PB97-964118
EPA/541/R-97/156
January 1998
EPA Superfund
Record of Decision:
Madison Metropolitan Sewerage District
Blooming Grove, WI
3/31/1997
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DECLARATION FOR THEJKECORD OF DECISION
SITE NAME AND LOCATION
Madison Metropolitan Sewerage District Lagoons
Madison, Wisconsin
STATEMENT OF BASIS AND PURPOSE
This decision document represents the selected remedy for the Madison Metropolitan Sewerage
District Lagoons Site, Madison, 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, to the
extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP).
This decision is based upon the contents of the administrative record for the Madison
Metropolitan Sewerage District Lagoons Site.
The State of Wisconsin has indicated their intent to concur with this Record of Decision. Their
letter of concurrence is in process and will be attached to the Record of Decision when executed.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the site, if not addressed by
implementing the response action selected in the Record of Decision (ROD), may present an
imminent and substantial endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE REMEDY
This final remedy addresses remediation of sludge containing hazardous substances by
installation of an in-place vegetative/soil cover hi order to minimize potential exposure to lagoon
sludge by human and ecological receptors.
The major elements of the remedy include:
* Construction of intra-lagoonal dikes in order to segregate sludge with
polychlorinated biphenyl (PCB) concentrations equal to or exceeding SO parts per
million (ppm);
* Placement of geotextile layer and lightweight soil cover;
* Seeding with appropriate vegetative growth;
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vegetative cover and integrity of all dikes; and
* Continuation of the institutional controls described for alternative RA-2.
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. However, because treatment of the principal
threat at the site was not found to be practicable, this remedy does not satisfy the statutory
preference for treatment as a principal element of the remedy. The large volume of material
containing relatively low levels of contamination and the fact that there are no on-site hot spots
that represent the major sources of contamination preclude selecting a remedy in which the
contaminant of concern could be excavated and treated effectively.
Because this remedy will result in hazardous substances remaining on site above health-based
levels, a review will be conducted five years after commencement of remedial action to ensure
that the remedy continues to provide adequate protection of human health and the environment.
17
William E. Muno, Director Date
Superfund Division
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
MADISON METROPOLITAN SEWERAGE DISTRICT LAGOONS SITE
MADISON, WISCONSIN
L SITE NAME. LOCATION AND DESCRIPTION
The Madison Metropolitan Sewerage District (MMSD) Lagoons Site consists of two sludge
lagoons that are located adjacent to the treatment plant facilities, south of the city of Madison in
Dane County, Wisconsin. The lagoons are referred to as Lagoon 1 and Lagoon 2. Figure 1
depicts the orientation of the sludge lagoons with regard to the overall MMSD plant.
Lagoon 1 is divided by several cross-dikes (Figure 2) and covers an area of approximately 52
acres. Three dikes run in a north-south direction, effectively dividing Lagoon 1 into four sub-
sections. The easternmost of these four sub-sections is termed Lagoon IB and the rest, (the three
westernmost sub-sections) Lagoon 1 A. Lagoon IB is further subdivided into four sections by
three dikes that run in an east-west direction. All sludge and a portion of the underlying peat
have been removed from Lagoon IB and a portion of Lagoon 1A (i.e., the first sub-section
immediately adjacent to, and west of Lagoon IB). All materials were sampled and analyzed for
PCBs during the removal process to ensure compliance with applicable requirements, and
beneficially reused in MMSD's sludge recycling program. Sludge with PCB concentrations less
than 50 ppm are used in the recycling program. The water level is maintained in the cleaned out
sections of the Lagoon in order to control weed growth.
Lagoon 2 covers an approximate area of 86 acres and is divided into three sections by two
earthen dikes that run in an approximately northeasterly-southwesterly direction (Figure 2). The
westernmost third is termed Lagoon 2A while the eastern two-thirds are collectively termed
Lagoon 2B. Sludge with PCBs greater than or equal to 50 ppm is contained within Lagoon 2A
and portions of Lagoon 2B.
Surface waters that border the lagoons include Nine Springs Creek, an old drainage ditch
(referred to as the North Ditch), which is a former effluent channel for the treatment plant, and
several other drainage ditches that flow into Nine Springs Creek. Nine Springs Creek flows
along the south and east borders of Lagoon 2. The creek flows into the Yahara River. The old
drainage ditch borders the northern sides of both lagoons and connects with Nine Springs Creek
near the northeastern corner of Lagoon 2. Wetlands, farms, parks, and open-space land exist
immediately to the north, east, and south of the lagoons as shown on Figure 1. Land use to the
northwest of the sludge lagoons is both commercial and industrial while to the west and
southwest, land use is primarily residential.
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— n \^- • £
F.- I '1 i '
- 3Z .' t : \
1 -^ I.- J.HBIMA-' ff
SITE LOCATION
,-: •• • «j| r
' sl.l
REFERENCE MADISON EAST USGS QUAD.
DRAFT
BLASLAND, BOUCK & LEE. INC.
ENGINEERS * SOEWTISTS
MADISON METROPOUTAN SEWERAGE
DISTRICT LAGOONS SITE
MADISON. WISCONSIN
FEASIBILITY STUDY
SITE LOCATION MAP
FIGURE
1
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(SUJOCI KIMOVEO)
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MADISON UCTROPOLJTAN StWERACC OISTRIC1
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SITE PLAN
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n. SITE BACKGROUND
MMSD has operated the Nine Springs Wastewater Treatment Plant (Nine Springs Plant) since
1933. In 1942, a 52-acre sludge lagoon (Lagoon 1) was constructed by MMSD. This lagoon
was constructed in a marsh area to the east of the Nine Springs Plant with the dikes being
constructed of imported fill material. By the mid-1960s, as Lagoon 1 began approaching its
sludge capacity, MMSD constructed a second 86-acre lagoon (Lagoon 2) to the east of Lagoon 1.
The dikes for Lagoon 2 were constructed of dredged surface soil and peat, obtained from the area
of construction.
In April 1970 a portion of the north dike of Lagoon 2 collapsed and approximately 85 million
gallons of lagoon contents was released into the adjacent ditch. The dike was subsequently
repaired. In November 1973, dike subsidence occurred along the south side of Lagoon 2.
Following repair of the south dike, MMSD curtailed active use of Lagoon 2. Details of the dike
failure and subsidence and results of investigation of the release are included as appendix 1A of
the Remedial Investigation (RI).
A Facilities Plan, prepared during the mid-1970s in accordance with Section 201 of the Federal
Water Pollution Control Act of 1972, recommended reuse of the sludge by beneficially recycling
the material to agricultural land. The plan considered removal of all sludges from Lagoon 2 and
a portion of Lagoon 1, with the subsequent return of these areas to their natural state. The plan
included use of the western portion of Lagoon 1 for winter storage of sludge and sludge
dewatering.
The Facilities Plan included the sludge recycling program that is currently referred to as the
Metrogro program. During development of the sludge recycling program, as part of a sludge
monitoring sampling effort, PCBs were detected in the sludge lagoons. The sludge monitoring
program was subsequently modified to include routine analysis for PCBs.
In 1982, analysis of a sludge sample from the lagoons first showed the presence of PCBs at a dry
weight concentration exceeding SO ppm. The 50 ppm PCB level represents the upper
concentration limit for land application under the Toxic Substances Control Act (TSCA).
Further sampling revealed that other areas of the lagoon system contained sludge with PCB
concentrations above 50 ppm.
Between 1983 and 1986, U.S. EPA acting under the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA) evaluated the lagoons for potential
inclusion on the National Priorities List (NPL). On the basis of these evaluations the* site was
placed on the NPL in February 1990. Under an Administrative Order on Consent issued
September 24,1992 MMSD has undertaken a Remedial Investigation/Feasibility Study (RI/FS)
for the site.
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During the spring and summer of 1991, cleanout/closure activities were conducted in Lagoon 1B.
Three cross dikes were constructed to aid in the removal of sludge and peat. All sludge and a
portion of the peat underlying the sludge, were removed from Lagoon IB. The sludge, which
had PCB concentrations less than 50 ppm, was recycled to agricultural lands and the peat was
used as a soil conditioner on lands owned by MMSD.
Lagoon 1A was used for the temporary storage of currently produced sludge and continued to
serve this function until construction of new tank storage facilities was completed at the end of
1993. Two cross-dikes were constructed in Lagoon 1A during 1992 and 1993 to aid in
cleanout/closure activities hi a portion of the Lagoon. Closure of an approximately 10-acre
portion at the east end of Lagoon 1A was completed in mid-1993. A water cover is maintained
over the closed portions of Lagoon 1A to control weed growth.
Closure of additional portions of the lagoons was temporarily halted in 1994 in response to a
request by United States Environmental Protection Agency (U.S. EPA) to stop land application
of all lagooned sludge until EPA had an opportunity to review available information and
determine the consistency of land application relative to response actions taken under the
Superfund Program. In a letter dated March 28,1995, U.S. EPA withdrew its restriction of land
application of lagoon sludge containing PCBs at concentrations less than 50 ppm (i.e., Lagoons
1A and portions of Lagoon 2B), stating that this action would not be inconsistent with future
response actions at the site. Lagoon 2B cleanout and closure will be performed in those portions
of Lagoon 2B that contain PCBs below 50 ppm beginning in 1997.
The future land use of the MMSD lagoons is expected to remain unchanged. The lagoons are no
longer receiving sludge from the treatment plant, and sludge is gradually being removed from
some of the lagoons for use in the land application program. Residential and/or commercial
development of the areas immediately adjacent to the lagoons is not anticipated. This is because
most of the land surrounding .the lagoons is wetlands, and is considered part of the Dane County
Environmental Corridor.
Regional Geology
The MMSD Site is located in the Eastern Ridge and Lowlands Province physiographic region.
Glaciation resulted in the formation of numerous kettle lakes and disruptions of pre-glacial
drainage, thereby creating marshlands. The geologic profile generally consists of marsh and
lacustrine units (peat, marl, clay, and silt) followed by interbedded glacial units of lacustrine clay
and silt, outwash (sand and gravel), and till (silty sand with gravel) deposits. The Cambrian
bedrock beneath the site is Sandstone. Underlying the Cambrian bedrock is Precambrian
crystalline rock.
The bedrock depth below ground surface in the general vicinity of the site varies from less than
100 feet to over 200 feet along the deepest parts of the preglacial valley. In closer proximity to
the site, well logs indicate that depth to bedrock is 95, 180, and 100 feet below ground surface.
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a. Regional Hydrogeology
In the Madison area, groundwater discharges to the lakes and the Yahara River. In Dane County,
groundwater is released from the subsurface via springs and seeps into streams and lakes, as well
as by evapotranspiration and pumpage. Wetland deposits may be saturated, but are not a source
of potable water for wells in Dane County. The glacial deposits, including outwash and
alluvium, morainal deposits, glacial lake deposits, and undifferentiated glacial deposits yield
varying quantities of water to wells, depending upon the location and lithology of the deposit.
The deposits of drift, outwash and alluvium in the Yahara River valley provide a thick reservoir
for ground water. The Cambrian sandstone bedrock is a single water-yielding unit. Even though
there are hydraulic interconnections between the Cambrian sandstone units, there are water-
yielding zones that may be perched, or partially confined due to heterogeneities in the rock such
as shale beds and preferential permeability zones. The Cambrian sandstones form the principal
aquifer and provide the major source of ground water for wells in Dane County.
In some areas, unconfined aquifer conditions exist. In other areas of eastern Dane County,
ground water is partially confined by glacial till. Underlying the Cambrian bedrock are
Precambrian crystalline rocks which are not water yielding, and form the base of the ground-
water reservoir in Dane County.
The regional flow in the vicinity of the site is from west to east towards the Yahara River system.
The ground-water potentiometric surface reflects topography, with deep water levels under hills
and shallow levels in the valleys.
The potentiometric surface for ground water in the unconsolidated deposits is generally related to
topography, but due to the potential for disconnected units and/or short ground-water flow paths,
the ground-water flow directions may be more localized than those of the bedrock aquifer. With
no pumpage, the site is a natural discharge area for regional ground-water flow, in both the .
unconsolidated and bedrock units. The ground water discharged in the Madison area is derived
solely from the Yahara River ground-water basin. In Dane County, movement of ground water
under natural conditions is extremely slow, so that movement of a few tenths of a foot per day is
common.
b. Local Ground-Water Use
There are two municipal wells upgradient of the MMSD Site. These wells provide water for the
Cities of Madison and Monona (see Figure 1). The City of Monona Well No. 3 is located at the
corner of Raywood Road (now known as South Towne Drive) and Highways 12 and 18
approximately 3,600 feet north-northwest of the site. The second well, City of Madison Well
No. 5, is located approximately 1,300 feet west of the site. This well is drilled to a total depth of
827.9 feet.
