United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R05-87/OS4
September 1987
SEPA
Superfund
Record of Decision
Schmalz Dump, Wl
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TECHNICAL REPORT DATA
(Pleat rtfd liutnutiom on tht revtn* btfon committing)
. REPORT NO. -
EPA/ROD/R05-87/054
3. RECIPIENT'S ACCESSION NO.
4. TITLE ANO SUrrtTUI
SUPERFUND RECORD OF DECISION
Schmalz Dump, WI
Second Remedial Action - Final
S. REPORT OAT I
fi»nr.«mh«r ?n. 1Qft7
6. PERFORMING ORGANIZATION CODE
r. AUTMOR«S»
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME ANO AOOR6SS
10. PROGRAM 6LEM6NT NO.
l. CONTnAwT/QHANT NO.
12. SPONSORING AGENCY NAME ANO AOOR6SS
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. TYPB OP REPORT ANO PERIOD COVERED
PT nal POD Renort
14. SPONSORING AGENCY COOE
800/00
6. SUPPLEMENTARY NOTES
«. ABif * ACf — — •
The Schmalz Dump site occupying approximately seven acres of the Waverly Beach
wetlands area, is located on the north shore of Lake Winnebago in the town of Harrison,
Wisconsin. Industries dumped wastes at various locations along the north shore of Lake
Winnebago for several years. Mr. Gerald Schmalz, the previous site owner, began filling
his property in 1968. Records show that wastes hauled there consisted of solid wastes,
car bodies, stone, trees, pulp chips and mash. Between 1972 and 1973 the site accepted.
fly ash and bottom ash from Menasha Utility, and in 1978 and 1979 Schmalz accepted the
demolition debris of a building owned by the Allis-Chalmers Corporation. Initial onsite
sampling in early 1979 determined that an area containing the Allis-Chalmers debris was
contaminated with concentrations of PCBs as high as 3,100 ppm with lead and chromium
also detected in relatively high concentrations. In August 1985, a ROD was signed
approving an operable unit to address the PCB contamination. This second operable unit
addresses soil contamination with lead and chromium +3.
The selected remedial action for this site includes: the installation of a low
permeability, compacted earth material cap over approximately seven acres of lead and
chromium contaminated soils; and implementation of ground water monitoring involving the
installation of slurry wall for lead and chromium. A voluntary well abandonment program
for nearby wells is also proposed. The estimated capital cost for this remedial action
ta &6S7.664 with annual Q&M of &17.940.
17.
KEY WOROS ANO DOCUMENT ANALYSIS
DESCRIPTORS
b.lO«NTIPI6HS/OP6N ENOBO TERMS
c. COSATi Field/Group
Record of Decision
Schmalz Dump, WI
Second Remedial Action - Final
Contaminated Media: soil
Key contaminants: lead, chromium*3
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EPA Pern 2220.1 (Rev. 4.77) (IUve«M)
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Schmalz Dump, Harrison, Wisconsin
STATEMENT OF PURPOSE
This decision document represents the selected remedial action for this
site developed in accordance with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980, 42 U.S.C. § 9601 et seq., (CERCLA) as
amended by the Superfund Amendments and Reauthorizatlon Act of 1986 (SARA),
and to the extent practicable, the National Contingency Plan (40 CFR Part 300),
The State of Wisconsin has concurred on the selected remedy, as stated in
the attached Letter of Concurence.
STATEMENT OF BASIS
This decision is based upon the Administrative Record developed for the
Schmalz Dump Site. The attached index for the Schmalz Dump administrative
record identifies the Items which comprise the record upon which the selection
of a remedial action is based.
DESCRIPTION OF THE SELECTED REMEDY
The preferred alternative Involves the Installation of a low permeability,
compacted earth material cap over approximately seven acres of lead and
chromium contaminated soils, and Implementation of groundwater monitoring for
lead and chromium. A voluntary well abandonment program for nearby wells is
also proposed.
> .
DECLARATION
As required by Section 121(a) of CERCLA as amended by SARA, the selected
remedy Is protective of human health and the environment, attains Federal
and State requirements that are applicable or relevant and appropriate, and
1s cost-effective. The statutory preference for treatment set forth in
Section 121(b) of CERCLA as amended by SARA is not satisi fed because treatment
was found to be Impracticable due to questionable technical feasibility,
Inadequate short-term protection, and inappropriate site conditions.
Date Valdas V. Adantus
Regional Admi/lstrator
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I
(V
>*^»«««
Wawty 1
18
0
0
o
rBrifbt«i
SITE LOCATION
FIGURE 1
0 20OO
SCALE. FT
V* lOCAIUNO^IHESCHMALZ DIM* SfTE
-------
VL WAVERLY BEACH
IlCCfNO
rn t....«.,
U - —
.'. Fpl (C»
-------
SCHMALZ DUMP SITE
HARRISON. WISCONSIN
to
Site Boundary it«NO
-—Of*ln*a* Ditch
— !••••» UM ft P»«« -M-M-Mallroatf Track
—utoa
FIGURE 3
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-2-
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. The Remedial Investigation/Feasibility Study (RI/FS) was
initiated during April 1985. Since a threat to public health had
been identified due to the PCB contaminated demolition debris, USEPA
and WDNR decided to prepare a phased feasibility study to evaluate
potential source control remedies.
In August 1985, a Record of Decision was signed approving an operable
unit to address the PCB contamination at the site. The operable
unit consists of removal of construction debris and sediments
containing elevated concentrations of PCBs. Additionally, the water/
solids mixture in the sediments will be separated, with solids
destined for a USEPA approved hazardous waste landfill. The water
will undergo metals precipitation and activated carbon treatment for
removal of PCBs, chromium and lead prior to discharge to the pond
area of the Schmalz property. Implementation of the operable unit
is scheduled to occur in the fall of 1987.
Site Characterization
RI/FS work has progressed concurrently with design of the operable
unit. Phase I of the RI was completed in April 1987. Phase II
of the RI, which was designed to characterize inorganic contamination
of the ground water, was performed in June 1987. The scope of the
RI work at the Site included the installation of monitoring wells,
and collection of soil, sediment, surface water, residential well,
and groundwater monitoring well samples. The objectives of the RI
were to characterize the areas of the site that were not addressed
by the operable unit and to determine if a public health or
environmental threat exists outside the PCB contaminated area of the
site. All samples were analyzed for priority pollutant metals and
PCBs. A percentage of these were also analyzed for EP Toxicity and
organic priority pollutants. Results of the RI are discussed below.
Groundwater
Groundwater samples collected during the RI indicate the presence of
low levels of trivalent chromium beneath the site, in the water
table aquifer. Levels range from 14 micrograms per liter (ug/1) to 48
ug/1 within the site boundary but do not exceed background levels
downgradlent of the site (see Figure 4 and Table 1).
Groundwater samples collected indicate the existence of two separate
plumes of trivalent chromium: a diffuse, east-west trending plume
beneath the site, and an isolated off-site anomaly west of the
Schmalz Site. In the diffuse east-west trending plume beneath the
site, groundwater samples contain levels of chromium ranging from 14
ug/1 to 48 ug/1. Groundwater samples in the vicinity of the isolated
anomaly to the west of th Site exhibited high concentrations of
soluble chromium (1140 ppb) (see Figure 4). The chromium contamina-
tion at this location is not associated with suspended particles, like
that found beneath the site, and appears to emanate from a localized
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Dissolved Chromium Distribution (/ig/0
.::
. ' -
Figure 4
•* aoo' *oo* 900
• •«»•• to"
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
SCHMALZ DUMP SITE
I. Site Location and Description
The Schmalz Dump Site is located on the north shore of Lake Winnebago
in the Town of Harrison. Harrison is located approximately ten
miles south of Appleton, and two miles east of Menasha, in Calumet
County, in the east central section of Wisconsin (see Figure 1).
The Site occupies approximately seven acres in the Waverly Beach
Wetlands area (Figure 2). Unauthorized dumping occurred at the
site in the late 1960s and 1970s. The property north and west of
the sfte has also been used for waste disposal. A wet marshy area
bounds the site to the east, with a railroad right-of-way to the
south. Beyond the railroad tracks, between the Site and Lake
Winnebago, is a moderately populated residential area. All of these
residences have 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 60,000, has its drinking water
intake approximately 1200 feet from the shore of Lake Winnebago, in
close proximity to the site.
II. Current Site Status
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, previous site owner, began filling his property in
1968. Records show that the wastes hauled there consisted of solid
waste, car bodies, stone, trees, pulp chips and mash. Between 1972
and 1973 the site accepted fly ash and bottom ash from Menasha
Utility, and In 1978 and 1979 Schmalz accepted the demolition debris
of a building owned by the Allis-Chalmers Corporation.
Initial on-s1te sampling by the State of Wisconsin and the U.S. Army
Corps of Engineers (U.S. ACE) in early 1979 determined that the area
containing the Allis-Chalmers debris was contaminated with concen-
trations of PCBs as high as 3100 parts per million (ppm). Lead and
chromium were also detected In relatively high concentrations at
several sampling stations.
In the summer of 1979, the Wisconsin Attorney General filed suit
against Mr. Schmalz, the waste hauler - Welseler Construction, and
Allis 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.
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TABLE 1
GROUNDWATER SAMPLE ANALYSES
Well
Location
Detection
Limit
GU-1
GU-2
GW-3
GH-4
GW-5
GW-6
GU-7
GW-8
GM-91
GH-9a
GU-10
GW-11
OW-01
Total
Pb
ug/]_
2.
.
149
64
-
-
-
-
—
-
-
-
~
• Dissolved Total
Pb Cr 3
ug/1 ug/1
2 0.5
89
390
120
45
60
22
40
25
1130
286
21
102
2.4
Dissolved
Cr 3
ug/1
0.5
38
48
27
14
8.9
6.5
2.1
2.4
1140
185
3.3
29
1.5
Ratio of
Total to
Dissolved Cr b
Cr ug/1
10
1.89
8.13
4.44
3.21
6.74
3.38
19.05
10.42
0.99
1.55
6.36
3.52
1.6
Total
Suspended
Solids
mg/1
5
392
603
418
102
274
77
188
274
429
210
280
382
-
- * Below detection limit.
OW-01 is a sample of the water used during drilling.
Note: Relative percent difference betwtin total and dissolved chromium in sample GW-9
0.88%, which Is well within the prer on limits of the analytical procedure.
-------
-3-
polnt source. Based on the history of dumping in the area, this
phenomenon 1s not unusual. Residential wells downgradient of the
site were also sampled during the RI. Sample results did not indicate
the presence of lead or chromium, but did show degraded groundwater
quality due to high levels of iron, magnesium, potassium, sodium,
ammonia, strontium and boron (see Table 2).
Based on existing literature, surficial soils overlie 15 to 35 feet
of fine grained, saturated silty sand and a 30 to 50 foot thick clay
layer, which in turn overlies a 5 to 20 foot thick hardpan layer.
