PB97-964106
EPA/541/R-97/097
January 1998
EPA Superfund
Record of Decision:
Tomah Armory Landfill
Tomah, WI
9/23/1997
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Tomah Armory Landfill, Tomah, Monroe Comity, Wisconsin
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the Tomah Armory Landfill
(TAL) site in Tomah, Monroe County, Wisconsin, which was chosen 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 is
consistent with the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) to
the extent practicable. This decision is based upon the contents of the Administrative Record for
the site.
It is anticipated that the State of Wisconsin will concur with this decision. A written
confirmation is expected by September 30, 1997, and will be added to the administrative record
upon receipt.
DESCRIPTION OF THE SELECTED REMEDY
The United States Environmental Protection Agency (U.S. EPA) has found that "No Action" is
appropriate because contamination from the landfill poses no significant risk under the current
land use and the reasonably anticipated future land use at the site. In addition, since waste
material will be left in place and because there is contaminated ground water under the landfill
itself, U.S. EPA is proposing groundwater monitoring to ensure that groundwater conditions at
the site continue to pose no significant risk.
DECLARATION STATEMENT
U.S. EPA in cooperation with the Wisconsin Department of Natural Resources (WDNR) and one
of the potentially responsible parties (PRPs) conducted a remedial investigation that identified
contamination both in site soils and in ground water at the TAL and analyzed risks posed by this
contamination. U.S. EPA has found that no remedial action is necessary at the TAL to ensure
protection of human health and the environment. A brief description of the basis for this finding
is set forth below.
For ground water, based on the information collected to date on the site contamination, site
conditions, and consideration of federal and state groundwater standards, U.S. EPA is
recommending no action for the groundwater contamination identified at the TAL. Groundwater
contamination found downgradient of the TAL was determined to be from a source upgradient to
the TAL. For groundwater contamination found under the TAL, U.S. EPA does not believe the
groundwater will be used as a drinking water source. The Tomah Armory property and the rest
of the City of Tomah is currently served by a municipal water service. Given that the municipal
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system has adequate capacity for expansion, U.S. EPA believes that any potential future
development on-site would use municipal water as well. In addition, since waste material will be
left in place and because there is contaminated ground water under the landfill itself, U.S. EPA is
proposing groundwater monitoring to ensure the groundwater conditions at the site continue to
pose no significant risk.
For surface and subsurface soils, based on the information collected to date on the site
contamination, associated risks to human health and the environment, and consideration of
federal and state soil standards, U.S. EPA concluded that remediation of soil is not warranted
under the current and anticipated future land use. U.S. EPA believes that, given the degree of
exposure associated with the current and future land use, contaminated soil poses no significant
risk to human health and the environment. Although the "No Action" decision is founded on the
fact that no significant risk was determined based upon current and reasonable future land use,
protections against inappropriate land use are already in place in the form of restrictive covenants
enforceable by the WDNR.
Although this decision is for "No Action", EPA will conduct five-year reviews in accordance
with CERCLA Section 121. The five-year reviews will be performed because hazardous
substances will remain at the site, and will evaluate the status of the site including any
institutional controls that are in place. If it is determined that conditions have changed at the site
such that unacceptable risk at the site exists, this decision may be reopened.
U.S. EPA has determined that its response at this site is complete. Therefore, the site now
qualifies for inclusion on the Construction Completion List.
ATE William E. Muno
Superfund Division Director
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U.S. EPA Superfund
Record of Decision
Tomah Armory Landfill Site
Toman, Monroe County, Wisconsin
September, 1997
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TABLE OF CONTENTS
I. Site Description 1
II. Site History and Enforcement Activities 1
III. Highlights of Community Participation 2
IV. Scope and Role of Response Action 3
V. Site Characteristics 3
VI. Summary of Site Risks 6
VII. Explanation of Significant Changes 10
VIII. State Concurrence 10
FIGURES
Figure 1
Figure 2
Figure 3
Figure 4
Figure 5
TABLES
Table 1
Table 2
Table 3
Tomah Armory Landfill Site Location Map
Tomah Armory Landfill Site Base Map
With Phase I Sampling Locations
Tomah Armory Landfill Site Base Map
With Phase II Soil Sampling Locations
Tomah Armory Landfill Site Base Map
With Phase II Groundwater Sampling Locations
Tomah Armory Landfill Site Base Map
With Landfill Boundaries and Property Parcels
Inorganics in Groundwater at Tomah Armory, Phase I
Volatile/Semivolatile Organics in Groundwater at Tomah Armory, Phase I
Groundwater Quality Data, November 1995, Volatile Organic Compounds
(VOCs) and Inorganics, Tomah Armory Landfill Site, Tomah, Wisconsin,
Phase II
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Table 4 Groundwater Quality Data, February 1996, Volatile Organic Compounds (VOCs)
and Inorganics, Tomah Armory Landfill Site, Tomah, Wisconsin, Phase II
Table 5 Occurrence Summary of Surface Soil Samples, Phase I/ Phase II RJ, Tomah
Armory Landfill Site, Tomah, Wisconsin
Table 6 Occurrence Summary of Subsurface Soil Samples for Armory and Museum
Areas, Phase I/Phase II RJ, Tomah Armory Landfill Site, Tomah, Wisconsin
Table 7 Comparison of Surface Soil Data to Background Concentrations and Risk-Based
Guidelines, Tomah Armory Landfill Site, Tomah, Wisconsin
Table 8 Comparison of Subsurface Soil Data to Background Concentrations and Risk-
Based Guidelines, Tomah Armory Landfill Site, Tomah, Wisconsin
APPENDICES
Appendix A - Responsiveness Summary
Appendix B - Administrative Record
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DECISION SUMMARY
L Site Description
The Tomah Armory Landfill (TAL) is located in the northeastern section of the City of Tomah,
Monroe County, Wisconsin (Figure 1). The site is bordered on the north by the City sewage
disposal and treatment facility, to the east by Mill Street and a residential area, to the south by
Arthur Street and a telephone museum, and to the west by Woodward Avenue which separates
the site from open fields and an apartment complex to the west. Access to the site is not
restricted.
The original landfilled area covered a significant portion of the area north of Arthur Street to the
South Fork of the Lemonweir River in the vicinity of Mill Street and Woodward Avenue. It
covered the majority of what is now the Armory property, a portion of the City of Tomah sewage
treatment plant property, a portion of a property on which a museum is located and finally a
small area west of Woodward Avenue. The small area west of Woodward Avenue was
excavated and the excavated material was disposed off-site in the early summer of 1997, for
general maintenance purposes.
Ground water in the vicinity of the TAL is currently not used for drinking water purposes. Area
residences are connected to municipal water services.
IL Site History and Enforcement Activities
The Armory Landfill was owned until 1968 by the City of Tomah. Landfilling occurred at the
site from 1950 until sometime between 1955 and 1960. Waste disposal methods consisted of
excavation of 6 to 8 feet of surface soil, disposal of waste material in the excavated area,
placement of a cover consisting of previously excavated topsoil, and a final grading process.
Some of the material disposed of in the landfill may have been burned before it was buried. No
disposal records regarding the types (residential, commercial, or industrial) or quantities of
material buried were maintained.
The Wisconsin Army National Guard (ARNG) purchased a portion of the site in July of 1968 to
support Wisconsin ARNG activities associated with the adnv-tistration, logistical support, and
readiness of the unit. The remainder of the site is currently used for operation of the City of
Tomah wastewater treatment plant, and the operation of a telephone museum.
Prior to the purchase of the property by the ARNG, a portion of the landfill was excavated and
disposed off-site in order to construct some Armory buildings. Also, during 1997, an area west
of Woodward Avenue was excavated and the excavated material was disposed off-site. An area
of the museum property was also graded, covered, and reseeded.
Representatives of the Wisconsin Department of Natural Resources (WDNR) and the U.S. EPA's
Field Investigation Team (FIT) investigated the site in 1984 to gain information for a preliminary
assessment. A site inspection report was prepared, and the site was scored using the Hazard
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Ranking System (HRS). The site was placed on the National Priorities List (NPL) on July 21,
1987. The possible effects of disposal directly into an aquifer and the potential for direct contact
with hazardous substances because of erosion of the landfill cap were the concerns raised during
the preliminary assessment.
In January, 1988, the Agency for Toxic Substances and Disease Registry (ATSDR) prepared a
preliminary health assessment for the site. The assessment lists a number of potential exposure
routes including ingestion and dermal contact with ground water, surface water, and soils and
inhalation of contaminated dusts or volatile compounds. The assessment was completed before
the collection of any samples at the site and thus recommended environmental characterization
and sampling of the site to address the environmental and human health exposure pathways.
