PB98-964108
EPA 541-R98-095
November 1998
EPA Superfund
Record of Decision:
Spickler Landfill OU 2
Spencer, WI
9/29/1998
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND~~LOCATION
Spickler Landfill
Spencer, Wisconsin
STATEMENT OF BASIS AND PURPOSE
This decision document' represents the selected remedial action
for Operable Unit (O.U.) #2 at the Spickler Landfill Superfund
Site (the "Site") in Spencer, Wisconsin, developed in accordance
with the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act of 1936 (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 Spickler Landfill site. Indexes attached to this
Record Of Decision (ROD) identify items that comprise the latest
updates to the Administrative Record upon which this ROD is
ba'sed.
DESCRIPTION OF SELECTED'REMEDY: NO ACTION
The United States Environmental Protection Agency (U.S.. EPA ) has
found that no further action is appropriate due to the
effectiveness of the remedial action for the first operable unit.
Proper closure of the landfills and mercury brine pit,
installation of a landfill gas collection and flare and leachate
collection systems and continued operation have eliminated the
primary human health risk posed by direct contact with
contaminated soils, eliminated the threat to the environment, and
mitigated the primary human health risk posed by contaminated
Site groundwater and landfill gas. The remedy established by
this ROD is the final Remedial Action for this Site.
STATUTORY DETERMINATIONS AND DECLARATION STATEMENT
Based on the information collected to date on site contamination,
associated risks to human health and the environment, and
considerations of state soil and groundwater standards, U.S. EPA
has determined no further action is necessary for O.U. #2. This
recommendation is based on the success of the O.U. #1 remedy in
eliminating threats associated with direct contact with
contaminated soils and containing shallow Site groundwater
through the leachate collection system. Because the primary
risks at the Site have been addressed by previous response
actions, this decision will not require additional remedial
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measures. The hazardous substances which remain on Site have
been addressed in the O.U.tfl ROD. This remedy will be considered
within the review conducted every fj.ve years for the previous
O.U. #1 Remedial Action, to assure that the remedies remain
protective of human health and the environment.
The U.S. EPA has determined that its response at this site is
complete. Therefore, the site now qualifies for inclusion on the
Construction Completion List.
The State of Wisconsin has indicated a willingness to concur with
the selected remedy described in this document. The state's
letter of concurrence will be added to the administrative record
upon receipt.
Date
William E. Muno, Director
Superfund Division
U.S. EPA - Region 5
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TABLE OF CONTENTS .
I. Site Location and Description 3
II. Site Enforcement Activities 3
III. Highlights of Community Participation 5
IV. Scope and Role of the Operable Unit 5
V. Summary of Site Risks 6
A. Contaminants of Concern 6
B. Risks Identified in O.U. #1 ROD 7
C. Risk Reduction through O.U.#1 Remedy 8
VI. Site Characteristics 9
A. Initial Site Conditions 9
3. Site Chronology of Remedial Actions to Date 10
C. Current Site Conditions 11
VII. The "No Further Action" Alternative 13
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LIST OF FIGURES. TABLES. AND APPENDICES
Figure Following Page
I Site Location / Site Map 3
Table
1 Summary of Chemicals of Potential Concern Identified
in O.U. #1 ROD 13
2 Summary of Site Risks as Identified in O.U. #1 ROD 13
3 Chronology of Site Events 13
4 Historical Summary of Leachate Production 13
Appendices
1 Responsiveness Summary . 14
2 Administrative Record
15
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I. SITE LOCATION. DESCRIPTION. AND HISTORY
The Spickler "Landfill is located in a sparsely populated, rural
area, at S-2550 Eckes Road in the Town of Spencer, Marathon
County, Wisconsin (see Figure 1). The Site is located on an
eighty acre parcel of land and consists of a ten acre landfill
with two fill areas (Old and New Fill areas), separated by a
crude oil pipeline right-of-way.
The Spickler Landfill was owned by Frederick Spickler and
operated by Spickler's Sanitation Service in 1970 as a municipal
open dump. The landfill accepted municipal and industrial wastes
from July 1970 to March 1974. In December 1970, BASF Wyandotte
received approval from the Wisconsin Department of Natural
Resources (WDNR) to construct an approximately 100 by 100 foot,
10 foot deep clay-lined sludge disposal area (the "mercury brine
pit") at the landfill. There were no construction records for
this disposal area and therefore no verification that the pit was
clay-lined as planned. The mercury brine pit was used from
January to April, 1971 and received mercury brine muds. The
mercury brine pit was closed with a clay cap in September 1971
and posted with monuments (concrete posts). Other industrial
wastes known to have been disposed in the Spickler Landfill
include kalo dust which contained asbestos, toluene, xylenes,
methyl-ethyl ketone, and methylene chloride.
There are two homes directly west cf the landfill, and additional
homes to the south and southwest of the landfill. Groundwater is
flowing to the northwest and could impact some residential wells
and the two homes to the south and southwest. Sampling of
residential wells was conducted during the remedial investigation
but no evidence of contamination was found. Surface water from
the Site originally drained along several unnamed intermittent
streams which flow north and northeast. The intermittent streams
subsequently flowed east and southeast approximately 1.5 miles to
the East Branch of the Yellow River.
The Site, as discussed in this document, consists of the Old and
New Fill areas, the mercury brine pit, and the groundwater
contamination plume.
II. SITE ENFORCEMENT ACTIVITIES
In August 1972, Carmen Way purchased the property from Frederick
Spickler, and the landfill was renamed Way's Sanitary Landfill.
Ways's Sanitary Landfill was licensed to accept solid wastes,
including industrial waste, with the exception of toxic and
hazardous materials. During 1973, numerous violations were noted
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01RCCTION
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by the WDNR at Way's Sanitary Landfill. Among these were failur"
to perform da_i~ly cover operations and ineffective drainage
control.