In the Immediate vicinity of the site, the silty sand unit has a
thickness of 20 feet. Clay and hardpan layers are Impermeable, and
isolate the contaminated silty sand aquifer from the deeper Paleozoic
dolomite and sandstone aquifers 1n which local residents have their
wells. Schematic east-wast and north-south cross sections through
the site are illustrated in Figures 5 and 6.
Based on the above discussion, the silty sand aquifer beneath the
site appears to be separated from the lower aquifer by a fairly
thick, continuous clay layer. It is therefore unlikely that
contaminants from the site would enter the lower aquifer and reach
residential wells. Also, chromium levels found in groundwater do
not exceed the drinking water Maximum Contaminant Level (MCL) of
50 ug/1 under the Safe Drinking Water Act (SOWA).
Surface Water and Sediments
Surface water and sediment samples collected during the RI from the
area of demolition debris disposal contained elevated concentrations
of PCBs, lead and chromium. This area will be addressed during
removal of the debris under the first operable unit remedial action.
Samples collected in the drainage ditch south of the site and at the
entrance of Lake Winnebago did not contain elevated levels of these
contaminants.
>
The shallow aquifer beneath the site contains levels of trivalent
chromium above background but not above the MCL. Based on RI data,
the water table Is three to five feet below the land surface and
direction of flow Is to the southwest, towards Lake Winnebago.
Because the City of Appleton obtains its drinking water from the
Lake, the City's population was identified as a potential receptor
(see Figure 7).
As part of the RI, a groundwater modeling study was performed to
determine movement of chromium in the groundwater over time. Although
the model did indicate that chromium found at the site would migrate
toward the lake shore, the flow rate of groundwater 1s estimated to
be between eight and eleven feet per year. This indicates that in
fifty years, groundwater containing chromium would have migrated
just beyond the site boundary (see Figure 8).
Based on the rate of groundwater movement, and taking into considera-
tion the dilution that would occur once ground water discharges to
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TABLE 2
SMMU Mtf SHE - KMDIM. OWSTIMTM - KSIKNTW «Ol MM
(Sw»lM rtllKtH M. Urn *c. IU51
CConrtfitrttunt txfrtnH in «ij/IJ
1
1
KMS:
it*
film
fcm
Iviui
tvttim
OlTMIW
C*H*r
Irw
Uttm
talJMtW
Slrtntiw
UK
Cilclw
NtmiM
toywtlw
Miw
flwri*
fcMMi In m
MtilMIr In OttJl
Sniritt In IMI
CM*!* In Cl-l
VOUIILCS:
Cwtw NMlfi*
sfNMuiius:
IkMl
M-*-Myl|kUwl«t«
Myltmyl|MliilM«
KStKINt:
MM KTRTO
» » M Ivttrltl
1 • CttiMtN V(lw
MWK
SIK
N
y
»
IMI
N
*I2M
I2M
IM
I SMI
C2NM
4MI
I29MM
• I3MN
• asM
• ISM
k
Ml. SIK
""•"*** *
I
I
I
•
I
I
3
t
1
t
•
•
•
I
ISM ISM 2531 ISII ISM 1ST*
MM tt-2 W-3 MM M-S M-i
MM) M M) » »
» 1.4 • M 2.7 HI
W M) 4.41 W (.1 Ml
IB 345 3K 2W 411 21*
231 141 157 141 17 III
• 3.47 M » • M
M M 1.24 M M M
47 M • 4M 1 M
7121 24W 277 UN HIM 2MI
17.1 14 12.9 12.1 13 M
11.1 11.7 7 IS.7 (.3 21.2
IMI ISM ISM 1121 IWt Mf
Ml M •) » 74.4 M)
«I4M «7M 52IM SUM 434M «9M
2241 3331 27N 24M 3171 M
333M SNM SMM 442M 41 IM 4I2M
MM 32MI 234N 3MM 21SM 27MI
3M 3M 3M 3M 3N 3M
29M »7I I7M ISM I4N 2121
SIMM 4IMM 43MM 3*4MI 43MM 3MOM
IMM 44M SMI • W M)
2MM IMM 2MM 2IMI MM M
• • 1.9 M • M
• • • I.I 1.4 •
• 1.2 m M> M M>
M> M) • • 1.41 •
A • Fr**M4 MwiMi CMMMltMlM U«tll
I • llMllh M»iHtf fci«Mt lf«tl
C • ta»rlc» UMII AttMiMlM fcu»n
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Figure 5
Schematic East - Wast Croaa-Saction Through Schmalz Slta
Baaad on Rapraaantativa Wall Loga
Weat
Sell and Fill
Gravel
Vertical Scale
Approilmate
•it* Location
Schnali Site'
Location
ItavatloMa eatimatatf from Topearapkla
Map ana* arlllara toa»
l.mil*
Seal*
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Figure e
Schematic North - South Cross-Section Through Schmalz Site
Based on Representative Well Logs
SOUTH
Soil and Pill
Approximate
•It* Location
SchMalt SIM
Location
novation* oatlmatod froa» Tonosrnnhlc
Map an« tfrlllor* Los*
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Water Table
Figure 7
?*&**• l*»X£i
LEGEND
074t.t1 Or*m«V«l«ff L«V«I *- Flow Direction
A(74>.04> •»!••• W«l«r — ?4§— W«l«r
ItpMmy ttovatto* T47f«)
::;££§: ; " ••••; • •: •• • '
O* tOO* 400* «00* tOO* 1000'
§«•!•
-------
Figure s
Contour Interval* O.S foot
LIOEND
Water Taate Coiitoor
Contamtaaat Mlflratloa Path
1 tyre Contaminant Location
altar if yaara
»artlelo Loeottoa A
Contaminant Migration in Dry Period Water Tabie
at 5, 15, and 50 years.
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-4-
the Lake, the levels of chromium In the groundwater should never
pose a threat to Appleton's water supply. Also, as discussed above,
chromium levels In the groundwater do not exceed the SDWA standard
of 50 ug/1.
Soils
Surface and subsurface soil samples collected at the Site show lead
and chromium to be the contaminants of concern. Lead and trlvalent
chromium were found throughout the site at concentrations ranging
from detection limits to 1940 milligrams per kilogram (mg/kg) and
964 mg/kg respectively (see Figures 9 and 10).
PCS contamination Is confined to the area where demolition debris
was disposed. The first operable unit will address the PCB contami-
nation at the site. During the RI, volatile and semi-volatile
organics were found at low levels and at scattered locations.
During the RI, it was noted that several teenaged children use the
Site as a dirt bike trail. It was also noted that fresh refuse was
continuously being dumped on site. Given that the Site is an
attractive nuisance, and that the area containing high levels of
lead and chromium in soils is accessible, 1t was determined that
direct contact is an exposure route.
Threat to Public Health
The Public Health Evaluation (PHE) summary in the Phase II RI
report for the Schmalz site Identified lead and chromium as the
contaminants of concern. The pathway of exposure is direct contact
with lead and chromium contaminated soils on site.
Potential risks from contaminated soils are based on the assumption
that the site would be used for residential development in the future.
Since lead and trlvalent chromium are noncardnogens, the acceptable
chronic dally Intake (AICs) were used to calculate allowable daily
chemical Intake levels from the Identified exposure route. An AIC
is the dose that Is anticipated to be without lifetime risk when
taken daily.
Exposure risks from direct contact were calculated based on the
assumption that a child 1n a residential setting would consume
one gram of soil per day. The AICs for lead and trivalent chromium
are .014 and 140 milligrams per kilogram per day respectively. Based
on these values, lead and chromium 1n soils on the Schmalz site
with concentrations greater than 14 mg/kg and 100 mg/kg respectively,
pose an unacceptable lifetime risk from direct contact.
Groundwater was determined not to be a public health threat because
chromium concentrations are below the SDWA drinking water standards.
However, leaching of chromium and/or lead to groundwater could
potentially cause drinking water standards to be exceeded. To
determine 1f leachable amounts of contaminants would leach, EP
-------
FIGURE 9
B-M7
GRAVEL & SAND ROAD
.„...—„ _
• CHROMRM FOUND M SOI. (m«A«)
AT CONCEM1RA1MN SHOW!
AU LOCAHONS 1E51EO FOR CHMOUMI
KEY:
SITE BOUNDARY
FENCE
SCHMALZ DUMP SITE
HARRISON, WISCONSIN
CHROMIUM IN SOILS
CAMP DRESSER it MCKEE
-------
FIGURE 10
A-477
-SCHUALZ HOUSE
B-J45
—.......... jp___ -^T-<-^_^-^ o o u
GRAVEL it SAND ROAD
• LEAD FOUND M SOL
AT CONCENIRAIION SHOVM (m«A9)
ALL LOCATIONS TESTED FOR LEAD
KEY:
f—MFOT
... SITE BOUNDARY
.. FENCE
SCHMALZ DUMP SITE
HARRISON, WISCONSIN
LEAD IN SOILS
CAMP DRESSER & MCKEE
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-5-
Toxiclty Extraction Tests were performed on soils during the RI.
Results of the tests show that very low levels of both lead and
chromium are leachable. Leachable concentrations ranged from .071
to .146 mg/1 for lead and from .011 to .063 mg/1 for chromium.
Considering dilution factors, these values are not expected to
cause contamination in the ground water to exceed drinking water
standards. These values are well below the EP Toxicity test's
5 mg/1 limit for determining if the soil is a RCRA hazardous waste
and indicates that very little of the contaminants will leach from
soils to groundwater. In addition, trivalent chromium has an affinity
to fine grained, silty soils like those found in the site area.
This would inhibit movement of chromium through the aquifer, and
probably explains why chromium has not migrated farther to date.
Based on the above discussions, onsite soils are not likely to ever
increase chromium and lead concentrations in the ground water to
greater than the drinking water MCLs of 50 ug/1. However, because
there is a remote possibility that this pathway could later become a
concern, it was determined that groundwater should be monitored over
time. In addition, residents in the vicinity of the site will be
asked to voluntarily abandon any existing wells. This is a precau-
tionary measure to ensure that no potential for exposure exists
should contaminant levels in groundwater increase in the future.
III. 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 based on information indicating their involvement in the site,
including parties who were named in the State's unsuccessful 1979
lawsuit. Notice letters were sent to each party and a negotiating
meeting was held to discuss the RI/FS. At the end of the negotiating
period, none of the parties committed to perform the RI/FS.
In August 1987, Potentially Responsible Parties (PRPs) were again
notified for the Remedial Design and Remedial Action (RD/RA) of the
final remedy. Notification letters were sent to:
Allis-Chalmers Corporation
Akrlsol
Mr. Gregory Schmalz
Mr. Gerald Schmalz
Menasha Corporation
Menasha Electric and Water Utility
James Peters Company
Weisler Construction
After receiving the notification letter, Akrisol and Menasha Corporation
requested that U.S. EPA delete their names from the PRP list. Following
review of information in U.S. EPA files, including Information submitted
to U.S. EPA by Akrisol and Menasha Corporation, Akrisol and Menasha
Corporation were deleted from the list of PRPs.