In July, 1993, U.S. EPA, in cooperation with WDNR and the United States Geological Survey
(USGS), conducted a Phase I remedial investigation (RI) at the TAL. The purpose of the Phase I
RI was to collect ground water and soil samples to characterize the nature and extent of
contamination and associated exposure risks. This characterization would provide a basis for
deciding whether further action was necessary at the site. Results of the Phase I RI indicated that
additional ground water and soil sampling was needed to adequately characterize the site.
Research to identify parties responsible for conditions at the TAL was completed in December,
1994. U.S. EPA named the City of Tomah and the Wisconsin Department of Military Affairs as
potentially responsible parties (PRPs), based on their ownership and operation of the site. U.S.
EPA sent a special notice letter to PRPs in January, 1995, requesting a "good faith" proposal to
continue the Phase II remedial investigation/feasibility study (RI/FS). In February 1995, the City
declined the offer to perform the response action. In March, 1995 the Wisconsin Department of
Military Affairs agreed to conduct the Phase II RI/FS.
III. Highlights of Community Participation
In July, 1993, U.S. EPA hosted a "kick-off' public meeting at the Tomah City Hall Council
Chambers. The purpose of the meeting was to inform local residents of the Superfund process
and the work to be performed under the RJ.
An information repository was established in 1993 at the Tomah Public Library, 716 Superior
Avenue, Tomah, Wisconsin. U.S. EPA maintains a copy of the administrative record for the site
in the information repository and at the U.S. EPA Region 5 office. The RI was released to the
public in April, 1997. A Proposed Plan was made available on July 22, 1997. A public meeting
was held on August 18, 1997, to discuss the RI and Proposed Plan. Advertisements were placed
in local newspapers to announce the public meeting and comment period. A public comment
period for the Proposed Plan was established from July 25, 1997, to August 25,1997. The public
generally supports the selected remedy. The responsiveness summary is contained in Appendix
A.
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The public participation requirements of Sections 113 (k)(2)(B) and 117 of CERCLA, 42 U.S.C.
§§ 9613 (k)(2)(B) and 9617, have been met in the remedy selection process. This decision
document presents the selected remedy for the Tomah Armory Landfill Superfund site, chosen in
accordance with CERCLA, as amended by SARA, and to the extent practicable, the NCP. The
decision for this site is based on the Administrative Record.
IV. Scope and Role of Response Action
U.S. EPA has selected a "No Action"decision at the TAL. This decision is based on an analysis
of site risks and conditions, described in detail below. The decision relies on the fact that under
current land use and reasonably anticipated future land use contamination associated with the site
does not pose any significant risk. Because hazardous substances will remain at the site, ground
water at the site will be monitored and the U.S. EPA will conduct a five-year review in
accordance with Section 121 of CERCLA to assess whether any other response is necessary.
Vj Site Characteristics
The Phase I and II RI involved sampling and analysis of ground water, air, subsurface soil, and
surface soil to determine site conditions. Groundwater samples were collected from residential
and monitoring wells around the site. Subsurface and surface soils were collected from within
the landfilled area to determine if contamination is present, and from outside the landfilled area
to determine background conditions. A geophysical investigation consisting of a magnetic survey
and an electromagnetic survey was conducted to determine the approximate boundaries of the
landfilled area.
Based on the results of the RI, U.S. EPA examined the threats to human health and the
environment through exposure by ingestion and/or direct contact with contaminants in the
subsurface and surface soils. Groundwater contamination found downgradient of the TAL was
determined to be from a source upgradient to the TAL. For ground water contamination found
under the TAL, U.S. EPA does not believe the groundwater will be used as a drinking water
source. The Tomah Armory property and the rest of the City of Tomah is currently served by a
municipal water service. Given that the municipal system has adequate capacity for expansion,
U.S. EPA believes that any potential future development on-site would use municipal water as
well. In addition, since waste material will be left in place and because there is contaminated
ground water under the landfill itself, U.S. EPA is proposing groundwater monitoring to ensure
the groundwater conditions at the site continue to pose no significant risk.
Site Conditions
Physical Features
1. Soils
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Data from soil borings indicate that the TAL is underlain predominantly by tan, brown, and gray
fine-grained soils. These deposits are alluvial and lacustrine in origin. Clayey sands, with the
characteristics of wetland soils, were encountered in borings outside of the landfill area at depths
of about 4 to 6 feet. These shallow clayey sand lenses may be associated with wetlands that are
numerous in the area and occur near the site.
2. Hydrology
There are no surface water bodies onsite. Parts of the TAL site are covered with buildings and
areas that are paved or covered with gravel. The landfill is slightly mounded and predominantly
grass-covered. Overland flow of water during storms occurs primarily in the paved and gravel
parking areas. The area is drained by storm sewers within and outside the TAL boundaries. In
general, surface drainage patterns are to the north-northwest towards the south fork of the
Lemonweir River.
3. Hydrogeology
Ground water at the TAL was encountered between 1 to 9 feet below ground surface, depending
on the topography. Regional ground water flow in the vicinity of the TAL trends east-northeast
towards the main branch of the Lemonweir River. Shallow groundwater flow, trends north-
northwest towards the south fork of the Lemonweir River. Hydraulic conductivities were not
measured as part of the RI. However, an average horizontal flow velocity of 28 ft/yr was
calculated, based upon data collected from monitoring wells screened in similar materials at the
Tomah Municipal Sanitary Landfill Superfund site, which is located on the northwest side of
Tomah.
The main regional and local aquifer in the area are the sandstone formations of Late Cambrian
age. The Cambrian sandstones also contain lenses of dolomite, siltstone, and shale. The aquifer
varies in thickness from 50 to 2,500 feet across the region.
Virtually all drinking water within the Tomah city limits is provided by municipal services.
There are five municipal wells sunk into the sandstone aquifer. Three of the wells are currently
in use at depths ranging from 280 to 325 feet. Two wells are not currently used. All of the wells
are within 1 to 3 miles of the site. Data collected as part of the RI indicate that the municipal
wells are unaffected by contamination at the TAL.
4. Ecology
The TAL site is characterized by buildings, paved and gravel covered areas, mowed lawns, and
some areas covered by shrubs. Wildlife habitat at the Armory is limited due to lack of vegetative
cover.
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Land surrounding the TAL site is predominantly residential and commercial with some vegetated
areas associated with the south fork of the Lemonweir River.
WDNR's Bureau of Endangered Resources reports no known occurrences of threatened or
endangered species, or natural areas in the vicinity of the site. The U.S. Fish and Wildlife
Service does report that endangered and threatened species occur in Monroe County. However,
the U.S. Fish and Wildlife Service believes that these species are not being adversely affected by
conditions at the site.
5. Contamination
Phase I RI
In July, 1993, U.S. EPA, in cooperation with WDNR and the United States Geological Survey
(USGS), collected groundwater and subsurface soil samples and had them analyzed for volatile
organic compounds (VOCs), semi-volatile organic compounds (SVOCs), and metals as part of a
Phase I RI. The Phase I sampling locations are shown on Figure 2. Sampling results indicated
that contaminants within the landfill boundaries (on-site) and in discrete locations outside the
boundaries of the landfill (off-site) are present in concentrations above state and/or federal
standards.
The primary contaminants of concern in ground water are lead, found primarily on-site at
sampling locations W-16, W-17, W-18, W-19, and W-20, and trichloroethene (TCE), found in
one sample location on-site, W-20. and one sample location off-site, W-24.
The evaluation of the nature and extent of contamination in the subsurface soils indicated that,
although some contamination occurs at depth, primarily lead and benzo(a)pyrene, the
concentrations detected do not warrant further investigation. However, the Phase I RI concluded
the surface soils needed to be characterized to evaluate risks associated with direct contact at the
landfill area through unrestricted access.
Phase II RI
Field investigations for the Phase II RI included installation of monitoring wells for sampling
ground water and the sampling of surface soils on and off the landfill. The location of the Phase
II sample locations is shown in Figures 3 and 4. Regional groundwater flow is east-northeast and
shallow groundwater flow is to the north-northwest, putting MW-1, MW-3, and MW-4
downgradient.
The results of the groundwater sampling indicated the presence of TCE in all the monitoring
wells. However, TCE concentrations in the upgradient wells, MW-2 and PZ-2, were
significantly higher than those in the downgradient wells. 1,2-dichloroethene (1,2 DCE) and 1,2-
dichloroethane (1,2 DCA) were also detected in substantially higher concentrations in the
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upgradient wells.
