EPA Superfund
Record of Decision:
PB94-964129
EPA/ROD/R05-94/255
September 1994
N.W. Mauthe Site,
Appleton, WI,
3/24/94
-------
Record of Decision Summary
N. W. Mauthe Site
City of Appleton, Outagamie County,
Wisconsin
March, 1994
-------
DECLARATION FOR THE RECORD OF DECISION
Site Name and Location
N.W. Mauthe Site
725 South Outagamie Street
Appleton, Wisconsin
Statement of Basis and Purpose
This decision document presents the selected remedial action for the N.W. Mauthe Site located in
Appleton, Wisconsin. The remedial action was selected in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act of 1980 (CERCLA), as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA), and, to the extent- practicable, the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP). This decision is based on
the Administrative Record for this site.
The State of Wisconsin and the U.S. Environmental Protection Agency (U.S. EPA) concur with the
selected remedy. .
Assessment of the Site
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.
Description of the Selected Remedy
This response action addresses remediation of soil and groundwater contaminated primarily with
chromium from prior electroplating operations at the N. W. Mauthe Site. The principal threats posed
by conditions at the site include ingestion, dermal contact and inhalation of impacted soils, surface
water and groundwater.
The selected remedy for the N.W. Mauthe Site entails:
. Demolition and removal of the buildings on the N. W. Mauthe property, with proper management
and disposal of the building debris;
. Removal and proper disposal of the containerized waste currently stored on-site;
. Excavation of soils with a total chromium concentration greater than 500 mg/kg, removing
approximately 80% of the chromium contaminant mass, including the removal of those soils from
beneath the railroad tracks if it is determined during RD that it is feasible to do so in a way that
allows the railroad reasonable and normal use of the tracks;
. Off-Site treatment (reduction and solidification) of the excavated soils which are determined to be
hazardous and subsequent off-site disposal;
. Backfilling the excavation with clean soils, and converting the excavated area into a groundwater
-------
collection sump if it is determined during RD that the addition of such a sump would significantly
hasten achievement of remedial goals for soil and groundwater, including containment and/or
control of contamination in groundwater and ultimate compliance with groundwater ARARs:
. Capping the site with two feet of clay soil and topsoil, with the establishment of a vegetative
cover;
. Installation of groundwater collection trenches and construction and operation of a groundwater
treatment (chemical reduction and precipitation with possible VOC and cyanide removal, if is
determined to be necessary) facility with discharge to the sanitary sewer, to contain and/or control
groundwater contamination with ultimate compliance with groundwater ARARs;
. Improvement or installation of foundation drain systems and cleaning, painting or sealing of
basement walls and floors, as needed, for homes or businesses in the area of the site, to prevent
seepage of contaminated water into the buildings;
. Institutional controls, such as deed restrictions or easements and site access controls that are
intended to prevent access, excavation, disturbance of the newly constructed cap, future soil
excavation in the railroad corridor for areas in the corridor where contaminated soils will remain
and installation of drinking water wells;
. Monitoring of the effectiveness of the groundwater treatment system and groundwater quality; and
. Operation and maintenance of all systems.
Statutory Determinations
The selected remedy is protective of human health and the environment, complies with 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 technologies to the
maximum extent practicable, and satisfies the statutory preference for remedies that employ treatment
that reduces toxicity, mobility, or volume as a principal element.
Because this remedy will result in hazardous substances remaining on-site above health based levels, a
review will be conducted within five years after commencement of remedial action to ensure that the
remedy continues to provide adequate protection of human health and the environment.
N\ 'CN.tU.... D. ~
~ Valdas V. Adamkus
Regional Administrator, U.S. EPA Region 5
.3 - S I
- ~ ~
Date
3 .21 .73
Date
-------
I.
II.
m.
IV.
V.
VI.
VII.
1
TABLE OF CONTENTS
Site Description, History and Background
. . . . . . . . . . . . . . . . . . . . . . ., 1
Community Participation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 4
Scope and Role of Response Action. . . . . . . . . . . . . . . . . . . . . . . . . . ., 4
Summary of Site Characteristics. . . . . . . . . . . . . . . . . . . . . . . . . . . . . ., 5
Summary of Site Risks. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
Remedial Action Objectives. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
Description of Alternatives. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
.
vrn. Summary of Comparative Analysis of Alternatives. . . . . . . . . . . . . . . . . . . 19
IX.
x.
Summary. . . . . .'. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .30
The Selected Remedy. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
XI.
Statutory Detenninations ................................... 33
xu.
Responsiveness Summary. . . . . . . . . . . . . . . . . . . . . . . . . . ATIACHMENT
LIST OF TABLES
1.
Contaminants of Potential Concern. . . . . . . . . . . . . . . . . . . . ATTACHMENT
2.
Summary of Risk Characterization Results - Current Land Use. . . ATTACHMENT
3.
Summary of Risk Characterization Results - Future Land Use. . . . ATTACHMENT
4.
Groundwater Quality Standards. . . . . . . . . . . . . . . . . . . . . . A TT ACHMBNT
5.
Remedial Action Alternatives Components and Costs. . . . . . . . . ATTACHMENT
6.
City of Appleton P01W Discharge Limits. . . . . . . . . . . . . . . ATTACHMENT
7.
Air Standards. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ATTACHMENT
8.
LDR Treatment Standards (FOO7 - FOO8) ................ ATTACHMENT
-------
LIST OF FIGURES
1.
Site Location Map. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ATTACHMENT
2.
Surface Soil Sampling. . . . . . . . . . . . . . . . . . . . . . . . . . . . ATTACHMENT
3.
Chromium in Subsurface Soils. . . . . . . . . . . . . . . . . . . . . . . ATTACHMENT
4.
Volatile Organic Compounds in Subsurface Soils. . . . . . . . . . . ATTACHMENT
5.
Groundwater Flow. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ATTACHMENT
6.
Chromium in Groundwater. . . . . . . . . . . . . . . . . . . . . . . . . ATTACHMENT
7.
Volatile Organic Compounds in Groundwater. . . . . . . . . . . . . . ATTACHMENT
8.
Alternative 4 (Hot Spot Removal) - Selected Remedy. . . . . . . . . ATTACHMENT
(,
-------
Record of Decision Summary
N.W. Mauthe Site
Appleton. Wisconsin
1. SITE DESCRIPTION, HISTORY AND BACKGROlJ1\'D
The N. W. Mauthe site is a fonner electroplating facility located at 725 South Outagamie
Street in Appleton. Wisconsin as depicted in Figure 1. Located in a neighborhood of mixed
commercial, light industrial. and residential propenies. the 2-acre site is roughly triangular in
shape and is bordered by Melvin Street on the nonh. a parking lot owned by Miller Electric
and Manufacturing Company on the west. and the Wisconsin Central Transpottation
Corporation (previously the Fox River Valley Railroad CoqJOration) railroad right-of-way on
the southeast. Private residences are located immediately southeast of the railroad tracks and
on the nonh side of Melvin Street.
Norben W. Mauthe founded the Wisconsin Chromium Corporation (WC) in 1946. Until
1960 WC operated from a facility at 1522 WesLMelvin Street. at which time WC moved to
725 South Outagamie Street. WC leased the propeny at 725 South Outagamie Street until
1966, when Norben Mauthe purchased the propeny. From that time on. WC leased the
propeny from Norbert Mauthe. Hard chromium plating took place in the on-site building
referred to as the Chrome Building from 1960 to 1976. In 1976, WC sold most of its
chrome plating assets, and chromium plating operations ceased at the site. Norben Mauthe
then fonned a new company known as the N. W. Mauthe Company.
Under the name of N.W. Mauthe Company, electroplating of zinc. cadmium. copper. and
possibly silver was conducted in the on-site building referred to as the Zinc Building, from
1978 until 1987. After operations ceased in August 1987. ill usable plating equipment and
solutions were removed. The propeny is presently owned by Carol Mauthe. !vlr. .\lauthe's
widow. .
Hard chromium plating is a process by which chromium is plated directly onto a base metal..
Much of WC's chromium plating was conducted on roller drums for the paper industry. The
source of the chromium was concentrated chromic acid. During the electroplating operation
the rollers were fIrst rinsed with a chlorinated solvent to remove surface oils. They were
then partially submerged in the chromic acid bath while current was passed through the roller
drum.
Hydrogen gas and chromic acid mists generated from the chromium plating process were
blown outside of the building by a ventilating fan. while splashes. drips, and spills from the
plating and degreasing activities were directed to a shallow noor trench and channeied into
the sanitary sewer system. The plating bath solutions reacted with components of concrete
which produced cracks and pits within trenches and the Hoor itself. This allowed inf1ltration
of chromium and solvent solutions into the soil and groundwater below the building.
-------
In March 1982, ponded yellow-green water in the railroad ditches adjacent to the N.W.
Mauthe propeny was reponed to the Wisconsin Department of Natural Resources (WDNR).
There was also a repon of yellow-green water being pumped from a nearby basement
foundation drain sump. In April and May 1982 over 30.000 gallons of water were pumped
from the puddles and transported to a municipally-owned wastewater treatment plant
(P01W), where it was discharged into the municipal system.
In May 1982, the WDNR installed a shallow drain..system to collect groundwater and
contaminated surface water. Collected water wasagain transferred to the POTW.
Approximately 1.3 million gallons of contaminated water were removed. The system has
been inactive since late 1984.
In November 1982, the WDNR contracted for the drilling and sampling of soil borings, and
installation of 16 monitoring wells. Significant concentrations of chromium were detected in
soil and water at the site, with the apparent source centered under the southeast portion of
the Chrome Building.
From 1982 to 1985, the WDNR attempted to gain site remediation from Mauthe. In 1985,
Mauthe was ordered to develop a cleanup plan by the Outagamie County Circuit Court, and
he subsequently hired a consulting fmn. In 1986, the consultant proposed site cleanup plans,
which were subsequently rejected by the WDNR. In 1986 Mauthe's insurance carrier
rejected claims for incurred costs and remedial efforts by Mauthe ceased.
In October 1984, contractors for the WDNR regraded the site and applied an asphalt cover to
channel surface runoff into a new stonn sewer inlet and limit infiltration of surface water
into the ground. The coat of liquid asphalt rapidly deteriorated.
A federal Superfund Field Investigation Team (FIT) a contractor for the U.S. Environmental
Protection Agency (U.S. EPA), conducted a site inspection in October 1984. The site
Hazard Ranking Score (FIRS) was not high enough for inclusion on the National Priorities
List (NFL). Therefore, in June 1988, at the request of the WDNR, the U.S. EPA formally
proposed that the site be placed on the NFL as Wisconsin's number 1 priority site. The
N.W. Mauthe site was added to the NFL in March 1989. In September 1988, the WDNR
signed a Cooperative Agreement with the U.S. EPA to conduct a fund fmanced, state-lead
Remedial Investigation/Feasibility Study (RIfFS).
In May 1987, a contractor of AT&T installed a fiber optics cable along the railroad right-of-
way adjacent to the site utilizing a train-mounted plow. In August 1987, a contractor of
U.S. Sprint also installed a fiber optics cable in a trench between the railroad tracks. The
City of Appleton Health Department and the WDNR were notified that several workers
developed skin irritation and rashes, apparently caused by contact with the water and soil in
the U.S. Sprint trench. The WDNR requested that U.S. Sprint restore the site to its prior
condition and take measures to ensure that the trenches would not serve as conduits for
transport of contaminated groundwater.
In November 1987, U.S. Sprint and AT&T cooperatively installed a joint conduit system for
-------
3
the fiber optics cables outside of the contaminated area. The cables originally installed along
the railroad right-of-way were abandoned and antiseep plugs were installed along the original
routes.
In May 1990, a Preliminary Health Assessment was prepared by the Wisconsin Division of
Health (WDOH) for the U.S. Agency for Toxic SYostances and Disease Registry (ATSDR).
The assessment concluded that the site posed a public health concern because human
exposure to hexavalent chromium. cadmium and other contaminants may occur through
contact with or ingestion of contaminated soil, water. or inhalation of dust. The report
recommended avoiding contact with the site and suspected contaminated soil, water, and also
with precipitates noted on neighboring basement walls.
Warzyn Engineering, under contract to the WDNR. compiled a Site Evaluation Report (SER)
for the N. W. Mauthe site summarizing existing information. In October 1990 they also
submitted a RIfFS Work Plan, however, the WDNR did not authorize Warzyn to perform the
RIfFS and opened it up for bid.
Also, in 1991, the U.S. EPA Emergency Response Program installed a fence around the
N.W. Mauthe site, and excavated some of the highly contaminated soils and placed them into
containers. The soils were excavated from along the southeast 'side of the Chrome Building
and from a tank pit inside the building. U.S. EPA also steam cleaned the walls, floors and
ceilings of the office areas and the floors and uninsulated portions of the Zinc and Chromium
Buildings. Miscellaneous debris was decontaminated and disposed of or placed in containers.
The containers are located in the on-site buildings. Decontamination water was pretreated
and discharged to the municipal POTW.
WDNR installed a groundwater diversion system in the basement of the 1414 West Second
Street residence in 1991 to diven contaminated groundwater flow around the home. The
system. called the Electro-Pulse Shield. uses electrical current to alter the direction of
groundwater flow. The Electro-Pulse Shield appears to have reduced seepage into the
basement.
Under contract to the WDNR, CH2M Hill conducted a RIfFS at the N.W. Mauthe site
beginning in November 1991. The RIfFS included the installation of monitoring wells;
surface and subsurface soil sampling; test pit excavation; groundwater, residential sump
pump, and sewer water sampling; hydraulic conductivity testing; surface water sampling; and
videotaping of the sanitary and storm sewer lines. A fmal RI Report, dated February 4,
1993, was approved by the U.S. EPA and the WDNR by letters dated August 20. 1993 and
September 28, 1993, respectively. A final FS Repon. dated May 1993, was approved by the
U.S. EPA and the WDNR by letters dated September 24. 1993 and October 20. 1993,
respectively.
-------
4
II. COMMUNITY PARTICIPATION
A fact sheet summarizing site background and history was distributed to the public in
October 1989. A second fact sheet outlining the Rl sampling program was distributed in
June 1991. A Rl initiation meeting was also held at that time at the Appleton Police
Department at 222 S. Walnut Street. In January 1993 a letter was distributed to persons on
the site mailing list to provide an update on the status of the site and its investigation. The
Rl and the FS Reports were both made available to the public in October 1993 through
placement in the Administrative Record. The Proposed Plan was distributed to members of
the current mailing list and made available to the general public in October 1993. Notice of
availability of the Proposed Plan was included in an advertisement in the Appleton Post
Crescent on October 13. 1993. Press releases were also sent to local media to announce the
availability of the Proposed Plan on October 5, 1993.
A public comment period was provided from October 15. 1993 through November 15, 1993.
A public meeting was held on October 27, 1993, where comments were accepted verbally
and in writing. The public meeting was held at the Appleton Police Department to discuss
the alternatives evaluated in the FS and describe the remedial alternatives presented in the
Proposed Plan. All comments which were received by the WDNR prior to the end of the
public comment period, including those expressed verbally at the public meeting, were
considered in making the fmal decision and are addressed in the Responsiveness Summary.
All of the documents discussed above, are available in the Administrative Record maintained
at the Appleton Public Library at 225 N. Oneida Street. the WDNR's central office at 101 S.
Webster Street (Bureau of Solid and Hazardous Waste, GEF 2, 3rd Floor), Madison,
Wisconsin and at the WDNR Lake Michigan District Office in Green Bay, Wisconsin. A
copy of the Administrative Record is also available at the U.S. EPA offices at 77 West
Jackson Boulevard (7th Floor Records Center), Chicago, Illinois.
ill. SCOPE AND ROLE OF RESPONSE ACTION
Contaminated soils and surface water at the site pose a threat to human health and the
environment because of the risks from possible ingestion or dennal contact. Contaminated
groundwater at the site poses a potential future threat to human health and the environment
because of the risks from possible ingestion of or dennal contact with the groundwater
should a well be installed at the site or should the contaminated groundwater reach the
bedrock aquifer, which is used as a regional drinking water source.
The selected remedial action, described below as Alternative 4, Hot Spot Removal. addresses
the principal threats posed by site conditions by eliminating the potential for direct contact
with contaminants of concern, containing and/or controlling the groundwater contamination at
the site and reducing the levels of contamination in the groundwater.
v
-------
5
IV. SUMMARY OF SITE CHARACTERISTICS
A. Overview
The following is a summary of the RI results. The RI d~tennined the natUre and extent of
contamination at the site.
The City of Appleton lies within the drainage basin of the Fox River, which flows to the
nonheast and discharges to Green Bay. The Fox River is located about a l/2 mile to the
southeast of the site. Surface water from the site either nows to the storm sewer system
along Melvin Street or the railroad tracks which ultimately channels water to the Fox River.
Topography in the area of the site is generally flat with the investigated area roughly at an
elevation of 805 feet above mean sea level (msl). The majority of the site itself is currently
covered by the two on-site buildings or gravel parking areas. Soil is exposed at the surface.
primarily in the southwest corner of the site and along Melvin Street.
There are a variety of fme-grained soils beneath the site that are approximately 70 feet thick.
which have been divided into upper and lower till units. These soils are underlain by
dolomitic bedrock. The bedrock aquifer is used as a drinking water supply for a limited
number of private wells within three miles of the site. however, the area surrounding the site
is supplied by a municipal water system. The City of Appleton obtains its water supply from
Lake Winnebago and does not depend on wells. Vertical fractUres and thin sand and silt
lenses were observed in the clay in soil borings completed during the RI. These fractures
and lenses are thought to provide the primary flow paths for groundwater movement from the
site. The fractures primarily occur in the top 15 feet of the soil column. Groundwater flow
in the upper till unit is to the southeast with groundwater now rates estimated to range
between 0.01 foot to 112 feet per year.