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- 6 -
August 17, 1987 marked the commencement of the negotiation moratorium.
October 16, 1987 is the deadline for PRP involvement in the RD/RA.
At this time, no good faith effort has been put forth by the PRPs.
Therefore, no extension of the negotiation moratorium has been made.
IV. Community Relations
The public comment period for the RI/FS began on August 17, 1987.
Copies of the Phase Two RI Report and the FS Report were made
available to the community on this date. Two locations served as
repositories for these reports as well as the proposed plan and the
remainder of the administrative record. U.S. EPA issued a press
release containing the proposed plan prior to commencing the comment
period.
A public meeting was held on August 19, 1987, to discuss the findings
of the RI/FS and to present the U.S. EPA preferred alternative.
Questions regarding the project were also answered. No public comments
were submitted during the meeting. Two subsequent written comments
were received. The public comment period ended September 8, 1987.
Public comments are addressed in the attached responsiveness summary.
V. Alternatives Evaluation
The Feasibility Study was initiated to evaluate alternative remedial
actions for remediation of contamination at the Schmalz Site.
Response objectives for the site were Identified in the Public Health
Evaluation (PHE). Based on the PHE, protection from direct contact
with contaminated soils and monitoring for degradation of groundwater
quality from these soils were identified as the site specific response
objectives.
A variety of technologies to address response objectives was identi-
fied and evaluated for further consideration. From these, eleven
alternatives were developed and screened for effectiveness, imple-
ment abi'ity and cost. Following screening, six alternatives remained
and were subjected to detailed analysis using the evaluation criteria
outlined in SARA. Table 3 lists the six alternatives evaluated.
TABLE 3
REMEDIAL ACTION ALTERNATIVES
Alternative Description
A-l Groundwater extraction coagulation/
flocculatlon, filtration, ion exchange,
and discharge
A-3 Slurry wall and cap
B-l RCRA Subtitle C cap
8-2 Soil cap
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- 7 -
B-5 Solidification, stabilization, on-site
disposal
C-l No action
In order to address response objectives adequately, two groups of
alternatives were developed; those addressing groundwater and those
addressing soils. The alternatives numbers in Table 3 refer to the
numbering in the feasibility study. Group A alternatives address
groundwater, group B alternatives address soils, and the no action
alternative makes up group C.
DESCRIPTION OF ALTERNATIVES
Alternative A-l: Groundwater Extraction, Coagulation/Flocculation,
Filtration, Ion Exchange and Discharge
This alternative would entail treating the groundwater at the Schmalz
Dump site to remove chromium to background levels. Treatment would
involve coagulation of the suspended solids contained in extracted
groundwater by means of polymer or lime addition, and flocculation
to enhance the formation of larger particles. Sedimentation would
follow, in which the insoluble forms of lead and chromium would be
separated from the water. The next treatment process would be
filtration, removing the fines and "polishing" the treated water.
The final treatment process would be a cation exchange unit, where
the soluble chromium remaining would be removed from the water.
Following treatment, water would be discharged to the on-site pond.
The volume of contaminated water to be pumped and treated was esti-
mated to be 42 million gallons or 3 pore volumes of the water table
aquifer beneath the site. This is the estimated amount that would
have to be extracted to reduce chromium levels to background.
Background for the site is assumed to be approximately 5 ug/1, based
on upgradient monitoring well samples. The extraction system would
be composed of 2-inch diameter wells placed on 10-foot centers
around the perimeter of the site. Water would be pumped at a rate
of 50 gallons per minute with a project duration of approximately
19 months.
Alternative A-3: Slurry Wall and Cap
The purpose of this alternative Is to prevent contaminant migration
by containing the plume and isolating the waste from surface infil-
tration. This alternative Involves the installation of a circum-
ferential slurry wall around the perimeter of the site (Figure 11).
The slurry trench would be excavated three feet into the confining
clay (located approximately 25 feet below the ground surface). The
backfill material would consist of a mixture of excavated soil,
water, and bentonite clay. The permeability of the walls would be
greatly reduced because of the swelling properties of the clay.
Thus, the lateral migration of contaminated groundwater within the
walls would be minimized. The low permeability of the underlying
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FIGURE 11 APPROXIMATE LOCATION OF SLURRY WALL
LEGEND
Dralnag* Ditch o«molillon Dabris
Powar Llna A Pala . « ••-+- Railroad Track
APPROXIMATE SLURRY TRENCH LOCATION
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- 8 -
clay layer prohibits the vertical movement of the groundwater.
Because the slurry walls would be keyed into this formation, the
potential for migration of contaminated water under the walls would
be low.
An impermeable cap would be constructed over the affected area to
prevent the area enclosed by the walls from filling with water. The
cap would consist of a 24-inch layer of vegetated topsoil, a layer
of geotextile fabric, 12 inches of gravel, a 20-mm synthetic liner,
and 24 inches of compacted clay.
Operation and Maintenance (O&M) on the slurry wall and cap would
be required as part of the alternative. O&M would include periodic
inspections of both the cap and slurry wall for signs of erosion,
settlement, or subsidence. Additional maintenance of the cap would
include the application of fertilizer and periodic mowing to prevent
invasion by deep-rooted vegetation.
It is not anticipated that extensive 'pooling* of water will occur
within the slurry wall. However, if necessary, a low capacity
extraction well could be installed to extract water. The amount of
leachate extracted would be very little and could be sent to the
local POTW for treatment.
The slurry wall and cap alternative would require that a groundwater
monitoring program be instituted. For the purposes of this alternative,
it Is assumed that the monitoring program will conform with RCRA
requirements (40 CFR Part 264.95 and 264.97). This program would
consist of placing monitoring wells at the boundary of the waste
management unit and upgradlent of the unit. The wells would be
sampled and analyzed for pH, conductivity, dissolved chromium, and
dissolved lead on a quarterly basis for the first year and annually
thereafter for 4 years. At the end of the five year period, the
monitoring program would be re-evaluted and a determination made on
future monitoring.
Operation and Maintenance (O&M) would include periodic Inspections
of both the cap and slurry wall for signs of erosion, settlement, or
subsidence. Maintenance of the cap would also include application
of fertilizer and periodic mowing and weed control techniques to
prevent Invasion by deep-rooted vegetation.
Alternative B-l; RCRA Subtitle C Cap
Capping of the site would Involve construction of a three-layer cap
conforming to RCRA guidelines. The area to be capped is outlined on
Figure 12. This operation would first consist of the placement of a
two-foot clay layer, compacted in six-Inch lifts. A twenty-mil
synthetic liner would then be placed over the clay. Next, a one-foot
thick drainage layer of gravel would be spread and overlain with
geotextile fabric. The geotextile fabric would maintain the
drainage layer and help to stabilize a final layer of twenty-four
inches of topsoil by keeping fine topsoil particles from filling the
pore space of the gravel layer. The topsoil would be vegetated to
prevent erosion. Also, the cap would have a minimum slope of two
-------
FIGURE 12
APPROXIMATE EXTENT OF CAP
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-9-
percent to the northeast. Drainage channels will be constructed to
direct surface runoff to the present site drainage. Precipitation
that percolates through the topsoil would flow laterally through the
gravel and over the impermeable synthetic and clay barrier and into
the drainage channels.
Operation and maintenance of the cap would include periodic inspections
for signs of erosion, settlement, or subsidence. Maintenance of the
cap would also include the application of fertilizer and periodic
mowing and weed control techniques to prevent invasion by deep-rooted
vegetation.
Groundwater monitoring would be recommended in conjunction with this
alternative. The monitoring plan described for Alternative A-3
would apply here.
Alternative B-2: Soil Cover
The placement of a soil cover over the contaminated area would
involve placement of 24 Inches of low permeability compacted earth
over the site (see Figure 12). The area would then be graded and
sloped adequately to allow surface water runoff. The final grade
would be approximately two percent to the northeast. The finished
surface would be covered with six Inches of topsoil and vegetated.
Site drainage would also be provided. A diversion ditch constructed
upgradient would divert flow to the pond to limit surface water
contact with the final cover. Runoff from the cover would be captured
by two drainage channels and directed to the ditch located south of
the site.
Operation and maintenance of the cap would include periodic inspections
for signs of erosion, settlement, or subsidence. Maintenance of the
cap would also Include the application of fertilizer and periodic
mowing and weed control techniques to prevent invasion by deep-rooted
vegetation.
4
Groundwater monitoring would be required In conjunction with the
soil cap. The monitoring plan described under Alternative
A-3 would also apply here.
Alternative B-5: Excavation, Solidification/Stabilization
This alternative Involves the excavation of all contaminated soil,
treatment of the soil with solidification/stabilization reagents,
and backfilling of the excavated areas with the treated soil.
Approximately 8000 cubic yards would be excavated in the contaminated
areas. Solidification/Stabilization (S/S) would be used as a perman-
ent remedial action to limit the off-site mobility, solubility and
toxidty of the heavy metals.
The S/S process Is commercially offered as a complete, on-slte mobile
treatment unit. The unit is outfitted with reagent tanks, metering
equipment and an operating console which monitors the entire process.
The waste is first slurried and then pumped to the treatment unit,
where mixing and chemical reaction with the solidiflcation/stabiliza-
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tlon reagents occurs. The treated material is then pumped back to
the excavated area, where solidification occurs within 36 to 72
hours.
A slurry tank would be used to mix the dry sand with water to produce
a sludge with a maximum solid content of 30 to 40 percent. This would
improve the efficiency of the process and the handling characteristics
of the waste. Following this, the material would be pumped to the
treatment unit and then to the excavated areas. The treated soil
would then be spread and. graded over the excavated areas, and a gravel
cover placed on the site.
Dewatering of the soils taken from the site may be necessary prior
to treatment unless a groundwater extraction alternative is implemented
in conjunction with excavation. The drawdown of the extraction
wells could effectively dewater the soils to a depth of greater than
five feet. If an alternative involving groundwater extraction is
not selected, the soils could be dewatered after excavation by
placement on a drainage pad next to the excavated area and water
allowed to drain back into the pit. In addition, steps for dell sting
the soil as a hazardous waste would also need to be considered and
carried out.
Alternative C-l: No Action
As the name implies, if this alternative Is selected, no remedial
action would be taken at the site and current conditions would
persist. This alternative was evaluated in the Public Health
Evaluation presented in the Remedial Investigation Report, and this
assessment serves as the basis for the evaluation of all other
remedial action alternatives. This option could be applied to the
groundwater, soil, or both. No capital or O&M costs would be
associated with this alternative.
EVALUATION OF ALTERNATIVES
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The alternatives listed in Table 3 were evaluated using factors
mandated by SARA Section 121(b)(l)(A-G) that have been organized
Into the evaluation criteria used in the evaluation. A discussion
of these criteria as they relate to each remedial alternative
follows. The no action alternative Is discussed separately at the
end.