In late 1973, Lawrence Laddick and Vernon Verjinsky, owners of
Midstate Disposal, purchased Way's Sanitary Landfill. Midstate
Disposal operated the landfill until its closure in June 1975.
In March 1974, the WDNR ordered Midstate Disposal to terminate
operations and close the landfill. Between March, 1974 and
February, 1975, most closure and abandonment work was completed,
including placement, grading, and seeding of the landfill cover,
with the exception of the west slope of the New Fill Area
northeast of the pipeline right-of-way. In April, 1975,
Frederick Spickler re-purchased the land from Midstate Disposal.
In August, 1975, Kenneth Fuller purchased the property on land
contract from Frederick Spickler. In November, 1975, the land
contract was assigned to John Rooney.
On June 20, 1984, a Hazard Ranking System assessment was
conducted by the U.S. EPA. It was noted thot areas of leachate
seepage occurred on both the north and south faces of the New
Fill Area, and that the mercury brine pit had subsided and
appeared to be collecting surface water. Soil samples from
landfill seeps were found to contain traces of mercury and
groundwater samples contained both organic and inorganic
contaminants. In July 1987, the Spickler Landfill was placed on
•the National Priorities List (NPL).
The Record of Decision (ROD) for the first operable unit was
signed by U.S. EPA on June 3, 1992. The ROD addressed the
closure and capping of the mercury brine pit and landfills,
landfill gas control, leachate extraction and treatment, and
groundwater monitoring. The second operable unit as described in
that ROD would consist of a final remedy decision for
groundwater.
BASF Corp. and Weyerhaeuser Co. signed an Administrative Order by
Consent to conduct the Remedial Investigation and Feasibility
Study (RI/FS). The order became effective on July 16, 1988. An
Administrative Order on Consent for Remedial Design was issued by
the U.S. EPA on September 30, 1993. On January 25, 1994, U.S.
EPA issued a Unilateral Administrative Order directing the
potential responsible parties to implement the Remedial Action
described in the O.U. #1 ROD. Construction of the remedy started
in April 1994 and was completed in August 1995.
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Ill. HIGHLIGHTS OF COMMUNITY PARTICIPATION
A Community Relations Plan for the Spickler Landfill Site was
finalized in 1989. This document lists contacts and interested
parties throughout government and the local community. It also
establishes communication pathways to ensure timely dissemination
of certinent information. The public comment period for the
O.U. til ROD occurred from December 9, 1991 to February 10, 1992
and the ROD was issued on June 3, 1992.
A Proposed Plan Fact Sheet outlining the no action remedy for
O.U. #2 was made available to the community on August 6, 1998,
and a public comment period occurred from August 6 to September
5, 1998. A public meeting to discuss the Proposed Plan Fact
Sheet was not requested. All comments which were received by
U.S. EPA prior to the end of the public comment period are
addressed in the Responsiveness Summary.
All Site documents have been made available in both the
Administrative Record (located at the Records Center, 77 W.
Jackson Blvd., 7th Floor, Chicago, Illinois 60604), and an
information repository, maintained at the Spencer Village Hall. .
IV. SCOPE AND ROLE OF OPERABLE UNIT
The O.U. #1 ROD, signed on June 3, 1992, required upgrade of the
landfill cap to standards dictated by Chapter MR 504 of the
Wisconsin Administrative Code (WAC) and the cap over the mercury
br:ne pit to NR 660 WAC standards. The O.U. #1 ROD also required
installation of leachate and landfill gas collection systems,
installation of a landfill gas flare, and long term groundwater
monitoring.
The O.U. #1 ROD reserved O.U. #2 for the possibility of Site
groundwater restoration through a more active means, such as
pumping and treating. U.S. EPA has determined no further action
is necessary for O.U. #2 because of the success of the O.U. #1
remedy in reducing threats associated with direct contact with
contaminated soils and containment of'shallow Site groundwater
through the leachate collection system.
This decision is based on an analysis of Site conditions and the
associated risks (described in detail below), the successful
construction and operation of the O.U. #1 remedy, and the
demonstration by long term groundwater monitoring that
contamination associated with leachate migrating into the
groundwater aquifer at the Site has been eliminated by placement
of a leachate collection system after completion of trhe O.U. 81
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remedy. The continued success of this decision relies on
implementation- of the land use- restrictions as described in the
ROD for OU #1~T
Because hazardous substances will remain at the Site, U.S. EPA
will conduct a five-year review under the requirements of the
O.U. #1 remedy in accordance with Section 121 of the CERCLA to
assess whether any other response is necessary.
V^ SUMMARY OF SITE RISKS
A Baseline Risk Assessment (BRA) was conducted for the Site and
is presented in documents contained in the Administrative Record.
The O.U. #1 remedy addressed threats to human health and the
environment from future exposure to seep sediments and future use
of the contaminated groundwater. Potential risk associated with
future use of groundwater was estimated in the 1991 Risk
Assessment using the maximum concentrations of contaminants
detected in monitoring '..'^lls at and do.wngradient of the Site, to
estimate exposure point concentrations. It was assumed that
individuals were exposed to chemicals of potential concern in
water daily for 3C years, and that exposure occurred as a result
of groundwater ingestion, as well as dermal contact and
inhalation while bathing. Based on analytical results, private
drinking water downgradient of the Site did not appear to be
affected by the landfill; therefore, this medium was not
considered a source of chemical exposure under initial Site
conditions.
