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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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.
-------
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
-------
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.
-------
• .• - *y ^x^
^'l^'*!?*''':>«W- .-. -^ (
^^^
•:• :.-..:* --r>*-.W*.:-.v.V:>s;••-.:... >.
-------
-.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
-------
-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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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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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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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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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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