Soil and groundwater sampling results from the RI indicate that the greatest concentrations ot
contaminants are under the southeast corner of the Chromium Building, along the floor
trenches and sanitary sewer lateral that drained its process area, and beneath a trough in the
Zinc Building. The chemicals detected above background levels or the State of Wisconsin's
Preventative Action Limits (PALs) for groundwater include chromium (hexavalent and total).
zinc, cadmium, cyanide, copper, lead, trichloroethene. 1.1, I-trichloroethane,
l,l-dichloroethene, and toluene. Benzene and xylenes were detected in samples collected
near a fuel oil distributor and do not appear to be attributable to the N. W. Mauthe site,
which is not known to have had underground or above ground fuel storage tanks.
The chlorinated hydrocarbons and hexavalent chromium in the N. W. Mauthe site soils are
relatively mobile and available to leach into the groundwater. Due to the site's low
permeability soils and relatively slow groundwater r1ow. contaminant movement in
groundwater is thought to be mainly through sand and silt lenses and fractUres in the clay.
Both soil and groundwater contamination appear to be dispersed preferentially along the
-------
6
railroad ballast and sanitary sewer lateral trenches extending from the Chromium Building.
B. Surface Soil
Twelve surface soil samples were collected and analyzed for total chromium. cadmium, zinc
and cyanide. Figure 2 shows the surface soil sampling locations and the concentrations of
contaminants detected.
Chromium levels above background were detected in most of the surface soil samples
collected. Cyanide was not detected above background levels (2 mg/kg) in any off-site soil
sample. Off-site surface soil samples contained chromium, cadmium, and zinc at
concentrations above background levels.
C. Subsurface Soils
Subsurface soil contamination was detected to a maximum depth of 25 feet, and found to
extend over the entire N. W. Mauthe property, ~ortheast and southwest along the railroad and
southward to the residence at 1414 West Second St. Inorganic subsurface soil contamination
is much more extensive than VOC contamination.
Figure 3 depicts the horizontal extent of total chromium contamination in the subsurface soils
at the site. Concentrations of cadmium, chromium, zinc, and cyanide detected at each
sample location are also shown in the figure. Sample locations outside of the background
(32 mg/kg) total chromium concentration contour did not contain other metals over
background levels. Therefore, the areas contaminated with cyanide and other metals
generally coincide with the areas with the highest levels of chromium-contaminated soils.
Figure 4 depicts the horizontal extent of VOC contamination in subsurface soils. VOC
compounds have been grouped into three categories; benzene. toluene, ethylbenzene and
xylenes (BTEX); chlorinated hydrocarbons; and, 2-butanone. Figure 4 also indicates the
interval at which the maximum amount of contamination was detected in that boring. The
presence of chlorinated hydrocarbons may be attributed to the degreasing solvents used at the
site, whereas BTEX contamination is typically associated with fuels, such as gasoline, fuel
oil or diesel fuel. . The source of the 2-butanone is unknown, although it may also be related
to fuel spills or may represent a laboratory contaminant. 2-Butanone was detected in samples
collected from several locations.
The VOC subsurface soil contamination appears to be centered around the Chromium
Building and around the Zinc Building. The major compounds detected were
1,1, I-trichloroethane and trichloroethene. The VOC-contaminated area is enclosed within
the chromium-contaminated area and the areas with the highest levels of VOC- contaminated
soils generally coincide with the areas with the highest levels of chromium-contaminated
soils.
-------
7
D. Groundwater
Groundwater elevations and samples were taken from 3-+ monitOring wells. Shallow wells
were installed to depths of 15 feet or le~s. while deep \vells were installed to a maximum
depth of 72 feet.
Contours from water level measurements in wells show a general southeastern groundwater
flow direction as shown on Figure 5. Downward vertical hydraulic gradients are indicated,
suggesting the potential for groundwater to flow from the upper saturated soils to the lower
soils towards the underlying bedrock.
Groundwater sampling of monitoring wells was performed at two separate times during the
RI (Rounds 1 and 2). Water samples from six residential foundation drain sumps were also
collected. Samples were analyzed for VOCs, metals (including total and hexavalent
chromium) and cyanide. Results from both rounds indicate that total chromium groundwater
contamination in excess of Maximum Contaminant Levels {MCLs) set by U.S. EPA under
the Safe Drinking Water Act and Wisconsin p~ and Enforcement Standards (ESs) extends
over much of the area bordered by Melvin, Outagamie. and Second Streets as indicated on
Figure 6.
Hexavalent chromium-contaminated groundwater extends over much of the same area. It
appears that most of the chromium in the groundwater exists in the hexavalent fonn. All of
the wells contained detectable levels of total chromium except W5C & WIB. Levels of
cyanide in excess of both Federal and State criteria and standards were detected in two
shallow wells (MW26R and MW34). A comparison of 1983, 1986, and 1992 groundwater
total chromium data shows that the horizontal extent of contamination did not change greatly,
but indicates that the chromium contamination is moving downward.
Figure 7 depicts VOC concentrations in groundwater. again categorizing the compounds into
chlorinated hydrocarbons, BTEX, and 2-butanone. Trichloroethene and 1, I , I-trichloroethane
were the main compounds detected, as well as 1, 1-dichloroethane, 1, I-dichloroethene, and
1,2-dichloroethene. The VOC-contaminated groundwater appears to be located mostly on the
north side of the railroad tracks. The majority of the VOCs were detected in the shallow
wells. BTEX contamination was primarily detected near the oil distributor facility east of
Outagamie Street. The extent of VOC-contaminated groundwater appears smaller than the
extent of chromium contamination and is contained within the chromium-contaminated area.
Table 1 presents the maximum concentrations of the contaminants of concern observed in the
various media.
E. Surface Water
Four surface water samples were collected from puddles in back of the Chromium Building
and in the ditch along the railroad tracks. Water samples were also collected from the
shallow groundwater collection system crocks that were installed in 1982. The source of the
-------
8
water in the crocks is likely to be a combination of groundwater seepage and surface water.
Every surface water sample contained elevated levels of chromium. Three of the sample
locations contained VOCs above detection limits. TIle main VOCs detected were
1.1, I-trichloroethane and trichloroethene.
F. Sewer Lines
A potential means of contaminant transport is through or along sanitary or storm sewer lines,
or along utility trenches. For this reason a test pit was excavated near the comer of Melvin
Street and Outagamie Street and several soil borings were drilled near sewer lines on Second
Street and at the Outagamie Street/Second Street intersection. Storm and sanitary sewers
were also sampled to investigate the possibility of contamination entering the system and
being transported away from the site.
Two soil samples collected from the test pit did not show inorganic contamination above
background levels. Chlorinated hydrocarbons ~ere detected in the test pit; however, they
appear to be from another source as chromium was not detected.
Soil borings drilled along storm and sanitary sewers along Outagamie and Second Streets
showed neither elevated chromium levels nor chlorinated hydrocarbons above detection
limits.
A total of four storm and sanitary sewer grab samples were collected from manholes along
Second Street, Outagamie Street and Melvin Street as indicated on Figures 5 and 6. High
concentrations of chromium and low levels of VOCs were detected in a manhole along
Melvin Street (SG 1). It appears that the pooled water at the bottom of the manhole, from
which the sample was obtained, is groundwater infiltration. No hexavalem chromium and
only low levels of tota! chromium were detected in the other samples.
A dye study showed the sanitary laterals from the N. W. Mauthe site to the sewer system to
be clogged or collapsed. The Melvin Street sanitary line contains low spots and shifting in
the joints based on a video survey. Water was noted to collect in the low spots with some
inftItration observed. The stonn sewer was found to be in better condition, (e.g., fewer low
spots, less shifting and probably less infiltration).
The condition of the sewer lines along Melvin Street coupled with the presence of
contaminants in the sewer grab samples suggest that the sewers in this area are acting as
conduits for the transport of contaminated groundwater.
-------
9
V. SUMMARY OF SITE RISKS
A. Overview
The RI included an evaluation of risks at the site to human health and the environment if no
remedial actions were taken. This process is calleaa Baseline Risk Assessment (Risk
Assessment). The Risk Assessment involves assessing the toxicity, or degree of hazard.
posed by substances related to the site. and describing the routes by which these substances
could come into contact with humans and the environment. Separate calculations are made
for those substances that can cause cancer (carcinogenic) and for those that can cause other,
non-carcinogenic health effects. The results are also used to identify the natUre and extent of
remediation required.
Cancer Potency factors (CPFs) have been developed by U.S. EPA's Carcinogenic
Assessment Group for estimating excess lifetime cancer risks associated with exposure to
potentially carcinogenic chemicals. CPFs, which are expressed in units of (mg/kg-day)'., are
multiplied by the estimated intake of a potenrial.carcinogen, in mg/kg-day, to provide an
upper-bound estimate of the excess lifetime cancer risk associated with exposure at that
intake level. The term "upper-bound" reflects the conservative estimate of the risks
calculated from the CPF. Use of this approach makes under estimation of the actual cancer
risk highly unlikely. CPFs are derived from the results of human epidemiological studies or
chronic animal bioassays to which animal-to-human extrapolation and uncertainty factors
have been applied.
Reference doses (RIDs) have been developed by U.S. EPA for indicating the potential for
adverse health effects from exposure to chemicals exhibiting non-carcinogenic effects. RIDs,
which are expressed in units of mg/kg-day are estimates of the lifetime daily exposure levels
for humans, including sensitive individuals, below which no adverse non-carcinogenic effects
will be suffered. Estimated intakes of chemicals from environmental media (e. g., the
amount of a chemical ingested from contaminated drinking water) can be compared to the
RID by dividing the estimated dose by the Reference Dose to obtain the Hazard Index (Ill).
RIDs are derived from human epidemiological studies to which uncenainty factors have been
applied (e.g., to account for the use of animal data to predict effects upon humans). These
uncenainty factors help ensure that the RIDs will not underestimate the pOtential for adverse
non-carcinogenic effects to occur.
The National Oil and Hazardous Substance Contingency Plan (NCP) established acceptable
levels of carcinogenic risk for Superfund sites ranging from 1 in 10.000 to 1 in 1 million
(lxlO-4 and lxlO-6) excess cancer cases and a ill of 1 or below for noncarcinogenic effects.
The NCP requires that the Risk Assessment consider exposure scenarios both for current land
use and for a conservative reasonable future use.
-------
10
B. Media and Contaminants of Concern
The media and contaminants of concern at the N.W. Mauthe site are fisted in Table 1 and
are discussed above. Table 1 presents the maximum concentration detected for those
parameters. by individual media. which were determined to be of poremial concern in the
Risk Assessment. In general, they are associated wjth the plating industry. and include
organic solvents, metals and cyanide.
C. Exposure Scenarios and Methodology
The noncarcinogenic risk and excess lifetime cancer risk for each exposure scenario
associated with both current and potential future land use are discussed below and are
summarized in Tables 2 & 3.
1. Current Land Use - The current land use scenarios involve a trespasser exposed to surface
and subsurface soils on-site, and residents exposed to surface soil off-site.
The results of the risk characterization for current land use show that noncarcinogenic risks
exceed a Hazard Index (HI) level of 1 for several of the exposure scenarios while excess
lifetime cancer risks slightly exceed a risk level of I x 1()"6. The main contributors to risk
are surface soils containing hexavalent chromium and cadmium. The reasonable maximum
exposure assumptions for direct contact with soil for the trespassing toddler. and adult exceed
the target In level of 1 for current land use. The average assumptions and average
concentration combination are below the U.S. EPA's acceptable risk level for both excess
lifetime cancer risk and noncarcinogenic risk.
As part of the Risk Assessment, In levels were calculated for the comaminants of concern in
soils at the N.W. Mauthe site. A hexavalent chromium concentration in soil. representing a
HI level of 1 for dermal contact was determined to be 570 mg/kg. A hexavalent chromium
concentration in soil. representing an ill l~vel of I for ingestion was dctermined to be 780
mg/kg. In levels were also calculated for groundwater. The concentration of chromium in
water which represents an ill level of I for occupational dermal exposure is 5000 ug/l.
While levels of chromium above 5000 /lg/l were detected in basement sumps, those sumps
were not expected to be a probable pathway of concern for direct contact.
2. Future Land Use - The main difference between current land use and future land use is
the potential for residents to move on-site and have contaminated groundwater as their source
of water for household use. The high concentration of chromium in groundwater causes the
noncarcinogenic risk from residential use from ingestion and showering to significantly
exceed the acceptable noncarcinogenic risk level (Ill level of 1). The excess lifetime cancer
risk is slightly greater than the U.S. EPA's acceptable risk level of ] 10-4. mainly due to
the presence of I, l-dichloroethene and trichloroethene.
-------
11
Inhalation of contaminants from soil paniculates or from volatiles during showering does not
appear to be a significant pathway. Ingestion of and dermal contact with cadmium or
chromium in soil or groundwater are the main contributOrs to pOtentiai future risk at the site.
The direct contact scenarios with either surface or subsurface soil show that the hazard index
is greater than the U.S. EPA's acceptable risk leY61 for a child. Cadmium and chromium are
again the chief contributors to the risk. Inhalation of contaminants from soil paniculates
does not appear to be a significant pathway.
3. Uncertainty of Risk Assessment
There are other scenarios that could contribute to the risk that have not been specifically
quantified. The consumption of garden vegetables grown in soil containing chromium and
cadmium could add to the daily intake of these contaminants. Likewise. contaminated
groundwater entering the basements of homes could add to the daily imake through ingestion
. or dermal contact with residues or through inhalation. Shon-term exposures. such as dermal
contact with surface water from puddles or contaminated soil could also add to the tOtal
intake of contaminants.
Conservative exposure assumptions are used to produce reasonable maximum intakes and risk
for the scenarios that have been quantified. Therefore, the contribution to risk from the
scenarios noted above should be accounted for by the conservative risk calculations.
Actual or threatened releases of hazardous substances from this site. if nOt addressed by the
response action selected in this ROD, may present an imminent and substantial endangerment
to public health, welfare, or the environment.
~. ~~ACTIONOwrnC~
A. Direct Contact Obiectives
There are several remedial objectives that are of a shon term nature. 1l1ese are primarily
measures to reduce the potential for direct contact with contaminated media such as
contaminated soil, surface water and groundwater at the site. Specific remedial action
objectives are to prevent direct contact or ingestion of ponded water. groundwater or soils or
debris with contaminants producing a total excess cancer risk greater rhat I X 10-6, or a III
level that exceeds 1 and to prevent the discharge of water that exceeds state or federal
surface water criteria to local storm sewers which would ultimately discharge to the Fox
River.
B. Groundwater Objectives
The NCP at Section 300.430(a)(l)(ili)(F), provides that under CERCL-'-.. U.S. EPA will
return usable groundwaters to their beneficial uses wherever practicable. '.\'irhin a timeframe
-------
12
that is reasonable, given the panicular circumstances of the site. When restoration of
groundwater to its beneficial uses is not practicable. U.S. EPA expects to prevent further
migration of the contaminant plume. prevent exposure to the contaminated groundwater, and
to evaluate further risk reduction.
The initial groundwater objective is to protect the W1derlying bedrock aquifer and contain
and/or control the further migration of contaminams. The long term remedial objective for
the N. W. Mauthe site is to reduce the contaminant concentration in groundwater to meet
state and/or federal groundwater quality standards, whichever are more stringent.
In addition to federal standards. or Maximum Contaminant Levels (MCLs), the State of
Wisconsin has established groundwater quality standards in NR 140, Wisconsin
Administrative Code (Wis. Adm. Code). Wisconsin's groundwater code, which is an
applicable requirement for remediation of the site, is more stringent than federal standards.
NR 140, Wis. Adm. Code, requires remediation of groundwater to meet numeric health
based standards.
Public health-related groundwater quality standards have been established for several of the
compounds found at the site. Many inorganic chemicals are naturally occurring in
groundwater with natural concentrations of chromium in the range of 1.0 to 5.0 p,g/L or
pans per billion (PPb). The NR 140 Wis. Adm.. Code's Enforcement Standard (ES) for total
chromium is 50 p,g/L and the Preventive Action Limit (PAL) is 5 p,g/L. The federal MCL is
100 p,g/L. Table 4 presents the state and federal standards for compounds that have been
detected at the N. W. Mauthe site.
In light of the site hydrogeologic conditions, achievement of NR 140 Wis. Adm. Code
standards and MCLs may take a very extended period of time using currently existing
technology. As a result, five (5) year reviews conducted pursuant to Sections 300.430
(t)(4)(ii) and 300.430 (t)(5)(iii)(C) of the NCP will assess whether newly developed
technologies exist to achieve NR 140 Wis. Adm. Code standards in a significantly shorter
timeframe. Should a review determine that it is not possible at that time to achieve the
groundwater standards or to achieve further reductions. then one of the following options
may be exercised:
. Continue with the action without modifications and wait until the next review to
reassess the situation;
. Consider establishing an Alternative Concentration Limit under the substantive
requirements of NR 140.28 Wis. Adm. Code, which can be no higher than the ES;
. Consider a technical impractibility waiver under Section 121(d) of CERCLA. which
may be used to set an alternative groundwater goal higher than the ES or establish other
approaches to groundwater containment or remediation that are protective of human health
and the environment.
-------
13
In no event, however, will groundwater containment and control activities be discontinued
until groundwater is cleaned to the standards designed to eliminate unacceptable health risks
based on dermal contact with the groundwater or ponded surface water.
Contaminated groundwater can appear at the surface and express itself as contaminated
ponded smrface water. Therefore, contaminated groundwater must be controlled and
remediated to meet standards designed to eliminate unacceptable health risks based on dermal
COK'l.W-ct. Remediation of contaminated groundwater to these levels is also needed to remove
h~ds associated with digging in soils saturated with contaminated groundwatcr.
VTI. D~CmwnONOFALTIillNA~
Six remedial action alternatives were carried through a detailed analysis in the Feasibility
Study (FS) prepared for the site. Detailed descriptions of each of the six remedial
al~ematives are presented in the FS. Brief descriptions of the six alternatives are presented
00 the next several pages. A summary of the c9mponents and costs associated with the six
alternatives is presented in Table 5.