To help streamline the project, the Phase II surface soil sampling concentrated on the two main
chemicals of concern, benzo(a)pyrene and lead, determined from the results of the Phase I
subsurface soil sampling. Approximately 48 surface soil samples were collected at locations on
and off the landfill and analyzed for benzo(a)pyrene and lead.
The Phase II investigation also included extensive geophysics and test pitting to determine the
boundaries of the landfill. Figure 5 shows the results of the geophysical investigation. Since the
boundaries of the landfill encroached on other properties besides the Armory property, the entire
site was divided into parcels. These parcels are also shown on Figure 5.
VI. Summary of Site Risks
Based on data collected during the RI, human health and ecological risks associated with
contaminants detected in soils and ground water within and near the site were assessed. This
assessment, called a baseline screening, was conducted to compare contamination levels at the
site with U.S. EPA and state standards. It considered ways in which people and wildlife could be
exposed to site-related contaminants and whether such exposure could increase the incidence of
cancer and noncarcinogenic (noncancer related) diseases above the levels that normally occur in
the study area.
Results of the groundwater investigation indicated that the inorganic contaminants are found
inside the boundaries of the landfill and the organic groundwater contamination is from a source
upgradient from the Armory Landfill site. Tables 1, 2, 3, and 4 are summaries of the Phase I and
II groundwater data. During the Phase I investigation, inoiganic contaminants, most importantly
lead, were detected inside the boundaries of the landfill at levels above the federal maximum
contaminant level (MCL). Lead was also found in one location outside the boundary of the
landfill at a concentration (15.3 ug/1) slightly above the MCL (15.0 ug/1). Phase II groundwater
sampling performed outside the boundaries of the landfill did not detect lead in any wells above
the MCL. Organic contaminants in ground water were found inside and outside the boundaries
of the landfill. The Phase I sampling detected trichloroethene (TCE) inside the boundaries of the
landfill and downgradient at concentrations above the MCL (5 ug/1). The Phase II sampling
confirmed the presence of TCE and detected other organic contaminants outside the boundaries
of the landfill. However, the Phase II sampling also detected these organic constituents in
upgradient wells at greater concentrations. Follow-up, to help determine potential sources for the
organic contamination, confirmed the presence of a site with leaking storage tanks upgradient to
the Armory landfill. The State of Wisconsin is addressing the presence of a contaminated
upgradient site. The U.S. EPA concluded that the organic contamination was from a source other
than the landfill and that ground water under the landfill would not be used as a drinking water
source, since the area around the landfill site, together with the rest of the City of Tomah, is
currently served by municipal water. Given that the municipal system has adequate capacity for
expansion, U.S. EPA believes that future development on-site would use municipal water as
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well. Ground water at the site will be monitored because waste will be left in place and to ensure
that groundwater conditions at the site continue to pose no significant risk. Results of the future
groundwater monitoring will be evaluated after five years to determine the need to continue
monitoring.
Moving on from groundwater issues, the assessment focused on risks associated with exposure to
surface and subsurface soils. It assumed that the degree of exposure to surface and subsurface
soils is strongly related to land use patterns. The assessment therefore evaluated risks under
current and expected future land use conditions.
Current land use and reasonably anticipated future use of the land at NPL sites are important
considerations in determining current risks, future potential risks, and the appropriate extent of
remediation. (See "Land Use in the CERCLA Remedy Selection Process," OSWER Directive
No. 9355.7-04, May 25, 1995). Land use assumptions affect the exposure pathways that are
evaluated in the risk assessment. The results of the risk assessment aid in determining the degree
of remediation necessary to ensure current and long-term protection at the site. The risk
assessment considers present use of the site to determine current risks. It may restrict its analysis
of future risks to the reasonably anticipated future land use.
Current land use at the Armory Landfill varies and the corresponding exposure possibilities
vary as well. To take this variability into account, the risk assessment divided the Armory
Landfill into land parcels (Figure 5). The parcels include: 1) the Wisconsin Army National
Guard (Armory) area, a parcel containing the National Guard facility; 2) the MuseuT1 *nd
Trespasser areas, a parcel containing the museum and a small area across Woodward Avenue
easily accessible to trespassers, including children at play; and 3) the Sewage Treatment Plant
area, a parcel containing the sewage treatment facility. It should be mentioned that the small area
across Woodward Avenue, area 3 in Figure 5, was excavated and the excavated material was
disposed offsite. Also a portion of the museum property, area 1 on Figure 5, was graded,
covered and reseeded. This work was voluntarily conducted in 1997 by the Wisconsin ARNG
upon recommendation of the WDNR. The risk assessment focused upon users who would face
the greatest exposure in each of these areas, i.e., those people who would be most likely to come
into contact with contaminated soils'. In all three areas, maintenance workers, whose duties
might include mowing lawns or construction work, seemed to be the group most likely to be
exposed. In addition, for the Museum and Trespasser parcel, the assessment calculated risks to
children who might occasionally play on the property.
In extending the analysis to future conditions, the risk assessment took into consideration the
reasonably anticipated future land use. It is assumed that future land use would stay more or less
the same, with continued light industrial zoning for the site itself, and residential and commercial
uses nearby. Such land use might include the construction of additional buildings and/or
maintenance of the current buildings on the site. New construction might be industrial,
commercial, or residential in character. Under these conditions, the risk assessment identified as
the focus group for estimating future site risks, on-site workers who may excavate soils for repair
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or construction purposes.
U.S. EPA uses conservative estimates when evaluating potential risks. This approach may
overstate the true risks, but it provides a high level of protection for public health and the
environment. In the case of the Armory Landfill, soil samples revealed a range of concentrations
for certain chemicals of concern. Tables 5 and 6 contain summaries of the surface and
subsurface soil data. The risk evaluation estimated an exposure point concentration (EPC) by
calculating the 95 percent upper confidence limit of the mean. For surface soils, EPCs were
estimated for benzo(a)pyrene and lead in each of the parcels under current conditions and for the
overall site using the hypothetical future scenario. For subsurface soils, EPCs were estimated for
benzo(a)pyrene, arsenic, barium, beryllium, chromium, lead, manganese, nickel and thallium in
the Armory and Museum parcels. The EPC was then compared to background concentrations,
soil screening levels (SSLs), risk based concentrations (RBCs), and/or a calculated adult lead
cleanup level. The SSLs were based on U.S. EPA guidance documents. (See "Risk-Based
Concentration Table", Roy L. Smith, Office of RCRA, Region 3, U.S. EPA, latest update; Soil
Screening Guidance, OSWER EPA/540/R094/101, 1994; and "Revised Interim Soil Lead
Guidance for CERCLA Sites and RCRA Corrective Action Facilities", OSWER Directive
#9355.4-12, July 14, 1994). RBCs were developed using standard U.S. EPA risk calculations to
determine screening levels for industrial and residential scenarios based on risk factors of 1 x 10"6
to 1 x 10"4. (See "Risk-Based Concentration Table", Roy L. Smith, Office of RCRA, Region 3,
U.S. EPA, latest update). Calculation of the adult lead clean-up model is presented in Appendix
O of the TAL RI Report, January 1997. In general, when an EPC falls below the background
concentration or the SRT no further action or study will be required. EPCs that fall above the
background and the SSL or where a specific SSL does not exist, do not automatically trigger an
action but warrant further site-specific risk evaluation by comparison with RBCs or the
calculated adult lead cleanup level.
In general, low levels of contamination have been observed in the surface and subsurface soil
throughout the landfilled area and there do not appear to be any hot spots (See Tables 5 and 6).
Methane and organic vapors were not detected during the sampling of surface soil, indicating
that volatization of landfill gases to the atmosphere is limited under existing conditions. In
addition, based on site specific conditions, including the size and depth of the landfill, the
distance of the surrounding residential areas from the landfill, and current deed restrictions that
eliminate possible exposures, U.S. EPA concluded that migration of subsurface landfill gas was
not a significant or completed pathway of concern. The potential for release of contaminated
dust to the atmosphere is limited based on the relatively heavy vegetative or gravel covers over
most of the contaminated areas. Moreover, activities such as excavation or grading that might
release contaminants to the air require WDNR approval under existing property restrictions.