A. Contaminants of Concern
The majority of the total noncancer health risk was associated
with the potential exposure to Arsenic, Barium, Lead, Manganese,
and Nitrites detected in groundwater. The majority of the cancer
risk associated with potential groundwater exposure was due to
Vinyl Chloride and Arsenic. Table 1 summarizes the chemicals of
potential concern identified in the O.U. #1 ROD and provides
their current status. As shown, thirty-one of the original
forty-seven contaminants were not consistently detected during
the design, construction, or operation of the O.U. #1 remedy and
thus no longer pose any threat.
Elevated concentrations of vinyl chloride and trichloromethane at
one location at the up gradient edge of the landfill are still a
concern. Inefficiencies in the leachate collection system may
have decreased the system's ability to collect leachate. In the
spring of 1996 the leachate collection system was modified to
more effectively capture leachate, which significantly increased
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the amount of leachate collected. The latest groundwater data
shows a reduction in concentration for vinyl chloride and
t r ichlorometh~ane, which seems to show modifications to the
leachate collection system were successful in improving leachate
collection. Continued monitoring of leachate and groundwater is
required to more adequately evaluate the effectiveness of the
collection system in capturing leachate.
B. Risks Identified in O.U. #1 ROD
Table 2 summarizes the risks associated with Site conditions at
the time of the O.U. #1 ROD. When the Hazard Index (HI) is
greater than I, there is a potential for health problems such as
damage to vital organs, birth defects, and anemia and other blood
disorders. A IxlO"6 cancer risk value corresponds to a 1 in
1,000,000 chance that an individual develops cancer as a result
of exposure to these concentrations of contaminants over a period
of '70 years. Similarly, 10"s corresponds to a 1 in 100,000
chance, 1x10"', 1 in 10,000, and so on. Current environmental
policy allows U.S. EPA to perform a Remedial Action if an HI is
1.0 or above or if cancer risks exceed 1x10"".
Site conditions at the time of the O.U. #1 ROD were used to •
calculate risk values associated with exposure to:
(1) contaminants in soil adjacent to former waste disposal
areas;
:2' contaminants in water that accumulates on Site from
precipitation and meltage; and
(3) contaminants in sediments associated with both accumulated
surface water and seepage (leachate) from disposal areas.
Risk calculated at the time of the O.U. #1 ROD qualitatively
considered contaminants introduced into air through landfill gas,
and contaminants introduced \nto air from disturbance of
contaminated soil. The installation of landfill gas collection
and flare system and the construction of the upgraded caps have
eliminated the potential for this type of exposure. As
previously noted, private drinking water downgradient of the Site
did not .appear to be affected by the landfill; therefore, this
medium was not considered a source of chemical exposure under
Site conditions at the time of the O.U. #1 ROD.
Table 2 also shows the risk to any individual who would use the
Site for a residence. In addition to the 3 exposure scenarios
listed previously, risks attributable to Site soil and the use of
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Site groundwater were calculated. As shown, the greatest risks
associated witti the Site are to a future residential Site user
that uses Sit"e~ groundwater which contains a lifetime cancer risk
of 3.0xlCT3 and a Hazard Index of 30. The majority of the total
non-cancer health risk due to groundwater ingestion was
associated with potential exposure to Arsenic, Barium, Lead,
Man«ganese, and Nitrites detected in groundwater. The majority
of cancer risk associated with potential groundwater exposure was
due to Vinyl Chloride and Arsenic.
Through the implementation and operation and maintenance of the
remedy implemented for O.U. #1 (which includes groundwater /
lecchate containment, institutional controls, and groundwater
monitoring) these risks are being mitigated, making the
requirement for an O.U. #2 active groundwater restoration remedy
unnecessary. In addition, installation of improved landfill caps
and the associated grading of cap soils has eliminated improper
surface accumulation of precipitation and meltage.
As documented in the O.U. #1 ROD, there were no threatened or
endangered species or critical habitats in the vicinity of the
Site. The landfill or hazardous components of the fill had no
discernible impact on the ecology in the immediate vicinity of
the Site. There are no areas of stressed vegetation.
C. Risk Reduction Through OU#1 Remedy
As previously mentioned, all risks associated with direct contact
with Site soil have been eliminated. Based on information
collected to date on Site groundwater contamination and the
associated risks to human health and environment, U.S. EPA
believes that it is unnecessary to require an active groundwater
restoration remedy as operable unit #2, mentioned in the O.U. #1
ROD. Groundwater contamination which exists primarily under the
landfill is contained on site and poses no significant risk under
the current land use-. With appropriate restrictions on access
and construction on the Site, groundwater contamination will pose
no significant risk.
Although current Site zoning by the Town of Spencer does not
prohibit residential future land use, protection against
inappropriate land use will be put in place in the form of
restrictive covenants pursuant to the O.U. #1 remedy.
Specifically, to enhance the likelihood and insure that future
land use of the Site remains appropriate considering the Site
contaminants, appropriate deed restrictions will be recorded on
the title to the real estate on which the Site is located.
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The scope of the O.U. #1 remedy requires long term commitments,
and, except for any contingent additional response action for
O.U. Sf 1, no further remedial action is necessary for this Site.
The continued effectiveness of the O.U. #1 remedy in protecting
human health and the environment wil^. be confirmed through the
five year remedy review process. If it is determined that the
'-.'.'. f 1 remedy becomes ineffective, -any contingent additional
response action will be performed within the scope of that
remedy.
VI. SITE CHARACTERISTICS
A. SITE CONDITIONS
Prior to implementation of the O.U. #1 remedy and landfill cap
upgrade, most of the surface water runoff from the Site appeared
to flow northwest through a culvert under Eckes Road and into a
wetland area approximately 15 acres in size. Based on
observations made of this area, there is not sustained flow
through this wetland throughout the year; only for a limited
duration after runoff events (e.g., precipitation events and
spring melt). Final surface grades of the upgraded landfill caps
now control Surface water run-off such that there is no sustained
flow anywhere on the Site that may present wetland
considerations.
