disposal of PCBs.  However, due to lack of
direct evidence, the court ruled against the State.  In 1983, Gerald Schmalz
sold the property to his son Gregory.

In September 1984, the site was listed on the National Priorities  List.
USEPA completed a report identifying potentially responsible parties,
including waste generators and transporters in October 1984.  RI/FS work
was Initiated during April 1985.  Since a threat to public health  has
been identified due to the PCB contaminated demolition debris, USEPA and
WDNR decided to prepare a Phased Feasibility Study (PFS) to evaluate
potential source control remedies.

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y
                                                                                        •CALE 1 IN. :2000 FT.
                                                                                         7 ra •«% emr   cimin

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                                    -2-


Current Site Status

The PCB contaminated demolition debris covers an area of about  one  half
acre; approximately 3500 cubic yards in volume.   The material consists of
primarily wood, masonry, shingle,  black granular material  and concrete,  and
is generally three to five feet deep, of which one to two feet  are  under
water.  Drawing D-l outlines  the area covered by debris.

Test results from 1980 indicate that PCBs are not uniformly dispersed
throughout the debris.  Some  locations sampled were below 1 ppm PCB while
others showed concentrations  as high as 3100 ppm PCB.  Samples  collected
outside of the debris area had concentrations less than 1 ppm PCB,  indica-
ting that the migration of PCBs had initially been confined to  the  debris
and the sediment below it. PCB concentrations for samples analyzed from
various substrate types and their  depths are presented in Table 1.  Sample
locations are shown on Drawing D-2.

PCB is a documented animal carcinogen and is known to bioaccumulate in the
fat tissues of humans and animals.  Studies have shown that exposure to
PCBs causes a variety of adverse effects in humans such as impared  liver
function; neurobehavorial and immunological impairment; and chloracne  (a
severe skin disorder).  Also  associated with PCB exposure are premature
births, decreased birth weight, birth defects, menstrual disorders  and
impaired reproduction.  Animals experimentally exposed to PCBs  have shown
pathological changes in the liver, stomach, and skin and increased  incidences
of cancer in those organs as  well.  There is some evidence that PCBs have
also caused increased cancer  incidence in workers who have been exposed  tr
PCBs over prolonged periods.
                                                  i
Based on available sample data and given the current recommended health
advisories for PCBs, the Schmalz site poses a significant risk  to public
health and the environment.  There are several pathways for exposure of  PCBs,
however, direct contact and ingestion of contaminated soil are  the  most
significant pathways at present.  The site is frequented by various wildlife,
including many types of nesting birds and domestic animals.  Local  residents
use the site for hunting and  as a short cut, and could possibly scavenge
the debris.  Also, children have been known to play in the area.

Other pathways include contaminated surface water, groundwater, and soils,
and.consumption of contaminated wildlife.  At present there is  no record of
off-site contamination, however, future risks may be created from PCBs
being transported by sediment, surface water or groundwater. Although  PCBs
have greater affinity to sediment, they can become soluble in water.   PCB
concentrations at the site are high enough to cause this to occur.  In
addition, solid particles moving in the groundwater and surface waters
transport significant amounts of PCBs.  These pathways could lead to increased
levels of PCBs in Lake Winnebago and consequently to increased  concentrations
of  PCBs in fish inhabiting the lake.  In addition, the City of  Appleton's
drinking water intake, located 500 feet off-shore, as well as private  wells
in  the area, could become contaminated.

Sample results from 1979 and  1980 also 'showed high levels of lead,  chromium,
and copper associated with the building debris.  These contaminants could
also pose a threat to groundwater and surface water pathways through
migration in solution or as solid particles.  The remedial investigation

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                          TABLE 1
SVffWARY OF PCB ANALYSIS CONDUCTED AT THE SCHKALZ DUMP SITE.
                    HARRISON. WISCONSIN
No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
•32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
Description
Granular
Mood
Black Sandy Peat
Granul ar
Black Sandy Peat
Granular
Mood
Roofing Paper
Black Sandy Peat
Granular
Mood
Black Sandy Peat
Granular
Mood
Black Sandy Peat
Granular
Mood
Granul ar
Mood
Black Sand
Granular
Mood
Granular
Mood
Black Sandy Peat
Granular
Mood
White Material
Black Sandy Peat
Granular
Mood
Black Sandy Peat
Granular
Hoed
Granular
Mood
Mhlte Sticky Solids
Granular
tin • A
wooo
Black Sandy Peat
Granular
Mood
Mhlte Solids
Granular
Mood
Black Peaty Sand
Granular
Mood
Red Solids
Granular
Mood
Depth (ft)
2.0
2.0
2.5
2.0
3.0
2.0
2.0
2.0
3.0
2.0
2.0
3.0
1.0
1.0
1.5
2.0
2.0
2.0
2.0
4.0
2.0
2.0
2.0
2.0
4.0
2.0
2.0
1.0
3.5
2.0
2.0
3.0
2.0
2.0
2.0
2.0
1.0
2.0
2.0
3.0
1.5
1.5
1.0
1.5
1.5
3.0
1.5
1.5
1.5
2.0
2.0
Analyst
1
1
i
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PCB
(«9/kgl
585.0
73.4
4.6
72.0
6.0
366.0
124.0
2.7
4.0
466.0
16.9
4.7
11.7
22.0
4.4
134.0
37.2
71.4
3.1
3.2
323.0
37.7
150.0
44.4
2.3
39.0
5.8
37.6
10.0
774.0
127.0
5.6
54.0
1.7
84.0
20.1
6.9
166.0
31.1
1.5
149.0
1.6
3.9
28.6
7.0
1.1
541.0
9.7>
60.4
1602.0
1396.0

