&EPA
United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R05-90/127
September 1990
Superfund
Record of Decision
Hagen Farm, Wl
Printed on Recycled Paper
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50272-101
I REPORT DOCUMENTATION
NPAGE
1. REPORT NO.
EPA/ROD/R05-90/127
2.
to and SubtMe
UPERFUND RECORD OF DECISION
agen Farm, WI
, . irst Remedial Action - Final
7. Autior).)
8. Performing Organization Nun* end Address
12. Sponsoring Organization Name and Addreas
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
3. Recipient1* Accession No.
S.
Report Dele
09/17/90
6.
a.
10.
11.
(C)
(G)
13.
Performing Organization Rept No.
Proiect/Taak/Work Unit No.
ContracqC) or Grant(G) No.
Type of Report * Period Covered
800/000
14.
15. Supplementary Notes
16. Abstract (Umlt: 200 words)
The 10-acre Hagen Farm site is a former waste disposal facility in Dade County,
Wisconsin. This site is in a rural area that is dominated by sand and gravel mining
I and agricultural activities. From 1950 to 1966, waste materials were disposed of in
[three subareas of the site's defined area of contamination. Onsite investigations
j^kndicate that subarea A, a 6-acre area in the southern portion of the site, contains
Hafndustrial wastes consisting of solvents and various other organics as well as
I municipal waste, whereas subareas B and C, each 1.5-acre areas in the northeastern
portion of the site, appear to contain only scattered municipal wastes. Site
investigations have determined the need for two concurrent operable units. The source
control operable unit, which is defined in this Record of Decision (ROD), addresses the
waste refuse and subsurface soil at areas A, B, and C with the goal of controlling the
migration of the waste refuse and sub-soil and reducing the volume of contaminants from
the waste and sub-soil to the ground water. The ground water operable unit will be
addressed in a subsequent ROD. The primary contaminants of concern affecting the soil
and waste refuse are VOCs including benzene, toluene, xylenes; other organics including
phenols and PCBs; and metals including lead.
(See Attached Page)
WI
17. Document Analysis a. Descriptors
Record of Decision - Hagen Farm,
First Remedial Action - Final
Contaminated Media: soil, debris
Key Contaminants: VOCs (benzene, toluene, xylenes); other organics (phenols, PCBs)
metals (lead)
c. COSATI Reid/Group
^8. AvaHabllty Statement
19. Security Class (This Report)
None
20. Security Class (This Psge)
None
21. No. of Pages
37
22. Price
(See AKSI-Z39.18)
See /rwtructjorw on Revene
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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KA/ROD/R05-90/127
gen Farm, WI
rst Remedial Action - Final
Abstract (Continued)
The selected remedial action for this site includes consolidating waste materials from
disposal areas B and C into disposal area A and backfilling excavated depression areas
within disposal areas B and C with clean soil, followed by revegetation; capping
disposal area A after consolidation; treating 67,650 cubic yards of waste and 112,000
cubic yards of contaminated sub-soil materials in disposal area A using in-situ vapor
extraction (ISVE) and treating off-gas emissions using carbon adsorption, followed by
regenerating the spent carbon from the off-gas treatment process; and implementing
site access restrictions and institutional controls including deed restrictions to
prevent installation of drinking water wells and to protect the integrity of the cap.
The estimated present worth cost for the remedial action is $3,299,000 which includes
an annual O&M cost of $29,530 for 30 years.
PERFORMANCE STANDARDS OR GOALS: The goal of the ISVE will be a 90 percent removal of
the VOCs from the waste and contaminated sub-soil. Off-gas extracts from the ISVE
will be treated to meet State emission standards.
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HAGEN FARM SITE, WI
SOURCE CONTROL OPERABLE UNIT
DECLARATION FOR THE RECORD OF DECISION
Site Name and Location
Hagen Farm Site, Source Control Operable Unit
Dane County, Wisconsin
Statement of Basis and Purpose
This decision document represents the selected remedial action
for the Hagen Farm site, in Dane County, Wisconsin, Source
Control Operable Unit, 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 Substance Pollution
Contingency Plan (NCP).
This decision is based on the Administrative Record file for the
Hagen Farm site.
The State of Wisconsin concurs with the selected remedy.
Assessment of the Site
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this Record of Decision (ROD), may present an
imminent and substantial endangerment to public health, welfare,
or the environment.
Description of Remedy
This.source control operable unit is the first of two operable
units for the site. The selected remedial action for this
operable unit addresses the source of contamination by
remediation of on-site wastes and contaminated sub-surface soils.