Two private wells were identified within 500 feet of the site. The wells are located upgradient
6
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from the lagoons, to the south of Lagoon 1 A.
III. SUMMARY OF SITE CHARACTERISTICS
Investigative activities undertaken at the Site since 1990 include the phased RI, followed by a re-
sampling of Lagoon 2B that was requested by the EPA. Summaries of both activities are
provided below.
Remedial Investigation Summary
The RI sampling was initiated in October 1990, using a phased approach involving an initial
Preliminary Field Investigation (PFI), and a more focused Comprehensive Field Investigation
(CFI).
During the PFI, sludge cores and supernatant were collected from the lagoon system and
analyzed for constituents on the Target Compound List (TCL) and Target Analyte List (TAL),
plus 30 (+30) other tentatively identified organic compounds (TICs). The sludge cores were also
analyzed for total organic carbon (TOC), total solids (TS), total volatile solids (TVS), and
particle size distribution. Temperature, pH, and conductivity were determined for the lagoon
supernatant.
During the CFI, sludge, underlying lagoon peat, nearby surface waters, ground water, and nearby
stream sediments were sampled. These samples were selectively analyzed, as appropriate, for
combinations of the individual parameters analyzed during the PFI. The results of these
sampling efforts were presented and evaluated in the draft RI Report submitted to EPA in
January 1992. The PFI and CFI collectively, have subsequently been referred to as the Phase I
RI.
In response to EPA request, additional sampling of Nine Springs Creek and North Ditch
sediment, soil from wetlands north and south of the lagoons, and ground water from three new
well/piezometer clusters was conducted. The creek and ditch sediments, and wetland soils were
analyzed for PCBs, TOC, and TAL constituents. The ground-water samples, both filtered and
unfiltered, were analyzed for TAL constituents. Summary results are shown in Table 1.
Groundwater samples were analyzed for TCL pesticide compounds and for PCBs. No PCBs or
pesticides were detected in these samples.
As discussed in the final RI Report, sampling results indicate that ground water is not affected by
the lagoon sludge constituents because the range of up gradient (background) concentrations are
generally comparable to those reported in ground-water samples obtained from down gradient
locations. The RI results also indicated that the sludge lagoons have not affected either the
wetland soils (Table 2) adjacent to the site or the surface water (Table 3) of Nine Springs Creek
or the North Ditch. Similarly, the RI inorganics results did not indicate any apparent site-related
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TABLE 1
Inomanie Analvtes in Ground-Water Samples
Inorganic
Analytes
Aluminum
Ar sonic
Barium
Beryllium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Sodium
Vanadium
Zinc
Observed Range, ppm
Unfiltered
NO - 68.6
NO • 0.0253
B - 1.01
..
20.7 - 684
NO - 0.101
..
NO - 0.207
0.287J - 97.2
B - 0.0261
10.7 - 188
0.0846 - 3.18
NO - 0.00028
NO - 0.114
B - 16 4
NO - 0.0203
136 - 153
NO - 0.180
BQL - 0.230
Filtered
NO
NO • 0.025
—
NO
18.6 - 171
NO
NO
--
NO - 0.230J
..
9.43 - 87.4
0.0688 - 1.18
..
NO
.-
.-
13.7 - 147
NO
R
No. of Samples
SQL/Total
Unliltered
5/6
2/6
2/6
0/6
6/6
2/6
0/6
2/6
6/6
2/6
6/6
6/6
2/6
2/6
2/6
1/6
6/6
2/6
2/6
Exceeding the
Analyzed
Filtered
0/6
1/8
0/6
0/6
6/6
0/6
0/6
0/6
1/6
0/6
6/6
6/6
0/6
0/6
0/6
0/6
6/6
0/6
NA
Noies
NO
SOL
Notes
Not detected
Sample detection limit
(cont'd)
J
B
NA
R
SOL
CRDL
•01
All values aia aithar estimated or repoiled as
Oala estimated as a lasuli ol validation
Concentration between CROL and IOL
Nol available
Oala leiecled as a result ol validation
Below sample quantilahon limit
Conliacl Requued Detection Ltmil
Insifumenl Detection Limit
not delected
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TABLE 2
Inorganic Anatvlea in VXetland Soil Samples
Inorganic
Analyles
Aluminum
Acienic
Barium
Calcium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Selenium
Vanadium
Zinc
Cyanide
North Wetland Soil
Observed Range
nd IOL
0«u •ilif*«l*a •• • (Mult ol v«M«tio«i
Sampto d«t*ction taiut
Canute! rtequiroa Otuclion LIIM
imtiiMwni DotoctMM Una.
Out MjtctM «• • mutt of vikdttBti
or f«pon*d M MM oteMciM.
sen, sjmmna «I«ULT. MM fee, mm roe rm«n in
LOG4>1NM
S*mps* No
S*«pt« O«i*
SampM Scorn*)**. (H)
."•di *2S«
AfOCMr !}§O
T*l*1l PC**
TOC
% roc
COOL
0 05
0 OS
0 03
0 Oi
0 OS
oos
005
N W«ilan4»
WNWOOtS
S/7O/1J
0-0 S
0 9
2 4
U
U
U
U
U
U
U
„
21 3
WNM002S
VZOfll
0-0 ft
a s
4 1
U
U
U
U
U
U
U
31 4
N. WtrtlaUMtf}
WNUOOJS
•/1tV»l
0-0. S
O.ft
• •
U
U
U
U
U
U
U
U
» 4
N. WotfMl.**
WHMW48
viina
0-0. S
o.s
4 r
u
u
u
u
u
u
u
u
t* 4
M w*>«aind»
WNUOMS
l/ft/t)
0-0 S
0.9
t 2
U
U
u
u
u
u
u
u
>4 •
S. WMIsWd*
wawoocs
i/aosu
0-0 S
0 1
2 t
U
U
u
u
u
u
u
u
I* I
S N«ll*fld*
wswoors
a/2ostj
00 5
0 5
3 1
u
u
u
u
u
u
u
u
12 0
S W«M*1*Vt
WSUOMS
S/2O/*J
0-09
0 S
J •
U IU)
U |U)
U IU)
U IU)
u tut
U (U)
u tut
U IU|
» 2 I2t 1)
S W*3«1«nd«
WSMOOtS
&/20/R2
0-0 »
0 S
t 0
u
u
u
u
u
u
u
u
41 1
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TABLE 3
Inorganic Anatvles in Surface Water Samples
Inorganic
Analylas
Aluminum
Arsenic
Barium
Calcium
Iron
Lead
Magnesium
Manganese
Sodium
Zinc
Cyanide
Nine Springs Creek Surface Water
Observed Range.
ppm. (including
background)
0.536 - 0.735
00011 - 0.0025
..
68 6 - 70.2
1 07 - 1 68
NO - 0.0064
33.4 - 35
0 128 • 0 19
13.6 - 15.2
0.0317 - 0.048
NO • 0.06
No. of Samples
Exceeding the
SOL/Tolal
Analyzed
4/4
4/4
0/4
4/4
4/4
2/4
4/4
4/4
4/4
4/4
1/4
North Ditch Surface Water
Obeerved Range,
ppm (including
background)
NO - 0.632
0.0032 - 0.0039
0.00635 • 0.007
64 - 112
0.73 - 5.5
NO - O.QO41
36 • 44.6
0.26 - 0.305
29.6 - 41.3
0.03 • 0.044
NO - 0.07
No. ol Samples
exceeding the
SDUTotal
Analyzed
2/3
3/3
3/3
3/3
3/3
1/3
3/3
3/3
3/3
3/3
1/3
NO
SOL
All V*IUM ii
NOI
NOWD10S
4J9W9I
N Okti
NCWDI4S
40MI
N CMdi
NDW016S
4/30U91
to
U
U
U
U
U
U
U
U
10
1.0
10 |l 0)
10
10
U
U
U
U
U
U
U •
U
U (U)
U (U)
U (U)
U |U)
U
U
U
U
U
U
U
U
NOI oeiect*d The ««mp*« tp*c
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impacts on sediments in Nine Springs Creek, and the sources(s) of ofganics to the sediment
could not be determined, due to infrequent detection and low concentrations. Additional details
concerning these sampling programs and results are provided in the RI report.
Lagoon Sludge
During the Phase I RI, a total of 35 sludge core samples and five surficial sludge samples (0 to 6
inches) were collected and analyzed for TCL/TAL+30 constituents (Table 4). Although sludge
samples were collected from throughout the lagoon system and prior to the construction of some
of the currently-existing cross-dikes, the only sludge data discussed here are chemical
concentrations in Lagoon 2A. This is due to the fact that sludge in Lagoon 2A has PCB
concentrations above 50 ppm, which are regulated under TSCA. The sludge in Lagoon 1A and
most of Lagoon 2B meets all the criteria for beneficially recycling to agricultural land, consistent
with U.S. EPA Standards (40 CFR 503) and the State of Wisconsin (NR 204) sewage sludge
management regulations. Consistent with the regulations, U.S. EPA (1995a) granted official
approval for beneficial recycling of Lagoon 1A sludge and Lagoon 2B sludge following further
sampling. The subsequent sampling for Lagoon 2B indicated that most of the samples (20 out of
27) had PCB concentrations below 50 mg/kg. Sludge from these locations will be removed and
land-applied as appropriate. Sludge from the remaining seven locations will be isolated within
an extension of the Lagoon 2 A dike. Results of this sampling are included in a letter report to
U.S. EPA dated April 16,1996.
Cleanout/closure operations are currently being conducted in Lagoon 1 A, with a scheduled
completion date of December 31,1997. Cleanout/closure operations in Lagoon 2B will begin in
1997-1998.
The frequency of detection and range of detected concentrations for chemicals of concern in
sludge from Lagoon 2A are presented in Table 3-1. Inorganic constituents were detected in
Lagoon 2A sludge at varying concentrations. Several volatile organic compounds were also
detected in sludge from Lagoon 2A, including acetone, carbon disulfide, 2-butanone, benzene,
toluene, chlorobenzene, ethylbenzene, xylenes, and 1,2-dichloroethene. One semivolatile
organic compound [bis(2-ethylhexyl)phthalate] also was detected in Lagoon 2A sludge. Two
pesticide organics (4,4'-DDE and 4,4'-DDD) were detected in Lagoon 2A. PCBs were detected
in each of the sludge samples from Lagoon 2A, with a maximum total PCB concentration of 170
mg/kg.
Lagoon Peat
Following sludge removal from Lagoons 1B1 to 1B4, 32 peat samples were collected. Sample
locations were distributed on a grid pattern, and the upper 2-inch segments of peat were analyzed
for PCBs. In addition, eight of the peat samples were analyzed for inorganics and conventional
parameters such as pH and total solids. Following sludge removal from Lagoon 1 A3, 15 samples
11
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TABLE 4
Inorganic Analvtes in Sludge Samples
Inorganic
Analytes
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Selenium
Silver
Zinc
Cyanide
NSSS Observed
Range (ppm)
NR
NR
0.3 - 316
NR
0.1 - 3.9
0.7 - 8.220
NR
2.0 • 3.750
6.8 • 3.120
NR
0.4 • 1.670
NR
NR'
0.2 - 47
2 • 976
05 - 70
NR
38 • 68.000
NR
Lagoon 1 Sludge
Observed Range.
ppm
2.540 - 6,430
NO - 7.2
NO • 14.2
414 - 1.170
NO
8.3 - 36.7
38.400 - 82.600
98 - 262
229 - 736
6.480 - 18.200
155 - 786
4.720 - 14.200
183 - 451
9 • 32.8
NO - 76.3
NO - 6.0
61 - 200
1.090 - 3.590
NO - 3.8
No. Of
Samples
Exceeding
the
SDL/Total
Analyzed
7/7
2/7
6/7
7/7
0/7
7/7
7/7
7/7
7/7
7/7
7/7
6/7
7/7
7/7
3/7
3/7
7/7
7/7
6/7
Lagoon 2 Sludge
Observed Range.
ppm
2.900 • 8.600
NO
NO - 18.3
296 - 1.540
NO - 4
13 - 50.3
26,600 - 78.700
28.3 - 456
152 - 1.030
6.330 - 18.700
138 - 626
NO - 14.200
152 - 534
9 - 34
NO - 75.2
NO - 13.4
45.7 - 216
672 - 3.700
NO - 8.97
No. Of
Samples
Exceeding
the
SDL/Total
Analyzed
13/13
0/13
10/13
13/13
1/13
13/13
13/13
13/13
13/13
13/13
13/13
10/13
13/13
13/13
4/13
4/13
13/13
13/13
12/13
I Notes
SDL S«mple detection limit
NO No( «eieeied
MR Not >eported
NSSS data
The NSSS o«ie ••»•—..m. tiudge inorganic
slandaids
Irom i«SO NMIonal Sewerage Sludge Survey (Black & Veatch. 1991)
)«!• leprecenit tiudge inorganic constituent concentration ranges re
concentration ranges repotted during I ha survey, and do not represent regulatory
12
-------
Volatile Organic Compounds in Sludge Samples
Volatile Organic
Compound
Methylene Chloride
Acetone
Carbon Disulfide
2-butanone
Benzene
Toluene
Chlorobenzene
Ethylbenzene
Xylenes (total)
Lagoon 1 Sludge
Observed
Range, ppm
NO - O.OB6B
BOL - 5.6B
NO - 0.14
NO - 1.2
..