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TABLE 1
(continued)
NO.
s<
S3
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
62
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
Description
Black Peaty Sand
Granular
Wood .
Black Peaty Sand
Granular
Wood
Granular
Mood
Gray Sand
Granular
Mood
Gray Sand
Granular
Mood
Gray Sand
Granular
Mood
Gray Sand
Granular
Wood
Gray Sand
Mood
Black Peaty Sand
Gray, Sand
Black Granular Solids
White Sol Ids
White Sol Ids
White Solids
Black Solids
White Solids
White Solids
Black Solids
White Solids
White Solids
Sediment
Sediment
Stdlunt
S*d1awnt
S«d1ment
S*d1aent
Sedluent
StdlMnt
Sediment
Stdlment
Sediment
Sediment
Sediment
Sediment
Sediment
Sediment
Sediment
Sediment
Sediment
Deotn (ft)
3.5
2.0
2.0
3.5
0.5
0.5
2.0
2.0
3.5
2.0
2.0
3.5
2.0
2.0
.4.5
2.0
2.0
3.5
2.0
2.0
4.0
2.0
3.0
4.0
Surface
Surface
Surface
Surface
3.5
4.0
1.0
2.0
Surface
Surface
1.0
3.0
1.0
3.0
1.0
3.0
1.0
- 3.0
1.0
3.0
5.0
1.0
5.0
9.0
1.0
5.0
1.0
3.0
5.0
Analyst
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
I
1
1
1
1
1
1
1
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
(nj/ko)
8.5
1CI.O
11.8
1.1
16.7
0.1
88.3
3.4
4.1
46.0
5.1
8.3
41.6
4.9
*•!
420.0
3.2
<1.0
7.8
<1.0
1.4
<1.0
1.3
<1.0
<1.0
^1 «0
<1.0
<1.0
<1.0
*jj ,0 •

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TABLE 1
(continued)
Sample
No.
105
106
107
108
109
110
111

112
113
114
115
116
117
118
119
120
121
122
123
124
125
126
127
128

129
130

131
132
133

134
-135
136
137
138
139
140
141
142
143

144
145
146
Description Ofpth (ft)
Matte 1-0
Waste 1-0
Matte 1.0
Matte Surface
Mood Surface
Mood Surface
Mood Surface
\
Mood Surface
Mood Surface
Mood 1.0
Mood Surfact
Mood Surface
Mood Surface
Mood Surfact
Soil /Sludge Surface
Sediment 1.0
Soil Surface
Sediment 1.6
Soil Surface
Black Granular Material 1.0
Black Granular Material 3.0
Oil Soaked Mood 1.0
Black Granular Material 1.0
Black Granular Material/
Mood 3.0
Met Granular Material 5.0
Black Granular Material/
Wood 1.5
011 Soaked Mood 1.5
Cinder Pile 0.5
White Sand/Black
Granular Material 1.0
White Sand 0.5
Clay Material Surface
Black Granular Material
Black Granular Material Not Located
Black Granular Material Not Located
Black Granular Material Not Located
Black Granular Material Not Located
Mood . Not Located
Other Material - 1.0
Black Granular Material/
Mood 1.5
Mood 1.5
Other l.S
Oil Soaked Mood 1.5
Analyst
2
2
2
2
2
2
2

2
2
2
2
2
2
2
2
2
2
2
2
3
3
3
3
>
3
3

3
3
3

3
3
3
3
3
3
3
4
4
4

4
4
4
4
PCS
2.3
5.9
2.9
5.6
6.7
2.1
3.4

2.4
2.1
2.8
1.1
2.5
5.3
4.1
0.06
0.04
0.12
0.03
0.52
15.0
210.0
9.8
220.0

36.0
88.0

2200.0
110.0
19.0

0.58
0.45
<0.05
<0.2
<0.2
0.77
<0.2
185.0
31.5
195.0

2400.0
128.0
3100.0
8.94
1  RHT. Inc.   M«y.  1980. July 1980
2  COM. Inc.   Novwtor, 1979
3  MONR  NovtWtr.  J979, *»rcl> 1*80
«  B«U*c«. Inc.  March. 1980
>«tultt ft
                      in «g'tg  on * dry
                                              bisit.