The major components of the selected remedy include:
* Within the larger area of contamination (AOC),
consolidation of non-native materials from disposal areas
B and C into disposal area A with subsequent backfilling
of disposal areas B and C with clean soil material;
* Installation of a WDNR NR 504 solid waste cap
over disposal area-.A after consolidation;
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* In-Situ Vapor Extraction of the waste refuse and sub-
surface soils in disposal area A;
* Off-gas treatment through carbon adsorption;
* Regeneration of carbon from the off-gas treatment;
* Installation and maintenance of a fence around disposal
areas A, B, and C during remedial activities; and
* Deed and access restrictions to prevent installation of
drinking water wells within vicinity of the disposal
areas and to protect the cap.
The following component of the selected remedy will be evaluated
during the implementation of in-Situ Vapor Extraction:
* Determination of the optimum amount of essential
nutrients (e.g., moisture, nitrogen, oxygen, and
phosphate) to be added to the waste refuse and sub-
surface soils in order to promote natural microbial
activities, without decreasing the mass removal of the
volatile organic compounds through in-Situ Vapor
Extraction.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State environmental
requirements that are legally applicable or relevant and
appropriate to the remedial action, and is cost-effective. This
remedy utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable and satisfies the
statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as a principal element.
Because this remedy will result in hazardous substances remaining
on-site, a review will be conducted within five years after
commencement of remedial action to ensure that the remedy
continues to provide adequate protection of human health and the
environment.
Valdas V. Adamku£ LS ' Date
Regional Admini
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RECORD OF DECISION
DECISION SUMMARY
HAGEN FARM SITE
SOURCE CONTROL OPERABLE UNIT
DANE COUNTY, WISCONSIN
Prepared By:
U.S. Environmental Protection Agency
Region V
Chicago, Illinois
September, 1990
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
HAGEN FARM SITE, SOURCE CONTROL OPERABLE UNIT
DANE COUNTY, WISCONSIN
TABLE OF CONTENTS
I. SITE NAME, LOCATION, AND DESCRIPTION 3
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 4
III. COMMUNITY RELATIONS HISTORY 5
IV SCOPE AND ROLE OF REMEDIAL ACTIVITIES 6
V. SUMMARY OF SITE CHARACTERISTICS 7
VI. SUMMARY OF SITE RISKS 9
VII. DOCUMENTATION OF SIGNIFICANT CHANGES 11
VIII. DESCRIPTION OF ALTERNATIVES 12
IX. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES. . 16
X. THE SELECTED REMEDY 20
XI. STATUTORY DETERMINATIONS SUMMARY 21
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ROD SI-WARY
HAGEN FARM SUPEKFUND SITE, SOURCE CCNTflDL OPERABLE UNIT
DANE COUNTY, WISCONSIN
SITE LOCATION AND DESCRIPTION
The Hagen Farm Site (the "Site") is located at 2318 County Highway A,
approximately one mile east of the City of Stoughton, Dane County,
Wisconsin. The 10-acre Site is situated in a rural surrounding that is
dominated largely by sand and gravel mining and agriculture. Soil and
gravel mining operations are located northwest, northeast and south of the
Site. The Stoughton Airfield is located adjacent to the northwest corner
of the Site. County Highway "A" passes just south of the Site (See Figure
1).
The City of Stoughton's municipal wells are located approximately two miles
to the west, and eight private wells are located within 1,200 feet of the
Site. The private wells located at the Site are no longer in use.
Approximately 350 people reside within one mile of the Site.
The Site is located in the Yahara River watershed, in an area of flat to
gently rolling topography. The Yahara River is located approximately 1.5
miles to the West and flows in a southerly direction. The land surface
generally slopes toward the Yahara River from topographically high areas
located to the northeast and east. Surface water drainage in the area is
generally poorly developed, apparently due to permeable surface soils. The
only substantial surface water bodies in the area are a pond located
approximately 1/2 mile south of the Site and the Yahara River. There is no
designated Wisconsin State significant habitat, or historic landmark site
directly or potentially affected. There are no endangered species within
close proximity of the Site.
The Site is located in an area dominated by glacial outwash deposits, which
extend approximately one-half mile to the northeast. These deposits are
dominated by sand and gravel. Beyond this, ground moraine and occasional
drum!ins are encountered. lacustrine deposits associated with Glacial Lake
Yahara are located approximately one-eighth mile south. Bedrock, primarily
sandstones and dolomites, underlie the glacial deposits in this area.