Compliance with ARARs
Alternatives were assessed as to whether they attain legally Applicable
or Relevant and Appropriate Requirements (ARARs) of other Federal
and State environmental and public health laws. The evaluation of
ARARs Included contaminant-specific, location-specific and action-
specific ARARs.
For contaminant-spedfie ARARs, all alternatives would meet the
following ARARs upon implementation:
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- 11 -
0 SDWA Drinking Water Standard Maximum Concentration Limits
(MCLs);
0 Wisconsin Statute NR140 (groundwater protection);
0 42 U.S.C. 7401 (National Ambient Air Quality Standards for Total
Suspended Particulates);
0 CWA Ambient Water Quality Criteria for Protection of Aquatic
Life;
0 Water Quality Act of 1987, Section 118, Great Lakes Protection.
0 Article VI., Annex 8 and 10, and Appendix 1, 2, and 12 of the
1978 Great Lakes Water Quality Agreement between the United
States and Canada.
Alternative A-l would also be required to meet the following ARARs:
0 NPDES requirements of the Clean Water Act (CWA) cited in 40 CFR
125.100-.104;
0 Wisconsin Statute NR 102, NR 104 and NR 219 (relating to stream
classification/standards and sampling/testing methods for surface
water);
0 Wisconsin Statute NR 108 (relating to wastewater treatment
facility plan review and standards).
Location-specific ARARs which have been reviewed for the site
include:
0 Executive Order 11990, Protection of Wetlands;
0 Executive Order 11998, Protection of Floodplains;
0 Wisconsin Statute NR 115, Shoreland Management.
The site has been determined not to be within the floodplain of
Lake Winnebago. Further, it has been determined that construction
of any of the alternatives being evaluated would occur in an upland
area not classified as a wetland. As such, implementation of any of
the remedial alternatives considered are compliant with these two
Executive Orders.
The following action-specific ARARs have been identified for the
site:
For Alternative A-l, the following ARARs have been identified:
0 40 CFR 122.44(a) (Best available technology economically
achievable is required to control toxic and non-conventional
pollutants);
0 50 FR 30794 (Applicable Federal Water Quality Criteria must be
compiled with);
0 40 CFR 136.1 - 136.4 (Sample preservation procedures, containers,
holding times are prescribed);
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- 12 -
0 40 CFR 122.21 (NPOES Permit Requirements).
For Alternative A-3, the following ARARs have been identified:
0 Section 404 of CWA, 40 CFR Part 230 and 231 (Part of the Clean
Water Act addressing dredge and fill requirements in wetland
areas);
0 Wisconsin Statute NR 180 and NR 181 (solid waste landfill cap
standards);
0 40 CFR Parts 264.117 (relating to post closure care);
0 40 CFR Parts 264.111 and 264.310(b) (relating to the preven-
tion of run-on/runoff from damaging a site cover);
0 40 CFR Parts 264.111 and 264.310 (relating to landfill closure);
0 40 CFR Part 268 (relating to groundwater diversion and slurry
wall Installations).
For Alternative B-l, the same ARARs must be attained with the
exception of 40 CFR Part 268.
For Alternative B-2, components of the clean closure requirements of
40 CFR 264.111 and 264.117, as well as the landfill closure require-
ments of 40 CFR 264.111, 264.117 and 264.310, are relevant and
appropriate. Wisconsin Code NR 180.13(12) is applicable for closure
as well. Compliance with these ARARs would be achieved upon imple-
mentation of this alternative.
For Alternative B-5, RCRA Subtitle C and Wisconsin Statute NR 181
were determined not to apply due to the residual stabilized mass
being delisted as a hazardous waste. RCRA Subtitle D and NR 180
would still be ARARs. Land disposal restrictions for certain
California 11st hazardous wastes under 40 CFR 268 would also be an
ARAR.
At this time, It Is not anticipated that any ARARs waivers would
be needed for the alternatives evaluated. Based on the evaluation
performed 1n the FS, all alternatives would comply with Federal and
State ARARs upon Implementation.
Reduction of Toxicity, Mobility or Volume
The degree to which alternatives employ treatment that reduces
toxlclty, mobility or volume was evaluated during the detailed
analysis of alternatives.
Alternative A-l has been developed to ensure that the mobility and
volume of lead and chromium in groundwater be significantly reduced.
A necessary result of this is that the concentrations of these
compounds would be Increased In process sidestreams (water, treatment
sludge and products of resin regeneration). This would cause an
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- 13 -
increase in toxicity. There is, however, no indication that EP
toxicity values for these sidestreams would necessarily increase.
Implementation of Alternative A-3 is not expected to reduce the
toxicity or volume of lead or chromium in groundwater, however the
mobility of the compounds would be curtailed by containment throughout
the effective life of the alternative. As the RI has indicated that
these compounds are currently of limited mobility, a slurry wall and
cap would essentially eliminate future mobility of these compounds
in groundwater within the area of remediation.
Implementation of Alternatives B-l or B-2 is expected to significantly
reduce the mobility of lead and chromium by containment in the site
soils, but do nothing to reduce toxicity or volume of contaminants.
The mobility and toxicity of lead and chromium are expected to be
somewhat reduced as a result of implementing Alternative B-5 due
to decreasing the potential for leaching. The volume of material
containing these compounds would increase slightly.
Short Term Effectiveness
The short-term effectiveness was assessed for each of the alternatives,
Factors evaluated include magnitude of reduction of existing risks,
short-term risks associated with implementation and time necessary
to achieve protection. A discussion of each follows.
In the short term of Alternative A-l, the risk of ingesting on-site
groundwater would decrease with decreasing influent chromium levels.
To a lesser extent, risk reduction would also occur as a result of
implementation of Alternative A-3, but only to those potential users
of the groundwater directly affected by the groundwater flow altera-
tion caused by the slurry wall and cap.
For Alternative B-l and B-2, short-term risks associated with direct
contact with soils would not be altered. Alternative B-5 would.
increase the short-term risks to workers responsible for implementing
the alternative and may contribute to increased risk to the local
residents as well, especially during excavation, due to potential
airborne migration of dusts from the site.
On a short-term basis, Alternatives A-l, A-3, B-l and B-2 are all
envisioned to provide equivalent protection to both the community
and workers conducting the remedial action, whereas Alternative B-5,
by virtue of Its necessitating intimate contact with on-site soils,
would offer a decreased level of protection to site workers.
The time until identifiable protection is achieved Is assumed to be
the duration of planning, construction and Implementation of each
alternative. In summary:
Alternative A-l 48 months
Alternative A-3 . 28 months
Alternative B-l 20 months
Alternative B-2 20 months
Alternative B-5 16 months
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- 14 -
Long-term Effectiveness and Permanence
Alternatives were evaluated for the long-term effectiveness and
permanence they afford along with the degree of certainty that the
remedy will prove successful. Factors considered include magnitude
of residual risks, type and degree of long-term management required,
potential for exposure to wastes, long-term reliability of engineering
and institutional controls, and the potential need for replacement
of the remedy.
Long-term risk reduction associated with the ingestion of chromium
in the groundwater would occur as a result of implementing Alternative
A-l; however, as there are no identifiable potential users of the
groundwater, the magnitude of risk reduction cannot be quantified.
Implementation of Alternative A-3 is not expected to decrease long-
term risks in the same manner, as chromium would remain in the
groundwater system and potential exposure could occur, particularly
1n the event of placing a drinking water well within the capped
area. Again, the risks are unquantlfiable.
Alternative B-l would eliminate risks associated with contacting on-
site soils for as long as the cap was properly maintained. Similar
risk reduction would occur with Alternative B-2. Implementation of
Alternative B-5 is not expected to significantly minimize risks
associated with ingestion of soils without additional restrictions
on use of the site (e.g., additional fencing).
Owing to the relatively complex nature of treatment system components,
Alternative A-l is deemed to have a relatively low reliability when
compared to other alternatives analyzed. In comparison, Alternatives
A-3, B-l, and B-2 are deemed more reliable due to their simplicity.
The reliability of Alternative B-5 is unknown principally due to the
lack of data documenting long-term success or failure of similar
projects.
4
Components of Alternative A-l will not require replacement throughout
the life of the remedial action (2 to 3 years). For Alternative A-3,
B-l and B-2, the only potential need for replacement is seen to be
that of the cap or soil cover. This need could occur if the original
cap was washed out by some storm event, if heavy equipment were to
abrade the cover, or If unforeseen subsidence were to occur. Replace-
ment of Alternative B-5 1s not applicable.
Implementability
The ease or difficulty of implementing each alternative was assessed
during the detailed analysis. Factors evaluated include the degree
of difficulty associated with construction, expected operational
reliability, need to obtain approvals and permits, and availability
of necessary equipment and specialists.
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- 15 -
All alternatives evaluated have been constructed for various appli-
cations in the past. Alternatives B-l and B-2 do not require as
great a degree of engineering as Alternatives A-l, A-3 or B-5.
Treatability or compatibility testing is required for Alternatives
A-l, A-3 and B-5 prior to design and construction.
Assessments of the reliability of the component technologies of
Alternative A-l reveal that several problems can occur at each
component stage. This could result in delays or inability to
implement the alternative. For Alternative A-3, the reliability of
slurry wall technology is deemed high, subject to the achievement of
design tolerances for head differentials across the wall.
Capping (Alternatives A-3 and B-l) employs reliable technology for
sealing off contamination from the aboveground environment and
significantly reducing underground migration of wastes. Alternative
B-2 employs reliable technology for sealing off contamination from
the aboveground environment, but is not reliable for reducing
underground waste migration.
For Alternative B-5, there is considerable research data to suggest
that silicates used together with a cement setting agent can stabilize
a wide range of materials including metals. However, the feasibility
of using silicates for any application must be determined on a site
specific basis, particularly in view of the large number of additives
and different sources of silicates which may be used. Soluble
silicates such as sodium and potassium silicate are generally more
effective than fly ash, blast furnace slag, etc.
Based on the content of soils on the site, Alternative B-5 may be
difficult to implement. Contaminated soils consist of solid waste,
wood, brick, and car bodies, which would make implementation difficult,
In order to implement the alternatives presented, U.S. EPA will
need to coordinate with and obtain necessary approvals and permits
from other offices within the Agency and from other Agencies.
4
The following Agency participation will be required in the remedial
action implementation:
0 U.S. Army Corps of Engineers - will design, construct and
oversee remedial action;
0 State of Wisconsin - will aid in coordination of a voluntary well
abandonment, assume responsibility for operation and maintenance
activities after one year following construction, coordinate site
access, and provide a 10 percent share of construction costs.
In addition, approvals from other agencies will also be necessary.
These are listed below for each alternative.