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• .• -  *y       ^x^


^'l^'*!?*''':>«W- .-. -^     (

^^^
•:•  :.-..:* --r>*-.W*.:-.v.V:>s;••-.:... >.

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                                    -.i-


to be performed at the site, following the source control  remedial  action,  will
study the various pathways to determine if migration of PCBs and  heavy metals
has occurred.

The PFS prepared by USEPA in June 1985 concluded that continued exposure of the
public and the environment to PCBs presents an unacceptable public  health risk.
As a result, a removal action to construct a fence around  the debris has been
completed and a source control  operable unit for remedial  action  is needed  to
protect public health and the environment from future exposure to PCBs.  This
action will also control  future release of heavy metals associated  with the debris.

Enforcement

CERCLA related enforcement activities began at the site in 1984.   A
responsible party search was conducted to identify potentially responsible
waste generators and transporters.  Eight parties were named for their
involvement in the site, including parties who were named  in the State's
unsuccessful 1979 law suit.  Notice letters were sent to each party and a
negotiating meeting was held to discuss the cleanup.  At the end of the
negotiating period, none of the parties had committed to do the work.

Alternatives Evaluation

The phased feasibility study was initiated to evaluate alternative remedial
actions for remediation of PCBs at the Schmalz site.  Controlling the
release of PCBs, by removing the contaminated debris, would eliminate the
threat of direct contact and would stop future releases to the surrounding
environment and receptor pathways.  Five remedial action alternatives were
looked at for the site.  They are listed in Table 2.'

                                  TABLE 2
                        REMEDIAL ACTION ALTERNATIVES

Alternative 1 - PCS Removal to less than 50 ppm

                Removal of building debris contaminated with 50 ppm PCB or
                greater and off-site disposal by landfill ing or incineration.

Alternative 2 - On-Site Disposal

                Construction of an on-site disposal facility which meets
                all applicable State and Federal environmental regulations
                and laws.

Alternative 3 - Source Control - Source Removal

                Removal of all PCB contaminated building debris and off-site
                disposal by landfilling or incineration.

Alternative 4 - On-Site Management

                Actions to minimize direct contact and migration of PCBs by
                capping, grading, and  revegetation of the site and by  limiting
                access.

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                                    -4-


Alternative 5 - No Action

                An alternative that involves no remediation of the site
                during this operable unit remedial  action phase.

Alternative 1

Alternative 1 involves excavation of 1389 cubic yards of material  from the
site.  Sample results from 1980 showed two areas within the debris contain
the highest levels of PCBs.  Excavation will include approximately four
feet of debris and one foot of sediment beneath it.  This material will be
dewatered on-site and rendered to a form acceptable for the proposed disposal
option.  A temporary berm will be necessary to prevent contaminated water
from reentering the wetland during dewatering and a wash pad will  be required
for decontamination of trucks and equipment.  A wastewater treatment unit
will be installed to treat contaminated water generated during dewatering
and decontamination.  Water treatment will remove PCBs to below the detection
limit of .5 ppb.  The treated water will then be discharged to the adjacent
pond.  Any metals in the water will also be removed in this process.

The landfill option for Alternative 1 calls for disposal of material in an
off-site TSCA (Toxic Substance Control Act) approved RCRA (Resource Conservation
and Recovery Act) landfill facility.  Table 3 summarizes the costs for this
option.

                                  TABLE 3
                       »
                  Cost for Alternative 1 - Landfill Option
                                                   i

                    Capital Cost               1,176,050

                    Annual Operation and         N/A
                      Maintenance  (0 & M)

                    Present Worth              1,176,050

The incineration option for this alternative calls for incineration of exca-
vated material at a TSCA and RCRA approved off-site facility.  This requires
rendering the material to a form acceptable for disposal.  This is accom-
plished by shredding and pulverizing the material on-site and placing it
into 30 gallon plastidrums for transport to an approved incinerator.  Bulk
scrap, that is too large to pass through the shredder, will require cutting
with a laser prior to grinding.  A fine spray of water over the shredder
will be necessary to minimize dust emissions during operations.  The costs
for this option are summarized in Table 4.

                                  TABLE 4

                Cost for Alternative 1  -  Incineration Option

                    Capital Cost               3,346,978

                    Annual 0 & M                N/A

                    Present Worth              3,346,978

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                                    -5-


AHernatlve 2

Alternative 2 involves construction of an on-site disposal  facility for
the PCB contaminated debris.  The facility would have to meet all  RCRA and
TSCA regulations for constructing a disposal  facility,  as well  as  all  State
laws and regulations involved in locating and constructing a disposal  faci-
lity.  In addition, the alternative must comply with site management  and
control techniques, installation of contaminant monitoring facilities, and
contaminant migration protection strategies.   This alternative would  include
excavation of demolition debris and placement in the constructed,  on-site
land disposal facility.  The facility would require a double liner and
double leachate collection system.  A berm would also be constructed  around
the facility in compliance with regulations.   Table 5 summarizes the  cost
for this alternative.

