United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R05-92/204
June 1992
Superfund
Record of Decision:
Muskego Sanitary Landfill, Wl
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NOTICE.
The appendices listed in the index that are not found in this document have been removed at the request of
the issuing agency. They contain material which supplement, but adds no further applicable information to
the content of the document. All supplemental material is, however. contained in the administrative record
for this site.
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50272-1 01
REPORT DOCUMENTATION 11. REPOATNO.
PAGE EPA/ROD/R05-92/204
I~
3. Reclplenh Accealon No.
4. TIlle 8IId Subtllle
SUPERFUND RECORD OF DECISION
Muskego Sanitary Landfill, WI
First Remedial Action - Interim
7. Aulhor(.)
5. Report 0818
06/12/92
6.
8. P8ffonnlng Org8lllz8llon Rept. No.
I. P"onnlng OrgaInlZ8llon N8m. ..d Addr8a
10. Proj8CtIT88klWortt UnIt No.
11. Contr8CI(C) or Gr8I'It(G) No.
(C)
(G)
12. Sponeorlng Org8llDtion Nam. end Addr88
U.S. Environmental Protection
401 M Street, S.W.
washington, D.C. 20460
13. Type of Report. P8riod Covered
Agency
800/000
14.
15. Supplementary HoI88
PB93-96412
16. Ab8tr1lCt (Umlt: 200 word8)
The 56-acre Muskego Sanitary Landfill site is located in the City of Muskego, Waukesha
County, wisconsin. Land use in the area is predominantly residential and agricultural,
with wetland areas located in the nearby vicinity. All of the site lies within the
100-year floodplain. The upper glacial drift aquifer, one of three principal sources
of ground water in Waukesha County, is used for human consumption. From the 1950's to
1981, municipal waste, waste oils, paint products, and other waste were disposed of at
the site. The site is separated into three disposal areas: the Old Fill Area (38
acres); the Southeast Fill Area (16 acres); and the Non-Contiguous Fill Area (4.2
acres). composed of a drum trench, north and south refuse trenches, and an L-shaped
fill area, all containing waste similar to the Old Fill Area. As a result of
deteriorating water quality at onsite ground water monitoring wells, Waste Management
of Wisconsin Inc. (WMWI) and the state conducted numerous investigations that revealed
elevated levels of contaminants in the ground water. In 1985, WMWI installed a methane
extraction system to alleviate the gas migration along the western portion of the Old
Fill Area. In 1986, public water was supplied to the site and private wells in the
area. Two separate areas at the site were discovered to contain buried drums and
(See Attached Page)
17. Document Analy8l. .. 088crIpt0re
Record of Decision - Muskego Sanitary Landfill, WI
First Remedial Action - Interim
Contaminated Media: soil, gw
Key Contaminants: VOCs (benzene, toluene, xylenes), other organics (PARs, PCBs.
pesticides. phenols, phthalates)
b. Idenllft8r8/Op8n-End8cl T......
0. COSA TI Fl8lcrGfoup
18. Av8ll8bUlty 8-'8IIt
11. s-.rIty a- (Till. Report)
None
20. s-mty a- (ThI8 Pege)
None
21. No. 0' P8gH
68
22. Prtce
(SM ANSI-Z38.18)
S881n8fluctlon8 on R-
. t"UHM 272 (4.77)
(Formerly NTtS-35)
Oeper1m8IIt 01 Commerce
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EPA/ROD/R05-92/204
Muskego Sanitary Landfill, WI
First Remedial Action - Interim
Abstract (Continued)
contaminated soil. The first area was located east of the Non-Contiguous Fill Area. The
second area, known as the drum trench, was discovered in a portion of the Non-Contiguous
Fill Area and contained 989 drums and 2,500 cubic yards of contaminated soil. In 1991,
the drums and soil from both areas were disposed of offsite at appropriate hazardous
waste disposal facilities. Liquid wastes and drums were also sent offsite for
incineration. This interim ROD addresses the control and remediation of the
contamination sources, including landfill waste, contaminated soils, leachate, and
landfill gas. Future RODs will address the control and remediation of the contamination
in the ground water aquifer as a separate operable unit. The primary contaminants of
concern affecting the soil and ground water are VOCs, including benzene, toluene, and
xylenesi and other organics, including chlorinated ethanes, ketones, PAHs, PCBs,
pesticides, phenols, and phthalates.
The selected remedial action for this site includes installing a cap over both the Old
and Southeast Fill Areasi the addition of a landfill leachate control system at the Old
Fill Area and improvement of the existing leachate control system at the Southeast Fill
Areai discharge of collected leachate to the sewer, provided pretreatment requirements
are met, or leachate treated with ground water as part of the subsequent OUi management
of sludge and residue as a hazardous waste if it exhibits the characteristic of toxicitYi
capping of the Non-Contiguous Fill Area, and installing in-situ vapor extraction (ISVE)
system; removal of the extracted gas either through activated carbon or thermal
destruction with catalytic oxidation, or other treatment method before emitted to the
atmosphere. An active gas control system, working in conjunction with the leachate, will
be applied to both the Old and Southeast Fill Areas with extracted gases destroyed by a
ground flare. Semi-annual ground water monitoring will be performed to contribute to the
definition of the contamination plume and to measure the effectiveness of the
implementation of the interim remedial measures. The estimated present net worth cost
for this remedial action is $9,914,000, which incl~des an annual O&M cost of $309,500 for
years 0-5, and $134,200 for years 6-30.
PERFORMANCE STANDARDS OR GOALS: A performance based clean-up standard will be applied to
the area covered by the ISVE system in the Non-Contiguous Fill Area. The clean-up
standard will be based on residual soil gas concentrations that are low enough to assure
compliance with ground water clean-up standards, which will be specified in the
subsequent ROD for the contaminated ground water.
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DBCLUAT%OIl
RECORD 01' DBC%S%OIl
SBLBC'.rBD RRII1m%AL ALTBRDT%VB pOR
%ll'.rBR:IX ACT%OIl SOURCB COII'.rROL OPBRABLB
1'02 DSnGO SDI'DRY LAlJDI'%LL
UN%T
si~. II... and Loca~ion:
Muskego Sanitary Landfill
Muskego, Wisconsin
s~a~"8D~ o~ B..is and Purpos..
This decision document presents the selected remedial action for
the Muskego sanitary Landfill located in Muskego, Wisconsin. The
decision has been developed in accordance with the comprehensive
Environmental Response, compensation, and Liability Act (CER~LA),
as amended by the superfund Amendments and Reauthorization Act
(SARA), and in accordance with the National oil and Hazardous
Substance continqency Plan (NCP). This decision is based on the
Administra~ive Record for this site. The attached index identifies'
the items that comprise the Administrative Record, upon which the
selection of the remedial action is based.
A8S.s""~ o~ ~h. si~.1
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action selected
in this Record of Decision (ROD), may present an imminent and
substantial endangerment to public, health, welfare or the
environment.
D.scrip~ion o~ ~h. S.l.c~.d R...471
The interim action source control operable unit addresses
protection of ground water and exposure to soil contamination by
reducing the risks posed by the site, through engineering a~d.
institutional controls. This remedy is consistent with the final
remedy' and overall clean-up of the site by addressing the principal
threats posed by the site. The principal threats are direct
contact to contaminated soils by workers or trespassers and
ingestion of contaminated ground water at private wells. This -
remedy is described as follows: -
.
Deed restrictions and site controls that prevent access,
excavation, and disturbance of the cap and installation of
wells;
Fence extension to contain areas not enclosed by currently
.
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8
8
existing fences;
Cap installation over the portions of the site deemed
necessary in the ROD according to Wisconsin Administrative
Code NR 504 standards; .
Installation or upgrade of landfill leachate control systems
at the site;
Active landfill gas control and monitoring for the site;
In-situ (In-place) soil Vapor. Extraction at portions of the
Non-contiguous Fill Area of the site;
Ground water monitoring of selected existing monitoring and
private wells to be determined during the remedial design; and
- Operation and Maintenance of all systems.
8
8
8
_8
state Concurrence.
The state of Wisconsin concurs wi th the selected remedy. The
letter of concurrence is attached to the Record of Decision (ROD)
package.
Declaration.
The selected remedy is protective of human health and .the
environment, attains Federal and state requirements that' are
legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. This remedy utilizes permanent
solutions and alternative treatment technology to the maximum-
extent practicable for this site. Because this remedy will result
in hazardous substances remaining on-site above health-based
levels, a review will be conducted within 5 years after
commencement of remedial action, to ensure that the remedy
continues to provide adequate protection of human health and the'
~:~~f~_- 4t ------
Date
Valdas V.
Regional
-
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I.
- II.
SUMMARY 01' REHBDZAL ALTBRRATZVB SELECTZOH
XOSKEGO SARXTARY LAHDPZLL SZTE
XOSKEGO, nSCOHSZH
TABLE 01' COftEH'lS
SITE NAME AND
LOaTION. . . . . . . . . . . . . . . . . . . . . . . . . . .
SITE HISTORY AND ENFORCEMENT ACTIVITIES............
III. COMMUNITY
PARTICIPATION. . . . . . . . . . . . . . . . . . . . . . . . . . . .
IV.
V.
VI.
SCOPE OF INTERIM ACTION SOURCE CONTROL
OPERA.BLE UNIT......................................
SITE CHARA.CTERISTICS...............................
SUMMARY OF SITE RISKS..............................
vrI. DESCRIPTION OF ALTERNATIVES........................
VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES...
IX.
X.
XI.
THE SELECTED REMEDY.................................
STATUTORY DETERMINATIONS.............~.........~...
1
3
5
6
7
15
17
25
31
33
RESPONSIVENESS SUMMARY.........................
(Attached)
XII. ADMINISTRATIVE RECORD..........................
Appendix A
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DBSCRZPTZOH OP PZGURBS
KDSKBGO SAHZTARY LARDFZLL SZTB
KDSKBGO, USCOHSZH
FIGURE 0
SITE LOCATION MAP
FIGURE 1
SITE MAP
FIGURE 2
WASTE MANAGEMENT OF WISCONSIN, INC. PROPERTY
WATER TABLE MAP
FIGURE 3
FIGURE 4
SAMPLING LOCATIONS
FIGURE 5
SAMPLING LOCATIONS
FIGURE 6
SAMPLING LOCATIONS
FIGURE 7
SAMPLING LOCATIONS
FIGURE 8
SAMPLING LOCATIONS (PRIVATE WELLS)
SEDIMENT. SAMPLE LOCATIONS
FIGURE 9
DBSCRZPTZOH OP TABLBS
KDSKBGO SAHZTARY LARDFZLL SZTE
. KDSKBGO, USCOHSZH
TABLE 1
ORGANIC GROUP RESULTS.
SAMPLES
ROUNDS 1 AND 2 GROUNDWATER
TABLE 2
NR 140 AND EPA MCL EXCEEDANCES FOR GROUNDWATER
TABLE 3
ALTERNATIVE 4: CAPPING, LANDFILL GAS & LEACHATE
CONTROL, AND IN-SITU TREATMENT OF THE NON-
CONTIGUOUS FILL AREAS
TABLE 4
COST SUMMARY ALTERNATIVE 4 FEASIBILITY STUDY
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SUMMARY OF REMEDXAL ALTERNATXVE SELECTXON
XNTERXM ACTXON SOURCE CONTROL OPERABLE UNXT
MUSKEGO SANXTARY LANDFXLL SXTE
MUSKEGO, WXSCONSXN
X.
SXTE NAME AND LOCATXON
The Muskego Sanitary Landfill Superfund site occupies approximately
56 acres north of State Highway 24 (Janesville Road), and east of
Crowbar Road in the City of Muskego, Waukesha County, Wisconsin.
The site is located in Southeastern Wisconsin approximately fifteen
miles southwest of the City of Milwaukee (see Figure 0). More
specifically the site is southwest of the urbanized portions of
the City of Muskego by roughly three miles. The site includes
three areas known as the "Old Fill Area", the "Southeast Fill Area"
and the "Non-contiguous Fill Area" (see Figure 1). The site also
includes wastewater ponds associated with a former rendering plant
complex (the "Anamax plant"). Those ponds are located east of the
Non-Contiguous Fill Area. Portions of the property associated with
the Anamax plant are also included in the Old and Southeast Fill
Area boundaries. Directly north of the site is the stoneridge
Landfill, a closed and covered solid waste landfill, that is not
.part of the Superfund site. Land use to the west of the site is
for sand and gravel excavation. To the south, east and north of
the site, the land use is a combination of residential and
agricultural. The area surrounding the site is semi-rural, but is
zoned to permit further development in the future. Several homes
and businesses are in the vicinity of the property, and many were
once served by individual private water supply wells. In the later
1980s, city water mains were extended into the area and several
homes and businesses were connected. currently, two residences
southeast of the site are not connected to public water. These
residences are indicated in Figure 1.