Ao AJltt2rn~fth't2 1 - No Action
Th~ no action alternative was developed as required by the NCP to serve as a basis for
comparison. Under the no action alternative, no remedial activities would occur that would
reduce the volume, toxicity, or mobility of the hazardous substances at the site. TIle only
fumre activities would include institutional controls, such as access and deed restrictions, and
ffimutoring.
Access to the site would be restricted by fences. Land use restrictions for the N. W. Mauthe
property would include prohibition of subsurface work. Land use along and under the
rnilioad uacks would be restricted to its current use. Restrictions could be implemented on
the residential properties immediately to the south of the railroad tracks to require health and
safety progrnms for subsurface activities and to prohibit groundwater use. The use of private
water wells within the limits of the City of Appleton is regulated by a Well Abandonment
and Cross Contamination Ordinance that is administered by the municipality through NR
SU, Wis. Adm. Code. Under this ordinance a permit must be obtained prior to well
ins~tion. Arrangements will be made with the City to discourage well installation in the
are2l of the site through enforcement of this ordinance. In the future it might be necessary to
extend the deed restrictions to areas funher downgradient of the estimated extent of
grmmdwater contamination if groundwater monitoring shows the contamination has migrated
fumer. Other deed restrictions would be implemented that would prohibit future propeny
development. It will be necessary to negotiate with property owners to obtain their signature
on any propeny deed restriction that would affect their propeny.
-------
14
Concerns exist regarding the effectiveness of cenain institutional controls. It may be difficult
for the U.S. EPA or WDNR to obtain propeny owners' signatures on deed restrictions and
to enforce their terms. However, deed restrictions may be supplemented by the City of
Appleton's enforcement of local ordinances, zoning regulations and building permits to
regulate property use in the area. The City will be asked to further restrict property use in
the area through these mechanisms.
Selected groundwater monitoring wells would continue (Q be sampled to assess whether the
nature and extent of contamination is changing and provide early warning if substantial
changes occur.
Duration: 3 to 5 months for Construction
Groundwater Restoration* - Over 4,300 Years to Hazard Index < 1 - Over 16.000 Years to PALs
Capital Cost: $150.000. Annual O&M: $17.000. Total Present Worth: $430.000
... Natural attenuation will eventually result in reductions ill the concentrations of contaminants
observed.
B. Alternative 2 - Direct Contact Control
Alternative 2 would consist of demolition of existing on-site buildings, removal, treatment,
and disposal of the building material and debris and stored containers of soil. It would also
include construction of a soil cover and the use of institutional controls discussed in
Alternative 1. Additionally, the basement floors and walls of the homes and businesses
within the area of contaminated groundwater would be cleaned and painted or sealed to
reduce the potential for infiltration of contaminated water; and to remove the potential for
direct contact with contaminants in the basements.
Before soil cover installation, containers of soil curremly located on-site would be removed.
treated, and disposed of. The site buildings would be decontaminated, demolished and
transported off-site for treatment and disposal.
The soil cover would extend over the area within the N. W. Mauthe property boundaries and
south along the railroad tracks. The extent of the soil cover is shown on Figure 8. 'This
area was selected because it covers the soil with chromium concentrations resulting in a HI
level exceeding 1. The cover would be constructed to satisfy substantive NR 506.08(3),
Wis. Adm. Code, solid waste landfill cap standards. and would consist of at least two
(2) feet of imported clay soil with topsoil over it. The topsoil would be seeded and a
vegetated cover established and maintained.
Surface water runoff controls would be constructed at the cover's perimeter. The runoff
controls would divert surface water to the storm sewer.
Operation and maintenance for this alternative would include inspection and maintenance of
the cover and the site in general. The hazardous substances would be left in place under the
-------
15
soil cover and as such, the soil cover and institutional controls would need to be maintained
indefmitely.
Duration: 3 to 5 Months for Construction
Groundwater Restoration'" - Over 4.300 Years to Haz.ard Index < 1 - Over i6.000 Yl'Rrs to PALs
Capital Cost: $940.000
Annual Operation and Maintenance Cost: $34.000
Total Present Worth: $1.600.000
.Natural attenuation wiU eventually result in reductions in the concentrations of contaminants observed.
C. Alternative 3 - Groundwater Collection
Alternative 3 would include the construction of a groundwater collection and treatment
system, removal of site buildings and debris, construction of a soil cover. and
implementation of institutional controls. The soil cover would be the same as that described
for Alternative 2, as would the building and debris removal and institutional controls.
Alternative 3 would also include cleaning and painting or sealing the basements of homes or
businesses as described in Alternative 2.
A groundwater collection system would be installed as shown in Figure 8. 'This figure
shows a conceptual layout for collection trenches; the final layout would be established
during the Remedial Design (RD) phase of the project. A trench would be constructed
parallel to the railroad tracks to prevent further migration of hazardous substances from the
N. W. Mauthe property. A second trench would be located to the west of the N. W. Mauthe
property, extending from the railroad tracks to Melvin Street. A third trench would be
constructed along Outagamie and Second Streets to collect contaminated groundwater that
had already migrated away from the property.
The placement of the trenches would be done in a manner to avoid damaging homes or
utilities, unless absolutely necessary. The majority of the collection trenches would be
approximately 16 feet deep. The trench parallel to the railroad tracks and the trench west of
the site would be excavated to a depth of approximately 25 feet to address deeper on-site
contamination.
Perforated polyvinyl chloride (PVC) drain pipe would be installed in the bottom of the
trenches, with the excavation backfilled with gravel and imponed soil near the surface. A
geotextile layer would be placed between the gravel and the soil to avoid migration of fine
material into the gravel. Construction near the railroad tracks would require safeguards and
coordination with the railroad to avoid significant interruptions of rail service and to avoid
hazards to site workers. New or improved foundation drain systems around the existing
homes and businesses in the area of groundwater contamination would be installed ~md tied
into the collection trench system.
Collected groundwater would be treated in an on-property treatment system. to meet local
pretreatment discharge limits before release to the City of Appleton sanitary sewer system.
-------
16
Table 6 lists the POTW discharge limits. If this discharge option was not available, a
discharge to the Fox River through a stonn sewer could be implemented. but would require
additional treatment. The need for VOC or cyanide treatment, in addition to treatment for
chromium, would be evaluated during RD considering both discharge and air emission limits
(Tables 6 and 7). Sludge from the treatment process would be dew ate red in a tiIter press
and would require treatment to meet applicable requirements prior to disposal.
As with Alternative 2, hazardous substances would remain in place if Alternative 3 was
implemented. Maintenance and monitoring would continue indefinitely. Operation and
maintenance would be required for the groundwater collection and treatment system, the
cover, monitoring, and institutional controls. The other elements of Alternative 3 would also
require maintenance and monitoring as discussed in Alternative 2.
Duration: 5 to 10 Months for Construction
Groundwater Cleanup - Over 280 Years to Hazard Index < 1 - Over 1.050 Years to PALs
Capital Cost: $4,600,000
Annual Operation and Maintenance Cost: $210.000
Total Present Worth: $8,100,000
D. Alternative 4 - Hot Spot Soil Removal
Alternative 4 would include the construction of a groundwater collection and treatment
system, removal of site buildings and debris, construction of a soil cover, basement
cleaning/painting and implementation of institutional controls. These remedial elements are
described above in the summaries of Alternatives I through 3. Alternative 4 would also
include removal of chromium, VQC and cyanide contaminated soil containing a
large percentage of the contaminant mass.
In addition to meeting the remedial action objectives, Alternative 4 accomplishes the
CERCLA objective of reducing the toxicity, mobility, or volume of hazardous substances.
Soil containing more than 500 mg/kg of total chromium would be removed, treated. and
disposed of off-property. This removal would result in approximately an 80 percent
reduction of the chromium contaminant mass and a large percentage of the cyanide and VOC
contaminant mass.
The soil that would be addressed in a hot spot removal is shown in Figure 8, as are the other
components of Alternative 4. It is estimated that a total of 6200 cubic yards of soil would be
removed. The hot spot removal excavation may be converted into an additional collection
sump. The feasibility of this conversion will be detennined during the design phase.
Additionally, removal of soils from beneath the railroad tracks will be considered if it is
detennined during the design phase that it is feasible to do so in a way that allows the
railroad reasonable and nonnal use of the tracks.
The maintenance and monitoring requirements for Alternative 4 would be similar to those
discussed for Alternative 3. In general, the duration of maintenance and monitoring would
-------
17
be indefInite. Because this soil removal would remove an estimated 80 percent of the
chromium contaminant mass, the time required to meet groundwater remedial objectives may
be reduced, compared to Alternative 3. However. a long period of time would still be
required.
Duration: 5 to 10 Months for Construction
Groundwater Cleanup - Over 270 Years to Hazard In~ < 1 - Over 1.012 Years to PALs
Capital Cost: $6.640,000
Annual Operation and Maintenance Cost: $220.000
Total Present Worth: $10.090,000
E. Alternative 5 - In Situ Soil Remediation
Alternative 5 would include removal of site buildings and debris, construction of a
groundwater collection and treatment system, construction of a soil cover, basement
cleaning/painting and implementation of institutional controls. These remedial elements are
described above in the summaries for Alternatives I through 3. Additionally, this alternative
includes in situ (in-place) treatment of contaminated soil. It is similar to Alternative 3 with
the addition of the in situ treatment of soil.
In addition to meeting the remedial action objectives. in situ, deep soil mixing would result
in a reduction of the toxicity and mobility of the hazardous substances in soil. It does not
reduce the volume of contaminated soil at the site because the contaminant mass is left in
place. The deep soil mixing would stabilize the soil mass to reduce the mobility of
contaminants.
Under Alternative 5, soil with total chromium concentrations exceeding the background
concentration would be treated using deep soil mixing technologies.. Reducing agents and
stabilization chemicals would be added to the soil to reduce hexavalent chromium to trivalent
chromium and stabilize the soil mass. The deep soil mixing would be performed using a
large crane with augers that bore into the soil, mixing it and introducing various chemicals.
The estimated limits of soil contamination extends under some of the residences. however,
soil mixing would end at least 20 feet from the buildings. At least two feet of clean fill
would be placed over the stabilized mass to maintain the existing surface elevation near the
residences.
In the soil around and below the railroad tracks, alternative soil mixing techniques would be
required to treat contaminated soil with minimal interruption of rail service.
Following the deep soil mixing, the soil cover and groundwater collection and treatment
system would be constructed. Institutional controls would be implemented, as in
Alternatives I through 4.
The maintenance and monitoring requirements for Alternative 5 are similar to those
presented in Alternative 3. Contaminant movement out of the solidified soil would be greatly
-------
18
reduced. but not eliminated entirely. Because some contamination would continue to leach
out, the achievement of groundwater remedial objectives would take a very long time. The
estimated time to meet groundwater goals is increased due to the increased retardation of
contaminants in the solidified mass and decreased groundwater flow through the mass.
Duration: 7 to 10 Months for Construction
Groundwater Cleanup - Over 28.000 Years to Hazani-lndex < 1
Capital Cost: $11.000.000
Annual Operation and Maintenance Cost: $210.000
Total Present Worth: $15.000.000
- Over 105.000 Years to PALs
F. Alternative 6 - Ex Situ Soil Remediation
Alternative 6 includes all of the same remedial elements in Alternative 5 except the cap,
however, soil containing chromium in excess of the background concentration would be
excavated and taken off-propeny for treatment and disposal instead of being stabilized in
situ. This alternative would achieve the same remedial action objectives as in Alternative 5
with the addition of fully remediating soils to background concentrations.
Under Alternative 6, soil containing total chromium in excess of the background
concentration would be excavated and transported off-property for treatment and disposal. It
is estimated that a total of 32,000 cubic yards of soil would be removed. Excavation would
occur on both sides of the railroad tracks, with the deepest excavation occurring on the
property .
The soil under the railroad tracks and the associated contaminant mass would be removed
under this alternative. Potential conflicts with the railroad may exist if the tracks were to be
put out of service for an extended period of time.
The excavated areas for this alternative would be backIilled with clean fill, with topsoil
placed over it. The surface would also be revegetated. A soil cover would not be required
because the soil containing significant concentrations of hazardous substances would have
been replaced.
The only institutional controls that would be implemented under this alternative would be
groundwater use restrictions and potentially some land use restrictions.
This alternative has the lowest degree of maintenance and monitoring of the alternatives,
excluding Alternative 1. Following completion of the soil removal, only the groundwater
collection and treatment system would be operational. There would not be a soil cover to
maintain. Because most of the contaminant mass will be removed in this alternative, it is
feasible that the groundwater remedial action objectives may be achieved within a shoner
time frame as compared to the other alternatives.
Duration: 9 to 24 Months for Construction
Groundwater Cleanup - Over 200 Years to Hazard Index < 1
-------
19
- Over 675 Years to PALs
Capital Cost: $12.000.000
Annual Operation and Maintenance Cost: $190.000
Total Present Worth: $15.000.000
VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
A. Introduction
To detennine the most appropriate remedial alternative for the N.W. Mauthe site. the
alternatives were evaluated against each other. Nine Criteria have been established by the
U.S. EPA that balance health, technical and cost considerations to detennine the most
appropriate alternative. Comparisons were based on these nine evaluation criteria. which are
outlined below.
1. OveraU Protection of Human Health and tbe Environment addresses whether a
remedy protects human health and the environment and whether risks are properly
eliminated, reduced, or controlled through treatment. engineering controls, or institutional
controls.
2. Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
addresses whether a remedy meets all state and federal environmental laws and
requirements that apply to site conditions and cleanup options.
3. Long-term Effectiveness and Permanence refers to the ability of a remedy to reliably
protect human health and the environment over time once cleanup goals have been met.
4. Reduction of Toxicity, Mobility, or Volume through Treatment are three principal
measures of overall perfonnance of an alternative. The 1986 Superfund Amendments and
Reauthorization Act (SARA) emphasizes that whenever possible, a remedy should be
selected that will pennanently reduce the level of toxicity of the contaminants at the site,
the spread of contaminants away from the site, and the volume, or amount, of
contaminants at the site.
5. Short Term Effectiveness refers to the likelihood of any adverse impacts to human health
or the environment that may be posed during the construction and implementation period
until cleanup goals are achieved.
6. Implementability is the technical and administrative feasibility of a remedy, including the
availability of materials and services needed to implement the remedy.
7. Cost includes capital, annual operation and maintenance (O&M) and total (net) present
worth costs of implementing a remedy.
8. Agency Acceptance indicates whether, based on its review of the data, the State of
-------
20
Wisconsin (Depanment of Natural Resources) "and the U.S. EPA concur with the
alternative proposed as the preferred response technology for the site.
9. Community Acceptance indicates whether the public concurs with, opposes. or has no
comments on the remedy presented in the Proposed Plan. Comments are addressed in the
Responsiveness Summary.
B. 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. Alternatives that do not meet the
Threshold Criteria will not be considered in evaluation of the remaining seven criteria.
These two criteria are discussed below.
I. Overall Protection of Human Health and the Environment
With the exception of Alternatives I and 2, and .assuming all deed, use and access
restrictions are adequately enforced, all remaining alternatives will be protective of human
health and the environment.
Alternative I is not considered protective of human health or the environment. Off-site
contaminated surface soils remain a threat through dermal absorption or ingestion.
Contaminated surface water runoff could discharge into the Fox River. As Alternative I
does not meet the requirements of the Threshold Criteria it will not be discussed further.
Alternative 2 would remove the threats related to surface soil through use of a soil cover.
Hazardous substances in groundwater would be allowed to migrate from the site. 'This
migration would be monitored. 'This alternative is not considered protective because it does
not remediate contaminated groundwater to remove health risks based on the dermal contact
with contaminated groundwater nor prevent the potential for contact with any surface
expression of contaminated groundwater. As Alternative 2 does not meet the requirements of
the Threshold Criteria it will not be discussed further.
Alternative 3 would also use a soil cover to remove the threats related to surface soil and
surface water runoff. It would additionally contain and/or control and over time reduce
groundwater contamination. Alternatives 4 through 6 provide active treatment, on- or off-
site, of contaminated site soils. These alternatives would also contain and/or control
groundwater contamination. They are additionally expected to produce reductions in
groundwater contamination more quickly than would Alternative 3. To ensure
protectiveness, excavated soils for which listed hazardous waste requirements are relevant
and appropriate for on-site activities will also satisfy such requirements for off-site activities.
including treatment and disposal. Because Alternative 6 removes the most contaminated soil
that acts as a continued source of groundwater contamination, it is the alternative that is
expected to obtain the most rapid reduction in groundwater contaminant levels, followed by
-------
21
Alternative 5 and then Alternative 4.
The groundwater collection alternatives would initially contain and/or control contaminated
groundwater through extraction and through influencing hydraulic gradients to inhibit flow of
contamination away from the site. Long term operation of the containment system should
also lead to ultimate achievement of the groundwater cleanup ARARs in NR 140 Wis. Adm.
Code. In light of the site hydrogeologic conditions, achievement of NR 140 Wis. Adm.
Code standards and MCLs may take a very extended period of time using currently existing
technology. As a result, five (5) year reviews conducted pursuant to Sections 300.430
(t)(4)(ii) and 300.430 (t)(5)(ili)(C) of the NCP will assess whether newly developed
technologies exist to achieve NR 140 Wis. Adm. Code standards in a significantly shorter
timeframe. Should a review determine that it is not possible at that time to achieve the
groundwater standards or to achieve further reductions. then one of the following options
may be exercised:
. Continue with the action without modifications and wait until the next review to
reassess the situation.
. Consider establishing an Alternative Concentration Limit under the substantive
requirements of NR 140.28 Wis. Adm. Code, which can be no higher than the ES;
. Consider a technical impractibility waiver under Section 121(d) of CERCLA, which
may be used to set an alternative groundwater goal higher than the ES or establish other
approaches to groundwater containment or remediation that are protective of human health
and the environment.
In no event, however, will groundwater containment and control activities be discontinued
until groundwater is cleaned to the standards designed to eliminate unacceptable health risks
based on dermal contact with the groundwater or ponded surface water.