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- 16 -
Agency Alternative
U.S. Army Corps of Engineers A-l, A-3, B-l, B-2, B-5
(Wetlands)
County Zoning Department A-l, A-3, B-l, B-2, B-5
(Shoreland Zoning)
WDNR A-l (Discharge)
RCRA (USEPA) B-5 (Delisting Residuals)
State of Wisconsin A-l, A-3, B-l, B-2, B-5
(Well Abandonment)
Menasha POTW A-3 (if POTW disposal of
leachate extraction is
required)
Since none of the alternatives have proposed off-site treatment,
storage or disposal services, availability of these services is not
a concern for the project. However, on-site activities for each
alternative will require specific equipment and specialist services.
For Alternative A-l, each component of the treatment process is
available; however, procurement of the ion exchange units and resins
may require 16 to 20 weeks after ordering. The remaining treatment
system components are available as prefabricated units. Treatment
plant operators would also be needed and may require licensing.
Alternatives A-3, B-l and B-2 do not require a high level of skilled
personnel for implementation. Equipment necessary for these
alternatives would be provided by the remedial action contractor.
For Alternative B-5. the manufacturer/supplier of the solidification/
stabilization process provides equipment and operations specialists
for the duration of treatment. Standard earth moving equipment
would be required for final placement of solidified materials.
Cost
Each alternative was evaluated for estimated costs of implementation.
Estimated costs include capital costs as well as annual operation and
maintenance costs. The net present worth of these costs provides
the basis for cost comparison.
The present worth analysis was performed on all remedial alternatives
using a 10 percent discount (interest) rate over a period of 30
years except where the life of a given component of an alternative
was less than 30 years. Inflation was not considered in preparing
the present worth costs and a depreciation of 100 percent was assumed.
The present worth costs for each alternative are summarized in Table 4,
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TABLE 4
COST COMPARISON OF REMEDIAL ALTERNATIVES
Total
Capital Annual Present
Alternative Cost O&M Worth
A-l Groundwater Extraction, $2,085,813 $902,083 $3,361,700
Coagulation Sedimentation,
Ion Exchange, Discharge
A-3 Slurry Wall and Cap $3,143,130 $9.315 $3,210,729
B-l Cap $2,292,848 $17,940 $2,391,798
B-2 Soil Cover $687,664 $17,940 $786,614
B-5 Excavation, Solidification/
Stabilization $2,790,152 $9,775 $2,812,131
C-l No Action $0 $0 $0
Community Acceptance
As the groundwater is not presently being used as a drinking water
source, and contamination at the site is confined to on-site media, the
community does not perceive the site as an immediate danger. Three
of the alternatives evaluated would entail mowing down the vegetation
present at the site. This could have a negative impact on the
community's perception of these alternatives.
State Acceptance
When evaluating potential response actions, it is important to
consider State concerns with alternatives evaluated. The State of
Wisconsin has expressed support for alternatives that address direct
contact threats. Because groundwater quality is within the Wisconsin
Code NR 140 requirements for groundwater protection, and due to the
excess cost involved, they do not feel that a groundwater treatment
alternative is warranted. Alternative B-2 will meet State ARARs for
closure under the State's Solid Waste Code, NR 180, and will comply
with relevant and appropriate portions of their Hazardous Waste Code
NR 181.
The State has concerns over whether adequate cap protection is
available for alternatives involving capping the site. Since the
preferred alternative entails capping, the State has agreed to
attempt to obtain a voluntary agreement from the landowner. The
agreement would provide a guarantee that the landowner will not
damage the cap once it is installed. The State is aware that
U.S. EPA has legal authority under CERCLA to issue an order for
corrective action, should the owner make an attempt to damage
the cap.
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Overall Protection of Human Health and the Environment
Following the analyses of remedial options against individual evalu-
ation criteria, the alternatives were assessed from the standpoint
of whether they would provide adequate protection to human health
and the environment based on the evaluation criteria discussed above.
Based on the evaluation criteria, it appears that Alternatives A-3,
B-l and B-2 would provide adequate protection from contaminated
soils on site. A-3 and B-l provide additional protection for ground-
water, which is not considered a pathway of concern. Alternative
A-l does not provide protection from contaminated soils which is the
only pathway of concern at the site. Thus, this alternative would
have to be combined with an alternative to achieve protection.
Although Alternative B-5 would be protective upon implementation,
there are risks to workers and residents associated with implementing
it. In addition, the ability to implement the alternative is some-
what questionable due to the content of the soils.
No Action Alternative
The no action alternative was also evaluated using the factors
listed in Section 121 (b)(l)(A-G) of SARA that were organized
into evaluation criteria for the selection of remedies. The
following discussion provides the results of the no action
evaluation.
If no action was implemented at the Site, it would not comply with
the ARARs listed below.
0 RCRA Subtitle C, Hazardous Waste Landfill Closure Requirements;
0 Wisconsin Code NR 180, Sanitary Landfill Closure;
0 Wisconsin Code NR 181, Hazardous Landfill Closure;
No action would not reduce mobility, toxicity or volume of contaminants
nor would it protect against future direct contact exposure. No,
short or long-term protect!veness or risk reduction would occur at
the site, and community response was not favorable to a no action
alternative. In addition, although there is no cost involved presently,
this alternative has the greatest potential for future remedial action
costs. In summary, the no action alternative does not provide adequate
protection of human health and the environment.
COMPARISON OF ALTERNATIVES
In order to determine the most appropriate alternative that is
protective of human health and the environment, attains ARARs and
utilizes permanent solutions and treatment technologies to the
maximum extent practicable, alternatives were compared to each other.
Comparisons are based on the evaluation criteria mandated by SARA,
and as discussed in the previous section of this ROD.
All the alternatives would comply with Federal and State ARARs if
implemented. Treatment Alternatives A-l and B-5 would require
compliance with additional action-specific ARARs, but this is not
seen as a problem.
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None of the alternatives would reduce toxicity of lead and chromium
in soils or chromium in the groundwater. Because metals are persis-
tent as natural elements, it is not feasible to change their form.
Alternative A-l actually increases the toxicity of chromium because
it increases the concentration. All alternatives reduce the mobility
of lead and chromium in soils except A-l. A-l reduces mobility of
contaminants in groundwater only. A-l also reduces the volume of
contaminated groundwater. A-3 and B-l reduce the mobility of
contaminants in both media. None of the alternatives reduce the
volume of contaminated soils and B-5 actually increases the volume
slightly.
For short-term effectiveness, Alternatives A-l, A-3 and B-l reduce
risks from groundwater; however, A-l does not reduce risks from soils.
Alternatives B-2 and B-5 provide risk reduction from soils only.
None of the alternatives, except B-5, pose a threat during implemen-
tation* B-5 would expose workers and the community to wind blown
contaminants and direct contact during construction. The schedule
for planning and implementation of all the alternatives call for one
and a half to three years. This is not expected to cause any adverse
effects.
In considering long-term effectiveness, Alternative A-l reduces risk
to groundwater but not to soils. Alternatives A-3 and B-l provide
protection from groundwater and soils. B-2 and B-5 provide good
protection for soils but only minimal protection for groundwater.
The reliability and potential for replacement for the alternatives
was also considered. Reliability of all alternatives, except B-5,
is considered good. Reliability of B-5 is unknown. Replacement of
A-l and B-5 is not applicable. There is a possibility that Alter-
natives A-3, B-l and B-2 would need replacement.
In evaluating implementability, it is envisioned that A-l, A-3 and
B-5 would be more difficult because they require more complex design.
Reliability would be low for A-l and B-5 during implementation.
This is due to complexity and the likelihood of one or more components
of the system failing. Alternatives A-l and B-5 would also requare
additional approvals and specialists and lead time to implement them.
The evaluation of overall protection indicates that Alternative A-l
does not protect against direct contact with soils, and Alternative
B-5 has risks associated with implementation and Implementability.
To summarize the comparison of alternatives, it is apparent that the
cost-effective alternative that is protective of human health and
the environment 1s Alternative B-2. Alternative A-l does not protect
against direct contact. Alternatives A-3 and B-l are not cost
effective because they provide excess protection for groundwater.
Alternative B-5 would be protective upon Implementation, however,
there are several problems associated with implementation of this
alternative that make it undesirable.
-------
- 20 -
VI. Selected Remedy
Section 121 of SARA requires that all remedies for Superfund sites
be protective of human health and the environment and comply with
applicable or relevant and appropriate Federal and State laws.
Based on the evaluation of all alternatives using the SARA Section
121 requirements, and the technical, public health, environmental
impacts and cost criteria, the U.S. EPA, in conjunction with WDNR,
selected Alternative B-2 as the final remedy for the site. The remedy
entails:
0 Installation of a low permeability soil cap over the conta-
minated soil;
0 Implementation of a groundwater monitoring program;
0 Implementation of a voluntary well abandonment program for
residents between the site and the lake;
0 Recommendation that adjacent property be evaluated under the
pre-remedlal program.
The selected remedy will adequately protect public health and the
environment from direct contact, ingestion and inhalation of soils
containing lead and chromium, which is the only exposure pathway
identified in the public health evaluation. Groundwater monitoring
will provide essential information on changes in groundwater quality.
Any increase in existing levels of chromium or lead will be evaluated
as to whether corrective action is necessary based on levels found.
The remedy is considered the most cost-effective remedial action.
It complies with Federal and State ARARs and is protective of human
health and the environment by eliminating the threat of direct
contact with contaminated soils. Based on current information, the
preferred alternative meets the protectiveness, implementability and
cost effectiveness standards of CERCLA, as amended by SARA, and the
NCP.
Protectiveness
A
Based on the Public Health Evaluation developed for the site, direct
contact with contaminated soils on-site 1s the only pathway of concern.
Eliminating the potential for direct contact by utilizing a compact
soil cap over the contaminated soils is protective of human health
and the environment. Establishing a groundwater monitoring program
to monitor long-term compliance with groundwater protection standards
for lead and chromium will provide protection from potential future
releases.
Compliance with Other Laws
The selected remedy has been evaluated to ensure that all Federal
and State public health and environmental requirements have been
identified and that all appropriate ARARs will be attained. The
site-specific ARARs for the selected remedy are listed below.
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- 21 -
Resource Conversation and Recovery Act (RCRA) Subtitle C
Because RCRA specifically regulates hazardous waste management after
November 19, 1980, RCRA 1s not legally applicable to the Schmalz
Dump site. However, since hazardous material was dumped at the
site prior to 1980, certain RCRA Subtitle C closure requirements are
relevant and appropriate. RCRA Subtitle C Subpart N defines closure
and post-closure requirements for landfills. Under Subpart N, two
closure options exist, clean closure and disposal, or landfill closure.
RCRA regulations on clean closure are found in 40 CFR 264.113,
264.228 and 264.258. Under clean closure, contaminant levels must
be below established Agency-approved cleanup-levels for all pathways.