The Muskego Sanitary Landfill site is situated on unconsolidated
deposits that are up to 300 feet thick and are generally comprised
of glacial till, outwash, and lacustrine deposits. site
investigative information and private well boring logs show layers
1
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FIGURE 0
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( ) . ---- "'. ~ "
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~n...~;'~~M~d~~'~!1 \ . '.
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# " '1:'... <::iiJI{ I,A~\"3 - ~,mo,-, ,,..,'-1:::< "I~' ,~' ~
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~ Troy -"\ ~~ 1 ' I';';': 0 tr I \~ 1'1.. - r . ""~ort" 8ay
. d W.t.rfor~,.IN;~ ,/"\I.'ItJJ I~ :n,.~ ~: fl'll
HO, ,'. !/ oiLY' V',L~?.' 1'1' ! 9 ,cD J- "VlII~
t; ~~~~;#. ~"t.u ']0< ::"'l~ ;: r;::-.. ~ I.~ ~"" . ~.,RACINE'
~-~ ~ \"'..~_l f ().. ,.. . ~J ....-
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r ..:.. -..,.( "nil'l::-..r. t
01 ~ r Ai;I : ~ GroWl .1" ,v:.. , ~ wood Pa,k
.. ur 'II (I .. .. .',"
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ka~""'1 G:'J. I... ,1'.10-, ;- ,", IA - '. ~'i
-------
Potential
Expansion
Fill Area
STONERIDGE
LANDRLL
Location of Former
Rendering Plant
Lagoons
Non. Contiguous
Fill Area
Office
(')
i
a
:XJ
o
~
~
Not To
Scale
Legend
'¥- Wetlands
o Residences
Not Connected
To Public Water
Figure 1
Site Map
Muskego Sanitary Landfill
Muskego, Wisconsin
:c
CD
:::J
C.
I»
CD
:D
o
I»
C.
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of fine-grained material (till and lacustrine deposits) south and
east of the site to depths of about 70 to 200 feet and coarse
grained material (outwash) below the till to depths of about 200 to
300 feet below land surface. .
There are three principal sources of ground water in Waukesha
County. In order of depth below the land surface they are; sand
and gravel within the glacial drift, Niagara dolomite, and an
underlying sandstone. In the Muskego area, a majority of the
private wells are finished in the thick sand and gravel deposits.
The water table for this shallow aquifer is approximately 20 to 40
feet deep and has produced yields as high as 2,000 gal/min. The
depth of the upper glacial drift is about 300 feet which
corresponds to the aquifer thickness. The ground water
classification for this aquifer is Class IIA (i.e., is used for
human consumption purposes and is not restricted).
In the Muskego area, ground water flow in the water table shallow
aquifer is generally in an easterly to southeasterly direction.
This is similar to the ground water flow at the site, which has two
flow paths. The first is in a north to south direction under the
eastern portion of the Old Fill Area where the basal clay unit
separates the sand and gravel unit from the landfill. The second
flow path is generally to the southeast under the Southeast and
Non-contiguous Fill Areas.
The site is located within the Fox River watershed, just south of
a local surface divide. There are numerous wetlands in the area
and the closest off site intermi ttent stream is located about
three-quarters of a mile to the southeast. None of the wetlands
are located within the site boundaries. Surface drainage at the
site is divided between flow to the wetlands and the intermittent
stream to the southeast. Surface water runoff from the Old Fill
Area is to the ditch along Crowbar Road or to the southeast through
a small swale. The western half of the Southeast Fill Area also
drains to this swale which eventually discharges to a small wetland
north of an abandoned railroad right-of-way. Runoff from the
neighboring Anamax property, the Non-contiguous Fill Area,
Stoneridge Landfill, and the eastern half of the Southeast Fill
Area is toward the ditch along the service road to a small wetland
southeast of the site and then through a culvert under Highway 24
to a larger wetland. The site is located within the 100 year
floodplain.
2
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II.
SITB HISTORY AND BBPORCBKBRT ACTIVITIBS
A. site Historv .
The 38-acre Old Fill Area accepted material from the
mid-1950s until 1977. An unknown amount of waste oils,
paint products, and other wastes were deposited into the Old
Fill Area during this time. The Southeast Fill Area which
covers about 16 acres, accepted only municipal wastes during
its operation from 1977 to 1981. The Non-contiguous Fill
Area .includes a drum trench, north and south refuse
trenches, and an L-shaped fill area. This Non-contiguous
Fill Area occupies approximately 4.2 acres northeast of the
Old Fill Area. Based on information from workers employed
during operation of the landfill, the L-shaped Fill Area is
expected to contain waste similar to that in the Old Fill
Area.
In response to deteriorating water quality at on-site ground
water monitoring wells, sampling of off site private water
supply wells was conducted in 1982 and 1984 by the site
operator, Waste Management of Wisconsin, Inc. (WMWI), and
Wisconsin Department of Natural Resources (WDNR). The
results of these analyses indicated that several of the
private wells may have been impacted by a source of
contamination, which could have been the landfill and/or the
Anamax wastewater lagoons. The results were based on
elevated indicator parameters. The test for indicator
parameters is a preliminary test completed to show signs of
ground water contamination. In 1986 public water was
extended to this area and private wells in the area were
connected to this supply. The site was evaluated and ranked
by the united states Environmental Protection Agency (U.S.
EPA) and placed on the National Priorities List (NPL) on
September 18, 1985.
In 1985, a partial methane extraction system was installed
by WNWI along the western portion of the Old Fill Area to
alleviate methane gas migration that was noted at the site.
The extracted gas is destroyed through flaring.
B. ReSDonse Actions
During preparation of a portion of the Phase I stoneridge
Landfill area called Module III, which is due east of the
Non-contiguous Fill Area, buried drums were discovered in a
pit. The drums and contaminated soils were excavated by
Chemical Waste Management, Inc., under the supervision of
WDNR, and transported to the Adams Center Landfill in Ft.
Wayne, Indiana. Also liquid wastes from the excavation and
drums were transported to the 'SCA Incinerator in Chicago,
Illinois. The contaminated soils were excavated until
contaminant concentrations in subsequent soil samples were
below action levels established by WDNR.
3
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During the Remedial Investigation (RI), a trench was
discovered in a portion of the Non-ContiquousFill Area that
contained a large concentration of 55-gallon drums. The
boundary of this Drum Trench area was further defined using
a maqnetometer metal detector. Through a Unilateral
Administrative Order issued on January 4, 1991, U.S. EPA
ordered WNWI to remove the drums and surrounding
contaminated soils. WNWI proceedednto conduct this removal
under U.S. EPA's supervision. Excavation of the drum trench
began in April 1991 and was completed in May 1991. A total
of 989 drums were excavated along with approximately 2,500
- cubic yards of surrounding contaminated soil. The soils
were excavated down to a depth of approximately 25 feet
below the original surface elevation until ground water was
encountered.
The drum trench was re-filled to a qrade that allowed
drainage away from the area. No final soil cleanup levels
were established for this removal action since the
excavation reached qround water. Soil samples were taken in
areas above the water table at the base o~ the trench and
contamination was found to be remaining. This remaining
contamination will be addressed in this Interim Action
Source Control Operable unit (SCOU) Record of Decision
(ROD).
Below is a list of contaminants that were found from a
representative sample of liquid collected from excavated
drums on the staging pad on April 17, 1991. The list below
shows contaminants that were above detection limits. The
detection limits for all contaminants were elevated due to
sample concentrations.
Benzene
Toluene
Chloroform
Trichloroethene
Ethyl Benzene
Methylene Chloride
Some of the other contaminants that were sampled for and
found but not quantified because of elevated detection
limits include; vinyl chloride, tetrachloroethene, 1,2-
dichloroethane, and 1,1-dichloroethene. contaminants found
within the drum trench_are contaminants that are present in
monitoring wells at the site.
The liquids from the excavated drums were separated, bulked,
and disposed of through either a fuels blending program or
incineration. The soils were disposed of in a hazardous
waste cell unit at the Calumet Industrial Design Landfill
(CID) in Calumet City, IL. Solids remaining in the drums
were tested, bulked and accepted at a fuels blending
facility in April of 1992 for repackaging. The solids
totaled approximately 15 cubic yards and were then sent to a
4
-------
-
facility in Texas for incineration. The disposal procedures
occurred from October 1991 through April 1992.
C. Remedial InvestiaationfFeasibilitv Studv (RIfFS)
On September 17, 1987, WNWI signed an Administrative Order
on Consent with u.S. EPA to conduct a Remedial
Investigation/Feasibility Study (RI/FS) for the site. The
purpose of the RI is to identify sources of contamination
and to characterize the contamination at the site. The RI
is currently not finalized but ongoing results have been
periodicaliy summarized in Technical Memoranda. The Final
RI and Baseline Ri~k Assessment for the site have not been
completed, although site investigation work was completed in
September 1991. Since the Baseline Risk Assessment has not
been finalized, this Operable unit will be considered an
Interim Action Source Control Operable unit. A final remedy
will be prepared for this site that will include a Baseline
Risk Assessment.
A Source Control Operable Unit FS was prepared in September
1991. The FS provides a detailed analysis of alternatives
evaluated for this interim action operable unit. The
alternatives developed in this FS are presented in the
Description of Alternatives, section VII.
III.
COHKUlfITY PARTICIPATIOR
-
The u.s. EPA released its Proposed Plan for the Site in
- November 1991, and has made it available for public review
and co~ent. The Pro~osed Plan and supporting documents
have been made available at the information repositories at
the u.s. EPA Region V offices, the Muskego Public Library,
and the Muskego City Hall. U.S. EPA has been placing
relevant information in these repositories since 1987.
Notice of the availability of the Proposed Plan was included
in advertisements in the Muskeao Sun and Waukesha Freeman in
November 1991. Press releases were also sent to local
media. Before reaching a final decision on how the site
contamination would be addressed for this operable unit,
u.s. EPA held a public meeting on December 12, 1991 at the
Muskego City Hall. At this meeting, representatives for
u.s. EPA and WDNR answered questions about the proposed
remedy and accepted formal comments from the public on the
Proposed Plan and remedial alternatives. U.S EPA also
accepted written comments during the comment period, which
ran from November 18, to December 18, 1991. u.s. EPA, in
consultation with WDNR, has modified, in this document, the
recommended alternative described in the Proposed Plan based
on public concern. The public was mainly concerned about
ground water contamination downgradient of the site.
Therefore, this document specifies that ground water
monitoring of selected, currently existing wells will be
5
C)
-------
required until the final ground water operable unit ROD is
co~pleted. A response to all comments received during the
public comment period in contained in the Responsiveness
Summary, which is attached to this the ROD.
Other community relations activities were conducted prior to
those associated with the Proposed Plan and FS. A comment
period was held from August 28 to September 27, 1987
concerning the signing of the RIfFS consent order. Press
releases announcing this comment period were sent to local
media. A community relations plan was finalized in early
1988. A "kickoff" meeting to discuss the initiation of the
RI was held at the Muskego City Hall on Aug. 25, 1988.
Advertisements and press releases were sent to local media.
A fact sheet was developed and sent to everyone on the u.S.
EPA's mailing list. In June 1991, a press release
concerning u.S. EPA's drum removal project was issued and a
fact sheet was developed and sent to everyone on the mailing
list.
xv.
SCOPB OP XBTERXX ACTXOH SOURCB CONTROL OPERABLE UNXT
As with many Superfund sites, the problems at the Muskego
Sanitary Landfill are complex. Early site characterization
activities conducted as part of the RI identified sources of
contamination that could be addressed before full
characterization activities were complete. Therefore, to
accelerate the remediation of the sources of contamination,
u.S. EPA, in consultation with WDNR, organized the work into
two operable units (OUs). These are as follows:
Interim Action Source Control OU (SCOU): Control
and remediation of the sources of contamination, .
including landfill waste, contaminated soils, leachate
and landfill gas.
Ground Water OU (GWOU): Control and remediation of the
contamination in the ground water aquifer.
The Interim Action SCOU addresses contamination movement
into the ground water aquifer and soils from sources within
the Old, Southeast, and Non-contiguous Fill Areas. These
areas pose a threat to human health and the environment
because of the risks from possible ingestion of or dermal
contact with contaminated soils located there or possible
ingestion of or dermal contact with contaminated ground
water at private residences downgradient of the site. Based
on sampling by the u.S. EPA in August 1991, there are no
current impacts of Volatile Organic Compounds (VOCs) at
private wells downgradient of the site. However, the threat
of future private well impacts exists since downgradient
monitoring wells have shown contamination. The first
,
-------
purpose of this response is to prevent current or future
exposure to the contaminated soils and to reduce contaminant
migration into the ground water that is a current source of
drinkinq water for local residents. The second purpose of
this response is to prevent current or future exposure to
landfill qas containinq explosive and potentially toxic
contaminants and to reduce the migration of landfill qasses
to adjacent soils and structures.