Alternative 4 reduces the soil chromium mass by approximately 80 percent. Soil containing
greater than 500 mg/kg of total chromium would be excavated, treated and disposed of. The
majority of the soil VOC and cyanide mass would also be removed. Under Alternative 6,
soil containing total chromium above the background concentration would be excavated,
treated and disposed of. Alternative 3 relies entirely on the leaching and collection of all the
contaminants through implementation of a groundwater collection system to remediate the
soils. Alternative 4 would rely on the groundwater collection system to remediate the
contaminant mass remaining after excavation through leaching. Alternative 5 would fix most
of the contaminants in place and would rely on the groundwater collection system to continue
to collect the leachable contamination.
Alternatives 1 through 6 would require land and groundwater use restrictions with indefinite
time frames because hazardous substances would be left in place. The only institutional
controls that would expected to be implemented under Alternative 6 would be groundwater
-------
22
use restrictions. However, some land use restrictions may be necessary under that
alternative (e.g., to avoid direct contact with contaminated groundwater).
2. Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
Alternatives 3 through 6 would be in compliance with NR 140 Wis Adm. Code through the
active collection and treatment of contaminated groundwater. NR 140 Wis. Adm. Code
requires that a remedial action be taken to restore contaminated groundwater within a
reasonable period of time (NR 140.26 (2) Wis. Adm. Code) when an ES is exceeded.
Additionally, under Chapter 160, Wisconsin Statutes (Wis. Stats.) and NR 140, Wis. Adm.
Code, PALs are the cleanup goals to which groundwater is to be restored if technically and
economically feasible. Alternatives 3 through 6 would conf'me the groundwater
contamination within a one-block area, and are expected to reduce the contaminant
concentrations. Alternatives 3 through 5 may achieve groundwater standards, but are
expected to take a long time to do so. Alternative 6 may eventually achieve groundwater
standards in a shoner period of time when compared to the other alternatives.
The groundwater collection alternatives would initially contain and/or control contaminated
groundwater through extraction and through influencing hydraulic gradients to inhibit flow of
contamination away from the site. Long tenn operation of the containment system should
also lead to ultimate achievement of the groundwater cleanup ARARs in NR 140 Wis. Adm.
Code. In light of the site hydrogeologic conditions, achievement of NR 140 Wis. Adm.
Code standards and MCLs may take a very extended period of time using currently existing
technology. As a result, five (5) year reviews conducted pursuant to Sections 300.430
(f)(4)(ii) and 300.430 (f)(5)(iii)(C) of the NCP will assess whether newly developed
technologies exist to achieve NR 140 Wis. Adm. Code standards in a significantly shoner
timeframe. Should a review detennine that it is not possible at that time to achieve the
groundwater standards or to achieve funher reductions. then one of the options discussed in
Section VI(B) of this document may be exercised. A decision to establish an alternative
cleanup standard or invoke a technical impracticability waiver may require an amendment to
this ROD.
Under Alternatives 3 through 6 the requirements of the Resource Conservation and Recovery
Act (RCRA) are applicable to all wastes (Le. building debris), treatment residuals, and
excavated soils that constitute characteristic wastes under NR 605.08 Wis. Adm. Code and
40 CPR Pan 261 Subpan C. In light of the nature of cyanide contamination in soil, and the
high likelihood that the contamination came rrom plating wastes, RCRA requirements for
listed plating wastes F007 and F008, including the requirements of 40 CPR Pan 268, are
generally relevant and appropriate for cyanide-contaminated material at the site which
exceeds the Pan 268 treatment standards. For Alternatives 3 through 6, consistency with
those requirements and overall protectiveness of human health require treatment of wastes
containing significant amounts of cyanide that are removed from the site to the standards
required for F007 and F008 waste in 40 CPR ~~ 268.41 and 268.43 (or alternatively to
standards set under a treatability variance pursuant to 40 CPR ~ 268.44) prior to disposal.
-------
23
Similarly, under Alternatives 4 and 6 this treated cyanide-contaminated material would be
disposed of in a RCRA Subtitle C landfill. An estimated ten (10) cubic yards of soil in both
Alternatives 4 and 6 would require separate management because of cyanide concentrations
which are expected to exceed LDR treatment standards and require compliance with LDR
treatment and disposal requirements.
Alternatives 3 through 5 will leave varying amounts of contaminated soils on site. RCRA
Subtitle C requirements for a multilayer cap are relevant, but not appropriate. for the soil
cover to be placed over those soils. Under Alternative 5 the soil will have been treated in
place to immobilize the contaminants. Even under Alternative 3, where all of the
contaminated soils will remain in place without treatment, at this site infIltration of
precipitation and snowmelt into the native, low penneability, clay soils is not expected to
have a significant impact on the movement of contaminants from those soils. The soil cover
in Alternatives 3 through 6, which will meet the substantive requirements for a solid waste
landfill cap under NR 506.08(3) Wis. Adm. Code, meets all relevant and appropriate landfill
capping requirements and will prevent direct contact with the remaining contaminated soil.
Substantive RCRA general operating requirements are also relevant and appropriate for on-
site handling, transportation, and treatment of contaminated materials.
Alternative 3 would not be in compliance with the requirements of the State Hazardous
Substance Discharge Statute, s.I44.76, Stats., and rules recently promulgated pursuant to that
statute, ch.NR 700 series, Wis.Adm. Code. These new rules are expected to be effective on
May 1, 1994. The statute and rule require that contaminated soil be restored to pre-spill
conditions to the extent practicable. Because promulgated soil standards, adopted pursuant to
s.I44.76, Stats., are not yet in effect, guidance on the restoration of spill sites to background
concentrations or to "no detect", where practicable would not be an ARAR, but, should
considered in the evaluation of alternatives 3 through 6. Alternatives 4 through 6 would
meet the requirements of s.I44. 76, Stats.. because they would restore the soils at the site to
the extent practicable. Alternative 3 would not.
Collected groundwater under Alternatives 3 through 6 will be treated to meet state and local
pretreatment standards prior to discharge to the Appleton P01W. Table 6 presents the
current and proposed discharge limits of the City of Appleton's Municipal Sewer Code. A
discharge permit or approval from the City of Appleton will be obtained prior to discharge.
Should the P01W discharge option be unavailable, due to P01W capacity limitations or
other unforeseen circumstances, then the discharge will be treated to meet state wastewater
discharge standards for a discharge to the Fox River. Treated water would be directed to the
storm sewer at the site. The groundwater treatment system would be designed to meet Best
Available Technology (BAT) requirements.
Injection of chemical agents through an auger mixing system under Alternative 5 is
considered underground injection through a well under the state well rule, NR 112 Wis.
Adm. Code. While underground injection is nonnally prohibited under that code. a variance
-------
24
may be granted. The injection process would be required to meet any substantive technical
standards generally applied under that rule in order to obtain a variance.
Based on the VOC concentrations in the collected groundwater (influent) and the effluent
discharge requirements, it may be necessary to air strip collected groundwater under
Alternatives 3 through 6 to remove VOCs prior to discharge. Should that become necessary,
the emissions from the air stripper would comply with the state hazardous air emissions rule.
NR 445 Wis. Adm. Code. Limits associated with the hazardous air emissions rule would
also apply to emissions caused by disturbance of contaminated soils at the site. The need for
VOC (as well as cyanide) removal will.be detennined during the RD. Table 7 presents the
emission limits from a point source treatment unit for contaminants of concern at the site that
are regulated for air emissions.
Therefore, Alternatives 3 through 6 will comply with ARARs or will proceed after satisfying
the substantive requirements for appropriate variances.
C. Primary Balancinl! 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 baJanced
to identify the preferred alternative and to select the tinal remedy.
1. Lone Tenn Effectiveness and Pennanence
The baseline risk assessment conducted during the RI indicated that significant risks exist
under current land use caused by surface soils containing chromium and cadmium, and even
greater risks exist under future land use caused by use of chromium-containing groundwater,
and future land development uncovering subsurface soils. Alternatives 3 through 5 use
institutional controls and a soil cover to serve as a barrier (0 mitigate the risk presented by
contacting or ingesting contaminated surface soils. and prevents surface water from
contacting contaminants.
Alternatives 3 through 6 collect and treat groundwater exceeding NR 140 Wis. Adm. Code
standards. Groundwater would be intercepted by trenches, minimizing further migration of
hazardous substances in groundwater. If discharge to the Appleton POTW is not allowed,
. for whatever reason, discharge of treated groundwater to the Fox River will meet Wisconsin
discharge standards, therefore, environmental impacts are not expected.
Groundwater use restrictions are expected to be readily enforceable, as a public water supply
is available, and its use for drinking water is required by the City of Appleton. Monitoring
and fence maintenance for all the alternatives are considered reliable if properly managed.
The reliability of the soil cover will depend on regular maintenance in addition to
establishing vegetation. The reliability of in situ soil remediation to reduce the hexavalent
chromium and stabilize soil contaminants would need to be tested.
-------
25
Concerns exist regarding the effectiveness of certain institUtional controls. It may be difficult
for the U.S. EPA or WDNR to obtain property owners signatures on deed restrictions or
t:asements. and to enforce their terms. However. lked restrictions may be supplemented by
the City of Appleton' s enforcement of local ordinances. zoning regulations and building
permits to regulate property use in the area. TIle City wiil be asked to further restrict
property use in the area through these mechanisms~
Alternatives 4 and 5 reduce the potential for introducing new contamination into groundwater
by removing the most highly contaminated soils or treating them in place. respectively.
Alternative 6 provides even stronger assurances that continuing sources of contamination are
removed from the site through the removal and off-site treatment of soils above background
chromium concentrations. .
Under Alternative 3 no soil contamination will be removed from the site. Approximately 20
percent of the soil contaminant mass will be left in place under Alternative 4. However, the
soil chromium concentrations remaining under Alternative 4 would be less than that
concentration representing a III of 1. Alternative 5 would not remove any contaminant mass
from the soil, but would stabilize it in place. All soils exhibiting a chromium concentration
above the calculated background level would be removed under Alternative 6.
In light of the site hydrogeologic conditions, achievement of the NR 140, Wis. Adm. Code
groundwater standards may take an extended period of time using currently existing
technology. As a result, five (5) year reviews conducted pursuant to Sections 300.430
(f)(4)(ii) and 300.430 (t)(5)(ili)(C) of the NCP will assess whether newly rlc"eloped
technologies exist to achieve those standards in a significantly shorter ti~.;irame. Data
developed over time may indicate that it is not possible at that time to achiev'.; NR 140 Wis.
Adm. Code standards or even to achieve further reductions. At that point. :.1e lead agency, in
consultation with the support agency, may develop alternative cleanup ~('lis. as discussed in
Section VI(B) of this document. or determine that further operation of the system is not
required.
2. Reduction in Toxicity. Mobility. and Volume ThrouI?h Treatment
Alternatives 3 through 6 include demolition of the site buildings and removal of stored soils,
building material and debris for off-site treatment and disposal. .
Alternatives 3 through 6 additionally include groundwater containment or control and
reduction of contaminant concentrations through coUection and treatment. The maximum
estimated flow of groundwater into the collection system is five (5) gallons per minute
(gpm). The effect of the extraction system on groundwater serves to reduce the mobility of
contamination in groundwater. The groundwater treatment system would be designed to
meet Best Available Technology (BAT) requirements. Metals would be removed using
chemical reduction and precipitation and activated carbon adsorption would be used to
remove VOCs (or treatment for cyanide if needed) to meet discharge or emission standards.
-------
26
Residual sludge will require off-propeny treatment and disposal. Alternative 5 is expected to
collect a smaller amount of contaminated groundwater because of soil solidification. The
contaminant concentrations in the collected groundwater would be expected to decrease over
time under Alternatives 4 through 6 because the alternatives include reductions in the volume
and mass or mobility of hazardous substances.
Alternatives 4 and 6 involve removing soil from the site for treatment to achieve appropriate
standards for disposal in a landfill. This treatment will reduce toxicity and mobility of the
materials. Approximately 6200 cubic yards of contaminated soil would be excavated and
treated under Alternative 4. This represents an estimated 80 percent reduction of the
chromium contaminant mass and a large percentage of the VOC and cyanide contaminant
mass. Alternative 6 includes removal of approximately 32.000 cubic yards of soil for
treatment and disposal. .Au1 estimated ten (10) cubic yards of soil in both Alternatives 4 and
6 would require separate management because of cyanide concentrations which are expected
to exceed LDR treatment standards and require compliance with LDR treatment and disposal
requirements. These soils would likely be taken to an out-of-state facility for cyanide
destruction and disposal.
Chromium would be reduced to the trivalent state under Alternative 5, with its reduced
toxicity and mobility. 'This Alternative's reduction of hexavalent chromium in the soil,
followed by stabilization inhibits the chemicals from mobilizing into the groundwater.
3. Short Term Effectiveness
Remedial actions may potentially affect the community and safety of on-site workers in three
ways: increased truck traffic and heavy machinery noise and accident potential; short-term
dust and VOC emissions; and possible temporary disruption of railroad service. Truck
traffic and the use of heavy machinery generally causes nuisances from noise and dust and
increases the risks of accidents. The amount of truck traffic needed to impon soil for the
soil cover or to export excavated contaminated soil and building debris will vary among the
alternatives. During construction of the soil cover under Alternatives 3 through 5, there will
be heavy truck traffic associated with bringing soil to the site for approximately 4 months.
Soil removal (Alternatives 4 and 6) will involve heavy truck traffic for transponing soil to a
facility for treatment and bringing soil to the site for backfill for up to a year. Safety
measures for traffic control, such as increased signage, will be taken to mitigate these risks.
Building demolition is pan of Alternatives 3 through 6 along with the removal and disposal
of contaminated soils stored on-site. Excavation of contaminated soil is included in
Alternatives 4 and 6, and excavation to install groundwater collection drains is included in
Alternatives 3 through 6. Dust containing hazardous substances and VOC emissions may be
released during excavation and demolition activities. Wetting solutions or foams would be
used to control emissions if monitoring indicated the need. Emissions would be expected to
be low during soil mixing, under Alternative 5, because the process is typically performed by
injecting liquid solutions and, if needed, using a shroud over the mixing auger. The
-------
27
effectiveness of, and emissions from. deep soil mixing would require evaluation through
treatability studies before full scale use. Air emissions would be monitored under all of the
alternatives.
Alternatives 3 through 6 involve varying degrees of activity near the active railroad tracks.
All activities perfonned near the tracks would req\ure additional safety considerations, and
communication with railroad personnel to avoid injury and work disruptions. Alternative 5
may include conducting deep soil mixing under the tracks with temporary disruption of rail
service possible. Alternative 6, and possibly Alternative 4, would require the temporary
closure of the tracks to facilitate excavation under them. The decision on whether to remove
the soil from beneath the tracks, for Alternative 4, will be made during RD.
The time required for design, procurement, and construction of Alternatives 3 through 6 is
estimated to range from two (2) to five (5) years. The time until remedial construction is
complete will be controlled by the technologies selected. Alternatives 3 could probably be
constructed within a single construction season. The groundwater collection trench could be
installed concurrently with the soil cover, with ~ expected duration of four (4) months. The
duration of soil removal alternatives would be controlled by the volume of soil involved and
the ability to treat the material. The duration of soil excavation and treatment for Alternative
4 would be approximately four (4) months and between six (6) and 18 months for removing
soil to background concentrations in Alternative 6. The deep soil mixing of Alternative 5. is
estimated to require approximately four (4) months. The construction of the groundwater
treatment system in Alternatives 3 through 6 would take an estimated three (3) to six
(6) months.
Some elements of the alternatives could be implemented in a short time frame. Demolition
of the buildings and removal of the containers of soil could occur concurrently with design of
other elements of the selected alternative.
Soil erosion and siltation during earthwork activities in Alternatives 3 through 6 could be a
problem, but use of silt cunains with regular inspection would mitigate potential impacts.
Alternatives 4 and 6 would create the greatest short -tenn risks to public health and the
environment during excavation, but air monitoring and construction controls would be
perfonned to minimize those risks. Those short tenn risks would be greatest for Alternative
6, which requires roughly 10 times as much soil excavation as Alternative 4.
4. Implementability
Technical difficulties may be encountered during construction activities along or under the
railroad, and during excavation and installation of the groundwater collection trenches along
local streets. The groundwater collection trench under Alternatives 3 through 6 would be
constructed in locations containing buried utilities, which would either have to be relocated
or excavation would have to proceed slowly to avoid disrupting service as much as possible.
-------
2S
Remediation in or near the railroad right-of-way must consider rail traffic requirements.
Obtaining access from the railroad may be difficult and time consuming for Alternative 6 and
possibly Alternative 4, if it is decided to remove the contaminated soils from beneath the
tracks. '
Access agreements from some of the adjacent propeny owners and the City of Appleton
would have to be obtained to construct the collection trenches under Alternatives 3 through
6. Such agreements from some of the adjacent property owners would also need to be in
place to perform the in situ soil treatment under Alternative 5 and the soil removal under
Alternatives 4 and 6. If access agreements cannot be obtained, it would be necessary to
pursue enforcement action to compel access under U.S. EPA's statutory authorities.
The technical feasibility of the deep soil mixing technology in Alternative 5 is unproven for a
full scale chromium reduction and stabilization project. However, it has been used to
stabilize other metals and some organic chemicals. The chemistry for reducing hexavalent
chromium is well established and the technology is expected to work effectively.
The ex situ treatment of chromium contaminated soil is a proven technology and reportedly
has been successfully applied.
Approval from the City of Appleton and compliance with the local and state pretreatment
standards will be necessary to discharge treated groundwater to the sanitary sewer. If the
sanitary sewer option is unavailable, then the substantive requirements of a Wisconsin
Pollution Discharge Elimination System (WPDES) permit must be met if treated groundwater
is to be discharged to the Fox River.