                                  TABLE 5

                           Cost for Alternative 2

                    Capital  Cost               4,582,000

                    Annual 0 & M                N/A

                    Present  Worth
                       2 year                  4,638,000

                      30 year                  4,886,000
                                                     \
Alternative 3

Alternative 3 involves excavation of 3500 cubic yards of material  from the
wetland.  This includes three to five feet of demolition debris and one
foot of sediment below it.  The material will be dredged from the  wetland,
dewatered on-site, rendered  to a form acceptable for the proposed  disposal
option and transported to a  TSCA approved RCRA facility for disposal.  A  tempo-
rary berm will be constructed to prevent contaminated water from reentering
the wetland during dewatering and a wasn pad  will be installed for deconta-
mination of-trucks and equipment.  A wastewater treatment unit will also
be required to treat contaminated water generated during dewatering and
decontamination.  Water treatment will remove PCBs to below the detection
limit of .5 ppb.  The treatment will remove heavy metals as well.   Once treated,
the water will be discharged to the adjacent  pond.

The disposal options for Alternative 3 are the same as for Alternative 1;
landfilling or incineration  of waste.  The difference in cost is due to the
increased amount of material for this alternative.  Table 6 summarizes the
cost for landfill ing the waste.

                                  TABLE 6

                  Cost for Alternative 3 - Landfill Option

                    Capital  Cost              2,088,300

                    Annual 0 4 M                 N/A

                    Present  Worth             2,088,300

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                                     -6-
The cost of the incineration option for this alternative is summarized  in
Table 7 below.
                                  TABLE 7
                Cost for Alternative 3

                    Capital  Cost

                    Annual  0 & M

                    Present  Worth
Incineration Option

      7,180,240

        N/A

      7,180,240
Alternative 4
Alternative 4 involves on-site management  of the contaminant source in an
effort to minimize the threat of direct contact, and reduce the migration of
contaminants off-site.  This alternative would include site cover and  site
control  -features.   Site cover would consist of an impermeable cover of
clays and soils with supporting vegetation.  It would be graded to provide
drainage away from the site, in order to prevent vertical  migration of rain
water, surface runoff and surface water ponding.

Actions taken for  this alternative would reduce public exposure to some extent,
but would not protect groundwater and the  surrounding wetland from leachate
transport of PCBs  and metals.  Cost estimates for Alternative 4 are summarized
in Table 8.

                                  TABLE 8

                           Cost for Alternative 4

                    Capital  Cost                 536,938

                    Annual  0 & M                  14,000
                    Present Worth
                       2 year

                      30 year
        561,250

        668,950
Alternative 5
Alternative 5 is the "No Action" alternative.  This alternative would
involve no remediation of the PCB contaminated material  at this phase of
the project.  Rather, the RI/FS would be completed and a final  remedy for
the site would be evaluated.

Alternative Evaluation Criteria

The alternatives were evaluated according to the following factors:

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                                    -7-
     0 Ability to protect public health and the environment
       Technical feasibility
       Compliance with environmental  standards
       Consistency with the final  remedy
       Environmental impact
       Community impact

Table 9 summarizes the analysis of the remedial action  alternatives.

Summary;

Alternatives 2 and A have only marginal technical  feasibility due" to  the
nature of the material and the location of the site.  There  would  be
difficulty in capping the site in its present condition,  and the long term
effectiveness of a cap at this site is questionable because  of settling of
material and seasonally high water table conditions.  The high water  table
would require that the disposal facility be built  almost  entirely  above
ground.  This would make it difficult to comply with  Federal and  State
regulations for construction of the facility.  Other institutional issues
arise from the sites location, because of its proximity to Lake Winnebago
and area drinking water supplies.  In addition, Alternative  4 does not con-
trol migration of leachate to the various pathways and  receptors.   A  failure
of the facility in Alternative 2 could also result in leachate migration.
Both alternatives would have high environmental impact  because the site is
in a wetland and sensitive flora and fauna are associated with it.  Both
alternatives have high community impact because the residents disagree with
actions, that would leave the possibility of contaminant  leachate  as  a
potential problem. Implementation of either alternative would make future
on-site studies difficult or impossible and could  conflict with the final
remedy for the site if that remedy involved further management, treatment,
or excavation of the demolition debris.

Alternative 5 does not meet the objectives for the operable  unit  remedial
action.  By taking "no action" at the site, the PCB contaminated  material
will remain unmanaged until a final remedy for the site is implemented.
This would pose a significant threat to public health and the environment
and wouldL not prevent migration of PCBs into the various  pathways  around
the site.

Both options of Alternative 3 are technically feasible, cost-effective, do
not require complex planning or design, protect public  health, would  not
conflict with the final remedy, exceed applicable  and relevant environmental
standards, and. have low community impact and high community acceptance.