BQL - 0.72B
BOL - 0.24
BOL - 0.33
0.17 - 1.9
No. of Samples
Exceeding the
SQL/Total
Analyzed
1/7
6/7
1/7
4/7
0/7
5/7
3/7
2/7
7/7
Lagoon 2
Observed Range.
ppm
NO - 0.1 GC
0.66 - 5. IB
NO - 0.088
0.062 - 1.0
NO - 0.112
BQL - 7.8B
NO - 0.19
NO • 0.57
NO - 1.6
Sludge
No. ol Samples
Exceeding the
SQL/Total
Analyzed
1/13
13/13
3/13
13/13
2/13
10/13
4/13
5/13
10/13
Nous:
NO
B
BQL
SQL
All value* are either estimated or reported •« not detected.
Nol detected.
Found in blank of the sample result noted.
Below the tample quantitatibn limit.
Sample quantitation limit.
Pesticides in Sludge Samples
Pesticides
4-4'DOE
4-4'DDD
Lagoon 1 Sludge
Observed Range,
ppm
--
--
No. of Samples
Exceeding the
SQL/Total
Analyzed
0/7
0/7
Lagoon 2 Sludge
Observed Range.
ppm
ND - 0.2
NO - 0.28
No. of Samples
Exceeding the
SQL/Total
Analyzed
4/13
2/13
Holes:
SOL
NO
Sample quantitalton limit.
All values are either estimated or reported as not delected.
Nol delected.
13
-------
IB
0-3 •
L2SOOSC
11/1WO
31
0-31
I I/I MO
20
020
• X (BJ)
UM
UM
424)0)
1 «•' I
977
SvnpONo
SxnpbDiH.
1o»iSuda»[>p«i(lt)
XTOC
CHOI
0025
0025
0025
us
L2SOI2C
aavoi
4.0
O-4.0
HIS 1
UO
u
u
520
11 7
N/A
2192
L2S013C
2ffl»1
40
o-to
»,»
490
U
U
rto
135
599
2639
US014C
2CW1
SO .
0-50
4 19 « (3650)
iroo (1200)
U(U|
UM
iroo(i»o)
143010)
604K07)
30 57 PO 41)
L2GOISC
2C7S1
45
(M£
187 < 1
390
U
43
423
.11.9
KM
20 S3
L2SD1S5
lAttl
45
O-2.0
2430 |
eao
u
u
ceo
NM
NM
2B60
L2S016C
2B7JBI
40
O-4O
162* |
570
U
J
57 OT
154
see
2937
L2S017C
207/91
IS
0-3.5
1799
470
U
U
470
11.1
El 3
2969
L2S01«C
207AI
10
0-10
1299
2*0
U
U
280
77
726
3251
Samp* No
Simp* Date
ToUI SMge O>«ln pi)
Sbdga Depot San*iM (11)
PCmimgAa)
C.o»et'4 0025
A»w t,- •:«! OO2S
1l*4l If^t'.
SUmi.MNIAI PAHAMCIERS
% IS
U IV",
% lt)C
L2S019C
2J2M1
40
0-40
2000(400)
120(120)
4 4 (4 21
U(U)
16 4 (IB 2)
765
696
3353
L2S020C
2/2MI
3.7
037
3556
330
90
M
420
929
704
4181
L2S021C
20M1
28
0-24
2460(2448)
530(430)
U(U]
U(U)
530(430|
913 |9 in
N/AIH/A)
3961(2638)
125022C
2/2OT1
SO
040
,6,
55
U
044
594
599
771
4066
12S023C
2/ZM1
25
0-2 5
.08
36
U
1 2
5 u
928
N/A
3720
L2S024C
2/2M!
2O
0-20
"
30
U
036
338
1380
N/A
4250
L2S025C
2JZMI
30
0-30
,22
t a
u
071
251
619
NM
4276
L2S026C
Z/26A1
30
O30
105
24
11
043
263
948
7S5
44 11
14
-------
were collected along a grid pattern. Each of the 15 samples was analyzed for total PCBs, and
four of the samples were analyzed for various inorganic constituents. A summary of the
combined post-sludge-removal peat data for Lagoons 1B1 to 1B4 and Lagoon 1 A3 and
identification of the chemicals of concern are presented in Table 5. The inorganic constituents
were generally detected in each of the peat samples at concentrations an order of magnitude
lower than those detected in previous sludge samples from the lagoon area. Dry weight total
PCB concentrations detected in the peat range from not-detected (<0.5 mg/kg) to 3.1 mg/kg.
Lagoon Supernatant
During the PFI, an unfiltered composite supernatant sample was taken from Lagoon 2. The
sample was a composite of five individual grab samples. Samples were analyzed for
TCL/TAL+30 constituents. These results are presented in Table 6.
Several inorganic constituents were detected in supernatant from Lagoon 2, with concentrations
generally in the low /zg/L (ppb) to mg/L (ppm) range. Volatile organic compounds, semivolatile
organic compounds, and pesticides were not detected in supernatant samples from the lagoon.
The total PCB concentration for Lagoon 2 supernatant was 0.0024 mg/L.
Sediments
Sediment samples were taken from the North Ditch during both Phase I and Phase II of the RI.
At each sample location, three discrete grab samples were collected from the upper six inches of
sediment, at locations equally spaced across the stream or ditch. These discrete samples were
then combined into a representative composite. At the center location, a deeper sample of the
sediment, below six inches, was also collected. Five of the 16 deeper samples were further
divided into two separate samples. All samples were analyzed for PCBs and TAL constituents.
A total of eight discrete surficial (upper six inches) sediment samples were collected from the
North Ditch during the Phase II Investigation (May 18 to 20,1993). Of these, three samples
were collected from upstream locations in the North Ditch (i.e., west of the Nine Springs Plant).
All sediment samples were analyzed for PCBs, TOC, and TAL constituents. Summaries of the
Phase II sediment data and comparison to the representative background concentrations for the
North Ditch are presented in Table 7.
Except for calcium, the inorganic constituents detected in the North Ditch were not significantly
above background and calcium was only three times the upstream concentrations. PCBs were
detected in the North Ditch with a maximum total PCB concentration of 0.44 mg/kg. However,
PCBs also were detected in the North Ditch upstream samples at a maximum concentration of
1.85 mg/kg. The PCB concentrations detected upstream suggest that an up gradient source of
PCBs exists and that the PCBs detected in the North Ditch may not be entirely site related.
Alternatively, however, the presence of PCBs in sediment samples adjacent to the Lagoons Site
15
-------
TABLE 5
Inorganic Analvtes in Peat Samples
Inorganic
;•• Analytes
Aluminum
Arsenic
Barium
Cadmium
Calcium
Chromium
Copper
Iron
Load
Magnesium
Manganese
Mercury
Nickel
Selenium
Silver
Zinc
Cyanide
Lagoon 1 Peat
Observed Range
ppro
2.600 - 4.110
NO - 9.8
77.7 - 546
NO - 16.9
29,500 - 46.700
NO - 110
NO - 282
4.170 - 9,320
ND - 488
NO - 7,510
76.4 - 199
R - 18.3
NO - 33
NO - 4.4
NO - 60.5
48.4 - 1,390
NO • 1 76
No. o!
Samples
Exceeding
the
SOL/Total
Analyzed
2/2
1/2
2/2
1/2
2/2
1/2
1/2
2/2
1/2
1/2
2/2
1/1
1/2
1/2
1/2
2/2
1/2
Lagoon 2 Peat
Observed Range
ppm
5.050 - 7,240
NO - 0.7
81.7 - 1.010
ND - 27.3
25.000 - 46.300
74.4 - 152
NO • 503
4.660 • 13,600
3.6 - 151
.-
102 • 271
R
.„
NO - 8.2
„
29.8 - 2.440
-
No. of Samples
Exceeding the
SDL/Total
Analyzed
3/3
1/3
3/3
1/3
3/3
3/3
1/3
3/3
3/3
0/3
3/3
NA
0/3
1/3
0/3
3/3
0/3
16
-------
Volatile Otnmnic ComooundS in Paal Samples
Volatile Organic
Compounds
Methylene
Chloride
Acetone
2-Butanone
Toluene
Chlorobenzene
Xylenes (total)
Benzene
Carbon Disullide
Lagoon 1 Peat
Observed Range,
ppm
NO - 0.158
2.4 • 4.5
NO - 0.81B
BOL - 0.1B
..
ND • 0.41
..
--
No. of Samples
Exceeding the
SQL/Total Analyzed
1/4
4/4
3/4
1/4
0/4
3/4
0/4
0/4
Lagoon
Observed Range.
ppm
BOL - 0.1 SB
2.4 - 7. SB
BOL - 1.1
SQL - 0.218B
NO - 0.16
ND - 0.91
NO - 0.045
NO - 0.043
2 Peat
No. of Samples
Exceeding the
SQL/Total
Analyzed
3/6
6/6
5/6
1/6
1/6
3/6
1/6
1/6
ML
•OL
NO
Sample quanlitalion limit.
All valuas ara •itlMi attimalod or raported as not detected.
Repoitad in tha blank ol lira tampto letull noted.
Belour g ample quanlitation limit.
Not datactad.
PEAT SAMPUKG RESULTS FOH PCBa
Locjmn.
Samp* No:
SaraptoDala
SkjOga Dapn CoMring Pan (1)
Paol Samr* CMpOi (1)
Pce.<~oym.
CixiDCbnn f acloi
AJOCICM 1242
Mocky I2M
Afoetoi 1260 '
Total pcau
caQL
0040
0140
OMO
LIATOMA
40
041
40
2*
IS
U
44
Lutoota
»*4I
49
0*14
WA
WA
WA
WA
Lagoon IA
: ami
U
41
u
u
u
u
Lagoon IA
UMnoai
04-14
WA
WA
WA
WA
Ugobna
LJT004A
nun ••••
u
M4
40
U
is
u
14
lagoon 2
13mo4B
,;•*•!
: U
04-14
WA
WA
WA
w.
lagoon 2
U
0-04
71
U
U
U
U
uoona
Lzroiia
if
04-14
WA
WA
WA
WA
lagoon 2
uneoA
0.10
41
U
U
u
u
LtraooB
awn
17
10-10
WA
WA
WA
WA
NOM
U - Ha dmclnj Th. unpk tpicdc qumtuton trx can t»
Arccln 1018 1271. 1217. Ind 1244 Mra KOKMlcl to
CRQL ° Conbarl Rtqi
dmnrtml by rna»p»«io *» CTQt b> »•
17
-------
TABLE 6
inoiq«r»c Anatvt«» m Suoernai»ni Samples
Inorganic Analyies
Aluminum
Aftenic
Cadmium
Calcium
Chromium
Copper
Iron
Laad
Magneeium
Manganaaa
Matcury
Nickal
Potassium
Silver
Sodium
Zinc
Cyanide
Observed P«no.». ppm
NO - 0.48
NO -0.0065
NO - O.OOS
3» 7 • 49.8
NO - 0.021
NO - 0.068
0.85 - 2.05
0.012 - 0.021
34.6 - 58.7
0.06 - 0.132
0.0003 • 0.003
NO - 0.048
106 • 12S
0.0014 • 0.014
185 • 216
0.06 - 0 284
NO - 0.183
No. ol Sample* Eiceedmg the
SOUTolal Analyzed
2/3
2/3
1/3
3/3
2/3
1/3
3/3
3/3
3/3
3/3
3/3
2/3
3/3
3/3
3/3
3/3
2/3
Mom:
SOL
NO
CONCENTRATIONS OF TCL CONSTITUENTS IN SUPERNATANT SAMPLES
Location:
Sample No.:
Sample Date:
Volatile Organics (ug/L)
Correction Factor:
2-hexanone
Toluene
CRQL
10
5
Lagoon 1
L1AP001C
11/14/90
1.0
Lagoon 1
L1BP001C
11/14/90
Lagoon 2
L2P001C
11/14/90
1.0
1.0
J
J
PCBs (ug/L)
Correction Factor:
Aroclor 1242
0.5
Total PCBs
1.0
0.96
0.96
78
U
1.0
0.78
0.78
U
U
1.0
2.4
24
Notes:
CRQL =
J
U
Contract Required Quanlitation Limit.