Groundwater flow is to the north, northwest, and somewhat to the
west. At the northwest corner of the Site,' depth to groundwater
in the area of the landfill is less than five feet below the
original Site grade, before installation of the upgraded landfill
cap. As demonstrated by documents contained in the
Administrative Record, leachate collection piping was installed
at a level close to the natural level of groundwater. This in
effect prevents groundwater from leaving the Site.
The following conditions were documented in the O.U. #1 ROD:
Depth to groundwater in the northwest area of the landfill
was less than five feet.
Explosive levels of combustible landfill gas were detected
in several new monitoring wells, an existing well, and in
three permanent gas probes on the west and north perimeters
of the Old Fill area.
The existing landfill cover did not meet the WDNR's clay
capping thickness requirements.
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Asbestos was confirmed to be present in a landfill cover
soi1 sample.
There was a significant amount of leachate production and
build-up. The refuse was sitting in leachate (saturated)
which had collected on top of an impermeable clay layer in
most areas of the landfill.
Leachate samples from the mercury brine pit contained
elevated levels of calcium, magnesium, mercury and nine
organic compounds.
Groundwater samples from monitoring wells showed exceedances
of Maximum Contaminant Levels (MCLs) for the following
chemicals: benzene, vinyl chloride, barium, copper, iron
and manganese. 'Mercury was detected in the groundwater
samples during the RI.
Eight private wells near the Site were sampled. One well
exceeded the Wisconsin Drinking Water Standard for
manganese, one well exceeded for lead, one well exceeded for
iron, and one well exceeded for copper. The standards for
these inorganics are based on taste and odor considerations
and not on health considerations. One well slightly
exceeded the Wisconsin Drinking Water standard for chromium.
Contamination in these private wells does not appear to be
Site related based on the presence of these contaminants
either in background samples that were taken or determined
to be related to the well construction and piping.
Surface water samples on Site exceeded the Ambient Water
Quality Criteria (AWQC) for manganese.
The O.U. ttl remedy was designed and constructed to address these
- :• n o : V i o n s .
B. SITE CHRONOLOGY OF REMEDIAL ACTIONS TO DATE
The completed cleanup action for the first operable unit
included:
Capping the landfill areas with a clay cap which meets the
requirements of NR 504 WAC.
Active landfill gas control system consisting of gas
collection piping and an intermittent flare which operates
only if gas accumulates to high enough levels.
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Leachate collection and transfer of accumulated leachate for
off-Site -treatment.
Treatability tests for stabilization/solidification of
the contents of the mercury brine pit which proved that
stabilization or solidification was not necessary.
Capping of the mercury brine pit with a clay cap which meets
the requirements of NR 660 WAC.
Monitoring of contaminated groundwater in the vicinity of
the Site, including a long term groundwater monitoring data.
Operation and maintenance of the landfill gas and leachate
collection systems.
Construction Quality Assurance procedures as recommended by the
appropriate U.S. EtA guidance was followed for each design and
construction phase. Construction of the remedy for O.U. #1 was
completed in October 1994 and declared Operational and Functional
by the U.S. EPA in September 1995. Table 3 is a chronology of
Site events to date including design and construction milestones
for the O.U.* #1 remedy. The Administrative Record for the Si-te
has been updated to include documents certifying each of these
milestones.
C. CURRENT SITE CONDITIONS
This ROD is for OU 12 and is the final remedy decision for the
Site. OU SI has eliminated risks through capping of the
landfills with a NR 504 cap, capping the mercury brine pit with a
NR 660 cap, active landfill gas control, and leachate collection.
The NR 504 cap provides protection against direct contact with
contaminated soils and has reduced infiltration of precipitation.
The NR 660 cap on the mercury brine pit has eliminated
infiltration into the pit insuring leachate will not be generated
and enter the groundwater.
The leachate collection system was modified in the spring of 1996
to improve its. efficiency. Since then the leachate collection
has increased significantly. Table 4 shows the leachate
generation at the site for the last 3.5 years.
The active gas control has insured that nearby buildings are
protected from the possibility of landfill gas migrating to
basements with potential for an explosion. Based on an analysis
of ten rounds of groundwater monitoring results from wells
adjacent to and on Site, the groundwater contamination has not
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been detected off-Site. Groundwater contamination on-site has
been intercepted by the leachate collection system. The
groundwater contamination that exists beyond the collection
system is currently not exceeding any groundwater water quality
standards.
The risks associated with future use of the contaminated
groundwater are addressed in this ROD. Groundwater has been
collected at the Site and analyzed throughout the design and
construction of the O.U. #1 reraedy. Following construction
completion and declaration of operational and functional in March
1996 samples have been collected on a semi-annual basis. Table 1
summarizes the maximum contaminant concentrations discovered in
groundwater before and after completion of the O.U. #1 remedy.
Vinyl Chloride concentrations have been discovered at levels
above the State of Wisconsin NR 140 Enforcement Standard (ES)
acceptable limits for several rounds of sampling at monitoring
locations at the edge of the landfill and a few hundred feet
downgradient. Although concentrations under the landfill exceed
MCLs, concentrations above MCLs have not been detected outside of
the waste boundary. Concentrations detected downgradient of the
landfill do not currently exceed MCLs.
The compound (cis) 1,2 - Dichloroethene has been above the PAL
for only one sampling location directly at the Mercury brine pit
area. 1,2 - Dichloroethane has been shown to be above^State of
Wisconsin Preventive Action Limits (PALs), but below Enforcement
Standards (ES) and MCLs. For several isolated sampling rounds,
Benzene has been shown to be slightly above PAL but below ES
standards and MCLs.