If necessary, a treatability variance for soils containing F007 and FOOS listed wastes would
be requested under several of the alternatives where cyanide is detected above LDRs. The
substantive requirements normally imposed under a variance from the WDNR prohibition on
injection of chemicals into the ground would be met for Alternative 5. Any required local
approvals to perform construction in the city streets and to demolish buildings would be
obtained, if necessary.
For those soils transported off-site for treatment and disposal there remains some uncertainty
regarding the availability of facilities. There are facilities that are currently in compliance
with state and federal environmental laws and capable of handling the waste generated from
the site. However, it is not possible at this time to state that there will be appropriate
facilities available that are in compliance and with the necessary capacity to handle the
volume of waste generated at the time the selected remedial action is implemented.
Concerns remain regarding the effectiveness of certain institutional controls. It may be
difficult for the U.S. EPA or WDNR to obtain property owners' signatures on deed
restrictions or easements and to enforce their terms. However, deed restrictions may be
supplemented by the City of Appleton's enforcement of local ordinances, zoning regulations
-------
29
and building pennits to regulate propeny use in the area. The City will be asked to further
restrict propeny use in the area through these mechanisms.
5. Cost
A summary of costs is presented in Table 5. Refei'to the FS Repon for detailed infonnation
on the cost estimates. The cost estimates were prepared to aid in the evaluation of the
alternatives. The costs were developed at an order-of-magnitude level, with an expected
accuracy of +50 to -30 percent. The cost estimates consist of total capital costs,
replacement costs, operation and maintenance costs and total present wonh (5 % discount rate
over a 30 year period). Final project costs will depend on actual labor and material costs,
actual site conditions, weather conditions and the fInn selected to perfonn the work. The
remedial cost estimates will be revised during RD.
D. Modifyine: Criteria
1. Agency Acceptance
The State of Wisconsin and the U.S. EPA are in agreement with the selected remedy. This
decision document has been issued jointly by botb agencies.
2. Community Acceptance
Several comments were given at the public meeting presenting the Proposed Plan and several
were also received in writing. The WDNR has reviewed and responded to all comments
submitted on the Proposed Plan in the attached Responsiveness Summary.
In general. the primary objection raised in the comments was the lack of a program in the
remedy to purchase, or otherwise obtain with compensation, adjacent homes and businesses
by the government so the owners of these propenies could recover the propeny values lost
by the presence of the contamination. It is U.S. EPA's policy not to buy propenies where it
is doing cleanup. There are several reasons behind this policy. The main reason behind this
policy is that U. S. EP A has limited funds to accomplish the task of cleaning up all of tbe
country's worst hazardous waste sites. As a result, U.S. EPA has a responsibility to see that
its limited resources go toward actual cleanup.
In addition, the site neighbors will benefIt from having contamination removed from under
their propenies and the action minimizes the potential for additional migration of
contamination from the Mauthe propeny onto their propenies. This should increase the
value of those properties. It is U.S. EPA's policy that it will not try to charge neighboring
residential landowners for any of the cleanup costs unless those landowners were the cause of
the pollution. U.S. EPA also has the ability to give protection from potential Superfund
liability to persons who might want to buy these properties under U.S. EPA's prospective
Purchaser Policy. .
-------
30
State of Wisconsin environmental laws basically state that the owner of a propeny with
contamination on that propeny is responsible for cleanup of the contamination. However, in
a situation where the source of contamination is known to be from a separate propeny, such
as the N. W. Mauthe site. it is the state's position to try and obtain remediation from the
responsible party, rather than the owner of a adjacent property. Additionally, it is not the
State of Wisconsin's policy to pursue cleanup frolJU!. purchaser of an adjacent propeny.
While U.S. EPA cannot purchase these properties. U.S. EPA will. in cooperation with the
WDNR, design the remedy to make sure that the inconvenience and intrusion on neighboring
properties is kept to a minimum. The cleanup will also be designed to ensure that any
unacceptable environmental hazards are removed from the neighborhood so it can be returned
to nonnal as much as possible.
Also, one commenter stated a preference for implementation of Alternative 6. as a 100
percent cleanup of soil contamination was desired.
IX. 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, nor do they comply with ARARs. They therefore
do not meet the threshold test for selection of a remedial alternative at the site. Alternatives
3 through 6 would all be protective and would attain ARARs. Meeting groundwater quality
standards would take a very long time for each of these alternatives.
Alternatives 3 through 6 all use treatment to reduce the toxicity, mobility or volume of the
contaminant mass to varying degrees. Alternative 5. does not however, reduce the volume
as it solidifies the contaminant mass in place. Alternative 3 removes contaminant mass only
through the collection and treatment of impacted groundwater. Sole reliance on groundwater
collection to remove contaminant mass, would be a very lengthy process without significant
short tenn benefits. As compared to Alternative 3, Alternative 4 removes the majority of the
contaminant mass, as well as satisfying the statutory preference for treatment and adding an
additional level of permanence.
Implementation of Alternatives 3, 4 or 6 is not expected to pose any technical problems since
the proposed actions utilize proven technologies and have been used at other sites with
similar problems. Alternative 5 utilizes technology that has not been proven to be effective,
as it has not had full scale application at sites with hexavalent chromium as the main
contaminant of concern.
Alternatives 5 and 6 would be significantly more costly than Alternative 4, however. they
would not be significantly more protective. The increased cost of Alternative 6 would
address approximately 20 % more of the contaminant mass than Alternative 4, . with much
greater capital cost. The additional soil removed by Alternative 6 would be at chromium
-------
31
concentrations less than those identified in the Risk Assessment as producing a III level of 1
for dermal exposure (570 mg/kg) or ingestion (780 mgl kg). Neither Alternatives 5 nor 6
eliminate the need for groundwater containment and/or controL with associated collection and
treatment or the related costs.
x. The Selected Remedy
Based on the evaluation of the alternatives, the State of Wisconsin and the U.S. EPA believe
the selected remedy, Alternative 4, (Hot Spot Removal) will be protective of human health
and the environment, comply with ARARs, (unless it is shown through a future review of the
site conditions that an exemption or waiver is required). be cost effective and will utilize
permanent solutions to the maximum extent practicable.
The selected remedy for the N.W. Mauthe site includes:
. Demolition and removal of the buildings on the N. W. Mauthe propeny. with proper
management and disposal of the building deb.cis:
. Removal and proper disposal of the containerized waste currently stored on-site;
. Excavation of soils with a total chromium concentration greater than 500 mg/kg,
removing approximately 80 % of the chromium contaminant mass, including the removal
of those soils from beneath the railroad tracks if it is determined during RD that it is
feasible to do so in a way that allows the railroad reasonable and normal use of the tracks;
. Off-Site treatment (reduction and solidification) of the excavated soils which are
determined to be hazardous and subsequent off-site disposal;
. Backfilling the excavation with clean soils, and convening the excavated area into a
groundwater collection sump if it is determined during RD that the addition of such a
sump would significantly hasten achievement of remedial goals for soil and groundwater,
including containment and/or control of contamination in groundwater and ultimate
compliance with groundwater ARARs:
. Capping the site with two feet of clay soil and topsoil. with the establishment of a
vegetative cover;
. Installation of groundwater collection trenches and construction and operation of a
groundwater treatment (chemical reduction and precipitation with possible VOC and
cyanide removal, if is determined to be necessary) facility with discharge to the sanitary
sewer, to contain and/or control groundwater contamination with ultimate compliance with
groundwater ARARs;
. Improvement or installation of foundation drain systems and cleaning, painting or sealing
-------
32
of basement walls and floors, as needed. for homes or businesses in the area of the site,
to prevent seepage of contaminated water into the buildings;
. Institutional controls. such as deed restrictions or easements and site access controls that
are intended to prevent access. excavation, disturbance of the newly constructed cap,
future soil excavation in the railroad corridor fOI areas in the corridor where contaminated
soils will remain and installation of drinking water wells:
. Monitoring of the effectiveness of the groundwater treatment system and groundwater
quality; and
. Operation and maintenance of all systems.
If properly implemented and enforced, site controls will assure minimal non-authorized
access to the contaminated areas and deed restrictions will assure that the land impacted by
contamination from the N. W. Mauthe site is not used for purposes that are incompatible with
the remedial action or could result in human exposure to the remaining contaminants. These
controls and restrictions will also assure that drinking water wells are not installed at or near
the N. W. Mauthe site. The excavation and removal of contaminated soils, in addition to the
capping will prevent direct contact hazards as well as reduce the infiltration of surface water
and subsequent leachate production. The removal of highly contaminated soils will also
reduce the amount of time required for groundwater cleanup. Installation of the groundwater
collection and treatment system will effectively contain and/or control the migration of the
contaminants in the groundwater as well as eventually improve groundwater quality.
Concerns remain regarding the effectiveness of certain institutional controls. It may be
difficult for the U.S. EPA or WDNR to obtain propeny owners signatures on deed
restrictions and to enforce the terms of the deed restrictions though coun orders. However,
deed restrictions may be supplemented by the City of Appleton's enforcement of local
ordinances. zoning regulations and building permits to regulate property use in the area. The
City will be asked to further restrict property use in the area through these mechanisms.
The remedial action objectives and cleanup goals for the site are presented in Section VI of
this ROD. The remedial action objectives include:
. Prevent migration of contaminants in groundwater and in the long tenn. to remediate the
groundwater to protect human health and the environment and to meet state and federal
standards;
. Prevent human exposure to contaminated soils, groundwater or surface water that pose
unacceptable risks.
The WDNR and the U.S. EPA believe the selected remedy will achieve the remedial action
objectives for the site. Table 5 provides a cost summary for the selected remedy.
-------
33
XI. Statutory Determinations
A. Protection of Human Health and the Environment
The selected remedy provides adequate protection of human health and the environment.
Excavation of highly contaminated soils along with:Capping removes the risk of direct contact
with more contaminated soils and surface water. The capping additionally minimizes the
potential for surface water to come into contact with highly contaminated soils. Capping will
also remove the potential for the generation of airborne dusts generated from contaminated
soils.
Shon term risks associated with the excavation of trenches or removal of contaminated soils
will be minimized through good construction practices.
Groundwater collection and treatment will contain and/or control the migration of
contaminants and eventually reduce contaminant concentrations in soil and groundwater. As
groundwater moves through impacted soil, contaminants in that soil will eventually go into
solution and be transponed by the groundwater to the collection system where it will be
collected and treated. However, an extended period of time will be necessary to reduce
contaminant concentrations below the levels identified as representing a direct contact hazard
or to meet groundwater standards. Chromium concentrations detennined in the Baseline Risk
Assessment as representing a ill level equal to 1 are noted in section V. C.1 of this
document.
B. Attainment of ARARs
The selected remedy will meet all ARARs under federal and more stringent state
environmental laws or obtain appropriate waivers. TIle primary ARARs that will be
achieved by the selected alternative are described below. The U.S. EPA OSWER Directive
No. 9234.1-01, defmes three types of ARARs - Action specific, Chemical specific and
Location specific.
1. Action Specific
Action-specific ARARs are substantive requirements that defme acceptable treatment and
disposal standards for hazardous substances. These requirements are triggered by the
selected remedial activities to accomplish a remedy. The action-specific requirements do not
in themselves determine the remedial alternative; they indicate how or to what level treatment
or cleanup will be achieved. Impottant action-specific ARAR considerations for the selected
alternative are discussed below.
-------
34
Resource Conservation and Recovery Act, as amended [42 V.S.C. ~ 6901 et seq.];
Wisconsin Environmental Protection Law, Hazardous Waste Management Act [Wis.
Stat ~ 144.60-74]
Most RCRA requirements are administered under the State of Wisconsin's implementing
regulations. U.S. EPA does not have sufficient e\lidence to demonstrate conclusively that
listed RCRA wastes were disposed of at the site. RCRA requirements for listed wastes 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.
The remedy will comply with the following applicable requirements:
Wis. Adm. Code NR 6U5; 40 CFR 261 - Identification of Hazardous Wastes. Provides
requirements for detennining when a waste is hazardous. The substantive requirements of
these regulations will apply to Toxicity Characteristic Leaching Procedure (TCLP) testing of
treatment residuals and waste excavated at the site which may be disposed of off-site.
Wis. Adm. 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 on-site activity
relating to off-site shipment of treatment residuals and other wastes.
Wis. Adm. Code NR 620; Department of Transportation Hazardous Materials
Transportation Act (49 U.S.C. S 1801]; 40 CFR 263 - Standards Applicable to
Transponers of Hazardous Waste. Requires record keeping, reponing and manifesting of
waste shipments. These requirements may apply to off-site shipment of treatment residuals
and other wastes.
\-Vis. Adm. Code NR 675; 40 CFR 268 - Land Disposal Restrictions. (LDRs)
The contaminated soil and likely some of the building debris at the N.W. Mauthe site
contains hazardous substances in sufficient concentration to be classified as hazardous waste
based on the RCRA characteristic of toxicity, detennined through TCLP testing.
Contaminated soil and debris that is removed from the ground and placed outside the area of
contamination (e.g., t4ken off-site for disposal) is subject to RCRA LDRs if it is classified as
a hazardous waste. The restricted wastes must meet treatment standards before land
disposal. For most characteristic wastes with concentration-based treatment levels, the LDR
treatment standards are set at the characteristic level that defmes the waste as hazardous.
Characteristic hazardous waste that has been treated to meet the treatment standards is no
longer considered hazardous after the characteristic is eliminated. and can be disposed of in a
Subtitle D solid waste landfill.
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.
-------
35
Wis. Adm. Code NR 605.09; 40 CFR 261.31 - Listed Hazardous Waste.
Based on site process activities. hazardous waste records and concentrations of constituents
detected at the N.W. Mauthe site, the U.S. EPA and WDNR have detennined that the
treatment standards for RCRA FOO7 and FOO8 listed hazardous wastes are relevant and
appropriate for soil and debris containing cyanide in concentrations greater than LDR
treatment standards and managed in a manner that-wnstitutes land disposal (placement).
FOG7 and FOG8 listed hazardous wastes are spent cyanide plating bath solutions from
electroplating operations. and plating bath residues from the bottom of plating baths from
electroplating operations where cyanide was used in the process. respectively. Under the
LDR regulations, soil and debris from the site containing cyanide at levels that exceed
treatment standards are subject to LDR treatment standards for cyanide. cadmium. chromium
(total), lead, nickel and silver, and require disposal in a Subtitle C facility.
LDR treatment standards for FOO7 and FOO8 listed wastes (40 CFR 268.41 and 268.43; NR
675.21 and 675.23 Wis. Adm. Code) are presented in Table 8 as well as the maximum
concentrations detected on site. The cyanide treatment standard is a constituent concentration
in waste (CCW) standard, while the metals are ~egulated by a constituent concentration in
waste extract (CCWE) standard (based on TCLP).
LDR treatment standards are based on treating the less complex matrices of industrial wastes.
For this reason a treatability variance is available to comply with LDRs when managing
restricted soils. This variance does not remove the requirement to treat the soil, but provides
alternative treatment levels, based on the data from actual treatment of soil (Superfund LDR
Guide No. 6A, 1990). A variance will only be sought should it be determined that the
regular LDR treatment standards are not attainable utilizing available technologies.
Wis. Adm. 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
excavation and handling of hazardous soils and materials.
Wis. Adm. 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. Adm. 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 are ARARs
for on-site activities relating to off-site disposal of any treatment residues or other hazardous
wastes.
Wis. Adm. Code NR 506.08 - Landfill Closure Requirements. Establishes substantive
requirements for design, operation and maintenance of landfill caps which are relevant and
-------
36
appropriate to installation and upgrading of the caps at the site. The cap
design and construction will comply with these requirements, which provide substantive
standards for cap design, implementation and documentation.
Clean Water Act of 1977, an amended [33 V.S.C. ~ 1317] 40 CFR 403 - Pretreatment
Standards. :).equire that waste waters to be dischcu:ged into a P01W satisfy both general and
specific requirements to protect against damage toP01WS. Any waste to be discharged to a
P01W must, if necessary, be treated to satisfy these applicable standards prior to discharge.
These pretreatment requirements are administered under NR 211 and NR 108 Wis. Adm.
Code. The substantive requirements of these regulations will apply to groundwater,
transponed through the sanitary sewer to the P01W.
In the event that the P01W is not available for discharge of treated groundwater. the
collected groundwater would be discharged to the Fox River. Direct discharges would
require establishment of WPDES permit requirements. The discharge limits will control the
design of the water treatment system. At a minimum, NR 220 Wis. Adm. Code requires
best available control technology for treatment before discharge. Chemical-specific ARARs
for treatment are discussed below.
Air Emission Treatment Requirements
Groundwater treatment may include removal of VOCs before discharge. The need for
treatment of air emissions would be evaluated based on requirements of NR 445 Wis. Adm.
Code and risk to public health. If emissions are predicted to exceed the emissions standards,
then air emission treatment would be included in the remedial alternative. The need for
VOC treatment will be evaluated during RD. Emission limits are presented in Table 7.
2. Chemical Specific
Chemical-specific ARARs are laws and requirements that regulate the release to the
environment of materials having cenain chemical or physical characteristics or materials
containing specified chemical compounds. These requirements generally set health- or risk-
based concentration limits or discharge limitations for specific hazardous substances.
They may also determine the extent of soil, sediment, and groundwater remediation and
residual levels of contaminants allowable after treatment.
Wis. Adm. Code NR 140 - Groundwater Quality St~L,::jards. NR 140 Wis. Adm. Code
establishes chemical-specific standards for groundwater, rncluding Preventive Action Limits
(PALs), Enforcement Standards (ESs), and (Wisconsin) Alternative Concentration Limits
(W ACLs). Table 4 presents the ESs and PALs of contaminants of potential concern at the
N.W. Mauthe site. Exceedance of the PAL does not necessarily require remedial action, but
rather it serves to establish the level of groundwater contamination at which the WDNR is
required to commence effons to control the contamination. Therefore, the applicable
groundwater remedial action goals at this site are the PALs. Exceedance of an ES requires
-------
37
that remedial action be taken to restore the contaminated groundwater within a reasonable
period of time. Under NR 140.28 Wis. Adm. Code. exemptions from the requirement to
achieve PALs may be granted if it is detennined that it is not technically or economically
feasible to achieve PALs. but the exemption levels may be no higher than the ESs. These
requirements must be met at all wells (points) where groundwater is monitOred.