Surface Soils
Risk associated with exposure to surface soils at the Armory Landfill were evaluated for the
current maintenance workers and trespassers, and the hypothetical future on-site construction
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worker. As mentioned previously, the surface soil sampling was primarily concerned with the
concentrations of benzo(a)pyrene and lead. Under current conditions risks were assessed for the
various parcels, including the Museum and Trespasser, Armory, and Sewage Treatment Plant,
areas (See Figure 5). For all three areas, surficial soils EPCs were compared to industrial value
guidelines. Additionally for the Museum and Trespasser area, residential values were also used
for comparison. Table 7 contains a summary of the risk analysis for surface soils.
For all the areas, the EPCs for benzo(a)pyrene and lead were slightly above background
concentrations. However, for all the areas, the EPCs for benzo(a)pyrene fell below the 1 x 10~6
risk based concentration for industrial soil ingestion and the EPCs for lead were below the SSL
and the lead cleanup level calculated in the modeling. For the hypothetical future scenario, a
separate site-wide EPC was calculated for benzo(a)pyrene and lead. The future scenario EPC for
benzo(a)pyrene was within the 1 x 10~6 to 1 x 10"5 risk based concentration range for residential
and industrial soil ingestion. The future scenario EPC for lead was below the SSL and the adult
lead cleanup level.
Subsurface Soils
This assessment evaluated risk associated with exposure to subsurface soils at the Armory Landfill
for the hypothetical future construction worker. Subsurface soils were collected at depths intervals
of 3 to 5 feet or 9 to 11 feet. Risks were assessed for various parcels and considered a wider range
of chemicals than the surface soils, including arsenic, barium, beryllium, chromium, lead,
manganese, nickel, anH thallium and benzo(a)pyrene. EPCs were calculated for each one of these
chemicals in the Armory and Museum parcels. All the EPCs exceeded background concentrations
except for thallium, which was not further evaluated. Of the remaining chemicals, arsenic,
beryllium, and benzo(a)pyrene are carcinogens. Chromium VI and nickel, as a refinery dust, are
carcinogens via inhalation. Because nickel is only carcinogenic as a refinery dust and this form of
nickel was not found at the site, the EPC for nickel was compared to the noncarcinogenic RBC for
industrial soil ingestion and the SSL- transfers from soil to air . EPCs for barium, lead, and
manganese were also compared to their respective noncarcinogenic RBCs and SSLs. Table 8
contains a summary of the risk analysis for subsurface soils.
At the Armory Area, benzo(a)pyrene, beryllium, and chromium EPCs fell below the 1 x 10~6 risk
based concentration for industrial exposures. The arsenic EPC fell between the 1 x 10"* and 1 x 10'5
risk based concentration range. None of the chemicals exceeded their respective risk based
concentrations for noncarcinogenic effects or the SSLs for transfer of soil'to air.
At the Museum area, benzo(a)pyrene, beryllium, and chromium EPCs fell below the 1 x 10'6 risk
based concentration for industrial exposures. The arsenic EPC fell between the 1 x 10'6 and 1 x 10'5
risk based concentration range. None of the chemicals exceeded their respective risk based
concentrations for noncarcinogenic effects or the SSLs for transfer of soil to air.
Lead EPCs in the Armory and Museum area exceed the residential SSL of 400 mg/kg, but are
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considerably below the RBC for lead in subsurface soils of 36,000 mg/kg calculated by using the
adult lead cleanup model assuming industrial use at the site.
Ecological Risk Assessment
Ecological risks to animals, plants, etc., are not expected to be significant because the Armory
Landfill is located in an urban setting and soil is the primary means by which exposure can occur.
No evidence of stresses to wildlife was observed during the field investigation.
Selected Remedy
Based on the information collected to date on the site contamination and associated risks to
human health and the environment, U.S. EPA believes that no remedial action is necessary.
Contamination from the landfill poses no significant risk under the current land use and the
reasonably anticipated future land use at the site. Protections against inappropriate land use are
already in place in the form of restrictive covenants, enforceable by the Wisconsin Department
of Natural Resources. Ordinarily, U.S. EPA identifies one or more engineering controls to
address contamination at a Superfund site and compares them in a feasibility study. But the lack
of significant risks eliminated the need for such a study in this case. U.S. EPA therefore selects a
"No Action" decision for this site. In addition, since waste material will be left in place and
because there is contaminated ground water under the landfill itself, U.S. EPA is requiring
groundwater monitoring to ensure that groundwater conditions at the site continue to pose no
significant risk.
In light of our decision not to select a remedial action, the requirements of CERCLA section 121
- including the provisions concerning applicable or relevant and appropriate requirements - are
not triggered; that section applies only in those cases where a remedial action is selected.
VII. Explanation of Significant Changes
There are no significant changes from the recommended alternative described in the proposed
plan.
VIII. State Concurrence
Based on its review on the remedial investigation, WDNR is concerned about the groundwater
monitoring component included in the proposed remedy. WDNR believes the U.S. EPA's
concerns regarding a change in site conditions can be addressed by U.S. EPA through a site
inspection at a future date. The purpose of the site inspection would be to document that land
use conditions have not changed, restrictive covenants remain viable, and that remedial progress
is being made at the off-site groundwater contamination source.
Despite this concern, the State of Wisconsin has indicated a willingness to concur with this
-------
11
decision. A written confirmation is expected by September 30, 1997 and will be added to the
administrative record upon receipt.
-------
FIGURES
-------
,->
~~1 r^jfTOMAH
1 '-i r r,
i '' i— ~r " I . '••" v|
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.-'• Leiimnweir\River
ffif \
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y Buckley [
lPar, ;lTf> . ..
SOURCE: Composite of USGS 7.5 Minute Topographic Maps, OAKDALE, TOMAH, TUNNEL CITY and WYEVILLE, WISCONSIN Quadrangles, 1983
S
S
o
£
Q.
O>
<
1000 2000
4000
SCALE IN FEET
WISCONSIN
MILLER, INC.
Environment and Infrastructure
a heidemlj company
TOMAH ARMORY LANDFILL
SITE (TALS) LOCATION MAP
PHASE II Rl
TOMAH ARMORY LANDFILL
TOMAH, WISCONSIN
FIGURE
1
-------
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PHASE i Rl SAMPLING LOCATIONS
-------
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SURFACE SOIL SAMPLING LOCATIONS
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-------
(IKHAfillTY
ff MII.I.KK, INC.
MONITORING WELL AMD STAFF GAUGE LOCATION MAP
PHASE II REMEDIAL INVESTIGATION
!;)'Mll AKMOKi | AhDI M I Mil
-------
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i \
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EXTENT OF FILL IN RELATION TO EXISTING
PROPERTY BOUNDARIES
-------
TABLES
-------
TABLE 1
INORGANICS IN GROUNDWATER AT TOMAH ARMORY, PHASE I
Sample Location W-16 W-17
Analvte Concentration (ue/l)
Aluminum
Arsenic
Iron
Lead
Manganese
Nickel
W-18
W-19 W-20
Secondary WPHGQ WPWGQ
MCL MCL Enf. St. Enf. St.
Risk
Cone.
638.2
ND
3018.8
67.9
733.8
ND
1650.5
24.2
4904.6
86.5
107.7
13992.0
3940.5
4.9
8407.2
46.5
850.9
ND
2172.9
ND
42640.0
310.5
1740.7
16.1
515.1
ND
28119.0
16.6
1464.3
ND
50.0
-
15.0"
-
100.0
50.0
-
300.0
-
50.0
-
50.0
-
15.0
-
-
-
300.0
-
50.0
-
11.0
180.0
730.0
* - This value is the Federal Action Level
Key:
Concentrations in bold face exceed one or more standards
MCL - Federal Maximum Contaminant Levels
Secondary MCL - Federal Groundwater Quality Maximum Contaminant Levels
WPHGQ Enf. St. - Wisconsin Public Health Groundwater Quality Enforcement Standards
WPWGQ Enf. St. - Wisconsin Public Welfare Groundwater Quality Enforcement Standards
Risk Cone. - Risk-Based Concentration for Tap Water from U.S. EPA, Region III, Risk-Based Concentration Table, July 11, 1994
ND - Compound not detected in analysis
(-) - Analyte not listed in Table
-------
TABLE 1
INORGANICS IN GROUNDWATER AT TOMAH ARMORY, PHASE I
(continued)
Sample Location W-21 W-22
Analvte Concentration (gg/h
Aluminum
Arsenic
Iron
Lead
Manganese
Nickel
W-23
W-2S MCL
Secondary WPHGQ WPWGQ
MCL Enf. St. Enf. St.
Risk
Cone.