Estimated value.
Not detected. The sample specific quantitation limit can be
determined by multiplying the CROL by the sample correction lactor.
18
-------
TABLE 7
Inorganic Analyle* in Sediment Samples
Inorganic
Analytes
Aluminum
Arsenic
Barium
Calcium
Chiomium
Copper
Iron
Lead
Magnesium
Mangaiiaaa
Meroury
Nickel
Potaaaium
Salanium
Silver
Vanadium
Zino
Cyan id*
Nina Springs Craak Sadimairt
Obaacvad
Background Rang*.
ppm (NSE023 • 25)
9.1 JO - 12.500
a - 96
B - 115
SI. IOO • 41.500
SO. 8 - 97.7
B - 16. 2
13.OOO • 14.50O
17 «J - 25.SJ
11.600 - 15.000
254 . 170
B - 0.22
..
..
R
..
B • 30.0
01 6J - 77. SJ
NO - 0.21
Obeetved Range
ppm, (Including
background)
0.760 - 17. IOO
B • 0.7
B - 137
31.100 • 41.000
20.6 - 40.4
a - 22.2
0.070 - 11.700
0.3J • 30.7J
0.440 - 16.000
264 - 621
NO • 0.22
..
—
ND - R
..
B • 30.2
50 3 - 100
ND - 0.21
No. ol
SttflBotot
Exceeding
toe
SOUTolal
Analyzed
0/0
2/0
5/0
0/0
0/0
7/0
0/0
0/0
0/0
Off
1/0
0/0
0/0 '
NA
0/0
5/0
0/0
2/0
Notlh Diloh Sediment
Observed
Background
Ranga. ppm
(NOEOI7-10)
10.100 • 23.400
B - 11.3
B • 421
21.300 - 44.000
40.2J - 04. 7J
65.4 - 01.1
27.500 - 30.3OO
61.0 • 101
•.200 - 21.400
64* - 07«
1.6 - 3.4
B - 32.2
8 • 2.100
ND.J • R
6.0 • 10.7
4I.OJ - 5t.5
334J - 570
O.IS - t.4
Obaarwad
Ranga, ppm
(ineliuting
background)
1.9*0 • 23.400
B • 11.3
B - 421
21.300 •
1 2O.OOO
61 • 04. 7J
B • 01.1
6.000 - 30.300
21.7 • 101
S.2OO - 21.4OO
203 • 071
B - 3.4
NO • 32.2
B - 2.160
NO.J • R
ND • 10.7
B • 56.5
75.8 • 570
NO - • «
No. 01
Samplai
Excaading
Ina
SOUTolal
Analyzed
•/•
2/0
5/1
-------
may have been due to a reported sludge release during the 1970 dike failure. As
such, and as requested by U.S. EPA, PCBs are considered a chemical of concern for sediments in
the North Ditch. Since higher concentrations of PCBs were reported in upstream sediment
samples, the potential risks posed by exposure to PCBs in North Ditch sediments will be
characterized and evaluated by comparison with risks associated with upstream sediment PCB
levels.
Biota
In 1982, Wisconsin Department of Natural Resources (WDNR) performed PCB analysis on carp
collected from four locations in Nine Springs Creek in the vicinity of the sludge lagoons. Carp
are frequently used as indicators of bioaccumulation due to their high lipid content and bottom-
feeding habits, and are thus considered to be maximally exposed to sediment constituents. Since
carp are relatively non-migratory and long-lived, they are good indicators of site-specific
constituent bioavailability. Total PCB (fillet composite) concentrations ranged from less than
0.2 to 0.58 mg/kg.
WDNR considered the PCB concentrations detected in the fish study to be representative of
regional background conditions (MMSD, 1983; 1985; 1990a). According to the U.S. Fish and
Wildlife Service (Eisler, 1986), low concentrations of PCBs are detected in fish from almost
every major river in the United States. As such, the PCB concentrations detected in carp from
Nine Springs Creek are within the range of regional background PCB concentrations for this
species, and no chemicals of concern are identified in biota. A summary of regional carp PCB
concentrations is presented in Section 2.1.6 of the Final RI Report (BBL, 1994b).
A summary of chemicals of concern for all media is presented in Table 8.
The approved RI Report (January 1994), contained the following conclusions:
• The peat acts as a capture zone that restricts migration of sludge constituents to
the aquifer beneath the lagoons. Available data indicate that constituents present
in the sludge are being captured and retained in the peat layer.
• Results indicate that ground water is not affected by the lagoon sludge
constituents. No organic constituents which can be attributed to the lagoons were
detected in the ground water. This is likely due, in part, to the restrictive geologic
and hydrogeologic subsurface characteristics. Although fluctuations in the presence
and concentration of inorganic ground-water constituents were noted, the range of
upgradient (background) inorganic constituent concentrations was generally
comparable to those reported in ground-water samples obtained from downgradient
locations.
20
-------
TABLE 8
CHEMICALS OF MTBCBT - SUMMARY OF ALL MEDIA
Poit~SiUdQ9 North Diten
I >Qjnn 2A RMDOMI Suptrraattfit SwMrwnt
NOflGANCS
Aluminum
Araanic
Barium
Cadmium
Chromium
Cobaft
Copper
tan
Laad
Magnwium
MaVtQBTMM
Marcury
Moryfactonum
a. IT .1. .1
NICXVI
Satonium
Slvar
Vanadium
Zinc
Cyanid*
.--• .,,^K=s==:^^=
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
-_— — .. — . ... . II
X
X
X
X
X
X
X
X
X
X
-^^— — • - — — • — - • 1^ -^ — _^_ ^^_—
X
X
X
X
X
X
X
X
X
VOLATILE ORGANC COMPOUNDS
Acatana
CartaondauMda
2-Buamn*
riMMff^
Toluana
jJAMfciDoigay^
Xytvntw (toM)
X
X
X
X
X
X
X
X
•
SEMrVOLATILE ORQANC COMPOUNDS
Bls(2-«lhytiaKyl)phtnalatr *
PESHCDES
4.4-ODE
4.4-ODD
PC8»
Total PCB»
w n
X
X
X
X
X X
Nous:
X - intficatnlh*pwam«tvnachamiCBlafintvMtlnlh*m»diaindicatMl
21
-------
• The Nine Springs Creek and North Ditch surface-water results indicate that no
sludge constituents are migrating through the lagoon dike walls. The majority of
the few TCL/TAL constituents observed in the surface water were also observed at
similar concentrations in upgradient/upstream water samples. The lack of a good
hydraulic connection between the lagoons and the surrounding streams was further
substantiated by sampling of peat, following the cleanout of Lagoon IB.
• No similar patterns between sludge and sediment constituents in samples
obtained adjacent to, or downgradient of, the sludge lagoons can be discerned
that indicate possible migration. Determination of the source of organic and
inorganic constituents reported in the creek and ditch sediments is confounded by the
presence of similar upstream constituents at comparable concentrations, analytical
and spatial variability, and a 1970 dike failure. The slight increase in the
concentration of PCBs and several inorganic constituents in the North Ditch is likely
related to the outflow of lagoon contents during the 1970 dike failure.
• The sludge lagoons, including the 1970 dike failure, have not affected the
wetland soils adjacent to the North Ditch. Concentrations of inorganics detected
in wetland soils were generally comparable to those noted in background.
Lagoon 2B Re-sampling (1996^
As noted previously, EPA indicated in a March 28,1995 letter (Appendix C-l) that it no longer
objected to the land application of MMSD's lagooned sludge containing PCBs at concentrations
less than 50 ppm. To ensure that any sludge in Lagoon 2B which possibly contains PCBs in
excess of 50 ppm not be inadvertently land applied, EPA requested additional sampling to better
characterize the Lagoon 2B sludge. Guidance for conducting this sampling was provided to
MMSD by EPA in a letter dated July 27,1995 (Appendix C-2). Using the EPA guidance,
MMSD prepared and submitted to EPA a sampling plan, dated August 2,1995 (Appendix C-3),
for further characterizing the PCB concentrations in Lagoon 2B sludges. In a letter dated
September 11, 1995 (Appendix C-4), EPA approved the sampling plan.
IV. SUMMARY OF SITE RISKS
During the course of an RI/FS the U.S. EPA requires that a risk assessment be prepared
according to U.S. EPA policy and guidelines. At the MMSD Site, PRP contractors prepared a
risk assessment under the Administrative Order for the RI and FS. This risk assessment provides
U.S. EPA with a basis for selection of a remedy which would be protective of public health,
welfare, and the environment. The risk assessment, prepared by the PRP contractor, utilizing
available information is consistent with the U.S. EPA policy and guidance. It provides an
estimate of the health or environmental problems that could result if the Site was left untreated.
This analysis, commonly referred to as a baseline risk assessment, is documented in the Human
22
-------
Health Risk Assessment and the Ecological Risk Assessment, September 1996 for the MMSD
Site.
Toxicity Assessment
Cancer potency factors (CPFs) have been developed by 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 potential carcinogen in mg/kg-day and the expected duration of chronic exposure, to
provide an upper-bound estimate of the excess lifetime cancer risk associated with exposure at
that intake level. Values for these parameters are included in Table 8 for the chemicals used in
the Risk Assessment. The term "upper bound" reflects the conservative estimate of the risks
calculated from the CPF. Use of this approach makes underestimation 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 (RfDs) have been developed by U.S. EPA for indicating the potential for
adverse health effects from exposure to chemicals exhibiting noncarcinogenic effects. RfDs,
which are expressed in units of mg/kg-day, are estimates of lifetime daily exposure levels for
humans, including sensitive individuals. Estimated intakes of chemicals from environmental
media (e.g., the amount of a chemical ingested from contaminated drinking water) can be
compared to the RfD. RfDs are derived from human epidemiological studies or animal studies to
which uncertainty factors have been applied (e.g., to account for the use of animal data to predict
effects on humans). These uncertainty factors help ensure that the RfDs will not underestimate
the potential for adverse noncarcinogenic effects to occur. Values for these parameters are
included in Table 8 for the chemicals used in the Risk Assessment.
Pathways and Risk Assessment
Excess lifetime cancer risks are determined by multiplying the intake level with the CPF. These
risks are probabilities that are generally expressed in scientific notation (e.g., 1 x 10"6). An
excess lifetime cancer risk of 1 X 10"6 indicates that, as a plausible upper bound, an individual
has a one in one million chance of developing cancer as a result of site-related exposure to a
carcinogen over a 70 year lifetime under the specific exposure conditions at the site.
Potential concern for noncarcinogenic effects of a single contaminant in a single medium is
expressed as the hazard quotient (HQ) (or the ratio of the estimated intake derived from the
contaminant concentration in a given medium to the contaminant's reference dose). By adding
the HQs for all contaminants within a medium or across all media to which a given population
may reasonably be exposed, the Hazard Index (HI) can be generated. The HI provides a useful
reference point for gauging the potential significance of multiple contaminant exposure within a
single medium or across media.
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The Baseline Risk Assessment identifies the potential for effects on human health and/or the
environment that may result from exposure to chemicals present at the site under current
conditions. The final Baseline Risk Assessment focuses on the sludge with PCB concentrations
greater than or equal to 50 ppm. Sludge with PCB concentrations less than 50 ppm in other
lagoon areas have previously been or will be cleaned out in the future in conjunction with the
lagoon closure plan and the Metrogro program.
The Baseline Risk Assessment was developed in accordance with EPA guidelines, including the
Risk Assessment Guidance for Superfund: Volume 1 - Human Health Evaluation Manual (EPA,
1989a) and Volume 2 - Environmental Evaluation Manual (EPA, 1989b). The Baseline Risk
Assessment reflects potential risks posed by sludge only in 2A and portions of 2B and residual
peat in Lagoons 1 A, IB, and the rest of 2B (i.e., assumes sludge is removed). The following
sections present summaries of the human health and ecological portions of the Baseline Risk
Assessment.