Trichloroethene and Methylene Chloride have been shown to be
consistently slightly above the PAL but below the ES and MCLs.
In the RI, Xylene was documented in exceedance of the ES but
during the long term monitoring has been only above the PAL.
Toluene has consistently been below both the PAL and ES. Xylene
and Toluene have only been detected in groundwater under the
landfill.
Iron and Manganese have been shown to exceed State limits, but
have been shown to remain on-Site for the 10 rounds cited.
Because these exceedances occur on Site only, are not detected
off Site, and are at relatively consistent levels there is no
need for implementation of an active pump and treat remedy
provided O.U. #1 operation and maintenance continues. Further,
groundwater flow patterns run to the north, northwest, and west,
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and the maximum concentrations are upgradient. Down- gradient
wells are an indicator as to whether any contaminant could
threaten any off-Site location.
However, it is because of these contaminant detections that long
term monitoring for the O.U. #1 remedy must continue to ensure
groundwater contamination remains on site and does not pose a
threat to off site users. If it is later determined through the
5 year review process that the O.U. #1 remedy is no longer being
protective, U.S. EPA may require contingent remedial actions to
occur to address unacceptable conditions. The review is
scheduled for completion in 1999.
VII. The "No Further Action" Alternative
As previously mentioned, all risks associated with direct contact
with Site soil have been eliminated. Based on information
collected to date on Site groundwater. contamination and the
associated risks to human health and environment, U.S. EPA
believes that it is unnecessary to require an active groundwater
restoration remedy as operable unit #2, mentioned in the O.U. #1
ROD. Groundwater contamination at the landfill .poses no
significant risk under the current land use. With appropriate
restrictions on access and construction on the Site, groundwater
contamination will pose no significant risk.
Although current Site zoning by the Town of.Spencer does not
prohibit residential future land use, protection against
inappropriate land use will be put in place in the form of
restrictive covenants pursuant to the O.U. #1 remedy.
Specifically, to enhance the likelihood and insure that future
land use of the Site remains appropriate considering the Site
contaminants, appropriate deed restrictions will be recorded on
the title to the real estate on which the Site is located.
The scope of the O.U. #1 remedy requires long term commitments,
and, except for any contingent additional response action for
O.U. #1, no further remedial action is necessary for this Site.
The continued effectiveness of the O.U. #1 remedy in protecting
human health and the environment will be confirmed through the
five year remedy review process which is scheduled for 1999. If
it is determined that the O.U. #1 remedy becomes ineffective, any
contingent additional response action will be performed within
the scope of that remedy.
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TABLE 1 - CHEMICALS OF POTENTIAL CONCERN IDEJNTIFIED1NO.U. #1 ROD
Contaminant Identified in
O.U. #1 ROD
Acetone
Benzene
2-Butanone
Chlorobenzene
Chloroform
1,1-Dichloroethane
1 ,2-Dichloroethene (trans)
Ethylbenzene
2-Hexanone
Methylene Chloride
4-Methy 1-2-Pentanone
Tetrachloroethene
1,1,1- Trichloroethane
Trichloroethene
Toluene
Styrene
PAL / ES
(ppb)
200/1000
0.5/5
5/90
20/200
0.6/6
85/850
20/100
140/700
-
0.5/5
50/500
0.5/5
40/200
0.5/5
68.6/343
10/100
Maximum
Concentration
Detected
Before LTM
120
8(J)
70
0.8 (T,J)
0.9 (J)
8
2
270(F,B,D)
1(J)
88 (U)
13
0.7 (J)
1(J)
3(J)
14
12
Maximum
Concentration
Detected in
(3/98)SamDline
11
3
5
5(U)
2
7
5(U)
5
25 (U)
9
25 (U)
2
5(U)
8
1
5(U)
Location of
Maximum
Concentration in
G/98) Samoline
MW-13S
MW-13&6S
MW-FB01
MW-S1AR
MW-S1AR
MW-S3AR
MW-S1AR
MW-S3&13S
MW-S1AR
MW-FB02
MW-S1AR
MW-S1AR
MW-S1AR
MW-S1AR
MW-13S&S1AR
MW-S1AR
Conclusions
Continue Monitoring
Continue Monitoring
Continue Monitoring
Continue Monitoring
Continue Monitoring
Continue Monitoring
Continue Monitoring
Continue Monitoring
Continue Monitoring
Continue Monitoring
Continue Monitoring
Continue Monitoring
Continue Monitoring
Continue Monitoring
Continue Monitoring
Continue Monitoring
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Vinyl Chloride
Xylenes (total)
Benzoic Acid
bis (2-Ethylhexyl)
phthalate
4-chloro-3-methylphenol
1 ,4-Dichlorobenzene
Diethylphthalate
2,4-Dimethylphenol
Di-n-Butylphthalate
4-Methylphenol
Y-BHC
Asbestos
Aluminum
Arsenic
Barium
Beryllium
0.02/0.2
124/620
—
0.6/6
-
15/75
-
-
-
-
-
0.7/7 MFL
--
5/50
400/2000
0.4/4
3
2700 (D)
35
900 (B)
34
3
9(J)
20
16
12
No Hits
No Hits
900
88.4
4860
0.72
41 (E)
36
NOT TESTED
NOT TESTED
NOT TESTED
NOT TESTED
NOT TESTED
NOT TESTED
NOT TESTED
NOT TESTED
NOT TESTED
NOT TESTED
NOT TESTED
2.4 (B)
729
NOT TESTED
MW-S1AR
MW-13S
Continue Monitoring
Continue Monitoring
Concentration below level of concern.
No consist detection; monitoring dropped
Concentration below level of concern.
NA
NA
Below PAL/ES
Lab Contaminant.