3494.9
ND
12225.0
7.8
1363.6
16.1
6109.0
ND
19617.0
15.3
411.6
29.3
3523.0
ND
5497.9
10.6
678.88
ND
760.8
ND
38638.0
7.6
2264.3
ND
1458.1
3.7
14719.0
5.65
1246.4
12.1
50.0
-
15.0'
-
100.0
50.0
-
300.0
-
50.0
.
50.0
.
15.0
-
.
-
300.0
-
50.0
_
11.0
180.0
730.0
* - This value is the Federal Action Level
Kej:
Concentrations in bold face exceed one or more standards
MCL - Federal Maximum Contaminant Levels
Secondary MCL - Federal Groundwater Quality Maximum Contaminant Levels
WPHGQ Enf. St. - Wisconsin Public Health Groundwater Quality Enforcement Standards
WPWGQ Enf. St. - Wisconsin Public Welfare Groundwater Quality Enforcement Standards
Risk Cone. - Risk-Based Concentration for Tap Water from U.S. EPA, Region HI, Risk-Based Concentration Table, July 11, 1994
ND - Compound not detected in analysis
(-) - Analyte not listed in Table
-------
TABLE 2
VOLATILE/SEMIVOLATILE ORGANICS IN GROUNDWATER AT TOMAH ARMORY, PHASE I
WPHGQ Risk
Sample Location W-20 W-22 && W-24 MCL Enf. St. Cone.
Compound Concentration (ttg/l)
Volatiles
Chloroform ND 1.0 2.0 ND 5.0 6.0 0.15
Trichloroethene 98.0 ND ND 16.0 5.0 5.0 1.6
Semivolatiles
bis(2-ethylhexyl)phthalate' ND 1.0 1.0 10.0 - 3.0 4.8
* - Compound also detected in laboratory or field blanks
Kev:
Concentrations in bold face exceed one or more standards
ND - Compound not detected in sample analysis
MCL - Federal Maximum Contaminant Levels
WPHGQ Enf. St. - Wisconsin Public Health Groundwater Quality Enforcement Standards
Risk Cone. - Risk-Based Concentration for Tap Water from U.S. EPA, Region III, Risk-Based Concentration Table, July 11, 1994
(-) - Analyte not listed in Table
-------
Table 3 . Croundwater Quality Data, November 1995, Volatile Organic Compounds (VOCs) and Inorganics', Toman Armory Landfill Site, Tomah, Wisconsin,
Sample I.D.
Laboratory I.D.
Sample Date
VOCs
Chloroform
Chloromethane
,1-Dichloroethane
,2-Dichloroethane
,1-Dichloroethene
Tetrachloroethene
, 1 , 1 -Trichloroethane
, 1 ,2-Tnchlorocthane
Tnchloroethene
Vinyl chloride
1,2-Dichloroelhene (total)
INORGANCS
Arsenic -Dissolved
Lead -Dissolved
FIELD PARAMETERS
PH2
Specific Conductance (nS)
Temperature (°C)
Upgradient
MW-02
A5K040107002
1 1/02/95
< 5.0 J
< 5.0 J
< 5.0 J
< 5.0 J
< 5.0 J
< 2.5 J
< 5.0 J
< 3.0 J
160 J
< 2.5 J
32 J
< 5.0
< 3.0
6.6
550
10
PZ-02
A5K040 107006
1/02/95
< 1.0
< 1.0
< 1.0
< 1.0
< 1.0
< 0.50
< 1.0
< 0.60
26
< 0.50
6.2
< 5.0
< 3.0
5.7
330
9
Downgradient
MW-01
A5K040 107001
1/02/95
< .0
< .0
< .0
< .0
< .0
< 0.50
< 1.0
< 0.60
< 1.0
< 0.50
< 1.0
< 5.0
< 3.0
7.8
280
11
Dup MW-01
MW-99
A5K040107007
1 1/02/95
< .0
< .0
< .0
< .0
< .0
< 0.50
< 1.0
< 0.60
< 1.0
< 0.50
< 1.0
< 5.6
< 3.0
7.8
280
11
PZ-01
A5K040 107005
11/02/95
< .0
< .0
< .0
< .0
< .0
< 0.50
< 1.0
< 0.60
11
< 0.50
5.4
< '5.0
< 3.0
7.5
440
11
MW-03
A5K040 107003
1 1/02/95
< .0
< .0
< .0
< .0
< .0
< 0.50
< 1.0
< 0.60
1.9
< 0.50
< 1.0
< 5.0
< 3.0
6.0
270
11
MW-04
A5K040 107004
1 1/02/95
< .0
< .0
< .0
< .0
< .0
< 0.50
< ' 1.0
< 0.60
2.5
< 0.50
< 1.0
< 5.0
< 3.0
6.6
680
11
I All concentrations are reported in ng/L (micrograms per liter).
2 pH measured in standard pH units.
J Estimated concentration.
VMdpuiJmV\MO48o\pahbeii\lables\nov9S.xlswsj
GKRAGHTY & MILI.HK. INCJ
w
-------
Table 4 . Groundwater Quality Data, February 1996, Volatile Organic Compounds (VOCs) and Inorganics', Tomah Armory Landfill Site, Tomah, Wisconsin,
Sample I.D.
Laboratory I.D.
Sample Date
VOCs
Chloroform
Chloromethane
,1-Dichloroethane
,2-Dichloroe thane
,1-Dichloroelhene
Tetrachloroethene
,1,1-Trichloroethane
,1,2-Trichloroethane
Trichloroethene
Vinyl chloride
1 ,2-Dichloroethene (total)
INORGANCS
Arsenic -Dissolved
Lead -Dissolved
FIELD PARAMETERS
PHJ
Specific Conductance ((iS)
Temperature (°C)
Upgradient
Dup MW-02
MW-02 MW-98 PZ-02
A6B140133003 A6B 140 133008 A6B 140 133004
02/13/96 2/13/96 02/13/96
< 3.3 J < 3.3 J < 2 J
< 3.3 J < 3.3 J < 2.0 J
< 3.3 J < 3.3 J < 2.0 J
6.4 J 5.7 J < 2.0 J
< 3.3 J < 3.3 J < 2.0 J
< 1.7 J < 1.7 J < 1.0 J
< 3.3 J < 3.3 J < 2.0 J
< 2.0 J < 2.0 J < 1.2 J
94 J 83 J 48 J
< 1.7 J < 1.7 J < 1.0 J
24 J 18 J 14 J
< 5.0 < 5.0 < 5.0
< 3.0 < 3.0 < 3.0
7.7 7.7 7.3
670 670 460
5.8 5.8 7.6
Downgradient
MW-01 PZ-01 MW-03 MW-04
A6B140133001 A6B140133002 A6B140133005 A6B 140 133006
2/13/96 02/13/96 02/13/96 02/13/96
< 1.0 < 2.0
< 1.0 < 2.0
< 1.0 < 2.0
< 1.0 < 2.0
< 1.0 < 2.0
< 0.50 < 1.0
< 1.0 < 2.0
< 0.60 < 1.2
< 1.0 | 48
< 0.50 < 1.0
< 1.0 8.0
< 5.0 < 5.0
< 3.0 < 3.0
8.4 8.3
330 570
4.5 8.3
J < .0 < .0
J < .0 < .0
J < .0 < .0
J < .0 < .0
J < .0 < .0
J < 0.50 < 0.50
J < 1.0 < 1.0
J < 0.60 < 0.60
J 2.4 2.4
J < 0.50 < 0.50
J < 1.0 1.1
< 5.0 < 5.0
< 3.0 | 4.7 |
7.5 7.3
960 970
6.4 7.3
1 All concentrations are reported in fig/L (micrograms per liter).
2 pH measured in standard pH units.
J Estimated concentration.
NTT]Downgradient concentration greater than background level.
GERAGHTY & MILLER, INC
-------
Table 5 . Occurrence Summary of Surface Soil Samples, Phase I/Phase n RI, Tomah Armory Landfill Site, Tomah, Wisconsin.
Frequency Range of SQLs
COPC Detects / Total Min - Max
Armory Area
Bcnzo(a)pyrene 7/12 0.044 - 0.047
Lead 12/12
Museum Area
Bcnzo(a)pyrene 5/8 0.044 - 0.046
Lead 8/8
Swage Plant Area
Bcnzo(a)Pyrene 3 / 9 0.043 - 0.045
Lead 9/9
Trespasser Area
Benzo(a)pyrene 8 ' 12 0.043 - 0.046
Lead 12/12
All Surface Soils
Bcnzo(a)pyrene 18/38 0.042-0.047
Lead 38/38
All concentrations are reported in milligrams per kilogram (mg/kg).
COPC Constituents of potential concern.