Human Health Evaluation
The human health evaluation portion of the Baseline Risk Assessment quantifies the potential
human health risks posed by chemical constituents present at the MMSD Lagoons Site. The
Human Health evaluation is organized into five general components: 1) Site Characterization; 2)
Data Evaluation; 3) Exposure Assessment; 4) Toxicity Assessment; and 5) Risk
Characterization.
Potential human receptor groups at the MMSD Lagoons Site were identified through evaluation
of land use, accessibility, and definition of site activities. The potential receptors include those
individuals who may come into contact with the sludge/peat and supernatant in the lagoons,
sediments of the North Ditch, and/or ambient air affected by the lagoon areas. These individuals
include MMSD employees, bird watchers, and local residents. Exposure routes vary by receptor
group and environmental media, but generally include dermal contact, incidental ingestion,
and/or inhalation. The various exposure routes (by receptor and media) used in the Baseline Risk
Assessment, are presented below.
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REGEPTQR
MMSD Employees
Bird Watchers
Nearby Residents
MEW
Lagoon 2A Sludge/Lagoon
1/2B Peat
Lagoon Supernatant
Ambient Air
Lagoon 2A Sludge/Lagoon
1/2B Peat
Lagoon Supernatant
Ambient Air
Sediment
Ambient Air
EXPOSURE ROUTE
Dermal Contact
Incidental Ingestion
Dermal Contact
Inhalation of Organic
Vapors
Dermal Contact
Incidental Ingestion
Dermal Contact
Inhalation of Organic
Vapors
Dermal Contact
Incidental Ingestion
Inhalation of Organic
Vapors
Consistent with EPA guidance, the potential for noncarcinogenic and carcinogenic effects are
evaluated separately in the Human Health Evaluation. To characterize the overall potential for
noncarcinogenic effects, an HI approach is used. An HI greater than 1 indicates the potential for
adverse health effects. Carcinogenic risk is expressed as a probability of developing cancer over
a lifetime. EPA's acceptable target range for carcinogenic risk associated with NPL sites is one-
in-one-million (1E-06) to one-in-ten-thousand (1E-04).
In the Human Health Evaluation, His and carcinogenic risks were generated for each receptor
and each pathway of exposure. A summary of the His and carcinogenic risks is presented below:
• Employees: Noncarcinogenic His for employees are well below the EPA target HI
of 1. The overall carcinogenic risk for employees is 5E-06, which is within the EPA
target risk range;
• Birdwatchers: Noncarcinogenic His for bird watchers are well below the EPA
target HI of 1. The bird watcher's overall carcinogenic risk is 3E-06, which is within
EPA's acceptable target risk range; and
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• Residents: The carcinogenic risk for off-site residents is 3E-07, which is well below
EPA's acceptable target risk range.
Ecological Assessment
The Ecological Assessment (EA) addresses the potential for ecological effects associated with
the MMSD Lagoons Site. The EA is organized into the following four sections: 1) Site
Characterization; 2) Exposure Assessment; 3) Ecological Effects Assessment; and 4) Risk
Characterization.
Ecological exposure profiles were developed in the Exposure Assessment of the EA based on
exposure potential, ecological significance, and/or sensitivity. Exposure profiles were developed
for both the lagoon habitat and the adjacent North Ditch. Representative receptor species
selected to evaluate the potential magnitude of exposure in the lagoon system habitats and the
North Ditch included shorebirds (spotted sandpipers), great blue herons, shrews, and raccoons.
Wildlife exposure to PCBs via food consumption and ingestion of sludge/peat was estimated in
the EA using exposure models and the methods presented in the EPA (1993) Wildlife Exposure
Factors Handbook to determine the potential average daily dosage. Exposure variables for the
EA were selected to represent two estimated degrees of exposure - a reasonable maximum
estimate and a typical-case estimate. This approach allows for the presentation of a range of
potential ecological risks, and is consistent with draft EPA guidance for performing ecological
risk assessments under Superfund. Food item PCB concentrations used in the exposure models
were estimated using bioconcentration factors (BCFs) and bioaccumulation factors (BAFs)
obtained from the available literature.
To determine the potential risk for lagoon wildlife, estimated potential average daily doses were
compared to appropriate toxicity endpoints. Toxicity endpoints included no-observed-adverse-
effect-levels (NOAELs) and lowest-observed-adverse-effect-levels (LOAELs). NOAELs and
LOAELs were obtained from toxicity data described in the literature. The estimated risks for
wildlife receptors are presented as HQs, which are defined as the potential average daily dose
divided by the NOAEL or LOAEL. EPA routinely considers a HQ of 1 as a benchmark for
determining potential significance of calculated ecological risks.
In summary, as a result of discussion with EPA, PCBs were the only chemical considered in the
ecological risk assessment. The only medium which resulted in HQ values greater than 1 under
any scenario was Lagoon 2A sludge. The most conservative exposure and toxicity assumptions
led to HQ values greater than 1 for shrews, sandpipers, and herons. In the more typical-case risk
calculations for these receptors (i.e., typical exposure estimates and toxicity endpoints), none of
the HQ values exceeded 1. HQ values for receptors exposed to other media (Lagoon 1 and 2B
peat and North Ditch sediments) were all substantially less than 1.
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V. DESCRIPTION OF ALTERNATIVES
RA-1 No Action
The No Action Alternative involves no active remediation or long-term management at the site.
Implementation of the No-Action Alternative would result in discontinuation of currently
ongoing dike monitoring, maintenance, and supernatant control. Lagoon 2A and the applicable
portions of Lagoon 2B largely would remain in its current state, with future changes occurring
only through natural processes such as biodegradation and increased vegetative cover. Inclusion
of the No-Action Alternative is required by the NCP as a basis against which action-related
alternatives are evaluated. No costs are associated with this remedial action.
RA-2 Institutional Controls
This alternative would involve the continuation of current routine activities at Lagoon 2 A and
portions of 2B. These activities include supernatant control, periodic dike monitoring and
routine dike maintenance (e.g. grading and maintaining dike roads). Any future changes that
occur would be due to maintenance activities, or through natural processes such as
biodegradation and continued growth of vegetative cover.
Physical barriers currently exist which limit access to the lagoons. These include fencing along
the western end of Lagoon 1, and a creek and ditch which border the lagoons to the south, east,
and north. Warning signs could be placed around the perimeter of the greater than 50 ppm PCB
sludge to help further restrict access.
Monitoring of the perimeter containment dikes in the lagoon system is currently accomplished
through the use of instrument clusters. Digital electronic readouts are obtained from the Sondex
settlement system, used to measure settlement of compressible layers in the dike foundation.
Digital electronic readouts also are obtained from the slope inclinometers which measure lateral
movement within the soil layers underlying the dikes.
Lagoon supernatant levels are also currently regulated as part of MMSD's routine maintenance
program. Piezometer water level measurements are obtained using a small diameter water level
indicator to measure excess pore water pressures in the substrata. Ground-water monitoring
wells facilitate the measurement of the water levels within the dikes using a conventional
electronic water level probe. The frequency at which readings are taken has varied from twice
per month to once per year, depending on the instrument and the trends observed from the
previous readings. The institutional controls would continue in perpetuity. The estimated present
worth cost of this alternative is approximately $425,000.
RA-3 Beneficial Reuse
The Beneficial Reuse alternative would involve the removal and recycling of sludge containing
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PCBs at concentrations greater than 50 ppm from Lagoon 2A and applicable portions of Lagoon
2B to agricultural land. Material to be removed from the lagoons would include vegetative
cover, supernatant, sludge, and a limited amount of peat at the sludge/peat interface.
Prior to implementing this alternative, dikes would be constructed to isolate the Lagoon 2B
sludge containing PCBs at concentrations above 50 ppm. The initial step in implementing the
Beneficial Reuse alternative would involve segmenting the lagoons into smaller working units
(cells), using intermediate dikes, to aid in the sludge removal. Vegetation covering the majority
of Lagoon 2A and applicable portions of 2B would be removed and used as a soil conditioner.
Sludge removal would be performed by directing sludge to a series of sumps located along the
intermediate dikes.
From the sumps, the sludge would be pumped to an overhead loading station, for subsequent
transportation. Sludge transportation to the field application site would be accomplished through
the use of tanker trucks.
To ensure adequate removal of sludge, a layer of peat (approximately one foot, based on previous
cleanout activities) at the sludge/peat interface also would be removed. The sludge/peat then
would be beneficially reused on lands owned by the District or other nearby farmland.
It is anticipated that sludge clean out and beneficial reuse of greater than 50 ppm sludge would
be completed in approximately six years. Following sludge removal, the lagoons could be
actively managed to enhance and control future use by wildlife, or allowed to naturally
revegetate and return to pre-lagoon conditions. Cost of the alternative is estimated to be $8
million.
RA-4 In-Place Vegetative/Soil Cover
The In-Place Vegetative/Soil Cover Alternative would involve the removal of supernatant from
water-covered areas of Lagoon 2A and applicable portions of Lagoon 2B, followed by the
placement of a geotextile layer and approximately one foot of a lightweight soil (e.g., peat)
cover. The soil cover would be seeded with appropriate aquatic vegetation and required
maintenance activities implemented as necessary, to ensure continued vegetative growth and the
development of a weed mat at the sludge surface. Remedial activities would involve only the
areas of Lagoon 2A and applicable portions of 2B that are covered with supernatant (i.e.,
exposed sludge). These areas are expected to total approximately 30 percent of the affected
surface since approximately 70 percent of it already is covered with vegetation, including a 6- to
12-inch weed mat.
Remedial activities would be performed during the winter so that the frozen ground could better
support additional weight due to construction equipment and activity. In areas where
construction activities would be performed surface water would be removed so that a minimum
amount of surface water would be present before freezing. Supernatant would be periodically
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pumped from these areas, starting in late fall until the ground freezes. The removed supernatant
would be pumped to the Nine Springs Treatment Facility for treatment.
Construction activities would commence with limited grading (if necessary) followed by the
placement of a layer of geotextile on the frozen sludge surface to support a soil cover until the
weed mat has had sufficient time to mature and support the cover. Geotextile placement would
be followed by the placement of an approximately one-foot thick layer of light-weight soil
material on top of the geotextile. The soil would then be hydroseeded with appropriate native
aquatic vegetation.
Following seeding, appropriate warning signs would be posted and the cover would be
maintained to facilitate ongoing vegetative growth. Maintenance of dikes and other physical
barriers would proceed as discussed previously for the Institutional Controls Alternative (RA-2).
The implementation of the In-Place Vegetative/Soil Cover Alternative (RA-4) would affect
approximately three acres of Lagoon 2A and approximately nine acres of Lagoon 2B.
Construction would be complete in one season, while the development of a viable weed mat
would require several seasons. Cost of the remedy is estimated to be $ 1.8 million.
RA-5 In-Situ Solidification/Stabilization
The In-Situ Solidification/Stabilization Alternative would involve the in-place addition of a
binder to convert the sludge into a less soluble and less mobile form. A binding agent comprised
of either a mixture of equal parts portland cement and Class C fly ash or only portland cement
would be added to the sludge at a ratio of 1:1 by weight. This mixture is based on results of the
1995 bench-scale study described in section 4.3.2. The mixture used in the 1989 study was
deemed to be too conservative and hence not as economical. The binder would incorporate the
sludge constituents in the resulting solid material. Based on the results of laboratory testing
(Section 4.4), the intended mixture would provide adequate strength within seven days of curing
to provide the 10 pounds per square inch (psi) required strength to support construction
equipment.
The vegetation overlying the surface of the lagoons would not be removed during
implementation of this alternative. Mixing would be performed to a minimum depth of
approximately six feet, which would include treating a portion of underlying peat in addition to
the sludge. A one-foot layer of lightweight soil material subsequently would be placed over the
stabilized mass and vegetated, to help control ponding due to precipitation, reduce weathering,
and enhance site aesthetics. At a treatment rate of approximately 700 cubic yards per day and a
construction season of about six months, this project should be completed in approximately three
years. The estimated present worth cost to implement this alternative ranges from approximately
$23 million to $28 million.
Ongoing maintenance activities would take place at the site, including periodic dike monitoring
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and maintenance (e.g., grading and maintaining dike roads), and surface-water control if areas of
persistent ponding are observed. The methods and approach to be used would be consistent with
those in the Institutional Controls Alternative (RA-2) described in Section 5.3.2.