Concentration below level o; concern.
NA
Lab Contaminant.
Concentration below level of concern.
Not detected in RI; monitoring dropped.
Not detected in RI; monitoring dropped.
No consist detection; monitoring dropped
MW-11S
MW-S2
Continue Monitoring
Continue Monitoring
No consist detection; monitoring dropped
-------
Cadmium
Chromium (III)
Cobalt
Copper
Iron
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Sodium
Vanadium
Zinc
Cyanide
0.5/5
10/100
—
130/1300
150/300
1.5/15
25/50
0.2/2
20/100
10/50
10/50
—
—
2500/5000
40/200
4.1 (B)
11.7
107
30.3
82300
28.3
30,200
.92
473
No Hits
8.6 (B)
195,000
17.2(B)
142
69
NOT TESTED
4(B)
NOT TESTED
NOT TESTED
28,900
5.4
7,270
0.10(U)
NOT TESTED
NOT TESTED
NOT TESTED
NOT TESTED
NOT TESTED
NOT TESTED
NOT TESTED
No consist detection; monitoring dropped
MW-11S
Continue Monitoring
No consist detection; monitoring dropped
Below PAL/ES; monitoring dropped.
MW-11S
MW-S2
MW-S1AR
Most Wells
Continue Monitoring
Continue Monitoring
Continue Monitoring
Continue Monitoring
No consist detection; monitoring dropped
Not detected in RI; monitoring dropped.
No consist detection; monitoring dropped
Naturally occurring in area mineralogy.
No consist detection; monitoring dropped
Below PAL/ES; monitoring dropped.
Below PAL/ES; monitoring dropped.
LEGEND: B = Analyte detected, but below contract required detection limit.
J = compound detected, but below contract required quantitation limit.
D = Diluted sample
N = Below QC limit.
E = Estimated value, parameter detected below contract required detection limit.
U = Compound not detected above concentration listed.
F = Also detected in associated blank.
X = Total xylene
-------
TABLE 2 - SUMMARY OF SITE RISKS AT TIME OF OtLtflROD
CONTAMINANT SOURCE '
Borrow Pit Surface Water
Borrow Pit Sediment
Borrow Pit Seepage (Leachate)
Sediment
Surface Soil
TOTAL RISK FOR
TRESSPASSERS OF SITE AT
TIMP nr o n ai ROD
CONTAMINANT SOURCE '
Borrow Pit Surface Water
Borrow Pit Sediment
Borrow Pit Seepage Sediment
Subsurface Soils at Site
Groundwater
TOTAL RISK FOR
INDIVIDUALS RESIDING ON
SITE
SITE TRESSPASSERS II-
HI
7.00e-04
5.GOe-03
3.00e-01
9.00e-03
3.15e-01
JCLUDING CHILDREN
CANCER RISK
6.00e-08
3.00e-09
l.OOe-06
6.00e-09
1.07e-06
INDIVIDUAL RESIDENTIAL SITE USERS
HI
4.00e-03
2.00e-02
2.00e+00
2.00e-02
3.00e+01
3.20e+01
CANCER RISK
3.00e-07
2.00e-08
5.00e-06
4.00e-08
3:00e-03
3.01e-03
FOOTNOTES FOR TABLE 2
1 Borrow Pit Surface Water water which may collect from precipitation and/or meltage in any excavated
areas adjacent to areas of known waste disposal
Borrow Pit Sediment is sediment within collected precipitation in any excavated area adjacent to areas of known
waste disposal
Borrow Pit Seepage Sediment is sediment which may collect in areas containing seepage (leachate) from areas of
known waste disposal.
-------
TABLE 3 - SPICKLER LANDFILL CHRONOLOGY OF SITE EVENTS
June, 1984
July, 1987
July, 1988
June, 1992
June 2, 1992
Aug., 1992
Sept., 1992
Dec., 1993
Feb., 1994
March, 1994
April, 1994
Oct. 7, 1994
Hazard Ranking System (HRS)
assessment conducted by U.S.
EPA.
Spickler Landfill site
included on the National
Priorities List (NPL) .
Administrative Order on
Consent (AOC) for the Remedial
Investigation/ Feasibility
Study (RI/FS) signed by
Potentially Responsible
Parties (PRPs) and U.S. EPA.
RI/FS started by PRP
consultant .
RI/FS completed.
OU #1 ROD signed by U.S. EPA
Regional Administrator.
AOC for the Remedial Design
(RD) signed by PRPs and U.S.
EPA.
Remedial Design (RD)' started
by PRP consultant.
RD completed.
Unilateral Administrative
Order (UAO) issued to PRPs for
Remedial Action (RA) .
Construction contract awarded
by PRPs.
PRP consultant and
construction contractor
mobilized on Site. RA
started.
PRP consultant (engineer)
certifies physical
construction as complete.
-------
Dec. 19, 1994
March, 1995
June 5, 1995
Sept. 28, 1995
Mar. 1996
Sept 1996
Mar. 1997
Sept 1997
Mar. 1998
Apr 1998
Apr 1998
U.S. EPA Site visit1 to confirm
completion of physical
construction. Items to be
completed by PRP consultant
consist mainly of Site
documentation such as As Built
Drawings, Long Term Monitoring
Plan and QAPP Addendum, O&M
Plan, and Construction
Completion Report.
PRP consultant submits Draft
Site documentation in response
to Agencies' "items to be
completed" .
U.S. EPA provides comments on
draft documentation.
U.S. EPA and WDNR approve RA
documentation and declare OU
#1 remedy operational and
functional .
1st Round LTGWM
2nd Round LTGWM
3rd Round LTGWM
4th Round LTGWM
5th Round LTGWM
O.U. #2 Proposed Plan to
Public
Public Meeting
Because WDNR visited the Site regularly, they did not
attend this walk-through.