The Ground Water Operable unit (GWOU) is at the FS staqe
with a ROD expected in 1993. It is anticipated that the
GWOU will be the final response action for this site and
that it will address on-site as well as off-site qround
water contamination concerns. The combination of these two
OUs is intended to address the entire site with respect to
the threats to human health identified, and to be identified
in the RI, FS, and site Baseline Risk Assessment.
v.
SXTB CBARACTBRXSTXCS-
A.
Geoloqy and Hydroqeoloqy
The site is located in an area of thick qlacial drift
overlyinq Niaqara dolomite. The drift thickness varies from
approximately 300 feet on the east edqe of the site to 50
feet at a location about 2,000 feet south of the site. The
site overlies a deep valley in the bedrock that is part of
the Troy Valley which trends to the east with a steep
bedrock slope risinq to the south.
The valley in the bedrock beneath the site is filled with
sediments consistinq of sand and gravel with a cover of
qlacial till. In qeneral, fine-qrained material (till and
lacustrine deposits) south and east of the site extend to
depths of approximately 70 to 200 feet.. Below the till is
coarse material (outwash) which extends to depths of about
200 to 300 feet below land surface.
At the northern portion of the site is the Upper New Berlin
Formation which is a till deposit forminq an east-west
trendinq moraine. The New Berlin Formation contains two
principal members, a lower sand and qravel unit and an upper
till unit. The western portion of the site consists of the
lower outwash sand and qravel unit that extends southwest
from the site toward the Fox River. The upper unit is
typically gravel, sand, loam till that averaqes about 58
percent sand, 29 percent silt, and 13 percent clay.
The sand and qravel deposits are present east of Crowbar
Road and south of the landfill access road, beneath the
western edqe of the site, and extend east to the boundary of
the basal clay under the Old Fill Area (Fiqure 2).
7
-------
Property Une ~
f~=:=ches \ /l1 --
L ~- Shaped FBI Area ~).-- Phase 1 of
A. Approximate ,,'\ / J': Separate Landfill
Basal Layer,.., \ - L__.J I
Bounda~~ n ~ . ~
/~- \ - c
:' , ',\ r Anamax .;
, ,,'\,} I I" \J Rendering 'g
I ,#' . I" Company CD
~ ( 'It Property :i:
, '''''''''''':' . .:.~,
, Old ," .. -..,
I . I
" Fill: :
\c Area' I
\ " . : Southeast a
~ \.... ~ \ ~~~ il
,.. \ I
,~ , I
.. \. ' ,
State Sand and .. -: - - - --\.,"" I ~
Property' Refuse' ~~.
\ ;. ~*,0
- 1\ ~/.; N
, ,."
FIGURE 2 . ,~
Waste Management 01
Wisconsin, Inc. Property
--
--
--
I
I
I
I
I
~
-------
-
Above the New Berlin formation is the Oak Creek Formation
which consists of a much finer textured composition of fine-
grained till, lacustrine clay, silt, and sand. This
formation on an average consists of approximately an 85
percent clay-silt composition. The western limit of the Oak
Creek Formation is the Valparaiso Moraine and ends within
the Old Fill Area. The western extent of the clay till and
other low permeability material is vertica~ly_and
horizontally irregular. As a result, its extent cannot be
accurately defined, nor can an edge of low permeability
material of constant thickness be mapped with an acceptable
degree of certainty. The approximate Basal Layer Boundary
is outlined in Figure 2.
The glacial sediments in the area are-underlain by the
Silurian-aged Niagara dolomite, at depths between 250 to 350
feet below land surface. The Niagara dolomite is
sequentially underlain by Maquoketa shale, dolomites,
sandstones, and igneous and metamorphic rocks. The
Maquoketa shale in the site area is documented by private
well logs which indicate there is about 200 feet of shale
below the Niagara Dolomite. .
The ground water flow in the site area varies in direction
due to the complex geological features. The general ground
water flow for the region is from the northeast to the
southeast. Within unconsolidated areas located a~ the
northern and western edges of the site, the ground water
- moves in a southerly direction. However the geology by the
South~ast and Old F~ll Areas consists of consolidated clay
layers. Therefore perched ground water conditions exist in
these areas. Ground water flows radially in all directions
from these areas as would be expected. (Figure 3) Ground
water from the northern portion of the site near the old
rendering plant lagoons is split by a low ground water
divide in the sand and gravel deposits. One flow path moves
generally along a Southeast route that is directed beneath
the Non-Contiguous Fill Area, the Southeast Fill Area and
the Anamax plant. The other flow path moves generally along
a southern route that is directed under the Old Fill Area.
The water table in the site area varies due to consolidated
areas, but in general is 20 to 40 feet deep. In areas where
ground water is perched or leachate is held within the basal
layer the water table is 20 to 30 feet deep.
Presently, the main aquifer in the sand and gravel unit is
currently used for private water supply downgradient of the
site in only two private residences. Public water was
provided to the site area in 1986 along Janesville Road to
_the South and Hillendale Avenue to the east, in 1986. The
8
-------
municipal well system is located a few miles east of the
site and is not near, or is it affected, by the site.
Hydraulic conductivity varies throuqhout the site dependinq
on the soil type. within the clay till, the hydraulic
conductivity ranqes from 1.6 x 10-6 centimeters per second
(cm/s) to 5.1 x 10-9 em/so However, the hydraulic
conductivity of the sand and qravel.deposits is much hiqher,
ranqinq from 3.9 X 10-2 em/ s to 1.2 X 10-3 em/ s.
B. Nature and Extent of Contamination
The RI samplinq of qround water, soil, sediment and leachate
was predominantly conducted at on-site locations, with the
exception of qround water samplinq at monitorinq wells and
private wells located off-site. samplinq was conducted for
orqanics, semi-volatile orqanics, polychlorinated biphenyls
(PCBs), and metals.
1.
Ground water
Ground water is the main pathway of concern for contaminant
miqration at the site. As mentioned above, there are two
main qround water flow paths. The first one, known as the
Southern flow path, runs from the northern section of the
site under the Old Fill Area and continues. to the south.
The second or Southeast flow path, also moves from the
northern portion of the site, but is diverted to the
southeast and flows beneath the Southeast Fill Area, the
Non-contiquous Fill Area and Anamax property. In addition,
conditions exist where leachate accumulates in areas above
these flow paths in perched or elevated conditions. (Fiqure
3)
Southern Flow Path - The Southern Flow Path is potentially
affected by the former renderinq plant laqoons, and the Old
and Non-Contiquous Fill Areas. Two rounds of qround water
samplinq occurred at 12 downqradient wells at seven
different locations. The results of the samples collected
from these monitorinq wells are summarized in Table 1;
locations of the monitoring wells are shown in Figure 4.
Orqanic contamination located in the Southern Flow Path
includes BETX (benzene, ethylbenzene, toluene, xylene),
chlorinated ethene, and chlorinated ethane qroups.
Individual chemical concentrations and well locations are
listed below.
Constituent
Concentration
Well Location
Benzene
Toluene
1 uq/L
3 uq/L
135A
123B
,
-------
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-------
TABLE 1
Orpak Group ResuIIl
Rounds. .. 2 Groa8d1'l8er Samplel
Muskeco Landml RIIFS
MONITORING ClILORINA TED CHLORINATED CHLORINATED
SAMPLE ID WELL !m. E11IENES E11IANES KETONES BENZENES PHENOlS ~ PHTHALA TES !£!!
Souahem Row Pith
Round 1
M[:OWE9S~1 E9S
ML-GWE9SP~1 EflP S
ML-GWE96~1 E96
ML.GWE96P~1 E96P
ML.GWEI23B~1 EI23B
ML.GWEI3SA.01 EmA 4 S
ML-GWEI3SB~1 EI3SB 9
ML-GWEI37A~1 E131A 6 2
ML-GWEI31B~1 EI37B 2
ML-GWEI38A.OI EI3IA
ML.GWE I3IB~1 EI38B
ML-GWP61A~1 P61A
Round 2
M[:OWE9S~2 E9S ..- NT NT NT NT
ML-GWE9SP~2 E9SP S ..- NT NT NT NT
ML-GWE96~2 E96 2 . ..- NT NT NT NT
ML-GWE96P-02 E96P I ..- NT NT NT NT
ML-GWE 123B-02 EI23B 19 2 ..- NT NT NT NT
ML-GWEI3SA-02 EmA I 4 1 ..- NT NT NT NT
ML-GWEI3SB-02 EI3SB 10 2 ..- NT NT NT NT
ML-GWEI37A.01 EI37A 6 2 ..- NT NT NT NT
ML.GWEI37B-02 EI37B 4 3 ..- NT NT NT NT
ML.GWEI38A-02 EI31A 1 ..- NT NT NT NT
ML-GWEI3IB-02 EmS ..- NT NT NT NT
ML-GWP61A-02 P61A ..- NT NT NT NT
Southeast Row Path
Round I
ML-GWE92~1 E92 3
ML-GWE92A~1 E92A 6 7
ML-GWE92P~1 E92P
ML.GWE93D~1 E93D
ML-GWE93P~1 E93P
ML.GWE94~1 E94
ML-GWE94P~1 E94P
ML-GWEI34-01 E134
ML-GWEI34A-01 EI34A
ML-GWP64C~1 P64C 7
ML-GWTW62~1 TW62
Round 2
M[:OWE9H2 E92 NT
ML-GWE92A-02 E92A 4 8 NT
ML-GWE92P-02 E92P NT
ML-GWE93D-02 E93D NT
-------
TABLEl
(COIIllaued)
Page 2 of 3
MONITORING CIIWRINATED CIIWRINA TED CHLORINATED
SAMPLE 10 I WELL ill! E11fENES ETHANES KETONES BENZENES PIIENOLS fM!! PIITIIALA TES r9!!
Soulhealt Row Pada
Round 2 (CcllllinuecI)
ML.GWE93P-02 E93P NT
ML-GWE94-02 E94 4 NT
ML.GWE94P-02 E94P NT
ML.GWEI34.02 E134 NT
ML.GWEI34A-02 EI34A NT
ML.GWP64C-02 P64C 5 .- I NT
ML.GWTW62-02 TW62 3 NT
Non-cOlltijluoul Fill Area/Anaron Facility
Round 1
M'i::=GWE97P-01 E97P 3 10
ML-GWElooA.OI ElooA IS 3
ML-GWEI02A.OI EI02A 34 5 17
ML-GWEI04.01 EI04 I 3 7 3
ML-GWEI36-01 EI36 Sl600 2970 360
ML.GWTW74R-01 1W74R II
Round 2
M'i::=GWE97P-02 E97P 4 10 NT
ML-l.WElooA-02 ElooA 19 NT
ML.' WEI02A-02 EI02A 503 10 2 NT
ML-l.WEI04-02 EI04 5 8 3 NT
ML-GWEI36-02 EI36 56300 2400 1280 NT
ML-GWTW74R-02 TW74R 1 7 9 NT
Nonhem Well.
Round 1
M'i::=GWEI7R-01 EI7R 6
ML-GWE48-01 £48
ML-GWES5-01 ES5
ML-GWE87-01 E87 3 8 7
ML-GWE90-01 E90 2
Round 2
MiAiWE 1 7R-02 EI7R 4 --. NT NT NT NT
ML-GWE48-02 E48 __8 NT NT NT NT
ML-GWES5-02 ES5 NT
ML-GWE87-02 E87 2 6 5 NT
ML-GWE90-02 E90 NT
Background WeD.
ML-GWEBO-02 E80 NT
ML-GWTW75-02 TW75 NT
-------
Table 1
(CoollDued)
Page 3 oD
NOTES:
I.
Cmcentnliom are in ua/l-
2.
Dashed Iymbob (--) indicaae CCDIpOUDdl were nOl ddeded in !he lample. The Iymbol (.) indicaaa that the c:I1Ioriaated benane conllil!lCDl1 are rOf the volatile compoundl only; lemivolatilel
were DOl analyad for in Ihae 1IIIIp1ea-
3.
NT indicalel compoundl were nOl analyzed for in lhil lample.
4.
Thil Table wa. oriainaUy Table 4-2 from !he Supplemenllo Tedmical Memonndum No. 2.
TJKJ\>Ir/JL V
Imad-403-76wl
I3S27.33
-------
Ethylbenzene
Xylene
Tetrachloroethene
Trichloroethene
1,2-0ichloroethene
Chloroethane
1,2-0ichloroethane
1,1-0ichloroethane
3 ug/L
1-13 ug/L
1 ug/L
1-3 ug/L
1-8 ug/L
2 ug/L
2 ug/L
1-5 ug/L
123B
123B, 96P
123B
123B, 135B, 138A
135A-B, 137A-B, 96
135A
135A, 137A
135A-B, 137A-B, 95P, 96
-
Semi-volatile compounds and pesticides/PCBs were not
detected in the Round I ground water samples collected from
the Southern Flow Path. Therefore, Round 2 samples were not
analyzed for these parameters.