The issue differentiating the two methods of disposal at  this site is the
extensive manipulating of the demolition debris required  to render it
acceptable for incineration.  The nature of the material  is such  that it
requires grinding and cutting to reduce the bulk.   This creates significant
handling and safety problems since PCB contaminated fugitive dust will
likely be generated during operations, and would have a negative  environ-
mental impact due to the dust emissions.  In addition,  some material, such
as concrete with reinforced rods, metal beams and other metal objects, are
unsuitable for incineration and must be landfilled.  Landfilling  all  of tne
material will greatly reduce the potential for dust emissions and significantly
cut down on safety and handling problems.

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                                             TABLE 9

                                SUMMARY OF ALTERNATIVES ANALYSIS
    ALTERNATIVES
 ABILITY TO
  PROTECT        TECHNICAL
PUBLIC HEALTH   FEASIBILITY
 COMPLIANCE WITH
  ENVIRONMENTAL
-   STANDARDS *
ENVIRONMENTAL   COMMUNITY
   IMPACT        IMPACT
PCB Removal to
less than 50 ppm Moderate High
On-Site Disposal Moderate Low
i
Source Control -
Source Removal Good High
On-Site Management Poor Low
No Action Poor N/A

Meets
Standards
Meets
Standards
Exceeds
Standards
Does Not
Attain
Standards
Does Not
Attain
Standards
Landfill: low
Incineration:
Moderate
High
Landfill: Low
Incineration:
Moderate
High
N/A
Moderati
High
Low
High
High
'Environmental  standards refer to the applicable and  relevant  standards as  refered  to in the
 proposed changes to the NCP dated February 12,  1985.

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Both options of Alternative 1 are technically feasible,  cost-effective, do
not require complex design.  However, this alternative could conflict with
the final remedy for the site because mobilization,  subcontractor procurenent
•nd bertn construction will have to be repeated If  the final remedy calls
for excavation of the remaining material.  In addition,  Regional policy
dictates advisory levels of 1 ppm for PCBs In soils  and  sediment and even
lower levels for water.  Health advisories currently being developed by
USEPA recommend setting advisory levels for PCBs much lower that 1 ppm for
sites where direct contact with PCBs Is • concern.

Alternative 3 1s the most cost-effective alternative because 1t best protects
public health and the environment and Is most consistent with the final
reoedy for the site.  However, due to the health and safety concerns associated
with dust Missions and handling problems, and the nature of the material,
the landfill option of Alternative 3 1s recommended  as the alternative that
cost-effectively protects public health and the environment.

Community Relations

Copies of the PFS were made available to the community on July 1, 1985.
Two locations served as repositories In the area:  the Fox Valley Library
of the University of Wisconsin In Henasha, and the Harrison Town Hall.  The
USEPA Issued a press release on June 25, 1985, which announced the avail-
ability of the study, the commencement of the 3-week public comment period,
and the schedule for the public meeting.

The public Meeting was held on July 9, 1985 at the Harrison Town Hall.
Approximately 20 residents attended the meeting.   Representatives of the USEPA,
MDNR and local government were present.  The USEPA presentation explained
the purpose of the PFS, described the current situation  regarding site
contamination, and the alternative being recommended by  USEPA.  Questions
regarding the project were also answered.  One public comment was submitted
during the meeting.  The public comment period ended on  July 22, 1985.
Public comments are addressed In the attached responsiveness summary.

Consistency H1th Other Environmental laws

The proposed action will not reqtlre on-s1te treatment,  storage or disposal
of hazardous wastes.  Therefore, there are no Issues Involving the consistency
of on-s1te actions with RCRA or TSCA.  The removal,  transport and disposal
of PCBs are regulated under TSCA.  Therefore, the disposal  facility must  be
TSCA approved and meet all disposal requirements  established In 40 CFR
761.60.

Generally PCBs 1n liquid medium, with concentrations above  50 ppm must  be
incinerated.  In  most Instances, USEPA recommends Incineration of PCBs
whether In a liquid or solid medium, regardless of concentration levels.
However, due to the nature of material at the Schwa12 site, and because the
PCBs are absorbed on solid medium, landfllHng the material  1s recommended.
The landfill must meet all requirements under TSCA and  RCRA and pass  a
compliance Inspection within six months of receiving the waste.

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The recommended alternative will  be in compliance with RCRA and TSCA as  well
as Act 404 of the Clean Water Act (CWA).  It will also be consistent witn1
Executive Order 11990 - Protection of Wetlands.  A wetlands assessment
Statement of Findings is attached to this document.  The recommended alternative
will require a discharge of treated water back into the wetland.  Althougn
Mill not be required to obtain a  permit for this action, all  discharge wil
treated to less than .5 ppb PCBs  and applicable metal concentration levels  .
comply with the State of Wisconsin's discharge limits.  The proposed action will
also comply with Wisconsin's environmental laws NR 181 and NR 157 of the
Wisconsin Administrative Code. These laws are essentially equivalent to RCRA
and TSCA, respectively.