Bedrock generally slopes from the west to southwest, toward a preglacial
valley associated with the Yahara River. The depth to bedrock ranges from
50 to 80 feet near the Site.
The current Site topography is the result of sand and gravel mining and
waste disposal activities. Prior to these activities, the ground surface
probably sloped from the existing topographically high area located west
and northwest toward the southeast and east. The excavated axiea in the
northwest corner of the property is flat. This flat area is separated by a
ridge from the water-filled depression located to the northeast.
Within the Site's larger "Area of Contamination (AOC)", waste disposal took
place within three subareas. These subareas are A (6 acres, located in the
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southern portion of the Site), B and C (1.5 acres each, located in the
northeastern portion) (See Figure 2). All three Areas reside within the
Site's formally defined AOC. The Site has been covered with soil and is
partially vegetated with grasses and tall trees.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Site was operated as a sand and gravel pit prior to the late 1950's.
Observations suggest gravel operations encompassed an area bounded by the
current access road to the east, the former Schroeter property boundary to
the west and the current property boundary to the north (See Figure 2).
Mining operations reportedly terminated approximately 14 to 18 feet below
ground surface. Excavation may have ceased at this depth due to the
presence of groundwater, more fine grained materials, or a change in sand
and gravel quality.
The gravel pit was then used for disposal of waste materials from the late
1950s to the mid-1960s. During the period that the Site was operated as a
disposal facility, the property was owned by Nora Sundby. The Site was
operated by City Disposal Corporation. City Disposal Corporation was
subsequently purchased by Waste Management of Wisconsin, Incorporated
("WMWI"). City Disposal was also the transporter of much of the waste that
was deposited at the Site. The Site is currently owned by WMWI. It is
known that Uhiroyal, Incorporated ("Uniroyal") generated industrial waste,
some of which was deposited at the Site beginning sometime in 1962 and
continuing through August 1966.
Waste solvents and other various organic materials, in addition to the
municipal wastes, were disposed of at the Site, including acetone, butyl
acetate, 1-2-dichloroethylene, tetrahydrofuran, solid vinyl, sludge
material containing methylethyl ketone and xylenes, and toluene. In a
103 (c) Notification submitted to the United States Environmental Protection
Agency ("U.S. EPA") by Uniroyal, in June 1981, Uniroyal indicated that F003
and F005 wastes, which are hazardous wastes within the meaning of the
Resource Conservation and Recovery Act ("PCRA"), 42 U.S.C. 6901, also were
disposed of at the Site. This site stopped accepting waste in 1966, prior
to regulation of hazardous waste disposal by RCRA Subtitle C.
Beginning in November 1980, in response to complaints received from local
residents, the Wisconsin Department of Natural Resources ("WDNR") began
conducting groundwater sampling at nearby private water supply wells.
Sampling of the on-Site monitoring wells during the period 1980-1986
indicated certain organic compounds were present in the groundwater,
including benzene, ethylbenzene, tetrahydrofuran, xylenes, and toluene.
In addition, nearby private water supplies on adjacent properties have also
shown detectable levels of volatile organic compounds (VDCs). The private
wells located on the Site had been impacted by acetone, tetrahydrofuran,
vinyl chloride, xylene, trans 1,2-dichlorethene, and trichloroethylene.
In 1983, the State of Wisconsin brought an enforcement action for abatement
of a public nuisance against WMWI and Uniroyal. At the same time, nearby
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residents at the Site brought a civil action against WMWI and Uniroyal,
seeking civil damages for reduced property values and potential health
hazards resulting from groundwater and well contamination. The State of
Wisconsin obtained a dismissal of its 1983 enforcement action against WMWI
and Uniroyal after the Site was listed on the National Priorities List
("NFL") . In 1986, the parties to civil litigation brought by the nearby
residents to the Site against WMWI and Uniroyal reached a settlement. The
exact terms of the settlement were confidential. It is known, however,
that one of the terms of the settlement required WMWI to purchase the Site
property from Orrin Hagen, as well as other property located adjacent to
the Site. Upon acquiring these properties, WMWI razed the structures
constructed thereon.
The Site was proposed for inclusion on the NFL on September 18, 1985. The
Site was placed on the NFL in July of 1987. Subsequently, WMWI and
Uniroyal, the two potentially responsible parties ("PRPs11) named by U.S.