Ground water monitoring wells were also-sampled for Target
Analyte List (TAL) metals and cyanide, and general ground
water quality indicators. These analyses were used to .
assess chemical concentration trends within the aquifer to
aid in the determination of ground water flow patterns, and
contaminant fate and migration.
There are seven TAL constituents that were detected in one
or more monitoring well sample(s) along the Southern or
Southeastern Flow Paths at levels higher than those detected
in the background wells E80 and TW75. All of these seven
were detected along the Southern Flow Path at various wells.
The constituents were as follows:
-*
*
*
Arsenic
Bar.ium
Chromium
* Lead
*_Manganese
* Nickel
* Zinc
Southeastern Flow Path - The Southeastern Flow Path which
diverts from the Southern Flow Path in the northern area of
the site, was characterized using 11 monitoring wells at six
locations. The sampling from these wells are summarized in
Table 1; locations of the monitoring wells are shown in
Fiqure 5.
There are four organic contaminant groups that were detected
on-site along the Southeastern Flow Path. These groups are
BETXs , chlorinated ethenes, chlorinated ethanes, and
phthalates. Individual concentrations and well locations
are listed below. One organic contaminant, vinyl chloride,
was found off-site, at levels in exceedance of Federal
Maximum contaminant Levels (HCLs) and WDNR Enforcement
Standards (ESs) shown in Table 2. The vinyl chloride
contamination was found during ground water monitoring
southeast of the site at Well P64C.
Constituent
Benzene
Concentration
1 ug/L
10
Well Location
92A
-------
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xylene
Tr~chloroethene
1,2-Dichloroethene
Vinyl Chloride
1,2-Dichloroethane
l,l-Dichloroethane
1 ug/L
2-3 ug/L
2-3 ug/L
5-7 ug/L
2 ug/L
6-7 ug/L
92P
92A
92A
64C
92A
92A
Additional organic compounds detected in this area include
1,2-dichloropropane from monitoring well E92A at a
concentration of 2 ug/L (Rounds 1 and 2); and methylene
chloride (a common/probable laboratory contaminant), TW62 at
a concentration of 2 ug/L (Round 1 only).
Phthalates were detected in one ground water sample from
this area during Round 1 (E92-3 ug/L), and two samples from
Round 2 (E94-4 ug/L, and TW62-3 ug/L). Constituent
compounds detected were di-n-octyl phthalate and bis (2-
ethylhexyl) phthalate.
As with the Southern Flow Path, pesticides/PCBs were not
detected in Round 1 ground water samples collected from this
area. Therefore, Round 2 samples were not analyzed for
these parameters.
There are five TAL constituents that were detected in one or
more monitoring well sample(s) along the Southeastern Flow
Path at levels higher than those detected in the background
wells ESO and TW75. These constituents are as follows:
*
*
*
Arsenic
Barium
Nickel
* Zinc
* Manganese
other areas - The Southern and Southeastern Flow Paths
described above affect well locations primarily downgradient
from the site as shown in Figures 4 and 5.
Monitoring wells are also located in the Non-Contiguous Fill
and Anamax plant areas as well as along the northern extent
of the Old.Fill Area (Figures 6 and 7). The highest
concentration of organic contamination for the site was
found at wells in the Non-contiguous Fill Area.
specifically, monitoring well E136, located in the Non-
contiguous Fill Area, was contaminated with several VOCs at
levels in exceedance of MCLs and WDHR Enforcement Standards
(ESS).
contaminant groups that were detected within the Non-
contiguous Fill, Anamax plant and northern boundary areas
include BETXs, chlorinated ethenes, chlorinated ethanes,
ketones, phenols, and polycyclic aromatic hydrocarbons
(PARs). Some of the individual concentrations and well
locations are listed below.
11
-------
Constituent
Ben~ene
Concentration
1-21 ug/L
8-12,000 ug/L
270-7,300 ug/L
5-39,000 ug/L
3 ug/L
1-7 ug/L
1-12 ug/L
Well Location
100A, 102A, 104
97P, TW74R, 87
102A, 136
102A, 136
102A, 136
17R
87, 100A, 104, TW74R
100A, 102A, 104
TW74R, 87
102A, 87
100A, 102A, 104
87, 97P
97P
136, TW74R
detected in wells
Fill Area. These
from well E17R, and
Toluene
Ethylbenzene
Xylene
Tetrachloroethene
Trichloroethene
1,2-Dichloroethene
1,2-Dichloroethane
1,1-Dichloroethane
Cbloroethane
2-Butanone
3-9 ug/L
3-8 ug/L
8 ug/L
9-2,400 ug/L
Two additional volatile compounds were
along the northern boundary of the Old
included 1,2-dichloropropane at 5 ug/L
tetrahydrofuran from E48 at 41 ug/L.
Individual semi-volatile constituent compounds included
phenol (870 ug/L), 4-methylphenol (2,100 ug/L), and
naphthalene (360 ug/L) from well E136i 4-methylphenol (5
ug/L) and benzoic acid (6 ug/L) from TW74Ri and 2,4-
dimethylphenol (2 ug/L) from E102A. Along the northern
boundary wells, only di-n-butyl phthalate was detected from
well 90 at 2 ug/L.
Pesticides/PCBs were not detected in Round 1 ground water
samples collected from these areas. Therefore, Round 2
samples were not analyzed for these parameters.
There are TAL constituents that were found in one or more
monitoring well sample(s) in these areas at levels greater
than levels found in background wells E80 and TW75. These
constituents are as follows:
*
Arsenic
*
Chromium
*
Lead
*
Manganese
Private Wells - Many of the private wells near the site have
been sampled several times during the history of operation
at the site. Sampling during pre-RIfFS activities by
WarzYn, WMWI's contractor, on May 3, 1991 and by U.S. EPA on
August 28, 1991, showed that nearby water supplies were not
currently impacted by site-related contaminants. Locations
of the nearby private wells are shown in Figure 8. All
private well sampling results are included in Appendix K of
the RI.
12
-------
,
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2.
Soil/Sediment
-
Soil samples were conducted at locations in the Old Fill
Area, Southeast Fill Area, North and South Refuse Trenches
and the Drum Trench of the Non-contiguous Fill Area (Figure
9). These samples were taken at the apparent base of fill
material in these areas to determine the effect of
contaminant movement in the soils under the waste. The soil
samples varied in depth from 20 to 40 feet below surface
- level. The samples in the Old and Southeast Fill Areas were
collected at leachate head well locations LH14, LH16, LH12,
and LH17. The six-Refuse and three Drum Trench samples were
completed after excavation to the soil beneath the waste in
these areas.
'BETX and ketones were the predominant orqanic compound
qroups detected-in the basal soil samples from the leachate
head well borinqs. The primary constituents and their
concentrations are listed below.
constituent
Benzene
Toluene
Ethylbeneze
xylene
Acetone
2-butanone
4-methyl-2-pentanone
-Isophorone
Concentration
160-13,000 uq/kq
120-130,000 uq/kq
40-24,000 uq/kq
2-100,000 uq/kq
13-7,100 ug/kg
3-13,000 uq/kq -
180-29,000 ug/kg
59-3,600 uq/kq'
Other volatile orqanics found in soil samples included:
trichloroethene (790 uq/kq) in the Drum Trench,
tetrahydrofuran (1~900 uq/kq) in the Drum Trench and (21
uq/kq) in the Refuse Trench, and chloroform (520 uq/kq and
150,000 uq/kq) in the Drum Trench.
Total phenols and PARs were the predominant semi-volatile
orqanics in the Drum and Refuse Trench Areas. In addition,
phthalates were also detected in these areas. The primary
constituents and their respective concentrations are listed
below.
Constituent
Phenol
2-Methylphenol
4-Methylphenol
Benzoic acid
Naphthalene
2-Methylnaphthalene
Phenanthrene
pyrene
Chrysene
Concentration
150-3,200 uq/kq
, 430 uq/kq
210-550 uq/kq
170 uq/kq
100-5,600 uq/kq
72-1,300 uq/kq
110 uq/kq
82 uq/kq
81 ug/kq
13
-------
Benzo (a) pyrene
Indeno(1,2,3-cd) pyrene
Dibenzo(a,h) anthracene
Benzo(q,h,i)perylene
Butylbenzyl phthalate
Diethylphthalate
Di-n-butyl phthalate
Bis (2-ethylhexyl) phthalate
110-140 ug/kq
210 ug/kg
230 ug/kg
190 ug/kg
42-1,000 ug/kg
98-150 ug/kg
86-310 ug/kg
300-440 ug/kq
PCBs were detected in one soil sample each from the Drum
Trench and North and South Refuse Trenches. Pesticides were
also detected in one or more samples from the North and
South Refuse Trenches. The constituents and their
concentrations are listed below.
Constituent
Arochlor 1242
Arochlor 1248
Arochlor 1260
4,4'-DDT
4,4'-DDE
4,4'-DDE
Concentration,
42-170 ug/kg
200 ug/kg
62 ug/kg
22 ug/kg
9.2-30 ug/kg
8.2-33 ug/kg
The only trace elements that were not within the common
,regional range for natural soils based on U.S. EPA
Publication Trace Chemical Element Content of Natural Soils
(1983) and other publications were magnesium and cadmium.
Magnesium was found in exceedance of the common range in the
-Southeast, Drum, and Refuse Trench areas. Cadmium was found
in exceedance of the ~ommon range in the Old, Drum, and
Refuse Trench areas. Nine TAL metals; aluminum, arsenic,
cobalt, copper, iron, lead, mercury, sodium, and zinc
exceeded the regional background soil levels at one or more
basal soil sample locations. '
In addition, a sediment investigation was conducted to
assess the effects of surface water runoff from the fill
areas and the Anamax property. Sampling was conducted at
various locations on and off the site. However,
concentrated efforts were conducted along a drainage swale
on the east side of the Old Fill and Southeast Fill Areas
(Figure 9). Below is a list of the constituents identified
along with concentrations and locations.
Constituent
Acetone
1,1-Dichloroethane
2-Butanone
Toluene
Phenol
4~Methylphenol
Concentration
- 180 ug/kg
11 ug/kg
53 ug/kg
2-190 ug/kg
790 ug/kg
570-960 ug/kg
14
Location
SD4
SD4
SD4
SD1, SD3, SD4, SD8
SD4
SD1, SD4
-------
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LOcations
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-------
Benzoic Acid
Naphthalene
2-Methylnaphthalene
Pyrene
bis (2-Ethylhexyl) phthalate
Di-u-butyl-phthalate
230 ug/kg
210 ug/kg
96-200 ug/kg
110 ug/kg
600-680 ug/kg
170 ug/kg
SD4
SD4
SD1, SD4
SD3
SD1, SD8
SD8
3.
Air
Ambient air, leachate head well, and gas vent vapor samples
were taken at the site during the RI. However, the results
were found to be invalid due to the exceedance of
recommended sample holding times. since the investigation
of the site began, the operator, WNWI, has agreed to
implement the Wisconsin requirement, NR 506.08 Wisconsin
Administrative Code (WAC) for landfill gas collection and
treatment and has committed to the installation of a
landfill gas management system as part of the overall remedy
for the Site. This system should control any releases to
the air from the waste material. Therefore, another round
of air-monitoring was not required by u.s. EPA at the Site.
4.
Surface Water
Topographic highs in the vicinity of the site consist of a
large end moraine north and northeast, and two topographic
highs created by the Stoneridge facility and the Southeast
Fill Area. The natural topographic high acts as a surface
water divide. The majority of the runoff from the site
flows to the southeast to two wetland areas and to an
intermittent stream. Runoff from the western portion of the
Old Fill Area flows to Crowbar Road on the west end of the
site.
Surface water is not a significant contaminant migration
pathway at the site due to the lack of permanent surface
water features and the presence of cover soils, which
generally prevent contact of surface-water runoff with
refuse. Sampling of surface water was not conducted during
the RI.
VX.
SUKKARY OP SXTB RXSKS
The comprehensive Environmental Response Compensation and
Liability Act (CERCLA) requires that u.S. EPA protect human
health and the environment from current and potential
exposure to releases of hazardous substances at or from the
site. As part of the ongoing RI/FS at the site, a Baseline
Risk Assessment is required in order to assess the current
and potential future risks from the site. The baseline risk
15
-------
assessment determines whether contamination at the landfill
could pose an unacceptable health risk or environmental risk
in the absence of any remedial action.. Potential threats to
public health are estimated by making assumptions about the
manner, frequency and length of time a person could be
exposed to site-related contaminants. However, for this
interim action operable unit the baseline risk assessment
has not been completed since the RI has not been finalized.
For the proposed SCOU, a qualitative risk assessment was
prepared consistent with u.s. EPA pOlicy, "Role of the
Baseline Risk Assessment in Superfund Remedy Selection
Decisions," dated April 22, 1991. The qualitative risk
assessment examined contaminants detected in ground water,
leachate, and soils during the field investigation phase of
the RI. These contaminants were evaluated with respect to
their carcinogenicity, toxicity, and possible exposure
pathways from and at the site.