Regulations for disposal, or landfill closure are found in 40 CFR
264.113, 264.228, 264.258,and 263.310. Under this closure option,
the site must be capped to minimize Infiltration, and a 30-year
groundwater monitoring, leachate treatment and post closure maintenance
program must be Implemented. A corrective action strategy for
potential releases from the facility must also be developed, and if
necessary, implemented.
For the Schmalz Dump site, neither clean closure nor landfill closure
is relevant and appropriate as a whole. Clean closure requires
elimination of exposure to all pathways. At Schmalz Dump there 1s a
direct contact exposure pathway. Landfill closure addresses contami-
nated groundwater and leachate pathways as well as direct contact.
At Schmalz Dump, groundwater contamination is not above MCLs and there
Is no leachate release. Based on the above considerations, components
of both closure options have been deemed relevant and appropriate.
This approach is consistent with U.S. EPA's July 9, 1987 "Interim
Guidance on Compliance with Applicable or Relevant and Appropriate
Requirements," which states that "it 1s possible for only part of a
requirement to be considered relevant and appropriate, the rest
being dismissed if judged not to be relevant and appropriate in a
given case." Thus, relevant and appropriate components from both
options have been tailored into a site-specific closure option that
1s protective of public health.
Safe Drinking Water Act
The Safe Drinking Water Act (SOWA) mandates that U.S. EPA establish
regulations to protect human health from contaminants in drinking
water. The drinking water standard, or maximum contaminant level
(MCL), for both chromium and lead is 50 ug/1.
For water that is used for drinking, the MCLs are generally appli-
cable where water will be provided to 25 or more people. MCLs are
relevant and appropriate where surface water or groundwater could be
used for drinking water. At the Schmalz Dump site, chromium detected
in groundwater did not exceed the MCL, and lead was not reported
above the detection limits. Therefore, groundwater at the Schmalz
Site is In compliance with the SDWA without implementing treatment.
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- 22 -
Clean Water Act
Section 404 of the Clean Water Act (CWA) regulates dredge and fill
activities 1n navigable waters in the United States. Protection of
wetlands is a primary goal of the dredge and fill permit program.
Permit applications for these activities are reviewed for impact on
public interest and compliance with relevant Section 404 (b)(l)
Guidelines. The U.S. Army Corps of Engineers (U.S. ACE) has agreed
that U.S. EPA need not obtain permits for Superfund activities;
however, the proposed activities should be based on technical factors,
including:
0 A determination that proposed filling activities will not
have adverse impacts on the aquatic ecosystem;
0 A determination that fill materials do not degrade water
quality or contribute to violations of any State standard;
0 A determination of the potential short-term and long-term
effects of filling activities on the physical, chemical and
biological components of the wetland.
The determination as to whether an area 1s actually a wetland
is made by the U.S. ACE. At the Schmalz Dump site, U.S. ACE
has determined that the area to be capped is an upland area
because it is not Inundated with water for any significant time
during the year. Therefore, CWA regulations for dredge and fill
activities in the area where the soil cap will be installed are
not applicable or relevant and appropriate.
The areas on-site that are emergent are considered wetlands and
thus, if any future actions were taken at these locations,
Section 404 of CWA would be applicable.
Wetlands Protection
Executive Order 11990 - Wetlands Protection, regulates activities in
wetlands. U.S. EPA Incorporated these requirements into Its Policy
on Floodplains and Wetlands Assessments for CERCLA Actions in August
1985. As discussed previously under CWA, the area to be capped on
the Schmalz Dump site 1s not a wetland area. Here too, if actions
are taken 1n wetland areas of the Site, the Wetlands Protection
Order would be applicable.
NR 140 Wisconsin Administrative Code (WAC)
Wisconsin's groundwater protection Administrative Rule, Chapter NR
140 WAC, regulates public health groundwater quality standards for
the State of Wisconsin. NR 140 is a promulgated State Administrative
Rule and 1s, therefore, applicable for Superfund activities in
Wisconsin. The enforceable groundwater quality standard for chromium
is 5u ug/1. This is equivalent to the MCL for chromium under the
SDWA.
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- 23 -
NR 180 MAC
Wisconsin's Solid Waste Management Administrative Rule, Chapter NR
180 WAC, regulates solid waste In the State. This rule Is
applicable for the Schmalz Dump site based on the history of filling
at the site. The proposed remedy will comply with NR 180.13(13)
closure requirements for unlicensed landfill closure.
NR 181 WAC
Wisconsin's Hazardous Waste Management Administrative Rule, Chapter
NR 181 WAC, regulates the handling of hazardous waste in the State.
Similar to Federal RCRA regulations, NR 181 regulates waste handling
after 1980. Like RCRA, NR 181 1s not applicable, but certain
requirements may be relevant and appropriate for Superfund sites.
Section NR 181.44(12) of the rule regulates closure of landfill
facilities without operating licenses. The requirements under this
section are relevant and appropriate for the Schmalz Dump Site. In
addition, certain components of closure for licensed facilities are
also relevant and appropriate. The selected remedy for the Site
fully complies with NR 181.44(12). And, since requirements for
closure of licensed facilities under NR 181 are not more stringent
than RCRA, the selected remedy complies with relevant and appropriate
components of closure under NR 181.
NR 115 WAC
Wisconsin's Shoreland Management Program Administrative Rule, Chapter
NR 115 WAC, regulates zoning and use regulations for shorelands in
the state. This rule 1s applicable to the Schmalz Dump site because
the facility is within 1,000 feet of Lake Winnebago, and is, therefore,
subject to the County Shoreland-Wetland Zoning ordinance, adopted
pursuant to Chapter NR 115, and enforced by the County. Under this
ordinance, all actions taken on shorelands-wetlands must be approved
by the County Planning Department. Preliminary indications by the
Planning Department favor the proposed remedy, provided proper erosion
controls are utilized. These erosion controls are also required
under RCRA and NR 181 closure regulations, and will, therefore,
comply with these requirements.
Cost-Effectiveness and Utilization of Permanent Solutions and
Alternative Treatment Technologies to the Maximum Extent Practicable
The selected remedy is the lowest cost alternative that adequately
protects public health and the environment from the threat of direct
contact at the Schmalz Site. While other alternatives evaluated
also provide protection, they are more costly while achieving the
same desired results.
-------
-24-
Under SARA, selected remedies should attempt to satisfy the statutory
preference for treatment as the principal element. The selected
remedy does not satisfy this treatment preference because none of
the components of the alternative involve treatment. Alternative
B-5, solidification/stabilization of soils, would seem to be the
most desirable alternative because it utilizes treatment as the
principal element. However, due to site-specific conditions, this
alternative has serious drawbacks. First, because the contaminated
soils consist of large amounts of solid waste, wood, brick, and car
bodies, solidification and stabilization of the soils would likely
be infeasible. Alternative B-5 also poses a short-term risk to
workers and the community during implementation, would increase the
volume of contaminated soils, and has unknown reliability. In
addition, solidification and stabilization of the soils is not
conducive to a wetlands environment. Capping and vegetation of the
site is.
Based'on the above considerations, Alternative B-5, which meets the
statutory perference for treatment, was considered impracticable due
to questionable technical feasibility, inadequate short-term
protection, and inappropriate site conditions. Therefore, the
statutory preference for treatment is not satisfied because treatment
was found to be impracticable.
Schedule
The following are the key milestones for implementation of the
remedial action:
0 ROD Signature 9/25/87
0 Award Interagency Agreement to FY 1988 Ql
U.S. ACE
0 Start Remedial Design (RD) FY 1988 Ql
0 Complete RD FY 1989 01
0 Begin Remedial Action FY 1989 Q2
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SCHMALZ DUMP, HARRISON, WISCONSIN
RESPONSIVENESS SUMMARY
The community responsiveness summary is developed to document community involvement
and concerns during the remedial investigation/feasibility study (RI/FS) phase of
the project, and to respond to public comments received during the public comment
period. Also included, as Attachment A, is a summary of the community relations
activities conducted by U.S. EPA during this phase of the project.
OVERVIEW
The preferred alternative for the Schmalz Site was announced to the public just
prior to the beginning of the public comment period. The preferred alternative
involves the installation of a compacted, low permeability soil cap over
contaminated soils to protect against direct contact with lead and chromium. It
also Includes the implementation of a groundwater monitoring program and also a
voluntary well abandonment by residents downgradient of the site.
Judging from the comments received during the public comment period, at least
some residents feel that a full RCRA Subtitle C Cap should be installed. Other
residents have not expressed a position either way. The State of Wisconsin
supports our preferred alternative, however It has several concerns related
to implementation of the remedy. These concerns are discussed in the Summary
of Remedial Alternative Selection section of the ROD.
BACKGROUND ON COMMUNITY INVOLVEMENT
Community Interest in the Schmalz Site dates back to 1978 when local residents
complained about Mr. Schmalz filling his property with PCB contaminated material.
Since that time, community concern and involvement have tapered off considerably,
primarily due to residents being hooked up to Menasha's water supply system.
The major concerns expressed during the remedial planning activities at the Schmalz
Site and how U.S. EPA and the State addressed these concerns are described below:
0 Amount of Money Involved in Planning and Remediation. A common cgmment
recorded was the large amount of money being spent on the site.
EPA Response: This Is a common comment from both officials and the
public. The public Is not familiar with Superfund procedures and the c
need for In-depth site Investigations. The reasons for the high costs
have been explained during public meetings and media interviews.
0 Appleton Intake. The public expressed concerns over the potential for
contamination of the Appleton water supply. The municipal water intake
for Appleton Is located in Lake Winnebago approximately 1200 feet from
the north shore In close proximity to the Site.
EPA Response; U.S. EPA contacted the Appleton water supply utility to
discuss adding PCBs to their quarterly sampling parameters. The utility
agreed to Include them. Sample analyses to date have not detected PCBs.
-------
-2-
0 Property Values. Citizens have expressed concern for their property
values due to the contamination at the Site.
EPA Response; Following implementation of the selected remedy, exposure
to contamination from the Schmalz Site will be eliminated. Once this
occurs, the site should not have an effect on property values. This has
been discussed with the public during the public meeting.
Summary of Public Comments Received During the Public Comment Period and Agency
Responses
The public comment period was held from August 17 to September 8, 1987, to
receive comments from the public on the draft feasibility study. Only three
comments were received during the comment period. These comments are summarized
and discussed below:
Comment; The Fox Valley Water Quality Planning Agency and one private citizen
expressed a preference for Alternative B-l. This alternative entails Installation
of a RCRA regulation cap. This would include layers of clay, gravel, and synthetic
liners in addition to what is proposed under Alternative B-2, the preferred
alternative.
EPA Response; Installation of a RCRA regulation cap was evaluated 1n the
feasibility study for the Site. This alternative was not recommended because
it was determined not to be cost-effective based on the public health evaluation
conducted for the site. The health evaluation concluded that direct contact
was the only.exposure route of concern. Alternative R-l 1s protective of
direct contact but 1s also designed to protect against ground water contamination.