Recommended Alternative

The National 011 and Hazardous Substances Contingency Plan (NCP) [40 CFR
Part 3Q0.68(j)] states that the appropriate extent of remedy shall be
determined by the lead agency's selection of the remedial Measure which  the
agency determines 1s cost-effective (i.e., the lowest cost alternative that
1s technologically feasible and reliable) and which effectively mitigates
and minimizes damage to and provides adequate protection of public health,
welfare or the environment.  Based on the evaluation of the cost and effec-
tiveness of each proposed alternative, the comments received front the public
and the WONR, and State and Federal environmental requirements, Alternative 3
has been determined to be most cost-effective.

The recommended alternative is considered a source control operable unit
remedial action (removal of contaminant source of PCBs), as defined in
section 30U.68(d) of the proposed changes to the NCP.1  The objective of  the
action 1s to eliminate future releases from the contaminant source to the
various pathways and to remove the threat of direct contact to the surrounding
community and the environment. The RI/FS will examine appropriate final
response actions for the site.

The capital cost of this alternative is estimated to be $2,088,300.  Since
this action involves excavation and off-site disposal, there are no 04M
costs for this alternative.  In addition, present worth values are equal to
capital costs because the recommended alternative involves a one time,
short term-action with no 0 & M costs and an estimated construction time of
two months.  Table 10 lists the tasks and estimated costs for the recommended
alternative.

Schedule

The USEPA REM II contractor, Camp, Dresser, and McKee Inc., will manage the
design and construction of the remedial action.  The St. Paul, Minnesota
District of the COE will offer oversite during construction.  The schedule
of activities 1s as follows:

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                                    -10-
   Complete Enforcement Negotiations                     08/09/85

   Approve Remedial  Action (sign ROD)                    08/09/85

   Start Design                                          08/12/85

   Complete Design                                       09/30/85

   Sign Superfund State Contract  N
    for Construction                                     10/01/85

   IAG with USACOE                                       10/01/85

   Start Construction                                    10/07/85

   Complete Construction                                 12/20/85

Future Actions

A USEPA funded RI/FS is scheduled to start in January*1986.   The study will
include an assessment of potential  pathways through which PCBs and metals could
migrate, and testing for other contaminants present on-site  or migrating
off-site.  The RI/FS is schedule for completion by Spring 1987.

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                            Table 10
    TASK LIST AND ESTIMATED COSTS OF RECOMMENDED ALTERNATIVE

Mobilization and on-site handling iosts                 150,000
Wash pad construction and access road                    50,000
Design cost                                              30:760
Construction Management                                 129,240
Office trailer and utilities                             25,000
Berm construction and material  cost                     120,000
Activated carbon water treatment                         60,000
Transportation cost for excavated materfal              737,100
  @ $2,100 per load x 351 truck loads
Disposal cost for material (include disposal            526,200
  of spent activated carbon) @ $15U per
  cubic yard x 3,508 cubic yards
Disposal of decon water                                  35,000

Shut down costs (includes berm removal)                 150,000
Administration/Management                                75,000
                                    Total Estimate   $2,088,300

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                WETLANDS ASSESSMENT - STATEMENT OF FINDINGS
This "Statement of Findings" documents the wetlands assessment  performed  at
the Schmalz Site.  The statement is in accordance with Executive-Order
11990 - Protection of Wetlands, which requires Federal agencies to take
action to minimize the destruction, loss or degradation of wetlands,  and  to
preserve and enhance the natural and beneficial  values of wetlands.

The Schmalz Dump Site is located in the Waverly Beach Wetlands  of the
Winnebago Pool.  The site has undergone unauthorized dumping of PCB contami-
nated building debris, which was disposed of directly into the  wetlands.
The recommended alternative for the operable unit remedial action proposes
to remove the debris and associated contaminated sediment in an effort  to
eliminate the threat to public health and the environment and to restore
the wetlands.

Because the site is located in a wetlands, there are no alternative actions
or locations to be considered in making the decision to locate  the remedial
action in the wetlands.  However, all proposed actions will comply with
state and local wetlands protection standards.
                                                   •
The design for construction will include safeguards to minimize harm to the
wetlands during operations.  A temporary berm will be installed between the
affected area and the remaining pond to prevent dispersion of PCB contaminated
sediments and water.  Once the debris and associated sediments  are excavated,
the water within the bermed area will be pumped through a water treatment
unit and then discharged to the adjacent pond.  The pump will also serve  as
a flood control device in the event of heavy rainfall.  This will prevent
contaminated water from overflowing onto adjacent land, and possibly conta-
minating -more of the wetlands.  All contaminated water generated from
dewatering of the excavated material and decontamination of equipment will
be collected and treated.  Temporary concrete pads will be built for on-site
truck, loading and storage of material.  Upon completion, the impermeable
liner along the face of the berm will be removed and the remaining uncontaminatec
clay and sand will be used as a sediment layer for the affected area.

The proposed remedial action will have beneficial effects on the wetlands.
The action wil not remove any acreage that is currently used as animal
habitat and will improve the quality of the wetland.  Upon completion of
the excavation and removal of material, the wetland will be closer to its
natural condition.