The following is a representative list of contaminants
detected in ground water, leachate, sediment, and soil at
and near the site:
Acetone
2-Butanone
2-Hexanone
Tetrahydrofuran
1,4-Dichlorobenzene
2-Methylphenol
4-Methylphenol
Pentachlorophenol
Phenol
Benzoic Acid
Benzene
Ethylbenzene
Toluene'
Xylenes
Chloroethane
l,l-Dichloroethane
1,2-Dichloroethene
Styrene
Dichloropropane
Trichloroethene
Vinyl Chloride
Bis(2-ethylhexyl)phthalate
Mercury
Butylbenzylphthalate
Diethylphthalate
di-n-octylphthalate
PCBs
Arsenic
Barium
Cadmium
Chromium
Copper
Cyanide
Lead
Nickel
Zinc
The sand and gravel aquifer in the immediate area of the
landfill is contaminated. The potential exists for this
contamination to move with ground water flow toward private
residences.
Exposure to landfill gas, through either methane migration
in the soils or VOC migration in the air, is a concern at
the site. Inhalation of landfill gas is of concern due to
the potential presence of unacceptable levels of VOCs that
may cause a health risk. A potential health risk would
. exist until landfill gas controls are installed and
operating to adequately manage potential exposure. WMWI has
l'
-------
committed to managing landfill gas at the site in accordance
with Wisconsin Administrative Code NR 506.08(6).
Direct exposure to contaminated soil or waste is currently
not a concern at the site. All fill areas are covered by at
least one foot of soil to limit the exposure potential.
However, future exposure may be a concern if the cover is
not adequately improved and maintained.
Continued leachate generation and the resulting additional
ground water contamination is another potential concern at
- th~ site. Private wells to the Southeast and South of the
site were sampled by u.S. EPA for VOCs in August 1991, but
no contamination was detected. Although most potential
receptors of contaminated ground water are now on public
drinking water supplies, some downgradient residents are
still using private wells that may become impacted by site-
related ground water contamination. Elevated leachate
levels in the Old, Southeast and Non-Contiguous Fill Areas
will result in continued ground water contamination until
leachate generation is adequately controlled or most of the
contaminants have been leached from the waste.
Of the chemicals in ground water, those with exceedances of
Safe Drinking Water Act or WDNR NR 140 WAC ground water
drinking standards are shown in Table 2. This Table
compares the maximum ground water concentrations in the
immediate' landfill area with the MCLs, ESs and WDNR NR 140
Preventative Action Limits (PALs).
Based on toxicological studies, benzene and vinyl chloride
are classified as u.S. EPA Group A - human carcinogens;
while trichloroethene, tetrachloroethene and
pentachlorophenol are classified as Group B2 - probable
human carcinogens. Pending completion of the complete
baseline risk assessment, exceedances of drinking water
standards alone justify the interim action operable unit
remedial action. Actual or threatened releases of hazardous
substances from this site, if not addressed by implementing
the response action selected in this ROD, may present an
imminent and substantial endangerment to public health,
welfare, or the environment.
VII. DBSCRIPTIOH OF ALTBRHATIVES
A.
Remedial Action Objectives
Upon completion of the first phases of investigation work at
the site, remedial action objectives were developed that
address the source areas while considering the long-term
goals of protecting human health and the environment and
17
-------
I
I
Table 2
NR 140 and EPA MCL EXCEEDANCES FOR GROUND WATER
UG/L (unless otherwise noted)
Chemical Maximum NR 140 NR 140 40 CFR
Compounds Concentration Enforcement Preventive Part 141
Standard Action MCL
Limit
VOCs
Vinyl" Chloride 7.00 .2 .0015 2
1,2 Dichloroethane 9.00 5 .05 5
Trichloroethene 7.00 5 .18 5
Benzene 21.00 5 .067 5
Tetrachloroethene 1.00 1 .1 5 (ptq)OSed)
Toluene 12000.00 343 68.6 1000
I
Ethylbenzene 7300.00 1360 2720 700
Xylenes (total) 39000.00 620 124 10000
Tetrahydrofuran 41.00 50 10
Chloroform 1.00 6 .6
-------
Table 2
NR 140 and EPA MCL EXCEEDANCES FOR GROUND WATER
UG/L (unless otherwise noted)
. Chemical Maximum NR 140 NR 140 40 CPR
Compounds Concentration Enforcement Preventive Part 141
Standard Action MCL
Limit
SVOCs
pentachlorophenol 4.00 300 30 1
Dissolved Metals
Arsenic 25.90 50 5 50 SMCL
Barium .708 mg/l 1. 0 mg/l .2 mg/l 2.0 mg/l
(prqJOSed)
Cadmium 11.70 10 1.0 5
Chromimum, total 133.00 50 5 100
Iron 50300.00 mg/l .30 mg/l .15 mg/l .3 nq/l EKL
Lead 5.20 50 5 15 SMCL
Manganese 4560.00 50 25 50 SMCL
.Seleni~m 34.00 10 1 50
silver 41 50 10 100 SMCL
SMCL - Secondary Maximum contaminant Level
-------
meeting applicable or relevant and appropriate requirements
(ARARs). Site-specific goals of limiting the potential for
the release of contaminants to the ambient air, sub-waste
soils, and ground water include the following:
.
Minimize the migration of chemical constituents from
soil/refuse transported by leachate to ground water
that would contribute to ground water concentrations in
excess of MCLs, ESs and PALs beyond the waste boundary;
Control the seepage, migration and concentration of
landfill gas generated by the refuse in the Old,
southeast, and Non-Contiguous Fill Areas, and in the
soils or air at or beyond the property boundary;
.
.
Minimize hazardous air contaminants that may be emitted
from the Old, Southeast and Non-contiguous Fill Areas,
and comply with applicable air pollution control
standards; and
Minimize the potential for human exposure to waste and
contaminated soils and for release of contamination to
the environment.
.
Since this interim action operable unit addresses source
control, site-specific cleanup standards for soils and
ground water will not be necessary for the Old and Southeast
Fill Areas, where containment provides the primary source
control. However, a performance-based cleanup standard,
which accounts for and incorporates ground water standards
will be established for soils in a portion of the Non-
Contiguous Fill Area, where the source area will be treated
as well as contained. A cleanup standard would be
established because of the more concentrated nature of the
hazardous materials located in this specific area.
The performance-based cleanup standard would be applied to
the area covered by the in-situ vapor extraction (ISVE)
system. The cleanup standard will be based on residual
soil-gas concentrations that are low enough to assure
compliance with ground water cleanup standards, which will
be specified in more detail (including compound specific
standards) in the ROD for the GWOU for the Site. The
relationship between soil-gas VOC concentrations and ground
water VOC concentrations would be modeled to determine the
concentration of VOCs in the waste/subsoil that must be
achieved in order to assure that, even if the remaining VOCs
leach into ground water, the level of VOCs in the ground
water will not exceed levels that are protective of human
health and the environment. The model will incorporate data
collected during a pilot-scale test, and the first two-year
period of full-scale ISVE operation, as well as previous
18
-------
sampling and monitoring data collected at the site. In
accordance with the National contingency Plan (NCP)
S300.430(f) (5) (iii) (A), if waste is left in place at the
conclusion of a response action, the specified ground water
clean-up standards should be attained at the points of
compliance identified in the GWOU ROD.
The ISVE system will operate until the concentration of VOCs
in the waste/subsoil calculated by the model is achieved.
This methodology would be superior to setting numerical
reduction rates, based upon the percentage of VOC removal
- from the soil, because it directly corresponds to achieving
ground water cleanup levels.
B.
Development of Alternatives
Alternatives developed in the FS for the SCOU considered the
Old, Southeast, and Non-contiguous fill areas. As stated
above, the remedial action objectives involve controlling
landfill leachate and gas, limiting the potential for
exposure to contaminants via inhalation, ingestion, and
dermal absorption pathways, and minimizing impacts. to ground
water.
In developing alternatives, the FS takes into consideration
previous removal work that has occurred. The remedial
alternatives were assembled from applicable remedial
technology options. The alternatives surviving the initial
screening were evaluated and compared with respect to the
nine criteria required by the NCP. In addition to the
remedial action alternatives, the NCP requires that a no-
action alternative also be considered for the site. The no-
action alternative serves primarily as a point of comparison
for other alternatives.
Two general strategies have been utilized to accomplish the
remedial action objectives for the source control portion of
this site. The first strategy is to control the production
of gas and leachate while minimizing potential exposure to
waste or contaminated soil. The second is to manage gas and
leachate after production. These strategies are evident
within the forthcoming alternative descriptions.
C.
Alternatives
Alternative 1 - No Action
Under Alternative 1 no additional corrective action would be
taken at the site to address sources or potential sources of
ground water contamination or direct contact threats. The
limited removal of leachate by WNWI from the Southeast Fill
l'
-------
Area would continue utilizing the current method of pumping
from a portion of the existing collection system directly to
the sanitary sewer. .
-
Under a no-action scenario, contamination from the source
areas in leachate or soils would not be prevented from.
reaching the ground water aquifer. This would result in
continued off-site migration of contaminants i~ the ground
water. Also, gas and air contamination would continue to
migrate through soils off-site and/or into the atmosphere.
Finally, the current cover over the source areas would
degrade due to freezing and thawing. This would result in
greater percolation of rainwater and more likelihood of
contaminant transfer into the ground water.
A no-action remedy would allow the site to remain as it
exists today with an incomplete fencing structure around the
site. Therefore, direct contact to soils would be a greater
likelihood for workers at the stoneridge Recycling facility
and trespassers. There would be no capital or operational
costs associated with this alternative.
Alternative 2 - Limited-Action
The Limited-Action Alternative involves implementing
measures to restrict access to the site and monitor gas
migration. Site controls include a fence extension and deed
restrictions for the site. Fencing would be extended across
-into the Anamax property to complete the enclosure of all
fill ar~as and the wa~tewater ponds. Landfill gas
monitoring would also be a component of this alternative to
determine compliance with solid waste regulations.
As in the No-Action Alternative, this remedy would not
prevent contamination currently in leachate or soils from
reaching the ground water aquifer through percolation or
direct leaking. This alternative also does not address the
prevention of gas migration through soils nor does it
prevent the current cover degradation through freeze-thaw
cycles.. . 0
The limited-action scenario would deter direct contact to
contaminated soils with the installation of a fence. In
addition this action would hinder premature destruction or
disturbance of the current cover. The current cover does
not contain any freeze-thaw protection layer of soil on top
of the clay. This allow~ the clay laye~ to expand and
contract from freezing conditions.
Capital cost for this alternatvie would be seventeen
thousand four hundred dollars ($17,400). There would be no
operational or maintenance costs.
20
-------
Alternative 3 - CaDDina and Landfill Gas and Leachate
Control
Alternative 3 consists of seven major components. The first
three: deed restrictions, fence extension, and landfill gas
monitoring and control are the same as Alternative 2. The
additional four components are:
.
.
Cap installation over the Old and Southeast Fill Areas
in accordance with NR 504 WAC;
Landfill leachate control in the Old Fill Area;
Improvement of the existing leachate control system in
the Southeast Fill Area; and
Active landfill gas control in the Old and Southeast
Fill Areas.
.
.
The first additional element of this alternative requires
that a new soil cover system (cap) meeting the standards of
section 504.07, WAC be constructed over the Old and
Southeast Fill Areas. The cap would have the following
profile (listed from the ground surface, downward):
A minimum 6-inch topsoil layer;
A minimum ls-inch to 30-inch thick rooting zone layer
(exact thickness determined during the design); and
A minimum 24-inch thick compacted clay layer, having a
maximum hydraulic conductivity of lxlO-7 em/s.
A new cap may involve reusing (Le., picking up and
replacing) existing cover materials that meet the standards
specified in Chapter NR 504, WAC presently covering the Old
and Southeast Fill Areas. If existing material is not to be
reused, or is insufficient, then new material will be
brought in to cover the existing fill areas. The cap would
be installed to meet minimum slope requirement specified in
section NR 506.0S(3) (c), WAC.
.
.
.
The second additional requirement of Alternative 3 entails
the installation of a leachate control system over the Old
Fill Area. Monitoring for the presence of leachate will be
conducted as part of the installation of gas collection
wells at the base of refuse. In areas of sufficient
leachate levels, gas collection wells may be retrofitted for
leachate collection. Collection wells will be installed to
the base of the refuse and spaced appropriately, as
determined in the remedial design, for leachate extraction.
At that time, it will be determined by u.S. EPA, in
consultation with WDNR, whether additional wells shall be
constructed to increase' leachate collection.
The existing leachate collection at the Southeast Fill Area
is intermittent. The third additional portion of
21
-------
Alternative 3 would increase the effectiveness of leachate
extraction by increased or maximized use of the current
system and installation of additional extraction wells
using the same procedure as in the Old Fill Area.