Safe Drinking Water Act [40 V.S.C. ~ 300 et seq.]
40 CFR 141, Wis. Adm. Code NR 109 - Maximum Contaminant Levels
MCLs are chemical-specific standards and criteria that are often ARARs for groundwater
remediation. Table 4 presents MCLs in drinking water for selected parameters. The MCLs
are generally not as stringent as the ESs and PALs established under NR 140 Wis. Adm.
Code.
The goal of the selected alternative is to contain and/or control and ultimately reduce the
contaminant concentrations in groundwater to the standards set under NR 140 Wis. Adm.
Code and the SDW A. This will be accomplished through the removal of the majority of the
source contamination and the construction and operation of groundwater collection trenches.
The groundwater collection alternatives would initially contain and/or control contaminated
groundwater through extraction and through influencing hydraulic gradients to inhibit flow of
contamination away from the site. Long term operation of the containment system should
also lead to ultimate achievement of the groundwater cleanup ARARs in NR 140 Wis. Adm.
Code. In light of the site hydrogeologic conditions, achievement of NR 140 Wis. Adm.
Code standards and MCLs may take a very extended period of time using currently existing
technology. As a result, five (5) year reviews conducted pursuant to Sections 300.430
(f)(4)(ii) and 300.430 (f)(5)(iii)(C) of the NCP will assess whether newly developed
technologies exist to achieve NR 140 Wis. Adm. Code standards in a significantly shoner
timeframe. Should a review detennine that it is not possible at that time to achieve the
groundwater standards or to achieve further reductions. then one of the following options
may be exercised:
. Continue with the action without modifications and wait until the next review to
reassess the situation.
. Consider establishing an Alternative Concentration Limit under the substantive
provisions of NR 140.28 Wis. .\dm. Code, which can be no higher than the ES.
. Consider a technical impractibility waiver under Section 121(d) of CERCLA which may
be used to and set an alternative groundwater goal higher than the ES or establish other
approaches to groundwater containment or remediation that are protective of human health
and the environment.
-------
38
In no event. however, will groundwater remediation activities be discontinued until
groundwater is cleaned to the standards designed to eliminate unacceptable health risks based
on dermal contact with the groundwater or ponded surface water.
Wisconsin Environmental Protection Law, Subchapter II-Water and Sewage [Wis. Stat.
~ 144.02-27]
Clean Water Act of 1977, as amended [33 V.S."C. ~ 1314(a)(I)]
Surface Water Quality Standards
Chemical-specific ARARs for the protection of human health and aquatic life from exposure
to contaminants in the Fox River are important at the N. W. Mauthe site because the river
may receive the natural groundwater discharge from the site or the discharge of treated
groundwater. Potential ARARs for protection of human health are Wisconsin's Water
Quality Standards (NR 105 Wis. Adm. Code) and the Clean Water Act Federal Water
Quality Criteria (40 CFR 131). Wisconsin surface water quality criteria depend on the water
use designation of the river. The section of the Fox River nearest the site is thought to be
classified as Public Water Supply, Wann Water Spon Fish Community (NR 104 Wis. Adm.
Code).
Discharges to Surface Water
If discharges of treated groundwater to the Fox River are necessary, these discharges are
regulated by NR 220 Wis. Adm. Code. The regulations require. the WDNR to establish
effluent limits for uncategorized point sources and to base those limits on best available
technology economically achievable. Groundwater would be treated to meet the substantive
requirements of obtaining a WPDES permit.
Clean Air Act [42 V.S.C. ~ 7401 et seq.]; Wisconsin Environmental Protection Law,
Subchapter ill-Air Pollution [Wis. Stat. 144.30-144.426]
40 CFR 50; Wis. Adm. Code NR 404. 415-449 - Emission Standards. Establishes standards
for emission of pollutants into the ambient air and procedures for. measuring specific air
pollutants. Groundwater treatment, 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.
3. Location Specific
Location-specific ARARs are substantive requirements that relate to the geographical or
physical position of the site, rather than to the natUre of the contaminants or the proposed site
remedial actions. They may limit the type of remedial actions that can be implemented or
may impose constraints on the remedial action. Flood plain restrictions and protection of
endangered species are examples of location-specific ARARs.
-------
39
No location-specific ARARs are thought to penain to the N.W. Mauthe site.
C. Cost Effectiveness
The selected remedy provides overall cost effectiveness as compared to the other alternatives
evaluated. Table 5 presents the costs associated wIth implementation of Alternative 4 in
relation with the other alternatives. The table additionally provides a summary of the actions
associated with the alternatives.
Alternative 4 represents an increase in cost as compared to Alternative 3. This increase
removes approximately 80 % of the chromium contaminant mass, providing the potential for a
shoner time to reach groundwater cleanup goals as well as providing rapid removal of direct
contact hazards.
Alternative 4 removes a large proportion of the contaminant mass from the site rather than
solidifying it in place as in Alternative 5 for significantly less cost.
The cost of implementing Alternative 4 is also significantly less than Alternative 6
(approximately a 46% increase in Capital Cost). The increased cost associated with
Alternative 6 represents removing contaminated soil to background levels. The additional
soil proposed for removal under Alternative 6 would be at concentrations identified as less
than those representing a In level of 1 (570 mg/kg hexavalent chromium in soils).
D. Utilization of Permanent Solutions and Alternative Treatment TechnolO!ries to the
Maximum Extent Practicable
The selected remedy for the N.W. Mauthe site, Alternative 4, meets the statutory
requirement to utilize to the maximum extent practicable permanent solutions and treatment
technologies. This fmding was made through evaluation of the protective and ARAR
compliant alternatives (Threshold Criteria) and through the comparison of the advantages and
disadvantages among the alternatives with respect to the Balancing Criteria. Alternative 4
provides the best balance of tradeoffs among the alternatives with respect to the evaluation
criteria.
The selected alternative treats contaminants in groundwater using reduction and precipitation
as a treatment for metals found in collected groundwater. If necessary, it will also include
treatment for VOCs andlor cyanide. No other alternative provides for more treatment of
groundwater.
The selected alternative addresses those soils impacted with chromium concentrations
exceeding the In level of 1 for dermal contact through permanent treatment technologies.
The increased volume of soil to be excavated and treated under Alternative 6 significantly
increases the cost for little improvement in protectiveness.
-------
40
Although Alternative 5 includes a potentially innovative treatment method. through in situ
reduction and solidification. this alternative does not remove any contaminant mass from the
site Other than through groundwater collection and treatment. The technology to be
employed in Alternative 5 has not been used at full scale for the treatment of hexavalent
chromium.
E. Preference for Treatment as a Principal Element
Through excavation and treatment of contaminated soils with chromium concentrations above
500 mg/kg and treating contaminated groundwater. the selected remedy satisfies the statutory
preference for remedies that employ treatment of the principal threat to pennanently and
significantly reduce toxicity, mobility or volume of hazardous substances.
The selected remedy removes the primary source material and the potential for that material
to continue to impact groundwater. Capping will further reduce the potential for intiltration
of water and subsequent generation of contaminated groundwater.
-------
?icrure 1
~ite Location Map
~: . ~.;. >! a u th e S 1 t a
41 )
'..,
"""
",
"
""....o~
WISCONSIN AVENue
TOWN OF
GRANO
CHUTE
APPLETON
",/
.'
..."",.,",.,
SPBtCER STREET
T1UJIAH S~EET
VAllEY ROAD
~
o 1/4 1/2
I I
SCALE IN MILES
~p Sourca: R.R. Donnea.., &
Sons Co. ~ SeMCes
Site Location MaD
N.W. MaUlhe :),10 RI R900n
l ~:'.~t:ll"
~. ,).
~ .,.
-------
A
. IJ
) G'
--:: :-=::.-1
" II.[ III I [[1
"01 NI'
".
"'I ,
\..1& i
...I' I."'.'
,. ','0[.,:
,. '.... "". ~ .
, . A ~
II.. .. "
\ '~J \ .
. t.'. ~ E . . ) . .
..,'."
','. .:
. i .,:,J:'.
., "f.r,
"l'.:'" '111'" Ie (ll I...,' t:. .,'",( 0'
.- ~ J:." I ..",,'.t .-..1 ".. cc....I:"o ' ...
".-; ."". I' 11. d.l..
I
.-- - \
C~':"~'Ill':" "'J"' ; LLL;('~:7
C. J2I35 ... d"-
Zn 1211120 L-I -
,~'!~~A!~_u ~'-;1s= -"'-. ",m '.
~~):----cr ~==-'-"-lf;
/ ........ - ,.ppno.......Tf
/. L'.::I ,;IHFfT i/' ~~~~~~~~
, ,. "C / -- --- -- Cd 44-:JIJ '-n~-- - ~<:' -'---
~ .,. 1l1...,rH")' I t~'(E c,,~. - _.~ -
.. -Y' " '~';~' =,' '" ''''N~;l , ' I
I s.; 1 C 'ClC'G:o.Ji!UO~ SSI2. ,,', CNl,mD
/ Zn V0/480 /10 Cd 1&":10 ',~ "
'~-Ct, 25J'41J t< Cr 1.2ODt1.'OO~"
lit' / ,-.' Zn no..L2.OJ
\ Cd S " . ". . ';' , ,/.-. -' ':' . CN III
li~~:~~'J .- .-.--:~'7;'..; .'-: \- ~". ,"
10"'0,J -;'>'" />" CdSl"j' ,>
! < -- C,l,!'01J.l2-20OJ
i ~;/~~:J"
I
, Cd 7,9 '()SSg
I c. f,JCOJ 1,300
Zn "11110
. CN liD [-I. 9510, ;',
-- ~~.... ~:~I~~~'I
\ Cd 'a';"' tll~~''''''
-. \' c. UIIIf ' I
... : \ Zn ,)0'14' r' -, II
"-"":'...... ..,1 Ctj '~'J I ~
" -'- -~l-'I~:!.- ~I L -- II L ,"
,-1__- 'C
,:. --------~. - ..--1---
-:-.":.~,:' :C~,- - -- -.- - - . :'~ '~--~--==- ~~~--==! L-'
..--.--.- -
,1..
---- -" --.... -- -..
,,:' ....~ -JL~
. ~~.q -
.~--~.
[.-, .
r. ,
I :
r
I,
559
c.~ '.l)
C, J, )J
Z, U78
C"/ Iii)
.
. ....;..'"
'~'. : :-:~ '-'~' .': ~
.1,
. -. ~ - - - . -
. : ':~l t,
, ',0: ='1'1 ,-',
" ;:: I
, I I
:~.J
I
I
I
I
. + - ---_.- - --.
'. - ----.-.
. -. . -.. - - --
". '..1' 'L
1-. I - !
-- -I
I
I
''''1 I
. I
I I
I
Figur~ 2
Surfacp Soil Sampling
N.W. Mauthe Site
I;')~=-<
Q
III /
I.,
I->
u:
...
"
1'-
I
1/.___---- L_u
:1
"
0(
;)
,)
r-,
--I---l
-t',:. -1
....r. !.
;. < l .'
~ -;)
_J
.~ ,---
:;t-
I,
, .
j:' .,
,"
,.. ---',
, 1
,.
, .
( )"I,j"
r-c ,I,
, /
1'----'-1
"--,.--
S,,,1.1~U Sa"
Inarga"ic SuDsla/lces
December 1991
U \',' fA.;auttt.8 s.'. ru n.pCt1
-
-
EZI:II!J
-
-------
.....
. ,..
-=~
Cr ZOJ m...,.e
Z~ '!
I
o
,)
~j
) f,O
--.:.: :::::j
".S:.LE 1~1 ,.[£:1
, (OPIlI
::~ ... I
. i:, '", 1'.:':~lCJ...t(...I:'
:..)0: ..r.)" ,f.,.'j:,) "'U....B£A
I' '. ; ... f ' ~
~ ~.: OIJ ~ £ .. [f1 II '.'.' " t f.
~ :.~ ....! ~;.'~
!"..,'.J1. ',..,1'1"',
"
l:..':.,"
.'
':.~;'. n:r'llId
".: r.....~[jEfi
".:. Ii
Tr~: rITlU:,r,"j
.].: 'j' ,"'ill II
. .:'~ :. .. .
t... 1."-';\.';
, .
I"",'.
- . ", . ( . ~ ; '.
£ ':.. p't: (, Ir,
(,,'\II", "
, .
t. : C "~ ( .~ ~ [ :>
. I: - '.
~ :DSUflr.&.CE 10Hl
(HAOU:v'U 0...(,,-0:
C :'::"~["11\": .::"~
C -:.(f :...:n r""i''''~J
II 1.. I'. ",I. ....110 C<-"". .,.
..L."II ,4 u'..u...."...,loo"'.
'~'..J. ., L' . or"':""''''''
'8!Q II." '-.
'".1'''':''' '
Figure 3
Chromium in shbsurface
"'., , , ",. \ II. \-J. Hauthe site
mf,1~L;:;:: J I~ \ \'1' 'c~ii ilJ . ""',,, .
---' Zn2TJ :J 2ft"~~<-:",J'J
~~~- \ --- -- I' ,';./:,-:.< J~'~
. ,;' .,. :,\'i- ~ " -:- ' '"
o r IELVIII ~'r- P~OP£RTYaov"D'"') cuC8J 0 .', fCF'" /
o '- .~~ - - - - - 32. ~ 21 ~.,(;,' ',' :", "
'----.----\--.---- ,""- -.;-;.;::=--'- - .';..;-;-- --- .,:." ' .' ,,>' ;/
~'~:':1':;;(" -- ~ - - - - - - - Y- _-a"""::':--=-c=.:;: ;-:;..~ ;J-=.-=-c- -'- - -,,-:" - ., -"\';', ,;~; :IIJ "
-' ~' ,t ,,<->-'-~"~ .-!:~l' J~~ ~~ '- - z"", ).::. .- ..,';~~",:~'
~~ 0.0 ~~~ --,'C..~t.=.!,11
. U; 'd 1" :,..) -~:.~~_'_,J_11~~~' -.:: \ I,., .~-''L,- -, ~~~~ ~J \ ..
.--: :~~'.~~',~.=,~77=\ ~ - -. -- ,- - ;' \ - ~-~~~-,=-=-:J L7 . - - Si,..a
::I.~,.":~) . !-I I '~i~~--~o'... C,ISoI
c,16J z,;:;
z" :4
--------
- ----..---.L.L=c.
Zf' , 1
t',
I
---.1-\
/ I
/ "
/ / .
/--_.. ./
/ '
/ '
/',' " '//~~:
" /' .,..,-
~~~~:
rn .', ':"
,,<.(,,\
Cr 10
In 3D ID,,'pl
~!
Cd ..
Cr l.g;O
lr,52
en ~,
!QI '
Cr SIJ
Zn 16
1 "
"
"
(D-
.. ...-.....,..---,
". -, ''\.- .... .
...
..,-
- - ----- -.Ji,
, "--~'~.~r'l
;. i~;; Ii
:., ..' I
--" I
.- .. -1
.J
C, 11
Zn :g 6
.
. ,
\----
I
. I
\ f~ ~I, '
.. -1-_1
.11.-
:...!£~ !--
(f r'J
Zr. ;4
S81.
C;i; :
Zn :J I
.-. ,'-' ,
Soils
. ' . '; ~. ,
( :';' II .~
r"l,~llll.
\ - -~~-\
'I. "
... . I
j' :~;.H..~ ::"..:;$I.,I.';US
S",bs",rlacII Scil
I,:. 01. :.~~r~~':~II~?~~
-
-
CEZI
-
-------
I
m ~.. H
...z:. .'
. ~ (.
II
;~
) 6'
......: ::-.:1
.:;,\l E "j FEET
ll. 01 II~.
1:1.
'.' ~ ~ . E; . t. '. .
.: ,'j J.',.IO.,.'''fq n
: If ~.{ .'. t ;, "..
.:; ,',
.J ",
t .
£I n:r...
", "'~ll.
[ ~
"
,'J l :-:,'
", .,(.fil
,,'.."t'
I" .
. ..& .
t, ,I.
~ . *",.. ..".
.1 . .1" . t,. ," ~.
.....'0 (2.1 ~ ." J
CIItC rJ
nlEX 1J
';:~l~;~~~~l
Bl EX oJ
CIIIC 416
:" P'I' ~ IJ
. t'
{JlfX 51
'21 HC ',914
': 0.., 11
"
'11
I
I' J' 'f'
l ! It.: IS
;' q ,.~.I
Figure 4
Volatile organic
N.W. Mauthe Site
compoundslfn
Subsurface
Soils
'~~~~~)IU~:";'~ ~:~;'~~:~;;-, L1L(::~L:~~' J I
CI HC 2,4J2 I! BTEX fJ -.I ;. '.,P
B1EX IoJ w, , ,,~'-
. j==;-- - - ~ I . )0".:«'" .'.
- .._J._--- L-L--L:::r::.:::~4.5'I-- I v " . / ,.' ;'
-....... ." ,01 ~9- . .
"",,",,(7(}901 0 " - APPROXIIAATE CIHC2I C2:I 0 /'..' ...,,:' ,'; .
.._---- EJ ,I III ,>TI1I:[l PROPERTY 2~vt2JIOupJ C> '-;'l,a '/,'
~!~:.: _u_. w;;;:;. '-"-- .800~DARY S&1~n~J..-- -- ,~(. )~"(),'
~ ..'.V t 8TEXZJ ,~.,./O". . ;;/
'.' " E--- -'.~:ii)(}i2°1:-:::---=- ,=.:-_~- --=--=-=tCIHC7i'-:-~ /,;'". o' "Lli ,. /'
r".' ..--- .Nt; . I ". '1m'
I :II'C IIJI /6'J.l;;,"::;,." ,--:' ,7:.-( -.' "
or"",,,,","'''" orEx 1J ,000. jJ!1.(10()"~ ,. -"-.: J - ,'~." /'
~o N~!!~(,eo).'.-8'--1 '. BTEX74," /.-;;.' " ,.' """AI' 0-30) I
OJN2>A(T(}90). --, (IH:i0~'--"" ---1- -CIHCII ~.'" BTOIJ
----. I t~:.. /' /:.. /' CfHCIJ
8m2J 11--'-~ "",I"rn /', " .r......