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                 COMMUNITY RELATIONS RESPONSIVENESS SUMMARY
                             SCHMALZ DUMP SITE
                            HARRISON, WISCONSIN
INTRODUCTION
This "Community Relations  Responsiveness Summary"  documents  citizen  concerns
and issues raised during the planning and preparation of the Phased
Feasibility Study (PFS)  for an operable unit remedial  action at  the  Schmalz
Dump Site, Harrison, Wisconsin.  It also documents, for the  public  record,
the U.S. Environmental  Protection Agency's (USEPA) response  to the  comments
presented during the public comment period on the  PFS.

CONCERNS RAISED DURING  THE COMMENT PERIOD

The PFS was completed on June 27, 1985.  Copies of the PFS were  made avail-
able to the community on July-1,  1985.  A public meeting was held at the
Harrison Town Hall  on July 9, 1985, to present the findings  of the  PFS and.
solicit public comment.  Approximately 20 residents attended the meeting.
One attendee submitted  a public comment regarding  the proposed action.  The
Agency subsequently received one  other public comment from a local  resident
and written comments from  the Wisconsin Department of Natural  Resources
(WDNR) regarding the PFS.   The public comment period ended on July  22, 19

Although none of the comments received by USEPA expressed dissatisfaction
with the recommended alternative, other issues of  concern were expressed
during the public comment  period.  These issues are addressed below.

ISSUE:  Testing for PCBs in Nearby Water Supplies

A number of residents are  concerned about the safety of the  water supplies
in the area.  The city  of  Appleton's drinking water intake is located in
close proximity to the  site, and  there are several private wells in  the
areas that are used as  auxiliary  water supplies.  Previous testing  of wells
near the site, and of the  Appleton water supply have not shown levels of
PCBs above trace amounts.   However, because these  tests were done in 1980,
citizens have raised questions regarding the lack  of current sample  data.

Comment;  USEPA should  test the City of Appleton's water supply  as  well as
all operating private wells in the area for PCBs.

Response;  During the development of the work plan for the site, USEPA and
WDNR determined that the PCB contaminated debris,  which is the source of
PCB contamination at the site, was the most serious threat to public health
and the environment. Based on this conclusion, the decision was made to
develop alternatives to control the release of PCBs, prior to other  scheduled
site activities.  Once  the source is removed, USEPA will continue the long
term study to determine if migration of contaminants to ground water,
surface water, or soils, has occurred.

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                                    -2-
Private well sampling is currently scheduled for spring 1986.   The tests
will be performed on three operating wells close to the site to determine
if PCBs or other contaminants are present.  A second sampling of additional
wells will be performed, if necessary, based on the analytical  results of
the initial samples.  If private wells in the area show contamination, a soil
sampling program will be implemented.  In response to citizen's concerns
about Appleton's water supply, USEPA and WDNR are working with the City of
Appleton to develop a PCB Sampling program.  The Initial  sampling date has
not yet been determined; however, biannual sampling for PCBs has been recom-
mended to the city.  In addition, USEPA is proposing to move up the private
well sampling date to winter 1986.  However, because residences are connected
to the Menasha water supply, and private wells are used for outdoor purposes
if the residents choose to do so, the Agency does not feel that sampling
sooner is necessary.

ISSUE:  Disposal of Materials Containing Less than 50 ppm In a Wisconsin
Solid Waste Landfill

The WDNR has commented that the high cost of disposal of the PCB contami-
nated debris could be reduced by developing a plan for disposal of PCBs
with less than 50 ppm in a Wisconsin landfill.

Comment:  We (WDNR) believe that the disposal cost will be significantly  -
reduced if the less than SO ppm waste was disposed of in a Wisconsin solid
waste landfill.

Response:  While the USEPA agrees with the idea presented by WDNR, there
are several factors that prevent this alternative from being viable.  Due
to the nature of the waste, and the uneven distribution of PCBs throughout
the debris, it is not possible to determine if material is highly contami-
nated without implementing an extensive and costly sampling program.  The
high cost of sampling would substantially reduce any cost savings for this
alternative.  In addition, a Wisconsin solid waste landfill would most
likely have to build a special cell for the waste.  This would be expensive
and would result in an increase in cost per ton for disposal.  Another
factor is the time involved for implementation of this alternative.  Because
of the high water table in the wetland, excavation must be done during the
dry season, which extends through December.  Extensive sampling and procurement
of a disposal site could not be done in time to complete the work this year.
This would result in the PCB contaminated debris remaining in place until
the dry season begins next year.  The prohibiting factors associated with
taking part of the material to a Wisconsin solid waste facility would be
the same for. a RCRA subtitle C landfill.

ISSUE;  WDNR's Position On Alternatives Evaluated

The WDNR has expressed concerns regarding various issues arising from the
evaluation of the remedial action alternatives.  Questions were raised as
to whether the alternatives for on-site management and on-site disposal
would meet the requirements of Wisconsin's Administrative Code, Chapters
NR 181 and NR 157, and whether they would be consistent with the permanent
remedy for the site.