Collection wells would be installed to the base of the
refuse and spaced appropriately to influence and collect
leachate from all areas where leachate can collect or build
up (i.e., create a head of leachate). The exact design and
spacing will be determined in the remedial design. The
determination of the final configuration of wells would be
made by u.s. EPA, in consultation with WDHR, during the
remedial design activities.
The leachate extraction systems would be operated to
maximize the amount of leachate withdrawn and minimize to
the extent practicable, the amount of leachate accumulated
on the base of both fill areas.
Leachate and gas system con~ensate will likely be discharged
to the sanitary sewer, provided pretreatment standards are
met. It may be necessary to pretreat leachate before sewer
discharge to meet pretreatment standards. Leachate may be
treated along with groundwater as part of the subsequent
GWOU. Effluent limits for possible discharge of treated
ground water/leachate to surface and/or ground water will be
determined for that action, if necessary. Sludge/residual
from treatment/pretreatment may have to be managed as a
hazardous waste if shown to be a Toxicity Characteristic
Leaching Procedure (TCLP) characteristic hazardous waste.
Wastes excavated or generated by the installation of
extraction systems (i.e., drill spoils)," may have to be
managed as a hazardous waste if shown to be a TCLP
characteristic hazardous waste. Sludge/residuals and/or
other "excavated/generated wastes, if shown to be a non-
hazardous waste, may be managed at a solid waste landfill.
The Land Disposal Restrictions (LDRs) woulu apply to any
TCLP hazardous waste that is to be disposed of (i.e.,
placement of the waste occurs) on or off site. certain non-
liquid excavated/generated wastes may be re-buried at the
site, in an appropriate location selected during the RD
(likely at the Southeast Fill Area), under the new cover
system when it is constructed. This would include some of
the investigation-derived wastes now being stored in
containers at the site. u.S. EPA has determined that such
re-burial would not constitute placement, and would not
trigger the LDRs. U.S. EPA has also determined that the
substantive analysis required under the Wisconsin pOlicy
"Interim Policy (Guidelines) For Promoting In-State and On-
site Management of Hazardous Waste in the State of
Wisconsin" should be performed for the management of any
hazardous wastes from the Site. It may be possible to treat
22
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TCLP hazardous waste so it no longer shows the
characteristic and manage it as a non-hazardous waste.
The final additional segment of Alternative 3 is an active
landfill gas control system in ,the Old and Southeast Fill
Areas. This system would work in conjunction with the
leachate collection system to extract landfill gases in the
Fill Areas. The extracted landfill gas would be destroyed
by a ground flare consistent with Wisconsin NR 445 WAC
requirements.
-Alternative 3 is composed of several segments that address
actual or potential contaminant migration from the Old 'and
Southeast Fill Areas. Alternative 3 addresses, through
containment and treatment, the reduction of contamination
and the prevention of human exposure to contaminants.
The NR 504 WAC cap will reduce the percolation of rain water
through contaminated waste material and into the ground
water by providing an impermeable layer above the waste
material. This decreased permeability will contain
contamination within the Fill Areas and help prevent
migration off-site. The cap will also provide added
protection from direct contact by adding additional cover
material. Added cover will also be installed to protect the
cap integrity from freeze-thaw cycles consistent with the
region's weather.
The installation of a gas extraction system would directly
reduce and treat, through thermal destruction, landfill gas
contaminants. The gas extraction system will also reduce
the chance of cap cracking caused by internal,pressure from
gas formation.
Alternative 3 addresses contamination problems in the Old
and Southeast Fill Areas but does not address contamination
in the Non-contiguous Fill Area except to the extent that
area is included in the fencing and deed restrictions.
The capital cost for this alternative is estimated to be
seven million dollars ('7,000,000). The operation and
maintenance costs for Alternative 3 are one million seven
hundred thousand dollars ($1,700,000).
Alternative 4 and Modified Alternative 4 (The Selected
R;~edv} - Cannina. Landfill Gas and Leachate Control. and
i~-situ Treatment of nortions of the Non-Contiauous Fill
~
Alternative 4 consists of all of the components contained in
Alternative 3 with the addition of the following:
23
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.
Installation of a Wisconsin HR 504
contiguous Fill Area; and
In-Situ Vapor Extraction (ISVE) in
Fill Area
cap over the Non-
.
the Non-contiguous
Modified Alternative 4 (the selected remedy) is the same as
Alternative 4, with the addition of:
.
A qround water monitorinq proqram conducted at
selected existinq monitorinq and private wells
by u.S. EPA, in consultation with WDHR, durinq
Desiqn (RD) and after implementation.
approved
Remedial
Alternative 4 is composed of several seqments that address
actual or potential contaminant miqration from the "Old,
Southeast, and Non-Contiguous Fill source areas. "
Alternative 4 addresses, throuqh containment and treatment,
the reduction of contamination and the prevention of human
exposure.
The HR 504 WAC cap will reduce the percolation of rain water
throuqh contaminated waste material and into the qround
water by providinq an impermeable "layer above the waste
material. This decreased permeability will contain
contamination within the Fill Areas and help prevent
miqration off-site. In addition, the decreased permeability
will increase the ISVE zone of influence and theref~re the
effectiveness of this system. The cap will also provide
-added protection from direct contact by utilizinq added
materia~ cover. Added cover will also be installed to
protect the cap from loss of integrity caused by the effect
of freeze-thaw"cycles on the soil.
ISVE in a portion of the Non-Contiguous Fill Area involves
the installation of qas extraction wells connected to a
blower by a qas header pipe system. The number of wells and
well locations will be determined by a pilot test conducted
durinq the Remedial Design (RD). Extracted gas would be
treated, if necessary, by removal throuqh activated carbon
or thermal destruction with catalYtic oxidation or other
treatment method to be determined during design, and emitted
to the atmosphere. Extracted vapor may be combined with
existinq and proposed landfill qas collected on the
property, and treated by thermal des~ruction in the form of
flarinq. Any condensate qenerated by the ISVE system would
be managed with the leachate (see the leachate management
discussion in the description of alternative 3, above).
Alternative 4 addresses contamination problems in all of the
source areas.
24
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The selected remedy includes ground water monitoring to be
completed at locations specified during the RD by u.s. EPA,
in consultation with the WDHR. This ground water monitoring
will be performed to contribute to the definition of the
contamination plume and to measure the effectiveness of the
implementation of the interim remedial measures. The
program will include, at a minimum, semi-annual monitoring
for Chapter HR 508 WAC indicator parameters and VOCs at low
detection limits in selected monitoring wells along the
south and southeast portions of the site, in a selected
background monitoring well, and in selected private wells.
The monitoring and private wells would be selected based on
well location, depth, past monitoring results, construction,
etc. This alternative is the most comprehensive cleanup
remedy of all of the alternatives.
Costs for Alternative 4 or the selected remedy would be
approximately the same with slight variance in comparison to
the capital and operational costs. The capital costs for
Alternative 4 or the selected remedy are eight million
dollars ($8,000,000). The operation and maintenance costs
are one million nine hundred thousand dollars.
VIII.
SUHIIARY 01' COMPARATIVB AllALYSIS 01' ALTERHATIVBS
A.
Introduct!Qn
u.S. EPA has established nine criteria that balance health,
technical, and cost considerations to determine the most
appropriate alternative. The criteria analyze the selected
remedy so that the remedy is protective of human health and
the environment, attains ARARs, is cost effective, and
utilizes permanent solutions and treatment technologies to
the maximum extent practicable. The remedial alternatives
developed in the FS have been evaluated and compared using
the nine criteria set forth in the NCP. The nine criteria
are set forth by u.S. EPA under NCP 300.430(e) (9) (iii).
These nine criteria are summarized as follows:
OVERALL PROTECTIOII 01' PUBLIC HEALTH AIID THB BllVIRONKD1T
addresses whether a remedy provides adequate protection of
human health and the environment and describes how risks are
posed through each exposure pathway are eliminated, reduced,
or controlled through treatment, engineering controls, or
institutional controls.
COKPLIUCB WITH APPLICABLB OR RBLBVAIIT AIID APPROPRIATB
REQOIREHBIITS (BAR.) addresses whether a remedy will meet
all other Federal and State environmental statutes and/or
provides grounds for invoking a waiver.
25
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LONG-TERK BPPECTIVEHESS AND PBRKAHEHCB refers to the ability
of a remedy to maintain reliable protection of human health
and the environment over time, once cleanup standards have
been met.
REDUCTION OP COHTAHINAHT TOXICITY, MOBILITY, OR VOLUME
through treatment is the anticipated performance -of.. the
treatment technologies a remedy may employ.
SHORT-TERK BPPECTIVEHESS addresses the period of time needed
to achieve protection, and any adverse impacts on human
health and the environment that may be posed during the
construction and implementation period, until cleanup
standards are achieved.
IKPLEMENTABILITY is the technical and administrative
feasibility of a remedy, including the availability of
materials and services needed to implement a particular
option.
COST includes estimated initial capital, operation and
maintenance (O&M) costs, and net present worth costs.
STATB ACCBPTANCE indicates whether, based on its review of
the RIfFS and Proposed Plan, the State concurs with,
opposes, or has no comment on the preferred alternative at
the present time.
COKHUHITY ACCBPTANCB is based on comments received from the
public during the public comment period. These comments are
assessed in the responsiveness sUmmary attached to this ROD.
B.
Remedial Alternatives for Source Control
The following briefly describes how the selected alternative
for source control compares to other alternatives using the
nine criteria. .
1. Threshold Criteria
The two most important criteria are statutory requirements
that must be satisfied by any alternative in order for it to
be eligible for selection. These two criteria are discussed
below.
a. OVBlU\LL PROTECTION OP BUIIUI 1IBAL'l'B AHD THB DVIROIDlDJ'l
Alternatives 1 and 2 are not sufficiently protective of
human health and the environment due to the continuing
2'
-------
potential exposure to waste and contaminants and continued
ground water contamination.
Alternative 3 is more protective of human health and the
environment than Alternatives 1 & 2. The combination of
institutional controls, capping and leachate/landfill gas
controls effectively protect potential receptors from
landfill contaminants as long as these systems are
maintained. However, Alternative 3 is not very effective in
controlling the sources of contamination in the Non- .
Contiguous Fill Area, where high levels of soil and ground
-water contamination are known to exist. Under alternative
3, this Area would continue to be a source of soils and
groundwater contamination.
Alternative 4 provides additional protection by upgrading
the cap and providing ISVE extraction for the Non-Contiguous
Fill Areas. These additional measures will reduce the
future potential for further soil and ground water
contamination i~, and arising from, this area.
The selected alternative adds a final element of
protectiveness beyond what Alternative 4 provides by
routinely sampling residential and monitoring wells most
likely to be affected by contamination at the site.
b.
COKPLXAHCB WXTB APPLXCABLB OR RBL~ AND APPROPRXATB
RBQUXRBIU!:JITS (ARARs)
The site was never an operating Resource Conservation and
Recovery Act (RCRA) facility. site records do not
conclusively demonstrate that the materials disposed of at
the site during its operation were listed RCRA hazardous
wastes. Therefore, RCRA closure requirements would not be
applicable at this site. RCRA Land Disposal Restrictions
(LDRs) are none the less applicable to the management of
treatment residues and/or any other wastes managed as part
of remedy implementation that are found to be characteristic
hazardous wastes and are disposed of through placement of
the waste on or in the land, on or off site.
-
Alternative 1 and 2 do not meet current state and Federal
landfill closure requirements, which are applicable to this
site.
Under NR 506.08(06) WAC, landfills containing over 500,000
cubic yards of waste that accepted municipal solid waste
must have an active landfill gas recovery system to
effectively control emissions of hazardous air contaminants
to the air. Alternatives 3 and 4 include active landfill
gas control systems that comply with those requirements for
27
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controlling methane migration and controlling emissions of
hazardous landfill gas constituents.
The improved cap and additional leachate collection system
in Alternatives 3 and 4 comply with Wisconsin solid waste
closure (NR 506.08 WAC), ground-water quality requirements
(NR 140 WAC), and landfill cover system design criteria (NR
504.07 WAC). Under Section NR 506.08(03) WAC, 4 site with
chapter NR 140 WAC ground water standard exceedances is
required to install a cover system meeting the standards in
section NR 504.07, if such a system is necessary to abate
such exceedances. -The ISVE system in Alternative 4 will
likewise be designed to meet ARARs. The ISVE cleanup
standards will be developed in conjunction with the
identification and compliance with ground water ARARs as
part of the GWOU remedy.
2.
Primary Balancing criteria
Five primary balancing criteria are used to identify major
trade-offs between the remedial alternatives which satisfy
the two threshold criteria. These trade-offs are ultimately
balanced to identify the preferred alternative and to select
the final remedy. Because Alternatives 1 and 2do not
satisfy the threshold criteria, they will not be evaluated
by the primary balancing criteria.