EPA in connection with the Site to date, entered into an Administrative
Order by Consent (U.S. EPA Docket No. VW 87-C-016, dated September 14,
1987) (the "Consent Order") with the U.S. EPA and the WCNR. In the Consent
Order, WMWI and Uniroyal agreed to conduct a Remedial Investigation and
Feasibility Study ("RI/FS") at the Site. Accordingly, in July of 1988,
upon U.S. EPA approval, in consultation with the WCNR, of the required Work
Plans, fieldwork at the Site commenced.
Two operable units, which are being conducted concurrently, have been
defined for the Site. Operable Unit ("OU11) I, which is the Source Control
Operable Unit ("SCOU") , is intended to address waste refuse and sub-surface
soils ("Waste/sub-Soils") at disposal area A and the two smaller disposal
areas B and C. OU II, which is the Groundwater Control Operable Unit
("GGOU") , is intended to address the contaminated groundwater at the Site.
The OU approach was agreed upon after discussions among U.S. EPA, WCNR, and
PRPs during the early phase of the implementation of the Work Plan for the
RI.
The RI for the SCOU was completed in early 1989, and the Technical
Memorandum for the SCOU was submitted in March 1989. The RI for the GCOU
was initiated in July 1989 and the Technical Memorandum for GCOU was
submitted in February 1990. Currently, additional field activities to
define the extent of plume migration are ongoing. The RI report for the
GCOU, including the Endangerment Assessment, is scheduled for completion in
July 1991. The ROD for the GCOU is scheduled for early 1992.
COMMUNITY POTATIONS
A Community Relations Plan for the Site was finalized in July 1988. This
document lists contacts and interested parties throughout the local and
government community. It also establishes communication pathways to ensure
timely dissemination of pertinent information. The RI/FS and the Proposed
Plan for the SCOU were released to the public in July 1990. All of these
documents were made available in the information repositories maintained at
the Stoughton Public Library and KLongland Realty. An administrative
record file containing these documents and other site-related documents was
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placed at the Stoughton Public Library. The notice of availability of
these documents was published in the Stoughton Courier-Hub and Madison
Capital Times on July 5, 1990. Press releases were also sent to all local
media. A public comment period was held from July 11, 1990 to August 10,
1990. In addition, a public meeting was held on August 2, 1990 to present
the results of the RI/FS and the preferred alternative as presented in the
Proposed Plan for the Site. All comments which were received by U.S. EPA
during the public comment period, including those expressed verbally at the
public meeting, are addressed in the Responsiveness Summary which is the
third section of this ROD.
A public meeting was held on July 27, 1989 to explain the findings of the
RI and the operable unit approach. A fact sheet was developed in
conjunction with this meeting. Advertisements were placed to announce the
meeting and a press release was sent to all local media. Prior to the
public meeting, U.S. EPA representatives held a separate briefing for Town
officials.
A press release was sent to local media on March 27, 1989 to update the
community on the progress of Dane County, Wisconsin Superfund sites,
including Hagen Farm.
An RI "Kickoff" meeting was held on July 14, 1988 to explain the RI
process. A fact sheet was developed in conjunction with this meeting.
Advertisements were placed in the Madison Capital Times and Stoughton
Courier-Hub and a press release was sent to all local media.
Upon the signing of the Consent Order in July 1987, U.S. EPA held a 30-day
public comment period. A press release was sent to all local media and
advertisements were placed.
IV SCOPE AND ROLE OF RESPONSE ACTION
This response action is a final source control operable unit and is
consistent to the maximum extent practicable with Section 300.430 (e) (3) of
the National Contingency Plan ("NCP"). This final source control operable
unit is being implemented to protect human health and the environment by
controlling the migration and reducing the volume of contaminants from the
Waste/sub-Soils to the groundwater. This ROD addresses the source of
groundwater contamination, namely the waste mass in the ADC consisting of
subareas A, B, and C and the underlying contaminated sub-soils.
This source control action, by reducing the toxicity and controlling the
migration of contaminants, is fully consistent with all future site work,
including the ongoing groundwater investigation at the Site. In addition,
this action will positively affect the cost of the final groundwater remedy
by limiting the amount of groundwater that is likely to become contaminated
from this source.
The media that poses the greatest risk is considered to be the groundwater
contaminant plume. The contaminated Waste/sub-Soils are considered to be a
long-term threat to human health and environment, primarily as a principal
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source of groundwater contamination. The VOCs in the Waste/sub-Soils are
considered to be the principal threat for this SOOU.