RA-6(a) Ex-SitUf Biological Treatment - Reuse Residue
This alternative would involve the removal and biological treatment of sludge from Lagoon 2 A
and applicable portions of Lagoon 2B with PCB concentrations in excess of 50 ppm, to a PCB
concentration of less than 50 ppm in biological reactors, following which the treated sludge
would be recycled to agricultural lands. Materials removed from the lagoon would include
vegetative cover, sludge, a small amount of supernatant, and a limited amount of peat at the
sludge/peat interface. Vegetation which covers the majority of the lagoon, would be removed
and used as a soil conditioner. The cover material would be tested prior to its use as a soil
conditioner to confirm that the PCB concentration is below 50 ppm. Sludge would be pumped
directly to the biological reactors for treatment.
During sludge removal operations, the dikes would be closely monitored. To ensure adequate
removal of sludge, a layer of peat at the sludge/peat interface also would be removed. Following
sludge removal, the cleaned out lagoon could be managed to allow continued use by shore birds,
or allowed to naturally revegetate and return to pre-lagoon conditions.
The biological reactors would be constructed on MMSD property. An estimated 30 percent
reduction would reduce the average Lagoon 2 A and portions of Lagoon 2B sludge PCB
concentration to below 50 ppm.
PCB biodegradation would be effected by naturally occurring microorganisms to a target
concentration of less than 50 ppm. The necessary biochemical sludge characterization would be
performed prior to detailed process design. As part of process control monitoring, moisture and
nutrient levels (oxygen, phosphate and nitrate) would be periodically measured and maintained at
specific design concentrations. Adequate aeration would be provided based on the pre-
determined oxygen demand of the sludge.
Following treatment, the sludge would be recycled to agricultural land. It is estimated that the
Ex-Situ Biological Treatment - Reuse Residue Alternative (RA-6[a]) would take approximately
15 years to complete. The estimated present worth cost of this alternative is in the range of $44
million to $66 million.
RA-6(b> Ex-Situ Biological Treatment - Landfill Residue
This alternative would involve the removal and biological treatment of sludge from Lagoon 2 A
and portions of Lagoon 2B to a PCB concentration of less than 50 ppm in a biological reactor
consistent with RA-6[a], following which the treated sludge would be disposed in a solid waste
landfill. Materials removed from the lagoons would include vegetative cover, sludge, a relatively
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small amount of supernatant, and a limited amount of peat at the sludge/peat interface.
Lagoon cleanout and sludge pre-treatment in biological reactors would be conducted as described
for the Ex-Situ Biological Treatment - Reuse Residue Alternative (RA-6[a]). Following
treatment to PCB levels less than SO ppm, the sludge would be stabilized for disposal. Sludge
would be treated to pass the paint filter test so that it is acceptable for disposal at a local
Wisconsin solid waste landfill. It is estimated that the Ex-Situ Biological Treatment - Reuse
Residue Alternative (RA-6[a]) would take approximately 15 years to complete. The estimated
present worth cost of this alternative is approximately $64 million to $89 million.
Following sludge removal, the cleaned out lagoon could be managed to allow continued use by
shorebirds, or allowed to naturally revegetate and return to pre-lagoon conditions.
RA-7 Ex-Situ Chemical Treatment - Landfill Residue
This alternative would involve the chemical treatment of sludge removed from Lagoon 2A and
portions of Lagoon 2B to a PCB concentration of less than SO ppm. Following treatment, the
residual sludge solids would be disposed in a local solid waste landfill in a manner similar to the
Ex-Situ Biological Treatment - Landfill Residue Alternative (RA-6[b]). As with the other
alternatives, the vegetative cover, sludge, a small amount of supernatant, and a limited amount of
peat at the sludge/peat interface, would be removed.
Lagoon cleanout would be accomplished following the procedures described previously in
Section 5.3.3. During sludge removal operations, the dikes would be monitored. Vegetation
which covers the majority of the lagoon would be removed and used as a soil conditioner.
Following sludge removal, the cleaned out lagoon could be managed to allow continued use by
shorebirds, or allowed to revegetate naturally and return to wetland conditions.
Chemical treatment is B.E.S.T.* solvent extraction. The B.E.S.T.* mobile unit operates at a rate
of up to 140 tons of wet sludge per day, using a solvent called triethylamine (TEA).
Following treatment, the sludge would be separated into three fractions: oil containing the
PCBs, water, and dry solids. The concentrated PCBs contained in the organic oil fraction
(liquid) would require disposal in an approved TSCA incinerator. The water would contain
negligible PCBs and would be treated by the MMSD publicly owned treatment works (POTW).
The sludge solids would be disposed of at a Wisconsin solid waste landfill. The removed peat
would be stabilized with fly ash (if necessary) and also disposed of in a local solid waste landfill.
Assuming a construction season lasting 180 days per year, it would take approximately 14 years
to treat the Lagoon 2 A and applicable portions of Lagoon 2B sludge at a treatment rate of 140
tons of wet sludge per day. Present worth cost of this alternative is in the range of $55 million to
$73 million.
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RA-8 TSCA Landfill Disposal
This alternative would involve the removal, stabilization, and disposal of sludge from Lagoon 2 A
and portions of Lagoon 2B in an out-of-state, TSCA-permitted landfill. Materials removed from
the lagoons would include vegetative cover, sludge, some supernatant and a limited amount of
peat at the sludge/peat interface. Lagoons cleanout would be accomplished following previously
described procedures. Following sludge removal, the cleaned out lagoon could be managed to
allow continued use by shorebirds, or allowed to naturally revegetate and return to pre-lagoon
conditions.
Vegetation, which covers the majority of the lagoon would be removed and used as a soil
conditioner. During sludge removal operations, the dikes would be closely monitored.
The stabilized sludge would be transported to an out-of-state TSCA-permitted disposal facility.
The sludge would be manifested and transported in accordance with applicable state and federal
regulations. It is estimated that this alternative would take approximately six years to complete
at a present worth cost estimated to be in the range of $160 million to $168 million.
RA-9 Wisconsin Solid Waste Landfill Disposal
The Solid Waste Landfill Disposal Alternative (RA-9) would involve the removal, stabilization,
and disposal of sludge from Lagoon 2A and portions of Lagoon 2B in a Wisconsin solid waste
landfill. Sludge removal, stabilization, and transport would be conducted in a manner consistent
with that described for the TSCA Landfill Disposal Alternative (RA-8). However, disposal
would take place in a local solid waste landfill that complies with Wisconsin Administrative
Code Chapters NR 500 through 520 and is approved to accept such material from the WDNR
and EPA. It is estimated that this alternative would take approximately six years to complete.
The cost to implement this alternative is in the range of approximately $40 million to $53
million.
VI. COMPARATIVE ANALYSIS OF REMEDIAL ALTERNATIVES
Based on current information, Alternative RA-4 appears to provide the best balance of tradeoffs
among the alternatives with respect to the nine criteria that U.S. EPA uses to evaluate
alternatives. This section profiles the performance of the preferred alternative against the nine
criteria and explains the rationale for the selection of the final remedial action. These nine
criteria are:
1. Overall Protection of Human Health and the Environment addresses whether or not a
remedy provides adequate protection and describes how risks posed through each pathway are
eliminated, reduced, or controlled through treatment, engineering controls or institutional
controls.
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2. Compliance with ARARs addresses whether or not a remedy will meet all of the
applicable or relevant and appropriate requirements (ARARs) of other Federal and state
environmental statutes and/or provide grounds for invoking a waiver.
3. Long-Term Effectiveness and Permanence refers to the magnitude of residual risk and
the ability of a remedy to maintain reliable protection of human health and the environment over
time once the cleanup goals have been met.
4. Reduction of Toxicity, Mobility, or Volume is the anticipated performance of the
treatment technologies that may be employed in a remedy.
5. Short-Term Effectiveness addresses the period of time needed to achieve remediation
levels set out in the ROD, as well as the remedy's potential to create adverse impacts on human
health and the environment that may result during the construction and implementation period,
until cleanup levels are achieved.
6. Implementability is the technical and administrative feasibility of the remedy, including
the availability of materials and services needed to implement the chosen solution.
7. Cost includes estimates of capital and operation and maintenance costs.
8. State Acceptance indicates whether, based on its review of the RI/FS and Proposed Plan,
the State concurs with, opposes, or has no comment on the recommended alternative.
9. Community Acceptance will be assessed in the ROD following review of the public
comments received on the RI/FS report and the Proposed Plan.
The 10 alternatives are being evaluated in relation to one another for each of the evaluation
criteria. This evaluation identifies the relative strengths and weaknesses of each alternative. The
No-Action Alternative (RA-1) will serve as a baseline for comparison. However, it should be
noted that the Institutional Controls Alternative (RA-2) represents current site conditions. The
alternatives that are undergoing a comparative analysis in this section, are as follows:
RA-1 No Action;
RA-2 Institutional Controls;
RA-3 Beneficial Reuse;
RA-4 In-Place Vegetative/Soil Cover,
RA-5 In-Situ Solidification/Stabilization;
RA-6[a] Ex-Situ Biological Treatment - Reuse Residue;
RA-6[b] Ex-Situ Biological Treatment - Landfill Residue;
RA-7 Ex-Situ Chemical Treatment - Landfill Residue;
RA-8 TSCA Landfill Disposal; and
RA-9 Wisconsin Solid Waste Landfill Disposal.
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Overall protection of human health and the environment and compliance with ARARs are
threshold requirements that each alternative must meet in order to be eligible for selection. The
five primary balancing criteria are long-term effectiveness and permanence; reduction of toxcity,
mobility, or volume through treatment; short-term effectiveness; implementability; and cost.
State and community acceptance are modifying criteria that shall be considered in remedy
selection.
Overall Protection of Human Health and the Environment
All of the alternatives are protective of human health. RA-3 and RA-6a provide protection of
human health and the environment at the site through removal of contaminated sludge. These
alternatives would eliminate: (1) potential risks at Lagoon 2A and applicable portions of 2B
associated with human and wildlife exposure to the lagoon sludge; (2) the potential for future
migration of sludge from the lagoon; and (3) the potential need for long-term management at
Lagoon 2 A and portions of Lagoon 2B.
Protectiveness is achieved by Alternative RA-5 through reduction of the potential for human
exposure and reduce wildlife exposure to greater than 50 ppm PCB lagoon sludge to acceptable
levels by physically making the sludge constituents unavailable for ingestion, dermal exposure,
or inhalation.
The in-place remedial alternatives protect human health by reducing or eliminating potential
exposure pathways. Lagoon 2A sludge could pose an ecological risk to certain wildlife receptors
if Alternative RA-1 or RA-2 was the selected remedy. Protectiveness is provided by the
vegetative/soil cover in RA-4. RA-5 provides protectiveness by stabilizing the sludge to reduce
the potential ecological risks to acceptable levels. RA-3 may pose concerns because it exceeds
the 50 ppm standard for beneficial use, which is based on an analysis of acceptable risk.
Compliance with ARARs
Although no chemical-specific ARARs were identified that apply to municipal sewage sludge,
federal and state guidance to be considered (TBCs) exists that may be considered for the
remedial alternatives. Alternatives RA-2 through RA-9 are all expected to comply with the
TBCs referenced in Appendix A, Table A-l. The No-Action Alternative (RA-1) may not comply
with EPA guidance (EPA, August 1990), which states that Institutional Controls are warranted
when low concentrations of PCBs remain on site.
With regard to action-specific ARARs (Appendix A, Table 2), the No-Action (RA-1) and
Institutional Controls Alternatives (RA-2) are least apt to comply with 40 CFR Part 503 -
Subpart C or NR 204, which specify municipal sludge management requirements. The action-
specific ARARs identified for the In-Place Vegetative/Soil Cover (RA-4), In-Situ S/S (RA-5),
and TSCA Landfill Disposal (RA-8) Alternatives are considered readily achievable.
Implementation of the remove and treat, reuse and/or dispose (RA-3), RA-6[a], RA-6[b], RA-7)
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and Wisconsin Solid Waste Landfill Disposal (RA-9) Alternatives would all first require written
approval from the Region 5 Administrator as an alternate disposal method under TSCA.
The location-specific ARARs identified in Appendix A, Table A-3 are considered readily
achievable for Alternatives RA-2 through RA-9. In the absence of Institutional Controls, long-
term compliance with NR 103 under the No-Action Alternative (RA-1) cannot be ensured.
Long-Term Effectiveness and Permanence
The two alternatives involving Beneficial Reuse (RA-3 and RA-6[a]) would result in the least
residual risks at the site and the highest degree of long-term effectiveness of the nine alternatives
evaluated. This is due to the removal and permanent treatment of the sludge, with no need for
long-term monitoring/management. A similar level of effectiveness and permanence is also
afforded at Lagoon 2A and applicable portions of Lagoon 2B, following implementation of the
other removal alternatives (RA-6[b], RA-7, RA-8, and RA-9). However, they all involve
landfilling of the removed sludge which poses a potential future long-term liability and hence
would require monitoring to ensure continued, permanent and effective protection at the
associated landfill.