CIHCHJ /' i' I ". ..------- /' /', ,.;".,-'
. / r.1 ' '. .,. ,~~ - ", ,.,,' ./.<'. ~-:'r'" I
( : I ,. 1 00 ~",>,-,--- '8' :;~~:~ ~;' ~'rn8..: . ~,c Ie (} 10 '.) I
' I. r~. /";::ffji"" I -L-
t I "'I'!>G~)
~~! (5 ().7 QJ :::::- ..:" ',' S m ClHC,] .
CIIIC IOJ m~'''8 ........:::=_-,-~ f' U - II
, "~ I - . ill ~!.!U5"55') --U
.,t..: I UI;I~".'IYJor: BTEX2J
".11'~' 11'.) --." "ffirL-{' :~';l:"":' .....r-.) rCIHC2J
~~: : ~ ---,' ',' i f'~'1 "'('11 :11: .:" '. I~ ..1
L( ..! ,1.- i',1~__!i
I.
I:.,
/ ,
: r I ..
( .;:; I'!~' J'
f ",( .,1:"(
--------'-'-
:~~':=~,\C~::' .
~~~~~~I
Bru In
2 n,. zrJ
,.
ill
Il<)
, r'
'0 If,
....;)(}~dn
2 Bul 9J i
i
\
. J
'''lw(G:}8C) -
--_._--
CI IIC 30Q
(!:"N""
r,D
[3 E-'-l
~:i~~;r~" I 1';:" '. '
I , ,I; 'II, I'
---.I ------,
',n8
'I
I
. .
I' '
.J
:'!~ J.;:22 ~ ~ 1
BTE)( ~
CI HC 52J
2 Bv1 SJ
,:1
r--+- '--_.-
" j--
"', :
.
. --.
°0.
:.,." I1j~~ ~~ !':
IHEX 4J
CI H: 2J
...' tit
.
.!!!!!~9..L
BTEX JJ
SQ.,.,
rr.:.
" .
r-llp' ;"J
-. ~!_~i':'~ ~)
1(.- OrEX2J
UJ
I;
~~!.t~-~ ;:_~ ~J II I
Cllte 51J. . ~I . 1
..I I
'I
I
I
:----\
! .
.
-- ~~~ 1~ ~ I~ " 1
t I)IC SJ
,." I
!
... , 1 :: ' ~
erE' ~
;} II. r J...
- I
I
'-'nlalll" (;'~J"n,c CC;llIpounds
~;iJtJ~UlI.ICI/ Soil
J.lllll;try 1992
r4 ,', , 1.1,,'''. s,:" 1'1 n.ltCt1
-
-
EZI:U!J
-
-------
II
Figure 5
Groundwater
II . \']. r., aut h e
Flow
site
, .
,
...
...
...
1..11 :1_-'
I. ~ 1".1' . 'r ~,I . if': , ." l' f
:,,:::~; ;:';'\:"J II ..,' -_.t==::l~
,._-_.,.._.._._----~':;"u' ____l~jlb- ,5
T'----'-----'-'-'\' --- 7------'---/ ...=
.L-------'-- -.i-L..----, .--'------""-.- \ I \ L
'. i "
--
~
';'1
J
....... :::',-1
:Cf..lEHJfHl
l ( olt.U
. .1... '
,:,.. '0:1 I. .. .dll
~ .: ",. ,.'4 "j:1 r.1 ..iJ i I.
I.":'
"
1.( ','.' , tlj~. '''''~ t r II L. I'll .
l ~:.. T,;U "/.:1 'J\I'AH It
")I 54
ffi,..
. ,nl.lt Sf Nr ~ U"'Jjto( 11. t
l ~: ...110 )r. ...~.:> 't. 'tdHI "
,..,.,:,..10 ",f; ...EHHA,.II
l ';A!I:'IH "J;~'" l,tiH II
..
~ II '} nlll", l
.": 'I ,..'jill,
'; ;'111l',"
I" .
- 0'
. : ... .. ~ i .. .
:,c-
,.. . ,4 ." ~ t . I It. i
., ..' ,.E:
L f ,"!" ".5
:.. '. .t .-,;;:
6L-
,.
. i'
111,,-
'-"l
" .
I ;:.
. '
,. .---
~
~
~
~
I
I
i
I
I
i.:'
I"
I
1
~
!
. 'I..l I
(:~ (nUI):. :~
J l(klrt
[:-'~'1
'I' "
:.-, ",';
~ GIOLJIIO..,atcr Su,'acu
! Contour Map
~ August 1992 Oal3
Shallow Wells (S 15,0' BGS)
"W. t.,fal,l."1. $.18 nl n.po"
&1U,"....'"
'\I
-
-
EZI:II!J
-
-------
Figure 6
chrom'lum in
tI.H. Mauthe
Groundwater
site
; ,
., r
fII ". ".
Ij[) tjD
" .
()S..'
P ~1
~
J (;I)
--=-:::::1
~CAlE Itl rEET
l~O(HO
, I: ,. .' I 'III' j' ~ \'. ( t L
I ...1 '4 ""(1 'H,,,'r\(11
~J .f..., ~
.u
:i
"
~
::>
o
'. . ~ All ( (I ... ~tllT"" ,11 t. ",
. ,,",'.,. ,1..'.;1 t;, '1..411~ II
"r.'.".
!!i
,'. i ~ l t
m j'itjO
r-1
--C,V,"",t
-L.J
!" ~ ~.". '.l f. p1 "..u:I.":'l f
l . At, ., ~~:>'.U"'9£R
(, .. ..
I
! A). :...n. Sf'""P~ M,.&'.H . r
l '" ...:~ '.1-J.~f'l LJOrn
n'!
: I 'k,.r ',.".f'
'." .
, ~ "..' ~. J -I
~If( "I' C. I
lit ~'lJ~ 1...1 I
............. f'd
"...:.;. "';
l . '"
'1':10 '1
LA'I' .,.,
~f '~'. ,11,' I
. i . If
'.
::.;. ,,'L',
, . '-J I ,;.~ .:LA'l U
(Lfl(, 'lTAAU(N I' ,.:
........ "j !~p :1./'.Jrl&TER 1'9'.1
III~ l~n{"""'Cf.L'f)
/'
.:=':::-_::.:.1
'Oc-
u~'~~
()
80',\
.I-PI.:.. valE: 1 )'''.1.
C .do. ,.t IIA (C ,.C{N11,.tIJ - t,
(':',' :'II~ 1'4 GJIC(rr4(""": (n t \,1'1
II r n . ;'~2 fIAT'" ('., "
II fHI
fH
IC II~ aj~.-
---~'----:~=-=Jb
~]1I
4L-
0____-
11 II
'. f .'&.'.1.. "of.: a'a
. ,
]
Nol.'
H.-,."
....11"((.....,,.1"..
.--," ',,"
t_-- ~:l. ':,' ~~. t
..,.,11 ,I I (of'\lam.fYll.oO" .
["'L
.,", ;,.:--l_.J
IrN'I"" .,.1.., A;)'"'''''' i..,..
,.,..,-.. ,-..., i'''.'J''''!\'''' I
.... '.- '~'It..
" -I
I
,".:OLI-
" c,.."
a,-I". I
r
n
fUt.11 c..tUOfIllU'T1
COfl,:el1lr aliofls
10 Groundwalor in
Shallow tAoniloring
\"Iells, SeNor Grabs.
ilnd Sump Pumps
rl','/ u., ,... $"8 AI n.pot1
I
I
~.I'" tUD I
.. ,
.. !
, .,.. +110;
-
-
EZI:11!f
-
-------
l'1.gure I
Volatile organic
N . \'J. M aut he sit e
l~
0""
62 B'" 57
BOX 2J
- . ~~:::--=>
CIItC '.'~:2.J'O .
- -------'.[-l":";"
s:.i.:,j :Al' .
~
o G(J"
--:.::..::j
SCALE Itl rEET
l(O(HD
~u.o.l' CotO"",j'.;II()AI'",~Y.ElL
lOCATION AI'O NUu.9[R
I:' .,
flr".1- y LH~ TAll [D ....)t~IIC'1 tt;) ""Ul
l":-;Ah)" ",,.0 hUMilER
~~::::::=-= -~
BTEX IJ.$J
CI HC 111.1110
(J ~:;I
~ TOR.., SE It'Ef\ MAJn.tE
lOCATIC'4 .tIID tL Ma£n
.'
,~"-,:,,.J
. '..I')
Su....P Pl'"IP
L:'.1
V.. d.I,
. ' ~.,) .tlO
Compounds
'I
in
Groundwater
I \ ~
I \ UIEA ..1,"'9/
UJH1 ' --
\ '., -"0';" .,.)
~1 :(1b;4 ',J .,'
't) ~.
.' ....
. ......--
I ~. II
',!, I"
./
../'
...-
I-
I
.
I
."__0'-
.\
~.
ED 110.110
r")
- pL--1
I
I 1- ---,-
I
111~'--.1
I'~-'-- -]
I" .
~ ~ ~'. '.~..
.... J .~_.
,,;;,
8081['2J
-:1
1-10
.. ---,
I
,
\'1)(: t:,"h':Clltl_I'lon'~ .H
GrounuwahJl ill
I.Ionilori09 Wells. 511....01
Grabs. and Sump Pumps
U \'/ ,t.J It-o:::;:. (U Itapc"
-
-
~
-
, ~P.:::::
CItIC U
-------
---- - --
l
o:,-.!I
8
Figure 8
Alternative
N.W. Mauthe
S e fleeted
4 (Hot
Site
spot
Remova l)
Alternative
;J.rllJ1,k-
HJ 'I'o'IjI, B
. -~'---'--
~
60;
~. ...j
.-t,! Fl': f t I 1
j
I
I
1 M;l
1 ~KI
Il01
1
I
,
,
!
5
o
, U~W 2nD
ftlTCHlf S
Rl,.ol"U
1U2W2NO
l"'~H
~E ~IOE PiC{
,e~
e :_H
o
'-'ILLER ELECTJ1IC
r,H\P(rtJ; lOT
8810.
.~B')
D""Wj'
FtO,,'"
FtESIOf'i((
jo.I:3 o"r""JA[]"
v~OE"
WlfJ.[H
~f910fHc.E
,Ou
,~,w!:J
."'UtA ~
""E!EN p.,j):3 CIJT...c."'WIf.
A.E9tOfJ.la JfiUSf
EJ
LLOUID
\,J..,SCtJIAGA...O'
ROBEAfy)N
I1f>0E..c.£ +".,
WIL tOTAl. Cf;t )2 m~"'a COUTOUR
[1V
r
Extent of GrOllndwoter
(;ollwmlnatlon and Hot Spot. &:B
Soli l:Jerr OV "I ( A I .1 1\' 11\ ' II {!:;L~W.1!'
- ~ II, ~~..I'~l:: ::,I:~:r. ~1. ~ 'I~ r~lr:u..~;.l
.HE" OF SOil COVER
~Il '" : ,Ht&r.IU,J
J.prn - (1t..lA.TE EXTfP(T OF HOT SPOT &~l
-. r f)~:( T-;';ICO.'JBGSI
OH(,. 11.0''''0 TE R TOUt ~ ~ S ~;J '\
'-01' . .'.~ .,',.; r H .
;;.:'.I!!-S
;. "
WiB
-------
Table 1 - Cont88inants of Potential Concern
Noll. Mauthe Site
Inorganic Grou1dwater' Soi l2 SUrface WaterJ
Cont_inants Max. Conc. Max. Conc. Max.Conc.
Detected (ug/L) Detected (mq/kg) Detected (ug/U
A ll.l11i m.m - u ' _u I 122J'
Arsenic _u _u 5.6
Baril.l11 -u _u lSo5J
Cadnil.l11 n- 3,660 9.3
Chromil.l11 (total) 860,000 15,000 57, 000
Hexavalent Chromil.l11' 1 ,700,000 NA lS ,500
Copper 128 1,310 30.2
Cyanide 13,100 2,960 I 16.5J
Lead _u -u 3.5
Mercury 1.5J 0.95 - - -
Manganese 880 --- 182
Nickel . -- ... 19.7J
Sit ver --- 29 - - -
Zinc 468 14,900 391
I Organic Cont_inants i (ug/L) I (ug/kg) I (ug/L) !
2-Butanone 57 81J - - -
Carbon Disulfide 480 47 - --
Chloroform 4J 55 _n
1,1-Dichloroethane 120 120 16J
1,1-Dichloroethene 190 5J I 20
1.2-Dichloroethene 1,800 32 23
Toluene 740 85 n-
1,1, 1-Trichloroethane 2,100 1,500 220
1,1,2-Trichloroethane 7J 13 - - -
Trichloroethene 1 800 3,400 280
Benzene 1,200 - 0 - I on
Xylene 360 nO ---
, Includes Monitoring lIell, Sump & Grab Samples
2 Includes Surface & Subsurface Samples
3 Includes Puddle & Crock ~amples
. --- Indicates Parameter Not of Potential Concern for Specific Media
5 J Qualifier Indicates an Estimated Value
8 Analyses for hexavalent chromil.l11 (water) performed using co(orometric method
-------
Table 2 - S~ry of Risk Characterization Results :/
N.W. Mauthe Site
Current land Use Hazard Index Excess lifeti.e Cancer Risk ii
Scenario/location Exposure Pathway Average Reasonable Average Reasonabl e '1
I
Maxi- "ax1- il
Trespasser/ Ingestion <1 2 !I
Onsite-Surface Soil Dermal <1 - 18 II
Inhalation <1 - <1 <10.e <10"
t
Total <1 20 <10.e <10" II
Onsite-Subsurface Ingestion <1 <1 <10.e <10"
Soil Dermal <1 5 <10.e <10"
Total <1 5 <10.e <10.e
Residential/Offsite- Ingestion <1 3 I
I
Surface Soil--Toddler Dermal <1 15 !
Inhalation <1 1 <10.. 2 x 10.e
I
Total <1 19 <10.. 2 x 10.e il
Ii
Residential/Offsite- Ingestion <1 <1 d
Surface Soil--Adult Dermal <1 4 il
Inhalation <1 <1 <10.e 2 x 10.e :1
Total <1 4 <10.e 2 x 10" II
I
See R I Report for specific risk characterization resul ts (Appendices I) I
-------
Table 3 - s~ry of Risk O\aracter1zation Results
N.W. Mauthe Site
Future Land Use ... Hazard Index Excess Lifetime Cancer Risk
Scenario/Location Exposure Pathway Averege Reasonable Average Reasonable
Maxi- M-,-
Onsite-Surface Soi l-- Ingestion 2 - 13
Chi ld Dermal <1 61
Inhalation <1 <1 <10.4 <10'.
Total 2 74 <10'. <10.4
Ons i te-Surface Soil-- Ingestion <1 1
Adult Dermal <1 14
Inhalation <1 <1 <10'. <10.4
Total <1 15 <10'. <10..
Onsite-Groundwater-- Ingestion 1,200 31,000 2 x 10" 3 X 10..
Chi ld Dermal 30 800 3 x 10'. 4 x 10'.
Inhalation <1 <1 2 x 10'& 2 X 10'&
Total 1,230 32,000 6 x 10" 1 X 10"
Onsite-Groundwater-- Ingestion 360 9,500 2 x 10" 3 x 10"
Adult Dermal 16 400 7 x 10'. 9 x 10'.
Inhalation <1 <1 1 X 10.5 2 x 10"
Total 380 10,000 6 x 10" 9 x 10"
Onsite-Subsurface Ingestion 1 4 <10.4 <10'.
Soil- -Child Dermal <1 16 <10.4 <10.4
Total 1 20 <10.4 <10.4
Onsite-Subsurface Ingestion <1 <1 <10.4 <10.4
Soi l--Adul t Dermal <1 4 <10.4 <10'.
Total <1 4 <10.4 <10.4
See RI RepOrt for specific risk characterization results (Appenaices H)
-------
I Table 4 - GrOU'1dw8ter Quality Standards I
N.W. Mauthe Site
Contaminants State State U.S. EPA Maxi-
Enfora!8ent Preventive Contaminant
Standard' (ug/l) Action limit' (ug/l) Level2 (ug/l)J
Caaniun 10 1 5
Chromiun 50 ~ 100
Cyanide 200 40 200
Copper 1000 500 - --
Mercury 2 0.2 2
Manganese 50 25 - --
Zinc 5,000 2,500 5,000.
Chloroform 6 0.6 100
1,1-Dichloroethane 850 85 - --
1,1-Dichloroethene 7 0.024 7
1,2-Dichloroethene (ci s/trans) 100/100 10/20 701100
Toluene 343 68.6 1,000
1,1,1-Trichloroethane 200 40 200
1,1,2-Tr;chloroethane 0.6 0.06 5
Tr;chloroethene 5 0.18 5
Benzene 5 0.067 5
Xylene (Total) 620 124 10,000
, Wis. Aan. Code NR 140.10, Register. Jan. 1992. No. 433.
2 40 CFR 141.61 & 141.62, as of Sept. 1992.