Indicates that COPC was detected in all samples.
Range of Detects
Min - Max
0.048 - 0.41
3.6 - 80.2
0.21 - 1.3
6.3 - 422
0.076 - 0.40
8.3 - 52.4
0.048 - 1.3
6.3 - 422
0.048 - 3.9
3.6 - 422
Average
Detect
0.14
33
0.63
140
0.21
26
0.41
110
0.44
53
Mean
0.089
33
0.4
140
0.084
26
0.28
110
0.22
53
UCL
0.15
47
0.72
260.
0.16
37
0.49
190
0.4
79
EPC
0.15
47
0.72
260
0.16
37
0.49
187
0.4
79
EPC Exposure point concentration; lesser of the UCL and the maximum detected concentration rounded to two significant numbers.
Mean Arithmetic average of the total number of samples, using proxy concentrations
SQLs Practical sample quantitation limits for the non-detects.
UCL The upper 95 percent one-tailed confidence interval on the
mean for normally c
for non-detects.
listributcd data.
\siilptadm\\M0486\phaseii\tables\mow-2.xlsj GIvKAfiHTY & MILLI:R. INC.
-------
Table 6 . Occurrence Summaiy of Subsurface Soil Samples for Armory and Museum Area, Phase I/Phase n RI, Tomah Armory
Landfill Site, Tomah, Wisconsin.
Frequency Range of SQLs Range of Detects
COPC Detects / Total Min - Max
ARMORY AREA
Bcnzo(a)pyrene 1/1 - -
Arsenic 3 / 7 0.96 - 0.96
Barium 3/7 3.59-3.61
Beryllium 4 / 7 0.48 - 0.48
Chromium 5/7 1.44-1.45
Lead 7/7
Manganese 7/7 - -
Nickel 4/7 2.87-2.88
Thallium 4 / 7 0.97 - 0.97
MUSEUM AREA
Benzo(a)pyrene 1/1 - -
Arsenic /I - -
Barium /I - -
Beryllium /I - -
Chromium /I - -
Lead /I
Manganese /I - -
Nickel 11
Thallium /I - -
Min -Max
- -0.11
6.7 - 14.7
118-799.6
0.5 -2.1
1.6-45.6
2.5 - 1800
2.4 -931.2
3.7-45.7
0.7 - 0.9
- -0.14
- -21
- -630
- -1.2
- -57
- -4060
- -770
- -130
...
Average
Detect
-
10
440
1
19
420
210
28
1
-
.
.
-
.
-
-
Mean
-
5
190
1
14
420
210
17
0.67
-
.
-
-
-
-
-
All concentrations are reported in milligrams per kilogram (mg/kg).
COPC Constituents of potential concern.
Indicates that COPC was detected in all samples.
EPC Exposure point concentration; lesser of the UCL and the maximum detected concentration rounded
Mean Arithmetic average of the total number of samples, using proxy concentrations for non-detects.
SQLs Practical sample quantitation limits for the non-detects.
UCL The upper 95 percent one-tailed confidence interval on the mean for normally distributed data.
\vidntfldm\\vi 0486\phnscii\tables\logsub.xls
OF
UCL EPC
0.11
9 8.8
420 420
1 1.2
26 26
910 910
46U 460
31 31
0.8 0.8
0.14
21
630
1.2
57
4100
770
130
-
to two significant numbers.
IRAGHTY & MILLER. INC.
-------
Table 7 • Comparison of Surface Soil Data to Background Concentrations and Risk-Based Guidelines, Tomah Armory Landfill Site, Tornah. Wisconsin.
Background
Source Parameter EPC(l) Concentration*2'
Museum Benzo(a)pyTene(<) 0.72 0.067
Lead 260 36
Armory Benzo(a)pyrene(l) 0.15 0.067
Lead 47 36
Sewage Plant BenzoWpyrene'"' 0.16 0.067
Lead 37 36
All Surficial Soils Benzo(a)pyrene(t) 0.4 0.067
Lead 79 36
Background
Source Parameter EPC(1) Concentration'2'
Trespasser Benzo(a)pyrenew 0.49 0.067
Lead 190 36
NA Not applicable.
ND Not determined.
mg/Kg Milligrams per kilogram.
(a) Carcinogen.
( 1 ) Exposure Point Concentration.
RBC Industrial0'
10*
0.78
ND
0.78
ND
0.78
ND
0.78
ND
RBC
10^
0.088
ND
(2) Concentrations are the average background concentrations times two. Background samples include:
Benzo(a)pyrene was detected in the duplicate of BK22-02.
(3) Risk-Based Concentration, Industrial Soil Ingestion (USEPA, 1996).
10'5 10"4
7.8 78
ND ND
7.8 78
ND ND
7.8 78
ND ND
7.8 78
ND ND
Residential'7'
10'5 10"4
0.88 8.8
ND ND
BKSS-01 thru BKSS-06.
Adult Lead
Cleanup Level'4'
NA
36.000
NA
36,000
NA
36,000
NA
36,000
Residential
SSL(5)
0.09
400
SSL(5) Transfer
From Soil to Air
,,(6)
ND
n<6)
ND
u<6)
ND
n(6)
ND
SSL(5) Transfer
From Soil to Air
,,(6)
ND
(4) Adult lead cleanup level calculated using a frequency of 28 d/yr exposure (USEPA, Region VI, 1 995).
(5) Soil Screening Level (USEPA, 1 994).
(6) Soil Saturation Limit.
(7) Risk-Based Concentration, Residential Soil Ingestion (USEPA, 1 996).
widpUdm\wi04S6\ph*Mii\uMcf \uble6-2\iurfeUl.xli
GERAGHTYtf MILLER
-------
Page 1 of 2
Table ft . Comparison of Subsurface Soil Data to Background Concentrations and Risk-Based Guidelines, Tomah Armory Landfill
Site, Tomah, Wisconsin.
COPC
Armory Area
Carcinogens
Inorganics
mg/kg
*
**
ND
NA
ME
EPC
a
(1)
(2)
(3)
(4)
Background | RBC Industrial® |
EPC Concentration0' 10* W5 W4
Benzo(a)pyrene 0.11 •- 0.78 7.8 78
Arsenic 8.8 3.2 3.8 38 380
Beryllium 1.2 0.7 1.3 13 130
Chromium* 26 6.1 10,000* 100,000* 1,000,000*
Nickel** 31 5.8 ND ND ND
Barium 420 8.2 NA NA NA
Lead 910 6.6 ND ND ND
Nickel 31 5.8 NA NA NA
Manganese 460 24.6 NA NA NA
Thallium 0.8 1.2 NA NA NA
Milligrams per kilogram.
Not detected.
Value is for chromium VI.
Nickel is a carcinogen via refinery dust inhalation, this is not applicable to this site.
Not determined.
Not applicable.
Not established.
Exposure point concentration; lesser of the UCL and the maximum detected concentrations
rounded to two significant numbers.
Soil saturation soil.
Concentrations are the average background concentration.' times two.
Background samples include: B19DB (3-5 ft) and B19DB (9-11 ft).
Risk-Based Concentration, Industrial Soil Ingestion (USEPA, Region HI, 1996).
Soil Screening Levels, Residential Values (USEPA, 1994).
Adult lead cleanup level calculated using a frequency of 28 d/yr exposure (USEPA, Region
RBC Industrial
Noncarcinogenic
Effects
NE
610
NE
10,000
41,000
140,000
36,000W
41,000
10,000
ND
IV, 1995).
SSLa) Transfers
From Soil to Air
lla
380
690
140
6,900
350,000
ND
6,900
ND
ND
widptadm\wi0486\phaseii\tables\table6-2\soil.xls
GERAGHTY & MILLER, INC.
-------
Page 2 of 2
Table 8 . Comparison of Subsurface Soil Data to Background Concentrations and Risk-Based Guidelines, Tomah Armory Landfill
Site, Tomah, Wisconsin.
COPC
Background | RBC Industrial™ |
EPC Concentration'0 10"6 10"5 10"4
RBC Industrial
Noncarcinogenic
Effects
SSL(3) Transfers
From Soil to Air
Museum Area
Carcinogens
Inorganic
mg/kg
*
**
ND
NA
NE
EPC
a
(1)
(2)
(3)
(4)
Benzo(a)pyrenc 0.14 -- 0.78 7,8 78
Arsenic 21 3.2 3.8 38 380
Beryllium 1.2 0.7 1.3 13 130
Chromium* 57 6.1 10,000* 100,000* 1,000,000*
Nickel** 130 5.8 ND ND ND
Barium 630 8.2 NA NA NA
Lead 4100 6.6 ND ND ND
Manganese 760 24.6 NA NA NA
Nickel 130 5.8 NA NA NA
Thallium -• 1.2 NA NA NA
Milligrams per kilogram.