-------
Table 4 - Leachate Production
Month
January
February
March
April
May
June
July
August
September
October
November
December
Total/Year
Total/Month
Total/Week
1994
--
--
--
--
--
1728
49688
134500
139400
71200
36000
57600
490, 116
70,017
17,504
1995
38400
12800
25200
24800
44800
43400
6200
6200
18600
6200
24800
49600
301,000
25,083
5,788
1996
12400
0
0
0
12400
43400
173600
111600
53600
31000
12400
37200
487,600
40,633
9,377
1997
37200
37200
18600
18600
173600
117800
155200
117800
117800
130200
117800
86800
1,128, 600
94,050
21,704
-------
RESPONSIVENESS SUMMARY
This Responsiveness Summary has been prepared to meet the
requirements of Section 113{k)(2)(B)(iv) and 117(b)of the
Comprehensive Environmental Response, Compensation , and
Liability Act of 1980 (CERCLA), as amended by Superfund
Amendments and Reauthorization Act of 1986 (SARA), which requires
the U.S. EPA to respond to "...to each of the significant
comments, criticisms, and new data submitted in written or oral
presentations" on a proposed plan for remedial action. The
Responsiveness Summary addresses concerns expressed by the
public, potentially responsible parties (PRPs), and governmental
bodies in the written and oral comments received by the U.S. EPA
and State regarding the proposed remedy for the Spickler Landfill
Superfund site.
A. Overview
The selected remedial action for Operable Unit #2 (OU2) at the
Spickler Landfill Superfund is no further action. More detailed
information on the no further action alternative is available in
these documents. The documents are available in the information
repository and administrative record for the site at the Spencer
Village Hall.
B. Background on Community Involvement
The Remedial Investigation (RI) report, Feasibility Study (FS)
report and the Proposed Plan for the Spickler Landfill site were
released to the public for comment on December 9, 1991. These
documents were made available to the public in both the
administrative record file and the information repository
maintained at the U.S. EPA offices in Region V and at Spencer
Village Hall. The notice of availability for these documents was
published in the Marshfield Herald on December 4, 1991. A public
comment period was open from December 9, 1991 through February
10, 1992. The public was afforded the opportunity to request a
public meeting but no requests for a public meeting were
received. Based in part on comments the agency received during
the comment period U.S. EPA determined an operable unit approach
was more appropriate for this site than one final remedy. The
Proposed Plan for OU2 was released to the public for comment on
August 6, 1998. A public comment period was open from August 6,
1998 to September 5, 1998. The public was afforded the
opportunity to request a public meeting, but no requests for a
public meeting were received. No comments were received during
the public comment period.
-------
A*.
0.S. ENVIRONMENTAL PROTECTION AGENCY
REMEDIAL ACTION
ADMINISTRATIVE RECORD
FOR
SPICKLBR LANDFILL SITE
TOWN OF SPENCER, MARATHON COONTY, WISCONSIN
UPDATE #3
OPERABLE UNIT #2
APRIL 28, 1998
NO. DATE
r
1 1992-1996
2 02/05/92
AUTHOR
STS
Consultants,
Ltd.
Reiner, E.
U.S. EPA
RECIPIENT
U.S. EPA
3 06/02/92
U.S. EPA
Hunt, S.,
STS
Consultants,
Inc.
Public
TITLE/DESCRIPTION PAGES
Progress Reports #1-32 536
(September 1992 - April
1996) for the Spickler
Landfill Site
Letter re: U.S. EPA/ 1
WDNR's Approval of the
Final Leachate Removal
Work Plan for the
Spickler Landfill Site
Record of Decision and 65
Responsiveness Summary
for Operable Unit #1 at
the Spickler Landfill
Site
4 1993-1994
STS
Consultants,
Ltd.
U.S. EPA
Technical Memoranda Nos. 1076
1,3,4 and 6: Rounds 1-4
Quarterly Groundwater
MoniCoring Results for
the Spickler Landfill
Site
5 1993-1994
STS
Consultants,
Ltd.
U.S. EPA
6 02/26/93
7 03/02/93
STS
Consultants,
Ltd.
STS
Consultants,
Ltd.
U.S. EPA
U.S. EPA
Technical Memoranda Nos.
2 and 5: Rounds 2-3
Quarterly Leachate
Moni toring Reports for
the Spickler Landfill
Site
Leachate Removal Work
Plan for the Spickler
Landfill Site
Remedial Design Work
Plan for the Spickler
Landfill Site
154
154
-------
HO. DATE
8 03/11/93
AUTHOR
Reiner, E.
U.S. EPA
OV22/93
Rose, C.,
U.S. EPA
RECIPIENT
Hunt, S.,
STS
Consultants,
Inc.
Mayka, J. ,
U.S. EPA
10 08/16/93 STS
Consultants,
Ltd.
U.S. EPA
11
12
08/27/93
09/03/93
STS
Consultants,
Ltd.
Reiner, E.,
U.S. EPA
U.S. EPA
Ryan, T.,
STS
Consultants,
Ltd.
13 11/17/93 STS
Consultants,
Ltd.
U.S. EPA
14
11/17/93
15
11/17/93
STS
Consultants,
Ltd.
STS
Consultants,
Ltd.
U.S. EPA
U.S. EPA
Spickler Landfill AR
Update #3
Page 2
TITLB/DBSCRIPTION PAGES
Letter re: U.S. EPA/ 1
WDNR's Approval of the
March 1993 Remedial
Design Work Plan for
the Spickler Landfill
Site
Memorandum re: U.S. EPA 2
Final Approval of the
Conditionally Approved
First Revision of the
Quality Assurance Project
Plan for the PRP-Lead
Remedial Design Interim
Monitoring Activities
at the Spickler Landfill
Site
Final Leachate .Removal 163
Technical Specifications
for the Spickler Landfill
Site
Final Design Report for 348
the Leachate Removal
System at the Spickler.