Thus, the additional protection to groundwater 1s considered over-protective,
since groundwater is not contaminated. Alternative 8-1 is therefore not cost-
effective because of the additional cost Involved in providing for groundwater
protection.
Comment: An anonymous commenter asked why EPA does not make Allis-Chalmers pay
for the remedial action.
EPA Response; As part of the Superfund process, potentially responsible parties
(PRPs) are identified and given the opportunity to perform the RI/FS. If they
decline, U.S. EPA tasks a contractor to conduct the study. Following completion
of the RI/FS, the PRPs are again given the opportunity to take over the project. If
they again decline, U.S. EPA completes the remedial action and then enters Into
cost recovery litigation with the PRPs.
At the Schmalz Site, there are six identified PRPs Including Allis-Chalmers
Corporation. To date, PRPs have been given the opportunity to conduct the RI/FS
but have declined. They have also been notified regarding the proposed remedy.
At this time, none of the PRPs have committed to perform the remedial action.
If none are committed within the specified time frame set by U.S. EPA, the
remedy will be Implemented by U.S. EPA and the case will then go Into cost
recovery litigation to recover the costs spent.
-------
ATTACHMENT A
COMMUNITY RELATIONS ACTIVITIES CONDUCTED
AT THE SCHMALZ DUMP SITE
Community relations activities conducted at the Schmalz site to date include
the following:
0 U.S. EPA conducted community interviews with local officials and
interested residents (February, 1985);
0 U.S. EPA contractor prepared the community relations plan (March, 1985);
0 Two information repositories were established in the vicinity of the
site (June, 1985);
0 A press release was issued announcing a kick-off meeting and plans for
an expedited response action (operable unit)(June, 1985);
0 A fact sheet was prepared and distributed on the Superfund process and
the operable unit (July, 1985);
0 U.S. EPA held a public meeting to discuss kick-off of RI/FS and to explain
the operable unit (July, 1985);
0 U.S. EPA initiated phone calls and issued a press release regarding slowdow
of the Superfund program due to reauthorization delays (August, 1985);
0 U.S. EPA initiated several phone calls during the RI/FS to the press and
local officials to report on progress (ongoing throughout the RI/FS);
0 A press release was issued announcing the release of the remedial
investigation report and a public meeting to present RI findings (May, 1987);
0 A public meeting was held to discuss RI findings (May 13, 1987); >
0 A press release was Issued announcing the release of the feasibility study
and the beginning of the public comment period (August, 1987).
0 A fact sheet was prepared and distributed on the feasibility study and
the preferred alternative. This was considered the proposed plan for the
site (August, 1987);
0 A public meeting was held to discuss the feasibility study, present the
preferred alternative, and receive oral public comments (August 19, 1987).
-------
State of Wittconain \ DEPARTMENT OF NATURAL RESOURCES
CtrrollO.
Secretary
BOX 7921
MADISON, WISCONSIN 53707
September 28, 1987 4430
Fito R«f.
Mr. Valdus Adamkus, Regional Administrator
US EPA Region V
230 South Dearborn Street
Chicago, IL 60604
SUBJECT: Schmalz Dump - Final Superfund Remedy
Dear Mr. Adamkus:.
Your staff has requested this letter to document our position on the final remedy for the
Schmalz Dump Site. The proposed final remedy is a soil cap. The purpose of the cap is
to minimize direct contact of any contaminants remaining after the Operable Unit action
(removal of the PCB contaminated debris) 1s completed. I recently signed the State Cost
Share Contract for the Operable Unit action.
Based upon our review of the Feasibility Study/Alternatives Array, our agency, the
Wisconsin Department of Natural Resources (WDNR), concurs with the selection of the soil
cap. With our concurrence, I acknowledge that the State will be required to cost share
up to 10% of the cost of the remedy and commit to long-term care and maintenance costs
after site remedial actions are completed.
My staff has also advised me that the cap could be damaged by the landowner, who has
indicated a desire to build on the site. It 1s our understanding that if the remedy 1s
damaged, EPA has legal authority under the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA) to Issue an order for corrective action. I am
asking you to put a commitment in the State Cost Share Contract to take action should the
cap be damaged. I am also committing to have my staff attempt to obtain a voluntary
agreement with the landowner to protect the cap. The purpose of the agreement would be
to require the landowner to seek approval from our agency before any construction is
initiated. This will enable us to ensure the integrity of the cap while working
voluntarily with the land owner. However, if our efforts fail, then we must rely upon
you to rectify the situation.
As always, thank you for your support and cooperation in addressing this contamination
problem. If you have any questions regarding this matter, please contact Paul Didier,
Director of the Bureau of Solid Waste Management at (608) 267-1327.
Sincerely,
cc: Lyman Wible - AD/5
Paul Didier/Mark Giesfeldt/Barb Schultz - SW/3
Doug Rossberg - LMD
Renee Sanford - FN/1
mfg-msgl
-------
"ane No.
09/30/87
Title
Scnmalz Duma
flcsinistrative Record Incex
Descriotion
Date
Author
1 Sarnie Data: QA/QC'd Ran Data and
Chain of Custody Forms for SI
2 Record of ccamnication: Letter to
Gerald Schnaiz
3 Record of comunication: Letter to
Gerald Schaaiz
4 Record of coonunication: Letter to
Gtraid Schnaiz
5 Record of cotaunication: Letter to
Gerald Schnaiz
6 Record of communication: Letter to
Gerald Schnaiz
7 Record of eoanunication: Letter to
Gerald Schnaiz
8 Record of coMunication: Letter to
A. Acker-un, USAGE
9 Record of comunication: Letter to
R. Mustard. UStPfl
10 Record of coonmieation: Letter to
C. Bohl, US Attorney
11 Record of coonunication: Letter to
C. Bohl, US Attorney
12 Doeuatnt: Initial Assessment of
Schnaiz Disposal Site
13 Document: Results of Additional
Testing of Sciaalz Landfill
14 Record of eowunication: Letter to
D. Seno. USEM
15 Guidance Docucant
16 Guidance Document
17 Suicance Oocuoent
IS Document: Preiiainary Assessnent
19 Doeuaent: Site Inspection
20 Docunnt: Hazardous Ranking Scoring,
Package
21 Guidance Document
22 Guicance Document
These docunents art available to
the oublic but art not included in
the information repositories
Closure of unauthorized dum on
prooerty
Closure of unauthorized durao on
orooerty
Noncoswliance with instructions to
close auo?
Unautnorized doming on prootrty
unautnorized duaaing on
Initiation of investigation into
PCB contaainated fill
Destroyed wet i anas due to Scrwalz's
duaping activities
Characterization of hazardous
eateriais onsite
Lawsuit involving US vs Strald
Schnaiz and Witstltr Construction
Sanoie results fro* Schulz site
Reaort
Reoort
Results of site assessatnt of
Schoalz site
Procedures for Identifying
Responsioie Parties
OSUEft Oirtctivt I 9834.!^
Uncontrolled Hazardous Waste Site
Ranking Syster- A Users Manual
OSUER Directive t 933. 0-03
Suptrfund Coanmity Ptlations
Policy
09CR Directive * 3230.0-02
First Step in Suotrfund
Prt-Rentdial Prograa
Second Steo in Pre-Rentdial Process
.Ail d?cuRcntation for scoring site
for >.?:.. including references
Coirunity Relations in Sjasrfund: A
Harcrjok, ir;teria Vsrsion
GS,«-.r Directive * 5230.0-03
Coir:.-jR:ty ^slatioris 5-jidance for
svaiuating Citizens Corcerrs at
Suoerfuno Sites
Dir. I 9230.0-04
10/03/71
08/25/72
05/21/74
03/05/79
03/12/79
04/11/79
04/18/79
04/26/79
10/29/79
01/18/30
05/05/60
07/07/60
11/06/80
02/01/82
07/16/62
05/09/83
05/23/83 Ecology t Enviroment, Inc.
05/23/83 UDNft
C7/H/B3 USEPA
09/01/83
10/17/83
D. Martin, WDNR l
A. Schoen, WDNR 1
L Boehn, WDNR l
0. Klessig, Calunrt County 2
D. Misterex, WDNR l
J. Miller, USACE 1
ft. Hopot, US Fish t Wildlife 2
J. Miller, USACE
y. Miner, USEPA
S. Sarde&ring, USEPA
RUT, Ine
RMT. Inc.
D. Nicnois. Ri^T. Inc.
1
3
3
30
25
3
0
14
150
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aifi NO.
09/30/87
Title
Scnaalz DUBO
Administrative Record Inoex
Descriotion
Date
flutnor
Pages
23 Guidance Document
24 Suidanct Docuent
25 Record of coanunication: Litter to
V. fldamkus. USEPfl
26 Guidance Document
27 Guidance Docuewtt
28 Record of comunication; Letter to
D. Hanson, UDNR
29 Record of coewnication: Letter to
H. KtesoN, ECURPC
30 Record of eoaaunication: Letter to
H. KiesoM, ECURPC
31 Guidance Docuaent
•v Record of conunication: Letter to
I Strieou, USEPfl
jw Coanunity Relations: Letter to J.
Beck, USEPfl
34 Guidance Document
35 CR: Coranunity Delations Plan for
Sctaaiz Dura
36 Guidance Docuoent
37 Record of eoanunication: Letter to
1 J. Knoy, USEPfl
38 Record of coatunicitioni Notice
u letters to PRPs for Schwlz H/FS
39 Suicanee Document
40 Suicanee Do:w:ert
A! C^: Press Release
4' 'j.nent: R!/r3 i«ork Plan for
..nalz Duao Site
Slurry Trench Construction for
Pollution Migration Control
09CR Directive I 9380.0-02
EP Toxicity Test
OStCR Directive I 9443.04-44
Reouest for Suoerfund assistance
User's Guide to the Contract
Laboratory Progra*
OSUER Directive * 9240.0-01
Guidance on Issuance of Notice
Letters
OSUER Directive * 9834. 1
Prooosed Suoerfund activities at
Scnialz
Supoort for Suoerfund actions at
the site
Supoort for Suoerfund actions a:
Schuiz
Standard [berating Safety Guide
Manual
OSJ€R Directive 19283. K>!-8
Support for Suoerfund actions
CojEtnts on draft Cceaumty
Relations (CR) Plan
Preoeration of Decision Docunents
For flooroving Func-?:nancec Rfis
Under CERCLfl
Dir. » 9340.2-01
Document
I*OU Between the ATSDR and
OSWER Directive f 3295. 1-01
Consents on draft HUPS nork plan
fl total of eight PRPs wre noticed
and given an osoortumty to oerfort
the RI/FS
Guidance on feasibility Studies
Under CERCLfl
OSUER Directive • 935S.O-05C
Guicance on .isnwcia; Invest isat ions
Under CE3CLA
QSHSR Directive f S355.0-05B
fivailablity of Oserasis L;nit "3 ar;2
announcesent of RI/-S K:CK-O?*
meeting
Reoort
02/01/84
08/20/34
09/28/84 C. Besadny, nONS
10/01/84
10/12/84
10/26/84 B. Constantelos, USEPfl
11/14/84 U. ElBan, FVWOPA
11/14/84 D. Xlessig, Caluaet County
11/19/84
£4 R. Uillry, EOMPC
02/07/E3 R. O'Hara, W5NR
02/27/55
03/20/cf C-i£1 HILL, Inc.