The groundwater contamination problem will be addressed in a future GCOU,
Record of Decision which is expected to be the final action for the Site.
The FS identified two remedial objectives for the SOOU based on the data
obtained during the RI and the possible exposure routes identified. The
objectives identified in the FS are:
1) To reduce or minimize direct contact with contaminated waste and
soils; and,
2) To reduce or minimize release of contaminants to the groundwater.
V SUMMARY OF SITE CHARACTERISTICS
In March, 1989, a Technical Memorandum for the SOOU was completed under the
guidance and oversight of U.S. EPA and WENR. The Remedial Investigation
(i.e., Technical Memorandum #1) for the SOOU was to determine the nature
and extent of contamination at the source, and evaluate possible exposure
pathways. The report summarized all soil-gas, test-pit, soil, air, and
on-site groundwater analytical data that had been collected. This report
should be consulted for a more through description of the site
characteristics.
The following are the results of RI at the Site:
- Based on the geophysical survey, soil-gas, and test-pit survey, it
appears that most of the waste disposal activity occurred in disposal
area A. Disposal area A encompasses approximately six acres (100 feet
long and 400 feet wide). The wastes within disposal area A are buried
to a depth of two to three feet near the eastern edge, to a depth of 16
feet near the center. Eight feet is the average overall thickness of
buried wastes. The volume of waste for disposal area A is estimated at
67,650 cubic yards. The test-pit survey and refuse borings indicate
that the type of waste present in disposal area A includes plastic
sheeting, paper-coated plastic, paint sludge, grease, rubber, and
municipal waste, such as wood, glass, paper, and scrap metal. No drums
were discovered during the test-pit excavation activity.
Based upon refuse borings, test-pits, and groundwater table
measurements, the bottom of the waste refuse material is estimated to be
10 to 15 feet above the seasonal high water table in disposal area A.
The volume of unsaturated sub-waste soils for disposal area A is
approximately 112,000 cubic yards.
Disposal areas B and C seem to contain only scattered domestic
wastes. A geophysical survey, test-pits and soil gas tests revealed a
small quantity of municipal waste in disposal areas B and C. It appears
that disposal areas B and C were not used for the disposal of industrial
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8
waste.
Surficial soils are thin or absent over most of the waste refuse areas.
The waste is unsaturated. Contaminant movement through the waste occurs
as surface water percolates into the waste mass and dissolved
contaminants infiltrate through underlying unsaturated soils to the
water table. Soil erosion could contribute to some movement of
contaminants, but is not considered a primary pathway because the Site
has a relatively flat, vegetated topography.
During the soil-gas survey, VOCs detected include acetone, benzene,
toluene, 2-hexanone, ethylbenzene, and xylenes. The distribution of
VOCs in disposal area A appears to be fairly scattered, however, no
detects occurred in the northwest section of disposal area A.
To determine if the waste was "characteristic" according to RCRA
Subtitle C, an E>ctraction Procedure ("EP") toxicity and Flammability
test was conducted on a composite sample of refuse boring and soil
boring spoils. Results of the EP toxicity characteristic test indicate
that the waste refuse does not exhibit EP toxicity as defined by
Wisconsin Administrative Code ("WAC") NR 181.
Compounds detected in the source characterization wells (groundwater
beneath disposal area A) include tetrahydrofuran, xylenes, ethylbenzene,
toluene, and 2-butanone. The highest concentrations of these compounds,
such as tetrahydrofuran (630 parts per million (ppm)), xylenes (35 ppm),
and 2-butanone (4400 ppm) were observed in well SCW4, near the southern
end of disposal area A. Semi-VOCs, such as benzoic acid (29 ppm), 4-
methylphenol (6 ppm), and phenol (6 ppm) were also detected in the
groundwater at the Site. Table 1 summarizes the VDC and semi-VOC
groundwater concentration data.
The results of the air analysis indicated low concentrations of a number
of VDCs, generally below 10 parts per billion (ppb), in each of the
samples collected. Two compounds, methylene chloride and
trichlorofluoromethane, were detected at higher concentrations in the
samples (approximately 100 ppb). However, these compounds were also
identified in associated trip blanks. Air VDC concentrations measured
from downwind location were not substantially different from those
measured at the other locations. These data do not identify an
atmospheric gradient of VOCs across the waste area, because the type and
magnitude of VOCs identified from upwind samples were similar to
downwind samples.