J All Concentrations Expressed in micrograms/Liter (ug/L = ppb)
. Secondary MCL
-------
Table 5 - R~ial Action Alternatives C08pDnents and COSts
N.\I. Mauthe Site
Alternative Description Capital Cost Annual O&M Total Present
Worth:
Alternative 1 -No Action $150,000 $17,000 $430,000
No Action -Institutional Controls
-
Alternative 2 -Institutional Controls $940,000 $34,000 $1,600,000
Direct Contact Control -Building Demolition
-Soil Cover
Al ternative 3 -Institutional Controls $4,600,000 $210,000 $8,100,000
Groundwater Collection -Soil Cover
-Groundwater Collection
& Treatment
Al ternative 4 -Institutional Controls $6,640,000 $220,000 $10,090,000
Hot Spot Soil Removal -Soil Cover
-Groundwater Collection
& Treatment
-Limited Soil Removal
-Ex Situ Soil Treatment
Alternative 5 -Institutional Controls $11,000,000 $210,000 $15,000,000
In Situ Soil Remediation -Soi l Cover
-Groundwater Collection
& Treatment
-In Situ Soil Treatment
& Solidification
Alternative 6 -Institutional Controls $12,000,000 $190,000 $15,000,000
Ex Situ Soil Remediation -Groundwater Collection
& Treatment
-Extensive Soil Removal
-Ex Situ Soil Treatment
1 Present \lorth Estimate Calculated at 5X over 30 Years
-------
Table 6 - City of Appleton PON Discharge U.its 1
N.W. Mauthe Site
Constituent Current U mi ts Proposed New l i..i ts 2 I
(ug/L) (ug/l) J
Aluminum 200,000 70.000
Cadmium 1,300 400 -
chromium (total) 7,000 7,000
Hexavalent Chromium .. 4 500
Copper 5 000 3 500
Lead 2,000 2,000
Mercury - - 2
Nickel 2 000 2.000
Zinc 10 000 8.500
Cyanide 1,000 300
, POTW - Publically Owned Treatment Works
City of Appleton Municipal Sewer Code
2 Modified standards are proposed
J ug/L = micrograms per liter = ppb
-------
Table 7 - Hazardous Air Cant_inant Eaiuian Li.its
N.W. Mauthe Site
I
Organic Table 110. E8issian Rate limit E8iuian Rate li.it Eaission Rate I
CantlDinants of in IIR 445' < 25 feet Z > or = 25 feet li.it
Concern (pounds/hour) (pounds/hour) (pounds/yeer)
Carbon Disulfide Table 1 2.4984 10.4488 --
Chloroform Table 3 .. - 250.0
- ..
1,1-Dichloroethane Table 1 67.4568 283.296 - -
1,2-Dichloroethene Table 1 65.7912 276.312 - -
Toluene Table 1 31.2312 131.16 - -
1,1,2- Table 1 .3.7488 15.744 --
Trichloroethane
Tr;chloroethene Table 1 22.4856 94.416 -.
, Wis. Adm. Code NR 445
Z Stack He;ght
-------
Table 8 - LDR Treat8ent Standards (F007-F008)
N.W. Mauthe Site
Constituent TreatlEnt Standard Maxi.u. Concentration M8X/20' (mg/L)
Detected in Soils
(mg/kg)
Cyanide (total) 590 mq/kg 2,960 NA
Caciniun 0.066 mg/L 3,660 - 183
-
Chromiun (total) 5.2 mg/L 15.000 750
Lead 0.51 mg/L 1,960 98.5
Nickel 0.32 mg/L 36 1.8
Si lver 0.072 mg/L 29.3 1.5
t Max/20 - Maximum Detected Concentration/20 colunn shows the maximum TClP concentration
that a constituent could achieve if 100 percent of the constItuent was leached during the
TClP analysis (the TClP procedure involves a 1 to 20 dilution)
-------
Responsiveness Summary
N.W. Mauthe Site
City of Appleton. Outagamie County,
Wisconsin
March, 1994
This responsiveness summary has been prepared to meet the requirements of sections
113(k)(2)(iv) and 117(b) of the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), which requires a response"... to each of the significant
comments, criticisms, and new data submitted in written or oral presentations" on a Proposed
Plan for remedial action. The Responsiveness Summary addresses concerns expressed by the
public, potentially responsible parties (PRPs), and governmental bodies, in comments
received regarding the Proposed Plan for the remedial action at the N.W. Mauthe Site.
Public Comment Period
A public comment period was held from October IS, 1993 through November 15, 1993, to
allow interested parties to comment on the Proposed Plan, in accordance with section 117 of
CERCLA. On October 27, 1993, a public meeting was held at the Police Station in
Appleton, Wisconsin, at which the Wisconsin Depanment of Natural Resources (WDNR) and
the U.S. Environmental Protection Agency (U.S. EPA) presented the Proposed Plan,
answered questions and accepted comments from the public. Comments received during this
period are included in this Responsiveness Summary.
The Remedial Investigation (RI) Repon, Feasibility Study (FS) and the Proposed Plan for the
N. W. Mauthe Site were released for public review in October, 1993. The Administrative
Record was made available to the public in October, prior to the comment period. at the
Appleton Public Library, the WDNR district office in Green Bay, Wisconsin, the WDNR's
central office in Madison, Wisconsin and at U.S. EPA's Region 5 office in Chicago, Illinois.
Community Interest
Overall public interest in the N.W. Mauthe site has not been particularly high. However,
those residents and business persons owning propeny immediately adjacent to the N. W.
Mauthe site have shown a significant interest. Their interest in the site began years before it
became a Superfund site. For the past several years the primary concern of most of these
residents is their desire to have the government purchase or otherwise obtain their properties
to provide them with an opportunity to move from the area of the site. Public comments are
addressed in the following section.
1
;! .
,.... 1
; '..
-------
Summary of Comments Received and Agency Responses
The following comments were received by the WDNR as written comments during the public
comment period. The written comments reflect the issues that were noted verbally at the
October 27, 1993 public meeting.
1. Comment:
Alternative 6 is the proper solution. Anything shQlt of complete contaminated soil removal,
to background concentration levels, would be a great disservice.
Agency Response: Alternative 6 includes excavation of soil to the calculated background
level. This entails the removal of approximately 32.000 cubic yards of soil. Alternative
4 removes approximately 80 % of the contaminant mass with the excavation of a much
smaller amount of soil (approximately 6,200 cubic yards). All soil with chromium
concentrations above 500 mg/kg would be removed under alternative 4. The additional
soil removed under Alternative 6, approximately 25.800 cubic yards, would address only
20 % of the contaminate mass in soil exceeding the calculated background value. The
Baseline Risk Assessment, developed as part of the Remedial Investigation. detennined
that the chromium concentration of concern in soils. for direct contact, is 570 mg/kg.
This concentration represents a Hazard Index level of 1. Removal of soils to background
concentrations would mean that a significant amount of additional soils that do not
represent a direct contact risk would have to be excavated to obtain the additional 20% of
the contaminant mass. The cost of the removal is directly related to the volume of soil
removed. Thus, the capital cost associated with Alternative 6 is approximately 5 times
greater than Alternative 4, with little increase in protectiveness.
Alternative 4 includes groundwater collection provisions that are expected to contain and
control the remaining soil and groundwater contamination in the areas that are not
excavated. This means that the remaining 20 % of contaminant mass is not left
unaddressed.
Given the above considerations, and considering that Alternative 6 would have additional
short tenn secondary impacts, such as dust, noise and truck traffic as compared to
alternative 4, the agencies have detennined that alternative 6 would not be cost effective
nor would it provide the best balance of the nine selection criteria.
2. Comment:
Alternative 6 would shorten the length of groundwater clean up by many years as compared
to Alternative 4.
Agency Response: Alternative 6 would shorten the time to reach groundwater clean up
goals when compared to Alternative 4 according to the time estimates prepared as part of
the Remedial Investigation. However, removing the soils to background levels would nor
significantly shorten the amount of time necessary (calculated minimums) to reach
2
-------
concentration levels associated with direct contact with groundwater (5000 Jtg/l) while
increasing the cost by 46 % . The time estimate to reach this goal for Alternative 6 is
about 200 years and approximately 270 years for Alternative 4. In addition, the extent of
excavation should have little or no impact on the ability of the groundwater collection
system to contain and control the contamination.
3. Comment:
The Agencies should me suit against the Mauthe'S'lnsurance company to recover the cost of
clean up and annual O&M.
Agencv Response: The Agencies are in the process of evaluating the possibility of cost
recovery. If a party is determined to be responsible, the Agencies will attempt to recover
their expenses.
4. Comment:
Clean the site up 100% (e.g., implement Alternative 6), including the temporary shut down
of rail service and the removal of contaminated soil beneath the railroad right-of-way.
Agency Response: The comment on selecting Alternative 6 is addressed above. The need
. for removal of soil from beneath the railroad tracks will be evaluated during the Remedial
Design phase of the project, and therefore, remains an option for the fInal remedy.
However, only a limited percentage of the overall contaminant mass is thought to be
present beneath the railroad tracks. Removal of this material, with temporary shut down
of the railroad, would not alter the need for the installation of a groundwater collection
trench near the tracks. For this reason, a significant cost savings would not be Wl1i7.ed
by removing contaminated soil from beneath the railroad tracks nor would the amount of
time to clean up be significantly reduced. Even if the soil under the tracks is not
removed, the proposed collection trench positioned along the tracks will intercept
contaminated groundwater moving beneath the tracks and would eventually capture the
contamination that is leaching from the soil under the tracks.
5. Comment:
We can't sell our homes and businesses because no one will buy and no one will give loans
for repair, or to a new buyer for purchase.
Agency Response: The agencies recognize that lenders may choose not to provide loans
on property having existing contamination from off-propeny sources due to concerns over
potential purchaser or lender liability. However, considering the source of the
contamination, it is not expected that a purchaser of propeny or a lender who foreclosed
on propeny in the area would be held responsible for costs associated with clean up
related to the N.W. Mauthe site, on any purchased property. U.S. EPA's Prospective
Purchaser Policy provides that a purchaser of property in a situation such as at the N. W.
Mauthe site can be provided protection from potential Superfund liability. The state
Hazardous Substance Spill Statute generally provides that a property owner may be held
3
-------
responsible for clean up of contamination on their propeny. However, in a situation like
the N.W. Mauthe site, where the source of the contamination is known to be from off-
site, it is not the WDNR's policy to pursue innocent propeny owners or lenders who did
not cause the contamination, but simply had it migrate on to their land.
There are no state or federal restrictions to the sale of the homes or businesses in the
vicinity of the N.W. Mauthe Site, other than the requirement to disclos~ knowledge
regarding defects in the propeny as required by ch. 709, Wis. Stats.
6. Comment:
I'm concerned about the long term property values and potential livability for future residents
in the immediate area of the N. W. Mauthe site.
Agency Response: It is not the within the ability of the Superfund or state environmental
response programs to include measures within a remedial action for the purpose of
improving property values in the vicinity of a contaminated site. The purpose of these
programs is to clean up environmental contamination and remove health risks associated
with that contamination. The proposed remedial actions will remove all direct contact
hazards associated with the N. W. Mauthe site and will take appropriate actions toward
soil and groundwater clean up, so that residents can safely continue to reside in the
vicinity of the site.
7. Comment:
Contamination of soil has a very detrimental influence on property and the safety of residents
in the area.
Agency Response: Upon completion of the remedial action at the site, health risks
associated with the site will be removed. Surface and subsurface soils exceeding levels
representing a direct contact hazard will have been removed, except perhaps those soils
beneath the railroad tracks. Soils beneath the tracks would. however, remain beneath
railroad ballast and would not be readily available to direct contact. Current physical
hazards associated with the site itself would also be removed through demolition and
removal of the buildings. Steps will be taken to prohibit the installation of drinking water
wells in this area thereby removing the potential for ingestion of the contaminated water.
Capping coupled with groundwater collection will also remove the potential for contact
with contaminated surface water (puddles).
8. Comment:
I would recommend the on-site buildings be demolished including the houses on 2nd Street
and that a zero property value level be maintained for those homes.
Agency Response: The on-site buildings are to be demolished as one of the actions
associated with the selected alternative. It is our intention to remove these buildings as
soon as possible, probably during the Remedial Design (RD) phase of the process rather
4
-------
than waiting until the full implementation of the Remedial Action (RA). Removal of the
on-site buildings is required for the implementation of the excavation of the soils
representing the contaminant source. This is not the case for the homes near the site.
Their removal is not required to implement the selected alternative. Additionally, a
significant health risk has not been identified for the nearby homes to require their
removal. Improvement or installation (as appropriate) of foundation drain systems around
the homes, coupled with sealing or painting of the basements is anticipated to minimize
the potential for seepage into the basements. Neither of the agencies are able to require
that a propeny be assessed at a cenain value or determine the associated amount of
property taxes.
9. Comment:
Removal of homes and businesses adjacent to the N. W. Mauthe Site could save thousands of
dollars in the actual physical remedial work, as well as in the long term liabilities.
A~ency Response: U.S. EPA guidelines do not allow the purchase of homes or businesses
unless there is a significant health threat associated with continued occupancy of the home
or if the home is located in such a manner that it prohibits the implementation of the
selected clean up action. Neither of these situations have been identified. Direct
construction costs could potentially be reduced if the adjacent homes and businesses were
removed, as there would not be a need for careful excavation near the buildings or
replacement of utilities. However, this would probably be offset by the costs of
purchasing the homes and subsequent demolition. Additionally, location of the collection
trench along Second Street was not selected to avoid homes and businesses. It is located
in a manner to collect groundwater from the leading edge of groundwater contamination
and to prevent funher migration of that contamination. Its location would not change if
the homes and businesses were removed.
10. Comment:
The propeny owners have sat back and patiently waited for this site to be cleaned up for
over 10 years. Now they are told clean up could possibly stan in two years or so depending
on funding availability.
Agency Response: The agencies understand the adjacent property owner's frustration with
tbe length of time the Superfund and prior state actions have taken to address the site. It
is our intent to complete the design and construction process as quickly as possible. For
example, it is our intent to begin on-property building demolition and stored waste
removal before the design process is complete. We hope to begin that work this summer.
Superfund fInanced action is dependent on the availability of federal and state funds.
11. Comment:
By purchasing the adjacent land parcels there would be no delays or problems in getting
easements for the proposed clean up. When the clean up is completed the parcels could then
be converted to an alternative use with less complication.
5
-------
Agency Response: The reasons why the homes and businesses adjacent to the N. W.
Mauthe site are not being purchased are discussed in responses to previous comments.
Should significant difficulties occur in obtaining access for the implementation of the
selected remedial action. U.S. EPA has the authority to seek a court order granting
access.
12. Comment:
The property owners are getting mixed signals from- the Agencies. On one hand they are
told that their basements are safe to use but then any new construction will not be allowed to
have basements after clean up is done.
Af!ency Response: Significant health threats associated with the levels of contaminants
detected in the basements of the homes adjacent to the N. W. Mauthe site have not been
identified. Improvements to the foundation drains around the homes in the area coupled
with painting and/or sealing of the basement walls and floors should remove the potential
for continued seepage of contaminated groundwater into the basements. removing any
long tenn risks related to the site. Future use of the adjacent properties would be
restricted to prevent risks associated with excavation of contaminated soils or soils
saturated with contaminated groundwater without proper precautions and to prevent the
disturbance of the in-ground portions of the remedial action (trenchs, pipes, etc.).
The statement about new construction without basements was made at the October 27,
1993 public meeting in reference to restrictions on the Mauthe property itself. The
statement was a reply to a question about possible future uses of the Mauthe property. A
possible use would have to be one that would not disturb the in-ground portions of the
remedial action, and a developer might want to avoid the precautions and costs associated
with excavating contaminated soils. One such use would be a building without a
basement. However, buildings with basements are not precluded provided that the proper
precautions are taken.
13. Comment:
We question whether the plan adequately addresses the contamination of the properties
adjacent to the site. We are not convinced that the proposed remediation will be either cost
effective or successful in dealing with the problems of these locations. We have no
indication from the property owners that the proposed action is acceptable to them. We are
particularly concerned about the long-tenn monitoring and future corrective actions that may
be necessary to effectively manage the contamination at these properties.
Af!ency Response: The agency believes the proposed remedial action will adequately
address the contamination and be protective of human health and that future additional
corrective or remedial actions are unlikely. The actions in the proposed remedy that
address the adjacent properties, such as the collection trenches and foundation drains are,
if properly constructed and maintained, expected to be reliable over a long period of time.
The agency recognizes that the action will require long-tenn operation. maintenance and
6
-------
monitoring and intends to provide for those activities.
14. Comment:
The zone of contamination extends into the street right-of-ways for Melvin. Outagamie, and
Second Streets. What actions will be taken to insure the City's ability to maintain public
utilities and infrastructUre contained wiLhin the right-of-way?
Agency ResDonse: The proposed remedial acti<2!1 is expected to minimize the spread of
additional contamination towards the public right-of-ways and, over time, remediate the
contamination found there. Specifics related to protection, maintenance and/or
replacement of utilities located in City right-of-ways during construction of the remedial
action will be resolved during the Remedial Design phase of the clean up process. The
Superfund investigation results may be of value to the City to determine if precautions are
necessary during future utility work. For example. it should be noted that other than
along a portion of Melvin Street and near the comer of Melvin and Outagamie Streets
levels of contamination that have been identified in both groundwater or soils are not at
levels that are expected to represent a direct contact hazard. We do not believe the level
of contamination found in the public right-of-ways would restrict the City's ability to
perform normal utility work, provided proper precautions are taken. It may however, be
useful for the City to perform additional sampling along the streets in question in
conjunction with any future subsurface work to ensure the safety of their workers.
15. Comment:
Our understanding is that the site will be closed to public access for the foreseeable future.
We have concerns about this occurring and about long-term upkeep of the property. We
would prefer a solution that resulted in usable space. even if that were restricted to surface
activities.
A~ency Response: Specific land use decisions for the Mauthe property should be made
during the Remedial Design phase of the clean up process with the input of the City of
Appleton and the local residents. The agency imends to initiate this decision process
during the design, however, we stand ready to begin sooner should the City wish to
initiate the discussions. A portion of the site would obviously be used for construction of
a groundwater treatment facility and associated work area. The Mauthe property may
prove to be suitable for certain industrial or commercial uses or for parking or as green
space.
.0. S. GOVER..\'MENT PRINTING OFFICE: 1994 - 3 8 6 -S 41 / 03084
7
------- |