Not detected.
Value is for chromium VI.
Nickel is a carcinogen via refinery dust inhalation, this is not applicable to this site.
Not determined.
Not applicable.
Not established.
NE
610
NE
10,000
41,000
140,000
36,000W
10,000
41,000
NA
Ma
380
690
140
6,900
350,000c
ND
ND
6,900
ND
Exposure point concentration; lesser of the UCL and the maximum detected concentrations
rounded to two significant numbers.
Soil saturation soil.
Concentrations are the average background concentrations times two.
Background samples include: B19DB (3-5 ft) and B19DB '9-11 ft).
Risk-Based Concentration, Industrial Soil Ingestion (USEPA, Region III, 1996).
Soil Screening Levels, Residential Values (USEPA, 1994).
Adult lead cleanup level calculated using a frequency of 28 d/yr exposure (USEPA, Region
IV, 1995).
\vidptadm\wi0486\phaseii\tables\table6-2\soil.xls
GHRAGHTY^MIl.LL
-------
APPENDIX A
Responsiveness Summary
-------
RESPONSIVENESS SUMMARY
TOMAH ARMORY LANDFILL
TOMAH, MONROE COUNTY, WISCONSIN
PURPOSE
This responsiveness summary has been prepared to meet the requirements of Sections
113(k)(2)(B)(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 the United States Environmental
Protection Agency (U.S. EPA) to respond to each of the significant comments, criticisms, and
new data submitted in written and oral presentations on a proposed plan for remedial action. The
responsiveness summary provides a summary of residents' comments and concerns identified
and received during the public comment period, and U.S. EPA's responses to those comments
and concerns. All comments received by U.S. EPA during the public comment period were
considered in the selection of the remedial alternative for the Tomah Armory Landfill (TAL).
The responsiveness summary serves two purposes: it summarizes community preferences and
concerns regarding the remedial alternatives, and it shows members of the community how their
comments were incorporated into the decision-making process.
This document summarizes written and oral comments received during the public comment
period of July 25, 1996 to August 25, 1996. The public meeting was held at 6:00 p.m. on August
18, 1996 at the Tomah City Hall Council Chambers, Tomah, Wisconsin. A full transcript of the
public meeting, as well as all site related documents, are available for review at the information
repository, located at the Tomah Public Library, 716 Superior Avenue, Tomah, Wisconsin. The
only official comments received were from the Wisconsin Department of Natural Resources
(WDNR).
OVERVIEW
The proposed remedial alternative for the Tomah Armory Landfill was announced to the public
just prior to the beginning of the public comment period. U.S. EPA proposed no action.
WDNR Comments
1. Comment: The Wisconsin Department of Natural Resources (WDNR) and United States
Environmental Protection Agency (U.S. EPA) have agreed that the groundwater impacts
of volatile organic compounds (VOCs) in the vicinity of the landfill are likely from a
recently identified upgradient source. The VOCs identified exceed drinking water
standards and therefore are likely to pose significant risk to potential future users of the
ground water in this area. With this in mind, it does not appear logical that long-term
groundwater monitoring at the site will in fact confirm that the "groundwater conditions
at the site continue to pose no significant risk".
Response: U.S. EPA means by the statement, "groundwater conditions at the site
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continue to pose no significant risk," that groundwater conditions attributable to the TAJ,.
continue to pose no significant risk. This statement could be true, even though a source
other than TAL has released in the vicinity of the landfill VOCs in excess of drinking
water standards. In requiring some additional groundwater monitoring, EPA seeks to
confirm that the TAL will not cause any significant deterioration of groundwater quality
offsite in the future.
2. Comment: The Proposed Plan states that the ground water was considered to be an
unlikely pathway for exposure to contamination because the site is located in an area
served by a municipal water system. Furthermore, the City of Tomah has modified the
City ordinance to prohibit installation of drinking water wells within 200 feet of the
landfill. U.S. EPA did not recognize this in the proposed plan.
Response: A variety of factors were taken into consideration in determining the no-action
decision at the TAL, including those related to pathways for exposure. However, a
significant element of the no-action decision was the determination that to date
contamination from the landfill appeared to be restricted to the area under the landfill and
had not moved beyond the boundaries of the landfill. U.S. EPA feels monitoring is
needed to ensure that this condition does not change. If contamination related to the
landfill is found outside the boundaries additional factors need to be taken into account to
address the off-site contamination. This is not to say that the decision could be
something other than no-action; however, other actions may become more appropriate,
i.e. containment with monitoring, natural attenuation with monitoring, and others.
3. Comment: U.S. EPA has not explained the type or frequency of the groundwater
monitoring it is proposing. There are indications that the sampling would include only
lead. This seems to be based on the fact that lead was detected in a groundwater sample
collected underneath the site. This lead detection came from a geoprobe sample collected
during the Phase I Remedial Investigation (RI). The Phase I RI was a screening
investigation to determine the level of effort needed to move the site through the next
phase. The information collected was used to eliminate some compounds from future
sampling. The detection of lead in this sampling round was not confirmed, nor was it
discussed previously as a concern given that it was collected from a well which did not
meet the criteria in ch. NR 141, Wisconsin Administrative Code. This sample was
collected from a geoprobe that was installed through waste and was analyzed for total
lead.
Response: The Phase I RI collected geoprobe groundwater samples for screening
purposes to determine additional actions at the site. Geoprobe data indicated the presence
of inorganic (lead) and VOC (trichloroethene) groundwater contamination at a number of
sampling locations inside and outside the boundaries of the landfill. U.S. EPA policy is
to collect unfiltered samples to best mirror existing groundwater conditions.
Additionally, the Phase I sampling effort detected the presence of lead in subsurface
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samples collected within the landfill. The Agencies determined it was appropriate to
conduct additional Phase II sampling. Phase II groundwater sampling performed outside
the boundaries of the landfill verified the presence of VOCs, but also detected them in
upgradient wells at greater concentrations. Inorganic contamination, primarily lead, was
not detected at significant levels outside the boundaries of the landfill. Based upon both
phases of data collection the U.S. EPA determined that groundwater contamination from
the landfill was not significant and no remedial action was necessary. However, because
the Phase I sampling effort had discovered the presence of lead contamination in ground
r> water and subsurface soils within the landfill, and these wastes would be left in place as
part of the no-action record of decision, the U.S. EPA believed future groundwater
monitoring would provide additional insurance that the conditions at the site continue to
pose no significant risk. The type and frequency of future groundwater sampling will be
determined by the U.S. EPA after signature of the ROD. Responsible parties at the site
will be allowed input into the parameters of the sampling.
4. Comment: The Phase II Rl groundwater sample collected from an off-site monitoring
well contained lead above the Wisconsin Preventive Action Limit (PAL). This result was
not confirmed and at the time the Remedial Investigation was being finalized, the WDNR
and U.S. EPA agreed that this isolated detection was not considered an exceedance and,
therefore, did not necessitate additional investigation or sampling. In addition, this
information was evaluated prior to concluding that the site posed no risk and that a
Feasibility Study was not necessary.
Response: The U.S. EPA would like to reiterate that, based on the data collected and the
risk assessment performed at the site, it has determined that no remedial action is
necessary at the site. Since the U.S. EPA determined that there was no significant risk at
the site and no remedial action would be selected, a feasibility study was not conducted.
Future groundwater monitoring is necessary because waste will be left in place, to ensure
that the site continues to pose no significant risk, and to increase the significance of the
groundwater data collected to date with additional data points.
5. Comment: Because the WDNR believes that additional groundwater monitoring is not
warranted, it has stated to the potential responsible parties at the TAL that the monitoring
wells should be abandoned unless the alleged responsible party for the upgradient source
of VOC contaminations takes over ownership of them. Chapter NR 141, Wis. Adm.
Code requires the abandonment of all wells not used within a year.
Response: To avoid delays in the future monitoring and prevent additional costs of
installing new wells, the U.S. EPA requests that the WDNR consider allowing the
responsible parties to maintain the wells for the duration of the future groundwater
sampling. Once U.S. EPA has made a determination that groundwater sampling is no
longer necessary, the wells can be properly abandoned.