Comment:  The alternatives for on-site management and on-site disposal do
not meet the requirements of NR 181 nor are they consistent with the permanent
remedy for the site.                                         t

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                                    -3-
Response:  Under the Superfund law, USEPA is required to address various
alternatives during the development of the feasibility study.   The list
must Include at least the following alternatives for evaluation:  1)  one
that meets environmental standards; 2) one that exceeds environmental
standards; 3) one that does not attain environmental  standards but provides
protection to public health and the environment; 4)  one for off-site  disposal;
and 5) the No Action alternative.

Although USEPA recognizes the State of Wisconsin's position on these  issues,
we are obligated to address certain alternatives regardless of their  com-
pliance with environmental  regulations or consistency with a permanent
remedy for the site.


The remaining comments, submitted  by UONR, are related to the  context of
the PFS.  These comments are responded to as appropriate.  It  should  be
noted that although these comments will  not be incorporated into the  PFS,
they, will be a permanent part of the Record of Decision (ROD)  document.

ISSUE:  Permit for On-Site Berm

Comment:  We (WDNR) think there should be a discussion in the  report  on the
need for a permit from the Corps of Engineers (COE).

Response;  A permit from the COE is not required during on-site construction
at a Superfund site.  In lieu of a permit, the COE will review and approve
the proposed design for the remedial  action.
                                                   i

ISSUE;  Estimates for Operation and Maintenance Costs (O&M) of Alternatives

Comment:  O&M costs for on-site management and on-site disposal should  be
included in cost estimates for alternatives.

Response:  O&M costs for the alternatives (if applicable) have been calculated
and included in the ROD document.

ISSUE:  Fish in Wetlands

Comment;  It should be noted that  there are no fish  in the wetlands except
possibly during spawning.

Response:  Comment noted.
                                                                             4
ISSUE;  Institutional Considerations for Management  of PCBs

Comment:  Institutional considerations for management of PCB contaminated
material with concentrations below 50 ppm are not discussed in Section
6.1.3 of the PFS as inferred.

Response;  The USEPA is committed  to protect the public and the environment
from toxic chemicals such as PCBs.  Region V has taken a strong stance on this
issue and has implemented a recommended advisory level of 1 ppm for PCBs  in
the environment.  In addition, health advisories currently being developed
USEPA include recommendations for  advisory levels to be lower  that 1  ppm.

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ISSUE;  PCB Levels for Fish In Lake Winnebago

Comment;  Information on PCB levels in fish in Lake Winnebago should  be
included 1n the PFS risk assessment.

RESPONSE:  During the PFS, USEPA looked at the immediate hazards  associated with
the site and felt justified in performing a source control  operable unit  based on
the exposure to the surrounding population and the flora and fauna of the
wetland.  The RI/FS will address vthe various pathways  through which contaminants
could migrate and contaminate receptors, including fish in  Lake Winnebago.  In
addition, USEPA has discussed this site with the U. S. Fish and -Wildlife  Service
and will continue to get their Input throughtout the course of the RI/FS.

ISSUE:  Public health Considerations for Alternative 4 - Capping  Material
On- Site

Comment;  A discussion should be included in the Public Health Considerations
of Alternative 4 relating to animals burrowing through the  clay cap and
possible human consumption of this wildlife.

Response;  This is a valid consideration and would be  a concern if  Alternative
4 was the recommended alternative.  Studies have shown that PCBs  accumulate
in the fat tissues of animals and human exposure through the food chain  is
a definite threat to public health.

ISSUE;  Comparison of Institutional Considerations of  Alternatives

Comment;  Section 7.3 in the PFS, which summarizes the institutional
considerations for the alternatives, should be expanded to  include  a  more
detailed discussion of alternatives for on-site management  and on-site
disposal as well as the "no action" alternative.

Response;  Institutional considerations for the on-site management, on-site
disposal and the "no action" alternatives are discussed in  detail in  Section
6 of the PFS.  A summary of institutional considerations for these  alternatives
fol1ows.

On-site disposal would require compliance with several Federal and  State
environmental regulations and laws, including the locational criteria.
This would be difficult to comply with at this site.  In addition,  Federal
regulations would include:  TSCA and RCRA requirements for  construction of a
disposal facility; RCRA regulations for monitoring and protection of
groundwater and surface water; Executive Order 11990 - Wetlands  Protection;
requirements for management of PCBs under TSCA (and Chapter NR 157  of
Wisconsin's laws); and regulations for dredging and filling of a  wetland.
The on-site management alternative involves closure requirements  under RCRA
and Chapter NR 181 as well as TSCA and Chapter NR 157, in addition  to
several of the requirements mentioned under on-site disposal above.   These
numerous requirements would be very difficult, if not  impossible, to  comply
with due to the location and nature of the site.

The "no action" alternative would be in violation of several State and  Federal
laws.  Among-these are:  proper disposal of PCBs under TSCA and  NR 157;  and
fill ing "of a wetland under section 404 of the Clean Water Act and Chapter 30
of Wisconsin's. Statutes.                                     *

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