-a.
LOBG-TERK El'I'BCTlVEBBSS AI1D PBlUIABBBCB
Alternatives 3 and 4 and the selected remedy provide
controls for a permanent and effective source control
remedy. .
Alternative 4 and the selected remedy provide good control
of potential exposure to waste contaminants or continued
leaching of waste contaminants by treating soils in the Non-
Contiguous Fill Area, capping all identified source areas,
and providing leachate and landfill gas controls in the
landfill areas. The selected remedy provides additional
assurance of lonq-term effectiveness by monitorinq nearby
wells. . Capping and leachate/landfill gas controls in
Alternative 3 provides adequate controls for the areas
addressed, but may provide less long-term effectiveness than
Alternative 4 because it does not address the Non-Contiguous
Fill Area. Institutional Controls and O&M further reduce
the risks from direct contact under all alternatives.
28
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b.
RBDUCTZOB ZB TOZZCZTY, KOBZLZTY, OR VOLUHB THROUGH
TRBATXDJ'l'
Due to moist conditions in a portion of the Old and
Southeast Fill Areas, the waste is being reduced in volume
through biodegradation. However, biodegradation would not
significantly reduce contamination and the time frame and
uncertainties for such reductions would be much greater than
for implementing a remedy.
Alternatives 3 and 4 and the selected remedy will reduce the
toxicity, mObility, and volume of methane and other VOCs in
the subsurface through actively extracting and treating
landfill gas.
Alternatives 3 and 4 wil~ reduce the mobility and volume of
leachate in the Old and Southeast Fill Areas by extracting
leachate through a series of wells and constructing a
low-permeability cap~ The described cap option would allow
some infiltration to enter the landfill, which will aid the
natural biodegradation occurring within the landfill and
reduce the time until the refuse is stabilized. The
collected leachate will receive appropriate treatment and be
properly disposed.
In addition, Alternative 4 and the selected remedy would
also reduce the mObility and volume of VOCs at the
Non-Contiguous Fill Areas using ISVE. VOCs in the
surrounding soils would be extracted through wells
in the unsaturated zone and treated, if necessary,
ground.
waste and
screened
above
c.
SHORT-TERM E~~ECTZVBHESS
None of the alternatives would pose a substantial risk to
the community, workers, and environment during remedial
actions. Precautionary actions, through the remedial action
health and safety plan, would address risks to on-site
workers and potential off-site risks.
Capping, installation of a landfill leachate and gas
extraction system, and installation of an ISVE system can be
accomplished in one construction season. The risks of
construction activities for Alternatives 3 and 4 and the
selected remedy are adequately managed through dust
suppression and the use of personal protective equipment for
. construction workers. The need for leachate extraction may
decrease since the improved caps should result in reduced
leachate generation.
2'
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d.
IKPLEKBHTABILITY
Implementation for any of the alternatives should not be
difficult. Capping with an NR 504 WAC cap, a component of
Alternatives 3 and 4, would be the most extensive remedial
measure but still not difficult to implement, because this
type of cap is common at Superfund and. landfill sit~s.
A leachate extraction system, combined with an active
landfill gas collection system, a component of Alternatives
3 and 4, is common at landfills. Implementation should not
be difficult.
ISVE is also becoming a common cleanup technology at various
Superfund sites and implementation would be technically
practical. Although ISVE is a relatively new technology
when specifically being implemented in a non-homogeneous
landfill mass, this should not impede the implementation
since a similar technology1s being applied at the Hagen
Farm Superfund site in Wisconsin.
Implementability of institutional controls should not be
difficult because no significant off-site controls should be
necessary.
8.
COSTS
The estimated costs of the four FS alternatives are listed
below. The first column list the capital or construction
costs for the project. The second column are the costs to
operate the remedial system once it is constructed. The
final column is the sum of the first two columns.
1.
2.
3.
4.
CaDital Cost
o
$17,400
$7.0 mil
$8.0 mil
O&M
o
o
$1.7-2.6 mil
$1.9-2.8 mil
Total Cost
o
~17,400
$8.7-9.6 mil
$9.9-10.8 mil
The selected remedy adds monitoring costs of approximately
$20,000 to Alternative 4, 'but is in every other way
identical. A range is given in the Total Cost figures to
account for a 5' and 10' discount rate. The higher cost
figure corresponds to the lower discount rate. The
operation and maintenance for these alternatives is 30
years. In addition, capital Cost figures are based on
construction beginning immediately. The vast majority of
these cost will not actually be incurred until after
Remedial Design is completed. A more detailed description
of the costs for Alternative 4 is provided in Table 3.
30
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DISCOUNT DISCOUNT DISCOUNT
TOTAL RATE: NET RATE ": NET RATE: NET
I
CAPITAL O&M ANNUAL 10% PRESENT 5% PRESENT 3% PRESENT
YEAR COSTS COSTS COSTS PIW FACTOR WORTH PIW FACTOR WORm PIW FACTOR WORTH
o 7,984,000 7,984,000 1.00000o 7,984,000 1.00000o 7,984,000 1.00000o 7,984,000
1 309,500 309,500 0.909091 281,364 0.952381 294,762 0.970874 300,485
2 309,500 309,500 0.826446 255,785 0.907029 280,726 0.942596 291,733
3 309,500 309,500 0.751315 232,532 0.863838 267,358 0.915142 283,236
4 I 309,500 309,500 0.683013 211,393 0.822702 254,626 0.888487 274,987
5 309,500 309,500 0.620921 192,175 0.783526 242,501 0.862609 266,977
6 134,200 134,200 0.564474 75,752 0.746215 100,142 0.837484 112,390
7 134,200 134,200 0.513158 68,866 0.710681 95,373 0.813092 109,117
8 134,200 134,200 0.466507 62,605 0.676839 90,832 0.789409 105,939
9 134,200 134,200 0.424098 56,914 0.644609 86,507 0.766417 102,853
10 134,200 134,200 0.385543 51,740 0.613913 82,387 0.744094 99,857
11 134,200 134,200 0.350494 47,036 0.584619 78,464 0.722421 96,949
12 134,1200 134,200 0.318631 42,760 0.556837 74,728 0.701380 94,125
,3 134,200 134,200 0.289664 38,873 0.530321 71,169 0.680951 91,384
14 134,200 134,200 0.263331 35,339 0.505068 67,780 0.661118 88,722
15 134,200 134,200 0.239392 32,126 0.481017 64,552 0.641862 86,138
16 134,200 134,200 0.217629 29,206 0.458112 61,479 0.623167 83,629
17 134,200 134,200 0.197845 26,551 0.436297 58,551 0.605016 81,193
18 134,200 134,200 0.179859 24,137 0.415521 55,763 0.587395 78,828
19 134,200 134,200 0.163508 21,943 0.395734 53,107 0.570286 76,532
20 134,200 134,200 0.148644 19,948 0.376889 50,579 0.553676 74,303
21 134,200 134,200 0.135131 18,135 0.358942 48,170 0.537549 72,139
22 134,200 134,200 0.122846 16,486 0.341850 45,876 0.521893 70,038
23 134,200 134,200 0.111618 14,987 0.325571 43,692 0.506692 67,998
24 134,200 134,200 0.101526 13,625 0.310068' 41,611 0.491934 66,018
25 134,200 134,200 0.092296 12,386 0.295303 39,630 0.471606 64,095
26 134,200 134,200 0.083905 11,260 0.281241 37,143 0.463695 62,228
27 134,200 134,200 0.016218 10,236 0.261848 35,945 0.450189 60,415
28 134,200 134,200 0.069343 9,306 0.255094 34,234 0.431077 58,656
29 134,200 134,200 0.063039 8,460 0.242946 32,603 0.424346 56,947
30 134,200 134,200 0.057309 1,691 0.231377 31,051 0.411987 55,289
TOTAL: $9,914,000 TOTAL": $10,806,000 TOTAL: $11,417,000
VARIANCE: -8% VARIANCE: 0% VARIANCE: 6%
NOTE: "Superfund program RifFS guidance recommends that a dlscounl rate of 5°.41 before taxes and after Inflation be
assumed, as shown In the center column. The PAPs used 10% In the FS Report, as shown In the first column.
Totals shown are rounded to the nearest $1,000.
MUSKEGO SANITARY LANDFill
ALTERNATIVE 4: CAPPING, LANDFILL GAS & lEACHATE CONTROL,
AND IN-Snu TREATMENT OF THE NON-CONTIGUOUS FILL AREAS
Table 3
-------
3.
Modifying criteria
a.
STATB ACCEPTANCB
The WDNR has been the support agency for the RIfFS and has
reviewed this ROD. The WDNR concurs with the selected
remedial action. In addition, the WDNR does not feel that
Alternatives 1 through 3 are protective or would attain
ARARs; therefore, these alternatives are. not acceptable to
the State. .
b.
COHHUBZTY ACCEPTANCB
Comments have been submitted by the community, local
government officials, and potentially responsible parties
(PRPs). In general, issues presented in the comments were
directed toward the inclusion of ground water monitoring for
the final remedy, and a delay in the capping of the
Southeast Fill Area. Comments and responses to those
comments are described in greater detail in the
Responsiveness Summary attached to this ROD.
C.
Summary
Based on a comparison of the nine criteria, Alternatives 1
and 2 do not provide protection from all of the potential
risks at the site and do not comply with ARARs. They .
therefore do not meet the threshold test for selection of a
-remedy alternative at the site. Alternative 3 would be
protect~ve for a portion of the source areas of the site,
but would not provide protection from all of the potential
risks at the site either. Alternative 4 would be protective
of human health and the environment with respect to all
source areas and would attain ARARs. The selected remedy
adds a final element of protectiveness by periodically
monitoring those existing wells more likely to provide
potential representation of ground water contamination.
Alternative 4 and the selected remedy provide the greatest
degree of long-term effectiveness and permanence because
they provide the greatest degree of remediation and
containment of the contaminants. The selected remedy adds a
monitoring program to help provide assurance of long-term
effectiveness. Alternatives 3, 4 and the selected remedy
provide reduction of toxicity through destruction and
treatment of contaminants, but Alternative 4 and the
selected remedy encompass-all source areas and utilize ISVE.
Implementation for any of the alternatives is not expected
to pose any technical problems since similar remedies have
b~en selected and constructed at other Superfund sites.
31
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Alternatives 3 and 4 are more costly due to the scope of the
wo~k performed under each. Alternative 4 and the selected
remedy are the most costly because they encompass capping
and ISVE at the Non-contiguous Fill Area. The incremental
cost of this significant additional remedial activities, .
however, is rather small in comparison to the environmental
benefit obtained.
The WDNR concurs with the selected remedy for the site, and
does not consider Alternatives 1 through 3 to be protective
or in compliance with ARARa, and therefore would not accept
any of these alternatives. The community, local government
officials, and PRPs that submitted public comments agree
with capping the Fill Areas, although a question was raised
as to the need for immediate capping of the Southeast Fill
Area. These groups also concur that the leachate collection
and ISVE portions of this interim action operable unit are
necessary, valuable, and consistent with the final remedy.
IX.
TBB SBLBCTBD RBKBDY
Based on the evaluations of the alternatives, u.s. EPA and
the state of Wisconsin believe that the selected remedy
(Alternative 4 plus ground water monitoring of existing
wells) will be protective of human health and the
environment, comply with ARARs, be cost effective, and will
utilize permanent solutions to the maximum extent
practicable.
The selected remedy for the SCOU entails:
.
Deed restrictions and site controls that prevent
access, excavation, disturbance of the cap, and
installation of wells;
Fence extension to contain areas not enclosed by
currently existing fences;
Cap installation over the Old, Southeast, and Non-
contiguous Fill Areas according to Wisconsin NR 504 WAC
standards;
Installation of landfill leachate control in the Old
Fill Area;
Improvement of the existing leachate control system in
the Southeast Fill Area;
Supplemental leachate control in the Southeast Fill
area;
Active landfill gas control in the Old and Southeast
Fill Areas and gas monitoring;
ISVE in a portion of the Non-Contiguous Fill Area,
specifically the drum trench, North and South Refuse
Areas;
.
.
.
.
.
.
.
32
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.
Ground water monitoring of selected existing monitoring
and private wells to be determined during remedial
design; and .
Operation and Maintenance of all systems.
.
site controls, including the extension of the fence to
encompass the waste disposal portion of the Anamax property
currently outside the fenced area, will-minimize.
non-authorized access to contaminated areas, and deed
restrictions will ensure that the land is not used for
residential purposes in the future. Installation of a new
cover system over the Old Fill, Southeast Fill and
Non-Contiguous Fill Areas will remove the potential for
people to come in contact with the landfill waste, through
direct contact or inhalation of airborne particles, and will
reduce the amount of leachate produced in those areas.