04/02/S5
05/20/33 R. O'Hara. wDKfl
05/21/85 B. Constantelos. UScPfl
06/01.'::
CS-'Ol/eS
C5/25/e5 J. Bee*. LiScPfl
OS/57/S5 Caao Dresser 4 McKee. inc.
2
1
1
0
I
16
0
35
0
4
56
70
-------
aC= '.0. 5
09/30/87
Title
Schnaiz Ouno
Administrative Record Index
Dtscriotion
Date
Author
Pa OE
43 CR: Fact Sheet
44 CR: Agenda for Public feet ing
45 Record of eoawnicayion: Letter to
!f. Guerriero, USEPfl
46 Suidance Document
47 Document: Health t Safety Plan for
Sctaalz RI/FS
48 Suidance Document
49 Document: Sampling Protocol
Revisions to the RI/FS Work Plan
SO. Record of Coaminication: Phone
Conversation wittf D. Payne, USEPfl
Si Samole Data:Analytical Summary
Paces for RI Samples. N/QC reoorts
52 Document! Technical Memorandum for
Schmalz Dump Site RI
53 Guidance Document
54 Record of communication: Nemo to G.
v'anderlaan, USEPfl
55 Record cf communication: Conference
cali with A7SDR
56 Guidance Document '*
57 Record of communications Hew to L
Fabinski, AT3DR
SB Suidance Document
59 Document: Suppienentai kirk Plan
for Schoalz Duno RI/FS
60 Document: Supoleoental QflPP for
Additional Samoling at Schnalz
6! Samole data Analytical Summary
Pages for RI Saaoles, N/QC Resorts
62 Record of coanunication: Letter to
M. Guerriero, USEPfl
63 Guidance Document
Discusicn of operable unit actions 07/06/65
and the RI/FS plans
Outlines tooics of discusion for 07/09/85
•fting: Operable Unit FS and RI/FS
kick-off
Comments on RI/FS work plan 07/30/85
Policy on Flood Plains and totlands 08/06/85
Assessments
OSUER Directive §9880.0-02
Reoort 09129/85
CERCLfl Coiraliance with Other 10/02/85
Environaental Statutes
OSWER Directive I 9234.0-02
Addendua to work olan 10/08/85
Verbal aaaroval for RI/FS Saooling 10/18/65
activities prior to QflPP approval
Orsanics:S6RC01S01-lS93 12/12/85
Incroanics:8fiRC01S01-£S29
EP TOX:d6RC03SOi-3S09
Res N«lis:86RCOiS79-lS89
Reaort on RI field work 01/14/fiS
State Particioation in the 03/01/5i
Sucerfunc Procra* Manual
D5i£R Directive » 9375.1-04
Scsrovai of RI/FS 3fl?P exeeot for
crocedures for analyzino PCB's in
tissue
Conference call with L Fapinsxi,
B. willians. ATSD3 regardingtheir
review of res well saaoie data
Analytical Suooort for Suoerfund 03/20/65
QSUER Directive i 9240.0-02
Review of residential well data by 04/02/66
ATSOR
Discharge of wastewater fron CERCLA 04/15/££
Sites to POTbs
OSkeR Directive » 9330.2-04
work olan for the collection of 04/21/66
additional sannles on the site
QflPP for collection of additional 04/ctV66
saaoles at the site
Inorganic i organic samale f's: 07/07/86
S6*C03S01-3S09~
Review ano aaprovai ef R! resort 10/09/86
J. Beck. USEPfl
J. Beck. USEPfl
R. Q'Hara,
COM, Inc.
CDM. Inc. •
M. Guerriero. USEPA
Contract Lab Prograi laps
CON. Inc.
03/03/66 J. Acaffs. USEPfl
t 03/18/ts *!. uuerriero. L3HPA
J. Lybareer,M.D.. flTSDR
CIW, Inc.
CDM. Inc.
Contract Lab Program lab
R. O'.Hara, w'D.N3
4
1
2
0
35
0
10
1
500
75
0
0
5
0
16
24
c5
Suserfune Puolic health Evaluation
11/07/65
OSWcR Directive * 9285. 4-01
-------
^ace \0. 4
03/30/87
Title
Schmaiz Ouno
Administrative Record Index
Dtscriotion
Date
Aut.ior
vaoes
64 Guidance Document
65 Guidance Document
66 Document: Alternatives Array,
Sctwalz Dump
67 Record of conunication: Letter to
Cw Besadny, UONR
6B Document:Approved QAPP for Schmalz
Dumo RI/FS
69 Record of coranunicaticn: Letter to
V. Adamkus, USEPa
70 Record of conunication: Letter to
B. Constantelos. USEPA
71 Guidance Document
72 Record of communication: Letter to
M. Guerriero, USEPfl
/3 Guidance Docuwnt
74 Dccuoent: Phase I 31 Recort for
Schaaiz OUNO
75 CR: Press Release
76 Document: Phase II RI/FS work olan
f-r Schmalz Dump
77 CR: Fact Shett *
78 CR: Agenda for Public Meeting
79 Document: Suooleeental QflPP for
Additional Sampling at Schmalz
SO Record of conunication: Letter
C. Dicier, UDNR
31 ? ancle Data: Guonary sheets for
Phase II 3! sanoies
82 «en»: To file
"uidance Oocunent
Federal-tead Remedial Project
Nanaotwnt Manual
09CR Directive I 93S5.1-01
Interim Guidance on Suptrfund
Selection of Rewdy
OSK3 Directive I 933.0-19
Reoort
Reouest for notification of State
ARMs
Reoort
Resnonse to reouest for
notification of State ASflfis
Notification of site-soecific State
ftftARs
Preliminary ioentification of
ARARs attachment
Guidance for Coordinating ATSDR
Health Assessnent Activities
M/Superfund Rendiai Process
9285.4-02
Technical review conents on
Alternatives Array Document
Data Quality Objectives for
Remedial Resaonse Activities
OSWER Directive t 9355.0-7B
Public Health Evaluation induced
as an aooendix
Announcing csnaletion of Phase I RI
reoort anc clans for Phase II RI
and FS
Reoort
Completion of Phase I RI and
discusion of findings
Plans for Phase II SI and FS
Outlines toaics of discusion for
the meeting: Findings of Pnase I
and olans for Phase II of the Si
Reoort
Response to State's notification of
ARflRs
Inorganic saroie #'s:
87RC01S01-1S41
The use of filtered vs unfiltered
sanoles for netais analysis
Interim Guidance on Compliance mtn
Aoolicable or Relevant and
Aoorooriate Reouireaents
9234.0-05
12/01/66 0
12/24/86 0
01/27/87 COM, Inc. 70
02/04/87 V. Aaamkus. UScPA 2
02/20/87 CDN, Inc, 160
03/06/87 C. Besadny, MDNR 2
03/06/87 P. Dicier, W)NS 20
03/11/87 0
03/i£/87 R. O'Hara. UDNR 2
04/01/87 0
04/c9/S7 CM, Inc. £00
05/04/37 J. Becx. iiSEPA 1
05/07/87 COM. Inc. 25
05/11/87 J. Beck, US£?A 4
OS/::vS7 J. Beck, iJSePA i
05/1 :/s7 CO*. Inc. ' 35
riS/21.37 B. Constanteios. liScPfi £
C!6/i*''i7 C.?ntract Lao Prearaa las 20
07/07/87 .*. 5ue?r:erc. u5c?H 2
07/C-3/67 0
-------
age .«c. 5
09/30/87
Title
Scnnaiz Durao •
Administrative Record Index
Descriotion
Date
Author
?ao'
84 Guidance Document
35 CR: Synopsis of PropOHd Plan in
Aooleton Post-Cresent Newsoaoer
86 CR: Pr?ss Release
87 Record of coawmcation: Phont
conversation with P. Lagoy, IGF
88 New: To file
89 Record of coaminication: Phone
conversation with 6. Knapton,LJSflCc
i
90 Docuaent: Public Coweent Draft
Feasibility Study Report
91 Docuaent: Phase II RI Report
98 CR: Fact Sheet
93 Record of conwnication: Notice
letters to PRPs for Schuair RD/Sfl
94 Record of Kwunication: Letter to
». Guerrierc, USEPA
95 CR: Agenda for public Beeting
% CR: Transcriot of 8/19/87 puJlic
meeting on the proposed olan
97 CR: Public Comnts (3) on UBEWs
orooosed plan
98 Record of coonunication: Letter to
M. Suerriero, USEPA
99 Xeaoi To file
100 Record of Decision . •
Suaaary of Remedial alternative
Selection
Additional Interin Guidance for
FY'87 Records of Decision
OSCR Directive • 9353.0-21
Announcement of preferred
alternative and notice of oublic.
coawnt oeriod for F5 and public
meeting
Announcement of preferred
alternative and notice of oublic
netting date
The need to use JSEPA's Public
Health Evaluation Manual in
cetemining risk levels at Schaalz
Oiscusion of the Schsaiz PHE and
the detemination that protection
froi direct contact is needed
Determination that area to be
capped in the cerferred alternative
is not a netlands area
Final FS
PHE for second ohase RI is included
Coaoletion of Phase II RI and FS
and their findings
also includes the oroposed olan
for the site
The eight PRPs Mere sent notice
letters and civen the escortunity
to oerforn tie RD/.W at Scnialz
Comnents on the draft Phase II RI
resort and the draft FS reoort,
with attachment
List of tooics to be discussed by
soeakers during ouolic meeting
Coflwnts include: preference for
ROM cao
and reconnendation that PRPs are
•ade to pay for reeedy
Conents on oublic cement drafts
of Phase II RI and FS resorts
Issues outstanding Nith UDNR on
selected remedy, resolutions
discussed, and outcone
Package includes:Ressonsiveness
susmary
Letter of State Concurence
and Administrative Record Index
07/24/87
06/05/67 S. Pastor, USEPA
08/07/87 S. Pastor, USEPA
Ofl/14/87 N. Sufrritro, USEPA
08/14/87 N. Suerriero, USEPA
08/14/87 It. Guerriero, USEPfl
08/14/87 CW. Inc.
08/14/87
08/17/57
CON, Inc.
S. Pastor, USEPA
90
80
08/17/37 B. Constantelos. USEPA
08/17/67 11. Siesfeidt. i»DNS
S. Pastor, USEPA
08/19/87
08/19/87
09/08/87
09/11/87 ». Siesfeiot, *
•^9/18/87 M. Guerriero, USEPA
03/30/87 V. Adamkus. USEPA
80
20
1
23
3
2
3
35
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