Landfill Site
Letter re: U.S. EPA/ l
WDNR's Approval of the
Final Leachate Removal
Design Report, Drawings,
Specifications and
Operation and Mainten-
ance Addendum for the
Spickler Landfill Site
Final Construction 50
Quality Assurance Plan
for the Spickler Landfill
Site
Final Remedial Design 117
Technical _Specifications
(Capping) for the
Spickler Landfill Site
Final Remedial Design 160
Report (Capping)for the
Spickler Landfill site
-------
NO. DATS
16 12/09/93
AUTHOR
White, E.,
Ecology and
Environment,
Inc.
RECIPIENT
Reiner, E.,
U.S. EPA
Spiclcler Landfill AR
Update #3
Page 3
TITLE/DESCRIPTION PAGES
Letter re: E&E's Review 3
Comments on the Final
Design Documents for
the Spickler Landfill
Site
17
12/20/93
18
02/22/94
Reiner, E.,
U.S. EPA
White, E.,
Ecology and
Environment,
Inc.
Huibregtse,
K., STS
Consultants,
Ltd.
Fagiolo, J.,
U.S. EPA
Letter re: U.S. EPA/
WDNR's Approval of the
100* Remedial Design
Submittal (Final RD
Report, Final RD Tech-
nical Specifications,
Final RD Plans, Final
CQA Plan, Final Construc-
tion Cost Estimate) and
Review Comments on the
Draft Operations and
Maintenance Plan for the
Spickler Landfill Site
Letter re: E&E's Review
and Data Validation for
Technical Memorandum
No. 3 for the Spickler
Landfill Site
27
19
12/09/94
Pachowicz, T.
Ecology and
Environment,
Inc.
Fagiolo, J.,
U.S. EPA
Letter re: E&E's Review
Comments on the Draft
Remedial Action Work
Plan for the Spickler
Landfill Site
20
12/12/94
21
22
05/15/95
06/05/95
Fagiolo, J.,
U.S. EPA
STS
Consultants,
Ltd.
Fagiolo, J.,
U.S. EPA
Johnson, L.,
STS
Consultants,
Inc.
U.S. EPA
Johnson, L.,
STS
Consultants,
Ltd.
Letter re: U.S. EPA's
Conditional Approval of
the March 1994 Remedial
Action Work Plan for the
Spickler Landfill Site
Drawings: As-Builts for
the Spickler Landfill
Site
Letter re: U.S. EPA's
Conditional Approval of
the As-Built Drawings,
Construction Completion
Report, Long Term Ground-
water Monitoring Plan
and Operations and
Maintenance Plan for the
Spickler Landfill Site
53
-------
NO. DATE
23 08/11/95
24
08/31/95
25
09/28/95
AUTHOR
STS
Consultants,
Ltd.
Johnson, L. ,
STS
Consultants,
Ltd.
Fagiolo, J.,
U.S. EPA
26
09/29/95
Muno, W.,
U.S. EPA
27
11/03/95
28
29
11/03/95
1996-1997
30
03/06/96
STS
Consultants,
Ltd.
STS
Consultants,
Ltd.
STS
Consultants,
Ltd.
Fagiolo, J.,
U.S. EPA
RECIPIENT
U.S. EPA
Fagiolo, J.
U.S. EPA
Muno, W.,
U.S. EPA
Johnson, L.,
STS
Consultants,
Ltd,
U.S. EPA
U.S. EPA
U.S. EPA
31
05/00/96
Ecology and
Environment,
Inc.
Wolf, T.,
STS
Consultants,
Inc., et al.
U.S. EPA
Spickler Landfill AR
Update #3
Page 4
TITLE/DESCRIPTION PAGES
Final Construction 430
Completion Report for
the Spickler Landfill
Site
Letter: STS' Additional 53
Response to U.S. EPA's
Comments on the Draft
O&M Plan Submittal for
the Spickler Landfill
Site
Memorandum re: U.S. 8
EPA Approval of the
Remedial Action Report
for Operable Unit #1
at the Spickler Landfill
Site
Letter re: U.S. EPA/ 4
WDNR's Approval of the
August 1995 Final
Construction Completion
Report for the Spickler
Landfill Site
Final Long Term Ground- 60
water Monitoring Plan
for the Spickler Landfill
Site
Final Quality Assurance 283
Project Plan for the
Spickler Landfill Site
Long Term Groundwater 674
Monitoring Reports/
Rounds 1-4 (Progress
Reports #33-36) for the
Spickler Landfill Site
Memorandum re: Instal- 3
lation of New Monitoring
Wells S1AR* S2AR and
S3AR at the Spickler
Landfill Site
Remedial Action Field 106
Activities Summary Report
for the Spickler Landfill
Site
-------
NO. DATE
32 09/11/96
33
03/13/97
AUTHOR
Pachowicz, T. ,
Ecology and
Environment,
Inc.
Fagiolo, J.,
U.S. EPA
RECIPIENT
Fagiolo, J.
U.S. EPA
Wolf, T.,
STS
Consultants,
Inc.
Spickler Landfill AR
Update #3
Page 5
TITLE/DESCRIPTION
PAGES
Letter re: E&E's Review
and Data Validation for
the First Round: Long Term
Groundwater Monitoring
Results for the Spickler
Landfill Site
Letter re: U.S. EPA's
Approval of STS' Request
for Elimination of
Laboratory Analytical
Parameters for the Long
Term Groundwater Monitor-
ing Scope of Work at the
Spickler Landfill Site
11
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