The resistance to weathering of the solidified/stabilized sludge mass (In-Situ S/S Alternative,
RA-5) through cap and dike maintenance would result in long-term control (high-degree of
permanence) of sludge migration and thus in a level of effectiveness that approaches that of the
removal alternatives. The In-Place Vegetative/Soil Cover Alternative (RA-4) also would reduce
the potential for human or wildlife exposure to greater than 50 ppm PCB sludge to acceptable
levels for both human health and the environment. Through continued growth and thickening of
the cap, the long-term effectiveness and permanence of Alternative RA-4 would improve over
time. Ongoing monitoring and maintenance would be needed to ensure the long-term
effectiveness of the In-Place Vegetative/Soil Cover (RA-4) and In-Situ S/S (RA-5) Alternatives.
Potential risks to certain wildlife receptors exist if Alternative RA-1 or RA-2 was selected for the
lagoon sludge. In the absence of future dike monitoring/maintenance, access restrictions, and
any actions taken to reduce the sludge exposure potential, Alternative RA-1 would offer the least
degree of long-term effectiveness and permanence. In order to ensure long-term protection of
wildlife that forage in Lagoon 2A and applicable portions of Lagoon 2B, continued growth and
expansion of the vegetative cover over unvegetated areas would be necessary with Alternative
RA-2.
With Alternative RA-1, RA-2, and RA-4, Lagoon 2A and the applicable portions of Lagoon 2B
would continue to support most of the wildlife which currently utilize it. Exposure to the lagoon
sludge could pose an ecological risk to certain wildlife receptors with Alternatives RA-1 or RA-
2. Future use of Lagoon 2A and the applicable portions of Lagoon 2B, following
implementation of the In-Situ S/S Alternative (RA-5) would be limited primarily to terrestrial
biota. If an alternative involving removal of the lagoon sludge was implemented (i.e., RA-3,
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RA-6[a], RA-6[b], RA-7, RA-8, or RA-9), active management of the lagoons would allow future
control to enhance the lagoons for use by wildlife.
Reduction of Toxicitv. Mobility, or Volume
Reductions in mobility, volume, or toxicity would be realized through alternative RA-6[a], since
it involves removal and treatment. Similarly, all the alternatives involving removal and
landfilling (RA-6[b], RA-7, RA-8, RA-9) would also result in reductions in mobility and
potential toxicity but would result in an increase in disposal volume due to the addition of a
stabilization agent (with the exception of RA-7, which is not expected to require addition of a
stabilization agent). Alternative RA-5 would result in a reduction in potential mobility due to
encapsulation and possible reductions in potential toxicity through treatment. The
implementation of Alternative RA-5 would result in an increase in volume of the material in the
lagoons.
Monitoring and maintenance for the In-Place Vegetative/Soil Cover and Institutional Controls
Alternative RA-2 and capping for RA-4 would result in a reduction in the potential for future
migration of sludge and its constituents. For the No-Action Alternative (RA-1), mobility would
remain unaffected.
Short-Term Effectiveness
The No-Action Alternative (RA-1) provides for the lowest level of impact during implementation
because the alternative involves no active remediation. Implementation of the Institutional
Controls Alternative (RA-2) would result in no additional potential risks and would take little
additional time to implement since it represents current conditions at the Site. No modifications
or disturbances to the current Lagoon 2A and applicable portions of Lagoon 2B ecosystem would
result from implementation of RA-2.
Appropriate health and safety practices and engineering controls would be instituted that would
adequately minimize potential exposure risks to workers during cap installation and operation
and maintenance (O&M) activities associated with RA-4. Implementation time for this
alternative would take approximately one year. Since RA-4 would be implemented during one
winter season and would not involve sludge removal, handling, or transport, short-term effects to
the surrounding community or the environment would be minimal.
The implementation of Alternative RA-5 poses potential risk to workers and the surrounding
environment through exposure to sludge constituents during implementation. Access restrictions
and site monitoring would be instituted to minimize the potential for community exposure during
implementation. Engineering controls and appropriate health and safety practices would be
implemented to ensure worker protection during remedial activities and a monitoring program
would be implemented to reduce the potential for environmental exposure during the estimated
three-year construction period.
36
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Of the alternatives involving removal, Alternative RA-3 presents the least short-term potential
risks. This is due in part, to the controls used in the process. Sludge is transported short
distances in fully-enclosed tanker trucks, is injected directly into the ground (substantially
limiting human contact with the sludge), and is performed by MMSD using experience obtained
over two decades of land application practice. Additionally, RA-3 is one of the alternatives with
the shortest implementation time (up to six years) of all the removal-related alternatives.
Alternatives RA-6[b], RA-7, RA-8, and RA-9 take longer to implement, with biological
alternatives taking approximately 15 years, the chemical treatment/disposal alternative taking 14
years, and the removal/disposal options taking approximately six years to complete. Potential
exposure to workers and the environment during sludge treatment and stabilization would need
to be managed through engineering controls and proper health and safety practices. Off-site
disposition of the sludge would involve both transportation and additional handling, that would
result in an increased potential for human exposure and environmental impacts. For Alternatives
RA-6[b], RA-7, RA-8 and RA-9, an appropriate Health & Safety Plan with selected traffic routes
identified would minimize adverse effects related to transporting stabilized sludge to the
landfills.
Implementability
Alternatives RA-1, RA-2, and RA-4 present no implementability concerns and are technically
and administratively feasible alternatives, requiring no special permits or approvals. Alternative
RA-1 does not require that any remediation be performed. Since Alternative RA-2 has been
ongoing at the site for several years, no concerns regarding implementation of RA-2 exist.
Alternative RA-4 involves activities such as supernatant control and placement of fill, over
applicable portions of Lagoon 2A and Lagoon 2B, which could be conducted using readily
available equipment and materials.
Alternatives RA-5 and RA-8 are technically and administratively feasible and require no
State/Federal special permits or approvals. However, specialized equipment and labor are
required to implement Alternative RA-5, while implementation of Alternative RA-8 is dependent
upon acceptance of the greater than 50 ppm PCB sludge by a TSCA landfill facility and
availability of landfill space.
Alternative RA-3 is considered technically implementable. Although never implemented full-
scale using biological reactors, Alternative RA-6[a] is also technically feasible. Several
operational challenges (e.g., mixing, aeration, pumping, etc.) could make RA-6[a] difficult to
implement. In terms of administrative feasibility, both alternatives (RA-3 and RA-6[a]) would
require EPA Region 5 approval as an alternate treatment disposal technology. Implementation of
either Alternative RA-3 or RA-6[a] also is dependent upon acceptance of the Lagoon 2 A sludge
by farmers.
Alternatives RA-6[b], RA-7 and RA-9 require available landfill space. Similar to Alternative
37
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RA-6[a], several operational challenges make RA-6[b] difficult to implement. Alternative RA-7
would require specialized equipment and available incineration capacity for extracted PCB-
containing oils. Public concern regarding landfilling of TSCA-regulated materials in Wisconsin
could affect the implementability of Alternatives RA-6(b), RA-7, and RA-9.
Cost
Costs have been developed to reflect a +50 percent to -30 percent range of accuracy. These cost
estimates are based on current information. The following table presents the estimated present
worth costs for the alternatives.
ALTERNATIVE
RA-1
RA-2
•RA-4
RA-3
RA-5
RA-9
RA-6[a]
RA-7
RA-6[b]
RA-8
No Action
Institutional Controls
In-Place Vegetative/Soil Cover
Beneficial Reuse
In-Situ Solidification/stabilization
Wisconsin Solid Waste Landfill Disposal
Ex-Situ Biological Treatment - Reuse Residue
Ex-Situ Chemical Treatment - Landfill Residue
Ex-Situ Biological Treatment - Landfill Residue
TSCA Landfill Disposal
ESTIMATED PRESENT
W0HTHCOST
-0-
$425,000
$1,800,000
$8,800,000
$23,000,000 - $28,000,000
$40,000,000 - $53,000,000
$44,000,000 - $66,000,000
$58,000,000 - $73,000,000
$64,000,000 - $89,000,000
$164,000,000-
$168,000,000
The three least costly alternatives are No Action, Institutional Controls and In-Place
Vegetative/Soil Cover, which are all in-place alternatives. Of the removal alternatives,
Beneficial Reuse is the least costly. The other removal alternatives are between four and 17
times more costly than Beneficial Reuse and all but RA-6[a] involve a landfill disposal
component.
In terms of landfilling, it should be noted that the cost of the Wisconsin Solid Waste Landfill
Disposal Alternative (RA-9) is based on disposal costs estimated by commercial landfills, which
are currently pursuing permit approval from WDNR to accept sediment with greater than 50 ppm
38
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PCBs. Since disposal of materials with PCBs at concentrations greater than SO ppm in
Wisconsin landfills has not yet been started, the actual price charged at the time of such
landfilling may differ from the estimate used herein.
Costs for the alternatives involving sludge stabilization prior to disposal (RA-6[b), RA-7, RA-8,
and RA-9) were developed based on a target solids content of 25 percent. Pending the results of
treatability studies performed prior to implementation, these costs are subject to change.
State Acceptance
The State of Wisconsin has indicated that it concurs with the selected remedy for the MMSD
site. A letter from the WDNR indicating this support is attached.
Community Acceptance
In general, the community accepts the selected remedy. Comments from both the residents of
the local community and the regulated community are addressed in the Responsiveness
Summary which is attached.
VII. SELECTED REMEDY
The FS examined nine alternatives, and evaluated them according to the evaluation criteria
outlined in the NCP. From these alternatives, U.S. EPA has selected Alternative RA-4 for
remediation of the MMSD site. The alternative includes:
* Construction of dikes to isolate areas of Lagoon 2B containing sludge with greater
than 50 ppm PCBs;
* Placement of a geotextile layer and approximately one foot of lightweight soil cover
over areas of Lagoon 2A and Lagoon 2B not already cover by naturally developed
vegetative cover, and removal of supernatant from water-covered areas of Lagoon
2A and appropriate portions of Lagoon 2B as necessary;
* Seeding of these areas with aquatic vegetation and monitoring and maintenance to
ensure continued vegetation growth; and
* Continuation of institutional control as described for alternative RA-2.
Prior to cover placement, the sludge in Lagoon 2B with PCBs greater than 50 ppm first would be
isolated with dikes. The Lagoon 2B sludge would then be consolidated to an area adjacent to
Lagoon 2A so that all sludge with greater than 50 ppm PCBs would be contiguous. The In-Place
Vegetative/Soil Cover Alternative (RA-4) would involve the removal of supernatant from water-
covered areas of Lagoon 2 A and applicable portions of Lagoon 2B, followed by the placement of
39
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a geotextile layer and approximately one foot of a lightweight soil (e.g., peat) cover. The
removed supernatant would be pumped to the Nine Springs Treatment Facility for treatment.
The soil cover would be seeded with appropriate aquatic vegetation and required maintenance
activities implemented as necessary, to ensure continued vegetative growth and the development
of a weed mat at the sludge surface. The purpose of Alternative RA-4 would be to minimize
potential exposure by humans and ecological receptors to the Lagoon 2A and applicable portions
of Lagoon 2B sludge. Remedial activities would involve only the areas of Lagoon 2 A and
applicable portions of 2B that are covered with supernatant (i.e., exposed sludge). These areas
are expected to total approximately 30 percent of the affected surface since approximately 70
percent of it already is covered with vegetation, including a 6 to 12-inch weed mat.
Following seeding, appropriate warning signs will be posted and the cover will be maintained to
facilitate ongoing vegetative growth. Maintenance might involve the removal of any supernatant
ponding that potentially could limit vegetative growth and the placement of minimal amounts of
soil material over areas with any significant pooling. Dike maintenance, including monitoring
and regular grading of dike roads will proceed on a regular basis.
The implementation of the In-Place Vegetative/Soil Cover Alternative (RA-4) is expected to
affect approximately three acres of Lagoon 2A and approximately nine acres of Lagoon 2B.
Construction is expected to be complete in one season, while the development of a viable weed
mat would require several seasons.