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6. Comment: If the U.S. EPA is still concerned about the potential future impacts of lead,
which may raise the risk associated with the TAL, the WDNR suggests that U.S. EPA
perform a routine inspection of the site with the following purpose:
• to determine whether land use or exposure conditions have changed
• to determine whether institutional controls continue to be viable
• to evaluate the remedial progress being made at the upgradient
contaminant source
A qualitative evaluation appears to be a logical, site specific action that will equally
address the concerns of the U.S. EPA.
Response: As part of the five year review process the U.S. EPA may include a qualitative
evaluation that contains many of the elements proposed in the comment. The U.S. EPA
believes future groundwater monitoring will provide additional data to supplement or
even replace some of the evaluation criteria listed above.
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APPENDIX B
Administrative Record
-------
U.S. EPA ADMINISTRATIVE RECORD
REMEDIAL ACTION
TOMAH ARMORY
TOMAH, WISCONSIN
ORIGINAL
08/3O/95
DOCI DATE AUTHOR
s:s: £=== szrzss
RECIPIENT
TITLE/DESCRIPTION
PA6ES
1 03/01/84 Eigenbrodt, V., KDNR U.S. EPA
2 09/10/84 Sause, A., Ecology File
and Environient,
Inc.
Preliminary Assessment
August 28, 1984 Site Inspection Report
(•/Attached Cover Heiorandui
16
3 04/00/93 Evans, L., U.S. EPA
4 06/00/93 U.S. EPA
5 06/00/93 U.S. EPA
6 12/00/94 U.S. EPA
Health and Safety Plan for the Toiah Anory BO
Site
Quality Assurance Project Plan for the Toiah 71
Anory and Toiah Fairgrounds Superfund Sites
Hork Plan for the Toiah Anory and Toiah 203
Fairgrounds Superfund Sites
Phase 1 Reiedial Investigation Report for the 181
Toiah Ariory and Toiah Fairgrounds Landfills
(Revision 2)
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U.S. ENVIRONMENTAL PROTECTION AGENCY
REMEDIAL ACTION
ADMINISTRATIVE RECORD
FOR
TOKAH ARMORY LANDFILL SITE
TOMAH, MONROE COUNTY, WISCONSIN
UPDATE #1
JULY 17, 1997
NO. DATE
1 03/07/95
2 03/22/95
3 04/13/95
4 04/28/95
04/28/95
05/25/95
09/00/95
10/00/95
AUTHOR
Feingold, R.
U.S. Senate
Adamkus, V.,
U.S. EPA
Feingold, R.,
U.S. Senate
Adamkus, V.,
U.S. EPA
Petri, T.,
U.S. Congress
Adamkus, V.,
U.S. EPA
Geraghty &
Miller, Inc.
Geraghty &
Miller, Inc.
RECIPIENT
Collum, T.,
U.S. EPA
Feingold, R.,
U.S. Senate
Collum, T.,
U.S. EPA
Feingold, R.,
U.S. Senate
Adamkus, V.,
U.S. EPA
Petri, T.,
U.S. Congress
State of
Wisconsin/
U.S. EPA
U.S. EPA
TITLE/DESCRIPTION PAGES
Letter re: Status 1
of City of Tomah's
Superfund Sites
Letter re: U.S. EPA's 3
Response to Senator
Feingold's March 7, 1995
Letter Concerning the
Status of the Tomah
Superfund Sites
Letter re: City of Tomah 8
Superfund Sites
Letter re: U.S. EPA's 3
Evaluation of City of
Tomahs's Report Concerning
the Hazard Ranking System
Site Score and Placement
of the Tomah Armory and
Fairgrounds Sites on the
National Priorities List
Letter re: Status of Two 22
Landfills in the City of
Tomah Considered Super-
fund Sites
Letter re: U.S. EPA's 3
Response to Congressman
Petri's April 28, 1995
Letter Concerning Super-
fund Sites in Tomah
Preliminary Site 205
Evaluation Memorandum
for the Tomah Armory
Landfill Site (DRAFT)
Phase II Remedial 612
Investigation Work
Plan for t,he Tomah
Armory Landfill Site
08/01/96
Larsen, C.,
State of
Wisconsin
Department
of Justice
Mankowski, M.,
U.S. EPA and
W. Anderson,
WDNR
Letter re: State of
Wisconsin's Proposal
for Instituting Deed
Restrictions and
Institutional Controls
at the Tomah Armory
Site
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Tomah Armory Landfill AR
Updat* #1
Pag* 2
NO. DATS
ADTHOR
RECIPIENT
TITLK/DBSCRIPTION
10 08/19/96 Anderson, W.
WDNR
11 08/28/96 Thurlow, T.,
U.S. EPA
12 01/00/97 Geraghty &
Miller, Inc.
13
01/00/97
Geraghty &
"<11er, Inc.
14
02/17/97
15
03/21/97
16
04/30/97
17
18
06/18/97
06/25/97
Larsen, C.,
State of
Wisconsin
Department
of Justice
Larsen, C.,
State of
Wisconsin
Department
of Justice
Larsen, C.,
State of
Wisconsin
Department
of Justice
Anderson, W.
WDNR
Anderson, W.
WDNR
Larsen C.,
State of
Wisconsin
Department
of Justice
Larsen, C.,
State of
Wisconsin
Department
of Justice
State of
Wisconsin/
U.S. EPA
State of
Wisconsin/
U.S. EPA
Mankowski, M. ,
U.S. EPA
Mankowski, M.,
U.S. EPA
Laszewski, L.,
U.S. EPA
Mankowski, M.,
U.S. EPA
Mankowski, M.,
U.S. EPA
Letter re: State of
Wisconsin's Proposal
for Voluntary Action
at the Tomah Armory
Site
Letter re: State of
Wisconsin's Proposal
for Instituting Deed
Restrictions and
Institutional Controls
at the Tomah Armory
Site (UNSIGNED)
Phase II Remedial
Investigation Report:
Volume 1 of 2 (Text,
Tables and Figures)
w/Attached January 30,
1997 State of Wisconsin
Transmittal Letter for
the Tomah Armory
Landfill Site
Phase II Remedial
Investigation Report:
Volume 2 of 2 (Appen-
dices A-Q) for the
Tomah Armory Landfill
Site
Letter re: Status of
State of Wisconsin's
Voluntary Actions at
the Tomah Armory Site
Letter re: Update to
Status of State of
Wisconsin's Voluntary
Actions at the Tomah
Armory Site
Letter re: Update on
Progress at the Tomah
Armory Site
Letter re: WDNR's
Comments on the Revised
Draft Proposed Plan for
the Tomah Armory Site
Letter re: WDNR's
Additional Comments on
the Revised Draft
Proposed Plan for the
Tomah Armory Site
131
458
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Tomah Armory AR
Updat* #1
Pag* 3
NO. DATE AUTHOR RECIPIENT TITLB/DBSCRIPTION
19 06/25/97 Anderson, W. , Mankowski, M. , Letter re: Statement
WDNR U.S. EPA of State's Concern to be
Included in the Proposed
Plan for the Tomah Armory
Site
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U.S. ENVIRONMENTAL PROTECTION AGENCY
REMEDIAL ACTION
ADMINISTRATIVE RECORD
FOR
TOMAH ARMORY LANDFILL SITE
TOMAH, WISCONSIN
UPDATE #2
JULY 31, 1997
NO. DATE
1 07/00/97
AUTHOR
U.S. EPA
RECIPIENT
Public
TITLE/DESCRIPTION PAGES
Proposed Plan for the 6
Tomah Armory Landfill
Site
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U.S. ENVIRONMENTAL PROTECTION AGENCY
REMEDIAL ACTION
ADMINISTRATIVE RECORD
FOR
TOMAH ARMORY LANDFILL SITE
TOMAH, WISCONSIN
UPDATE #3
SEPTEMBER 12, 1997
NO. DATE
AUTHOR
RECIPIENT
TITLE/DESCRIPTION
PAGgg
1 08/12/97
2 08/15/97
3 08/18/97
Powell, T. and
K. Niesen;
Geraghty &
Miller, Inc.
Anderson, W.,
HDNR
Southwest
Reporters,
Inc.
Mankowski, M.,
U.S. EPA and
W. Anderson,
HDNR
Bill, B.,
U.S. EPA
U.S. EPA
Letter re: Documentation 12
of Completed Voluntary
Remedial Actions on the
Filkins and Museum
Properties at the Tomah
Armory Landfill Site
Letter re: WDNR's 2
Comments on the Tomah
Armory Proposed Plan
Transcript of Procee- 102
dings: August 18, 1997
U.S. EPA Public Meeting
re: the Tomah Armory
Landfill and Tomah
Municipal Sanitary
Landfill Sites
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