Implementing leachate controls in the Old Fill and Southeast
Fill Areas will prevent further ground water contamination
by removal and disposal of-contaminants prior to reaching
the ground water. Landfill gas controls in the Old Fill and
Southeast Fill Areas will minimize releases of hazardous
landfill gas constituents to the air. The use of an ISVE
system will provide additional protection by removing VOCs
before they can be leached into soil or ground water or
emitted to the air.
The remedial action objectives and cleanup goals for this
interim action operable unit remedy are presented in section
VII of this ROD. The remedial action objectives include.:
.
Minimize the migration of chemical constituents from
soil/refuse transported by leachate to ground water
that would contribute to ground water concentrations in
excess of MCLs, ESs and PALs;
.
Control the seepage, migration and concentration of
landfill gas generated by the refuse in the Old,
Southeast, and Non-Contiguous Fill Areas, to the soils
or air at or beyond the property boundary;
.
Minimize hazardous air contaminants that may be emitted
from the Old, Southeast and Non-Contiguous Fill Areas,
and comply with applicable air pollution control
standards; and
Minimize the potential for human exposure to waste or
contaminated soils.
.
Table 4 lists a detailed cost summary for the selected
remedy. u.s. EPA and the WDNR believe that the selected
remedy will achieve the remedial action objectives for this
operable unit remedy of .the site.
33
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Table 4
Cost Summary
Alternative 4
Feasibility Study
Moskego Landfill
CAPITAL COSTS
Site Fencing
Capping
- a. Old and Southeast Fill Areas
b. Non-Contiguous Fill Areas
Gas Control
Leachate Control
In-Situ Vapor Extraction
SUBTOTAL
OPERATION AND MAINTENANCE COSTS (ANNUAL)
~nng ancfMaintenance
Landfill GaslLeachate Control
Leachate Treatment
(years 1992 to 1997)
(years 1998 to 2022)
In-Situ Vapor Extraction
(years 1992 to 1997)
SUBTOTAL
(years 1992 to 1997)
(years 1998 to 2022)
Contingency (15%)
(years 1992 to 1997)
(years 1998 to 2022)
TOTAL
(years 1992 to 1997)
(years 1998 to 2022)
PRESENT NET WORTIi
(10% Discount Rate)
$ 12.000
$ 3,641,000
$ 426,000
$ 300.000
$ 884,000
$ 243.000
$ 5,506,000
$ 275,300
$ 1,101,200
$ 1,101.200
$ 7,984,000
S 39,700
S 29,000
$ 164,000
$ 48,000
$ 36,400
S 269,100
$ 116,700
$ 40,400
$ 17,500
$ 309,500
$ 134,200
$ 9.914.000
Administration (5%)
Engineering (20%)
Contingency (20%)
TOTAL
MAUvlr/JEMIKEB
[mad-400-16f)
13527.41
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z.
STATUTORY DETERXIHATIOBS
A.
Protection of Human Health and the Environment
The selected remedy provides adequate protection of human
health and the environment through ISVE to treat waste and
contaminated soil in portions of the Non-contiguous' Fill
Area; capping to contain wastes and contaminated soils,
alleviating threats from direct contact and minimizing
leachate generation; collection, control and appropriate
treatment of contaminants in landfill leachate; continued
extraction of landfill gas to prevent migration, buildup
and/or explosion; ground water monitoring to identify
potential impacts of contamination on existing wells; and
land use restrictions and fencing to limit direct exposure
to contamination.
Any short term risks associated with excavation of trenches
for ISVE will be minimized through good construction
practices.
Wetlands are located southeast of the site directly east of
the Anamax facility entrance road. An intermittent creek
flows over the site and discharges into the wetlands' area.
Sediment samples taken in the intermittent creek area,
specifically SD4, show contamination in this area.- The
levels were below surface water criteria levels for the
- contaminants with listed values in u.s. EPA water quality
criteria (Oualitv criteria for Water 1992). In addition,
the cap portion of the SCOU will prevent contamination in
soils from contacting surface water runoff. Therefore
wetland affects from the site will be mitigated.
The source control measures under the selected remedy, in
combination with the ground water operable unit, will
attempt to restore ground water to the State ESs and PALs
. and to Federal MCLs.
B.
Attainment of ARARs
The selected remedy will be designed to meet all applicable,
or relevant and appropriate requirements (ARARS) under
federal, and more stringent state environmental laws. A
list of ARARs for the site is contained in the alternative
arrays section of the FS. The primary ARARs that will be
achieved by the selected-alternative are:
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1.
Action SDecific
Clean Wa~er Ac~ of 1977, a. ..ended [33 V.S.C. S 1317]
40 CFR 403 - Pretreatment Standards. Require that waste
waters to be discharged into a Publicly Owned Treatment
Works (POTW) satisfy both general and specific requirements
to protect against damage to POTWs. Any waste to be
discharged to a POTW must, if necessary, be treated to
satisfy these standards prior to discharge. These
pretreatment requirements are administered under NR 211 and
108. The substantive requirements of these regulations will
apply to collected leachate to be discharged.
aesourc. conserva~ion and aecovery Ac~, a. ..ended [42
V.S.C. S 1901 e~ seq.]; wisconsin BnviroDmen~a1 Pro~ection
Law, Hazardous Was~e Kanagemen~ Ac~ [Wis. S~a~. S 144.10-74]
Most RCRA requirements are administered under the State of
Wisconsin's implementing regulations. u.s. EPA does not
have sufficient evidence to demonstrate that listed RCRA
wastes were disposed of at the site. RCRA requirements are
therefore not applicable to the site, except to the extent
that new hazardous wastes (such as treatment residuals) are
generated during the course of the remedy. Several other
RCRA regulations, although not applicable, address problems
or circumstances very similar to those encountered at this
site and are therefore relevant and appropriate. However,
the remedy will comply with the following applicable
requirements:
Wis. Admin. Code NR 605; 40 CFR 261 - Identification of
Hazardous wastes. Provide requirements for determining when
a waste is hazardous. The substantive requirements of these
regulations will apply to TCLP testing of treatment
residuals and waste excavated at the site which may be
disposed of off-site.
wis. Admin. Code NR 615; 40 CFR 262 - Standards Applicable
to Generators of Hazardous Waste. Provides requirements for
the shipment of wastes to treatment, storage or disposal
facilities.. These requirements may apply to off-site
shipment of treatment residuals and other wastes.
wis. Admin. Code NR 620; Department of Transportation
Hazardous Materials Transportation Act [49 U.S.C. S 1801];
40 CFR 263 - Standards Applicable to Transporters of
Hazardous Waste. Requires record keeping, reporting and
manifesting. of waste shipments. These requirements may
apply to off-site shipment of treatment residuals and other
wastes.
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Wis. Admin. Code NR 630.10-17; 40 CFR 264, Subpart B -
General Facility Requirements. Establishes substantive
requirements for security, inspection, personnel training,
and materials handling which are relevant and appropriate to
on-site activities involving excavations and handling of
hazardous soils and materials.
wis. Admin. Code NR 630.21-22; 40 CFR 264, Subpart D -
Contingency Plan and Emergency Procedures. Establishes
substantive requirements for emergency planning which are
relevant and appropriate for on-site activities involving
excavation and handling of hazardous substances.
wis. Admin. Code NR 675; 40 CFR 268 - Land Disposal
Restrictions. Requires that hazardous wastes cannot be land
disposed unless they satisfy specified treatment standards
and imposes record keeping requirements on such wastes.
These requirements apply to off-site disposal of any
treatment residues or other-hazardous wastes.
Wisconsin Bnvironmental Protection Law, Subchapter IV-Solid
Waste [Wis. Stat. 5 144.43-47]
wis. Admin. Code NR 504.04, 506.08(6), 506.07, 508.04 -
Landfill gas control. Establishes standards for landfill
gas control and monitoring practices. These requirements
apply to the landfill gas recovery operations at the site.
wis. Admin. Code NR 506.08(3) (b) - Additional Closure
Standards. Requires diversion and collection of surface
water runoff from closed portions of a landfill. These
requirements are relevant and appropriate during
construction activities at the site.
Wis. Admin. Code NR 504.07, 506.08, 514.07 and 516 -
Landfill Closure Requirements. Establishes substantive
requirements for design, operation and maintenance of
landfill caps which are relevant and appropriate to
installation and upgrading of caps at the site. The cap
design and construction will comply with these requirements,
which provide substantive requirements for cap design,
implementation and documentation.
2.
Chemical SDecific
Clean Air Act [42 D.S.C. 5 7401 .t seq.]; wisconsin
Environmental Protection Law, Subchapter III-Air Pollution
[Wis. Stat. 144.30-144.426]
40 CFR 50; wis. Admin. Code NR 404, 415-449- Emissions
Standards. Establishes standards for emission of pollutants
36
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into the ambient air and procedures for measuring specific
air pollutants. Landfill gas emissions, handling of
contaminated soils during excavation, and cap construction
could cause air emissions of VOCs, particulates, fugitive
dust or other contaminants which could adversely effect
human health and the environment. The design of the remedy
will reduce such emissions to acceptable levels or provide
for treatment to satisfy these standards.
Safe Drinking Water Act [40 V.S.C. S 300 et seq.]
40 CFR 141, Wis. Admin. Code NR 109 - Maximum Contaminant
Levels (MCLa). MCLs establish drinking water standards for
potential and actual drinking water sources. MCLs have been
exceeded at the site in the shallow aquifer, which is
classified as a potential drinking water source. The ISVE
component of the remedy, in combination with the upcoming
ground water operable unit, will achieve compliance with
MCLs and non-zero Maximum contaminant Level Goals.
wis. Admin. Code NR 140 - Groundwater Quality standards.
Provides for groundwater quality standards including
Preventive Action Limits (PALs), Enforcement Standards
(ESS), and (Wisconsin) Alternative Concentration Limits
(WACLs).. The ISVE component of the remedy, in combination
with ~he upcoming ground water operable unit, will achieve
compliance with 'any applicable substantive groundwater
quality standards.
Wisconsin Environmental Protection Law, Subchapter II-Water
and Sewage [Wis. Stat. S 144.02-27]
wis. Admin. Code NR 102 and 105 - Surface water quality
standards. NR 102 creates an antidegradation policy for all
waters of. the State and prohibits toxic substances in
surface waters at concentrations which adversely affect
public health or welfare, present or prospective water
supply uses, or protection of animal life. The ISVE
component of the remedy~ in combination with the upcoming
ground water operable unit, will achieve compliance any
substantive requirements of these regulations that
constitute ARARs.
Clean Water Aot of. 1'77, a. ...nded [33 V.S.C. S 1314 (a) (1)]
40 CFR 131 - Ambient Water Quality criteria. Establishes
pollutant concentration limits to protect surface waters.
The source control remedy is intended to eliminate
contaminated surface runoff at the site. To the extent
37.
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contaminated runoff is channeled directly to_a surface water
body" however, that runoff must comply with any applicable
concentration limits.
3.
Location SDecific
Clean Water Act of 1977, a8 amended [33q,U.S.C. -S 1344]
Executive Order 11990 and 40 CFR 6 - Protection of Wetlands.
-
These requirements-provide for protection against loss or
degradation of wetlands. Contamination in surface water
runoff will be controlled so that it does not have an
adverse impact on nearby wetlands.
C.
Cost Effectiveness
The selected remedy provides overall cost-effectiveness.
ISVE adds a significant degree of permanence, as does the
extraction of contaminants in leachate and landfill gasses.
The substantial additional protection and permanence
provided by the upgraded cap and ISVE under the selected
alternative is achieved with only a minor (roughly 9%)
increase in cost over the only other protective alternative.
Moreover, by effectively addressing sources of ground water
contamination, the selected interim action operable unit
remedy may also reduce the cost of the ground water operable
-unit.
D.
utilization of Permanent Solutions and Alternative
Treatment Technoloaies to the Maximum Extent
Practicable
The selected alternative represents the best balance of
alternatives with respect to the nine evaluation criteria
described in section VIII. An innovative treatment
technology, ISVE, is used to permanentl~address the most
highly concentrated source area of contamination. The
selected alternative treats the principal source of ongoing
ground water contamination and direct contact threats. The
cap further retards the movement of residual contaminants to
ground water by reducing the generation of leachate. The
upgraded leachate collection system captures for treatment
the leachate that is produced. Collected leachate will also
be treated and disposed of. The land use restrictions will
further assure protection to the public health and the
environment.
E.
Preference for Treatment As A PrinciDal Element
38
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By treating the most highly concentrated contaminated soil
an4 leachate as required, the selected remedy satisfies the
statutory preference for remedies that employ treatment of
the principal threat to permanently and significantly reduce
toxicity, mobility, or volume of hazardous substances.
The selected remedy reduces the likelihood that the source
areas will continue to be a significant source of ground
water contamination by use of ISVE, collection and
appropriate treatment of leachate, and capping to reduce
infiltration. The remaining existing contamination in
ground water will be addressed through the second operable
unit at the site. The cap, combined with institutional
controls will also act to prevent exposure through direct
contact.
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