VIII. STATUTORY DETERMINATIONS SUMMARY
1. Protection of Human Health and the Environment
The selected remedy protects human health and the environment by reducing the potential risks
associated with exposure to sludge constituents. The existing vegetative cover and the placement
of vegetative cover over areas of exposed sludge in sections of Lagoon 2A and applicable
portions of Lagoon 2B would reduce the potential for human exposure through dermal contact,
ingestion, and inhalation. The potential for wildlife exposure to lagoon sludge via food
consumption and direct sludge contact would be reduced from pre-remediation conditions by the
augmented vegetative cover. Long-term dike monitoring/maintenance activities will insure that
sludge continues to be adequately contained within the lagoons.
Short-term risks associated with the construction of the cap will be managed through the use of
good engineering practice and appropriate monitoring.
2. Attainment of ARARs
The selected remedy will be designed to meet all ARARs of Federal and more stringent state
environmental laws. The following discussion provides the details of the ARARs that will be
met by the selected alternative.
40
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Action-Specific ARARs:
Clean Water Act (CWA) of 1977, as amended [33 U.S.C. 1251)
40 CFR Part 122 and 40 CFR Part 125 - The National Pollutant Discharge Elimination
System (NPDES), which specifies the scope and details of the NPDES permit applications,
including limitations, standards, and other permit conditions which are applicable to all
permits including specified categories of NPDES permits. It also specifies schedules of
compliance and requirements for recording and reporting monitoring results.
40 CFR Part 403 - establishes responsibilities to implement National Pretreatment
standards to control pollutants which pass through or interfere with treatment processes in
POTWs or which may contaminate sewage sludge.
40 CFR Part 230 - provides guidelines to restore and maintain the chemical, physical, and
biological integrity of waters of the United States through the control of discharges of
dredged or filled material.
Occupational Safety and Health Act (OSHA)
40 CFR Part 1910 - Establishes requirements for worker health and safety.
Sewerage Sludge Use and Disposal Standards
40 CFR Part 503 - Establishes requirements for the final use and disposal of sewerage
sludge with less than 50 ppm PCBs.
Wisconsin Act NR 204, Municipal Sludge Management
Regulates land application of municipal sludge and overall sludge disposal. Establishes
standards and monitoring requirements for the use and disposal of municipal and domestic
wastewater sludge.
Location-Specific ARARs
Wisconsin Act NR 103, Water Quality Standards for Wisconsin
Establishes water quality standards for wetlands.
To Be Considered
Guidance on Remedial Actions for Superfund Sites With PCB Contamination,
OSWER Directive No. 9355.4-01, August 1990
n
41
-------
Presents guidance in selecting action/cleanup levels including TSCA PCB Spill Cleanup
policy.
3. Cost Effectiveness
The selected remedy provides the best balance of the nine criteria and overall cost effectiveness
of the protective remedies evaluated in the FS. Effectiveness is achieved by containment of the
sludge with PCB concentrations greater than SO ppm in Lagoon 2A and Lagoon 2B and
continuing monitoring and maintenance of dikes, and development and growth of the vegetative
cover. Permanence of the remedy is achieved by land-use restriction and continuing
maintenance within the area of activity of the MMSD plant and facility. The selected remedy
affords effectiveness and permanence at a cost which is proportional to the benefits achieved.
Cost of the selected remedy is at a minimum an order of magnitude below the cost of other
remedies described in the FS which offer marginal betterment.
4. Utilization of Permanent Solutions and Alternative Treatment Technologies or
Resource Recovery Technologies to the Maximum Extent Practicable
The selected remedy provides the best balance with respect to the nine evaluation criteria as
described hi Section VI of this ROD. The selected remedy uses permanent solutions and
alternative treatment technologies or resource recovery technologies to the maximum extent
practicable and provides the best balance of tradeoffs among alternatives in terms of the primary
balancing criteria. State and community support for the selected remedy contributes to this
balance of tradeoffs. Additionally when measured against costs of other remedies analyzed in
the FS, the selected remedy provides the best balance.
5. Preference for Treatment as a Principal Element
The selected remedy does not meet the preference for treatment as a principal element.
Opportunity for treatment is limited by the large volume of material with low levels of
contamination present on site. No "hot spots" have been identified which would lend themselves
to treatment. Cost for remedies, where treatment is a principal element, (which are similarly
effective) are less cost effective than the selected remedy. As discussed in Section VI and this
section the selected remedy is protective, ARAR compliant, effective, and cost effective.
42
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RESPONSIVENESS SUMMARY
MADISON METROPOLITAN SEWERAGE DISTRICT SITE
Overview
On November 19,1996, the United States Environmental Protection Agency (U.S. EPA)
proposed a remedial alternative which addressed contamination at the Madison Metropolitan
Sewerage District (MMSD) site, Dane County, Wisconsin. The alternative, as specified in the
proposed plan, called for construction of a vegetative cover system in lagoon areas not already
covered with naturally developing vegetative cover. The remedy was projected to be constructed
over one winter season to facilitate access to lagoon areas. In addition, the MMSD proposed
plan required long term monitoring and maintenance of the covered lagoon areas and the dikes
which enclose the areas in which contaminated sludge is located.
This Responsiveness summary addresses the concerns expressed by the public and the potentially
responsible parties in written and oral comments received by U.S. EPA on the proposed cleanup
plan for the MMSD site.
Summary of Comments Received During the Comment Period
Comments Which Support the Proposed Remedy
Oral comments received at the public meeting and written comments received during the 30 day
comment period which ended December 18,1996 strongly supported the proposed remedy for
the MMSD site. Favorable comments were received from a cross-section of the community
which is served by the MMSD wastewater treatment plant including local residents, business
owners, faculty of the University of Wisconsin, representatives of the Dane County Regional
Planning Commission, and administrators from the nearby communities of Deforest and
Fitchburg which are served by MMSD. The general view of these commenters is that the
proposed remedy is a cost-effective cleanup which is protective of human health and the
environment and among other things is consistent with the objectives and policies of the Dane
County Water Quality Plan, which is the area-wide water quality management plan for the
region.
Comments Which Support Other Alternatives
Comment: A commenter favored Alternative RA-8, TSCA Landfill Disposal. The commenter
favors the most costly alternative because it offers comprehensive protection of area wildlife and
human health and eliminates the need for restriction of land use. The commenter was also
concerned that RA-4, the proposed alternative, did not adequately consider the impact of
flooding and other catastrophic conditions and their effects on the movement of contaminants.
U.S. EPA Response: U.S. EPA evaluates all alternatives according to criteria established to
compare cleanup alternatives at Superfund sites. As a result of this analysis more than one
alternatives may meet the threshold requirements for protectiveness and compliance with
-------
applicable or relative and appropriate Federal and State requirements and may be equally
effective and implementable. In order to propose an appropriate remedy U.S. EPA must compare
the cost effectiveness of each of these alternatives.
Analysis of alternatives for the MMSD site indicates that several other alternatives, in addition to
the proposed alternative RA-4, meet the threshold requirements and are effective and
implementable. U.S. EPA has compared the costs of these alternatives. Although no more than
equally protective, estimated costs of other alternatives are from ten to one hundred times greater
than the cost of the proposed alternative. U.S. EPA has proposed Alternative RA-4 based on
analysis of its cost-effectiveness.
The proposed alternative provides monitoring and maintenance requirements to prevent release
of contaminants from the lagoon areas. These requirements include control of water levels in the
lagoon area to ensure the integrity of the vegetative cover and prevent release during periods
when local surface water levels may be high. Levels will be maintained by removal of excess
water and treatment at the MMSD facility.
-------
State of Wisconsin \ DEPARTMENT OF NATURAL RESOURCES
WISCONSIN
DEFT. OF NATURAL RESOURCES
Tommy G. Thompson. Governor
George E. Meyer, Secretary
Box 7921
1O1 South Webster Street
Madison, Wisconsin 53707-7921
TELEPHONE 608-266-2621
FAX 608-267-3579
TDD 608-267-6897
March 31,1997
IN REPLY REFER TO: MMSD-FID#113192970
Mr. Valdas V. Adamkus, Administrator
U.S. EPA Region 5
77 West Jackson Boulevard
Chicago, Illinois 60604
SUBJECT: Concurrence on Record of Decision, Madison Metropolitan Sewerage District
Lagoon Superfund Site, City of Madison, Dane County, Wisconsin
VeJL
Dear Mr. Adamkus:
This letter documents the States concurrence with the Record of Decision developed for the
Madison Metropolitan Sewerage District (MMSD) Lagoon Superfund Site by the Environmental
Protection Agency. The Department concurs with the conclusions reached with respect to the
environmental investigation conducted at the site, and with the results of the remedial option
selection process.
The remedial investigation conducted at MMSD determined that the contaminants of concern
have not adversely impacted groundwater, surface water or wetland soils at the site. Evaluation
often possible remedial options for the MMSD site resulted in the selection of the "In Place
Vegetative/Soil Cover" remedy. This remedial option involves the consolidation of all sludges
with polychlorinated biphenyl compound (PCB) concentrations greater than 50 parts per million
within existing berms and dikes, and the incorporation of a vegetated matt cover over their
surface. Maintenance, monitoring and supernatant removal will be conducted by the Madison
Metropolitan Sewerage District The estimated present worth cost of the remedy is $1,800,000.
Five years after the commencement of remedial action, a site review will be conducted to assure
that the selected remedy is protective of human health and the environment
Thank you for your efforts and cooperation in addressing the environmental contamination at the
MMSD superfund site. State staff will continue to work in close consultation with EPA staff
during the remedial design and construction phases of the remedy.
Quality Natural Resources Management
Through Excellent Customer Service
-------
Should you have any questions regarding this site please contact Joe Brusca, Air and Waste
Leader, in the South Central Region at (608)275-3296.
Sincerely,
George
Secretary
cc: Jay Hochmuth, AD/5
MarkGiesfeldt,RR/3
Dale Ziege, RR/3
Linda Meyer, AD/5
Ruthe Badger, SCR
Joe Brusca, SCR
-------
ADMINISTRATIVE RECORD INDEX
MADISON METROPOLITAN SEWERAGE DISTRICT SITE
DANE COUNTY, WISCONSIN
PAGES
3
g
29
48
123
IIS
24
23
2
18
1
95
3
3
96
96
40
37
8
DATE
1/28/87
4/1990'
11/13/86
9/24/92
1/1994
9/1996
9/1996
9/1996
7/27/9S
8/2/95
9/11/95
4/16/96
12/29/95
3/28/95
9/1992
4/1993
2/1992
11/27/96
11/1 8/96
TITLE
Federal HRS, MMSD
Sludge Lagoons
Response to Comments
HRS Scoring Package
Community Relations Han
MMSD Site, Dane Co. Wl
Administrative Order on
Consent re: Remedial
Investigation/Feasibility
Study and Design
Remedial invt Tf igilhvft
Report Vots.Uk Happen.
Feasibility Study Report
**-iiiii • • •• — •*•- p* i
rannan neaiui IUSK
Ecological Risk Assessment
Letter re: Sampling sludges
<50ppmPCB
Letter re: PCB Characterization
of Lagoon 2B
Letter re: approval sampling
in Lagoon 2B
Letter re: PCB Sampling in
Lagoon 2B
Letter re: halt usage of sludges
W/PCBconc. <50ppmin
Metrogrow
Letter re: Sludges w/PCB
concxSO ppm
Alternative Array fhmiimHI
Rl Phase D Field Sampling
Plan/QAPP/HeaMi and Safety
Plan
Gfomnlvater Chataclfriralion
Report
Transcript of Public Meeting
held 11/19/96
Proposed Plan
AUTHOR
M. Williams
USEPA
DaveCumock
USEPA
USEPA
Blasbnd,Bouck*Lee
Blastand, Bouck. ft Lee
P|«l>nH B^lrt f[ [ft
Blasland, Bouck & Lee
J.Cormell
D. Taylor. MMSD
J. Cornell, USEPA
D. Taylor, MMSD
A. Adamkus, USEPA
A. Adamkus, USEPA
Blasland, Bouck* Lee
Blasland, BoockJtLcc
Blasland. Bouck* Lee
T. Anderson, Verbatun
Reporting Service
USEPA
RECIPIENT
M.Giesfeldl
USEPA
USEPA
USEPA
USEPA
J. Nemke. MMSD
J. Connell, USEPA
D. Taylor. MMSD
USEPA
J. Nemke. MMSD
1. Nemke, MMSD
USEPA
USEPA
USEPA
USEPA
DOCTYPE
Correspondence
Correspondence
Other
Other
Pleadings/Orders
Reports/Studies
Report/Studies
Reports/Studies
pf[HffiVStudifi
' /*.,.,— .«..«,!«,.--
correspondence
\^UIIW«fMlMMrMhl&
Correspondence
Correspondence
Correspondence
Reports/Studies
Reports/Studies
Reports/Studies
Transcript
Fact Sheets
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