The screened data for the waste refuse indicate that waste refuse
material at the Site contains semi-VDCs, such as butylbenzylphthalate
(18 ppm), and bis(2-ethylhexyl)phthalate (120 ppm). low levels of poly
chlorinated biphenyls ("PCBs"), in the range of 300 ppb were also
detected in the waste refuse (See Table 2).
Surface water does not appear to be a direct pathway for contaminant
migration, due to a lack of an established surface water drainage
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system. Furthermore, based on surface water quality results and
inferred groundwater flow paths, it appears the drainage ditch east of
the Site and Sunby's pond to the south are not groundwater discharge
points.
The results of the RE at the Site indicate that the waste refuse materials
in disposal area A have been and continue to be a source for sub-surface
soil and groundwater contamination.
The investigation for the groundwater contamination at the Site is expected
to be completed by the end of 1990. Initial results of the investigation
indicate that the groundwater flows to the south and that the contaminant
plume extends south of the pond located one-half mile from the Site. The
exact boundary of the southern edge of the plume has not yet been
determined. Seven residential wells located downgradient of the Site were
sampled on August 1990 for any potential impact from the contaminant plume.
More details of the nature and extent of the groundwater contaminant plume
will be addressed in the subsequent GOOU.
VI SUMMARY OF SITE RISKS
This section qualitatively describes the risks posed by contaminants in
Waste/sub-Soils to human health and the environment. Based on the
historical findings and on-site groundwater data, which exceeded the
drinking water and groundwater quality standards of the U.S. EPA and the
WCNR, respectively, it is determined that remedial action is needed to
address the source of the groundwater contamination. Because this remedy
is a source control operable unit, a final baseline risk assessment for the
Site is not available. No quantitative risk numbers have been calculated
for exposure to site contaminants. However, qualitative risk information
is organized and outlined below to demonstrate that action is necessary to
stabilize the site and prevent the degradation of the groundwater. The
baseline risk assessment for the Site will be conducted later during the
GOOU phase.
The greatest risk present at the Site is from the groundwater
contamination. However, the source of the groundwater contamination is the
contamination found in the Waste/sub-Soils at the Site.
The following is a qualitative discussion of the site risks.
(A) Contaminants of Concern
The following chemicals have been detected in soil gas, leachate and on-
site groundwater wells at concentrations above background, and screened
waste refuse analyses and can be inferred to be present in source wastes.
VDCs Semi-VOCs
. Ethylbenzene . Benzyl alcohol . bis (2-chloroisppropyl) ether
. Toluene . Rienol . bis (2-ethylhexyl)phthalate
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10
. Xylenes . 4-Methylphenol . 4-chloro-3-methylphenol
. Tetrahydrofuran . 2,4-Dimethylphenol . diethylphthalate
. 2-Butanone . Benzole Acid . di-n-octyl phthalate
. Vinyl chloride . Naphthalene . 1,4-dichlorobenzene
. Aoetone . Dieldrin . 4,4-DDE
. Benzene . PCBs
In addition, inorganic compounds such as lead and barium were also detected
at the Site at concentrations above background.
Table 3 compares the concentrations of these contaminants detected in
groundwater at the Site with Federal and State Standards. As indicated in
this table, the levels of contaminants found at the source characterization
wells far exceed Federal and State standards. For the case of
Tetrahydrofuran, the most frequently detected compound at the Site, the
level (630,000 ppb) is 12,600 times higher than the State groundwater
enforcement standard (50 ppb). This data clearly indicates that the
Waste/sub-Soils are acting as a source of groundwater contamination. This
source will continue to load contaminants to the groundwater unless
addressed by a remedial action.
(B) Exposure Assessment
The exposure assessment identifies potential pathways and routes for
contaminants of concern to reach the receptors. The potential exposure
pathways are: exposure to air emissions from the landfill, direct contact
exposure to contaminated waste and soils, and exposure to contaminated
groundwater.
At present, the wastes do not appear to be a source of exposure via
inhalation of volatilized chemicals.. A preliminary evaluation of ambient
air quality at the Site boundary did not identify an elevated level of VDC
emissions. In addition, active generation of landfill gas, which can
facilitate VDC emissions, is not occurring at the Site. Based on these
preliminary air quality data, it appears that the air contaminants released
from the Site to the downwind residents do not pose a risk to human health
or the environment.
Wastes at the Site are covered with approximately 1 to 3 ft of soil, much
of which supports thick vegetation. However, some areas of the Site are
not vegetated and show exposed waste material. Therefore, a potential
exists for direct human contact with waste. The most likely population
group which may come in contact with the Site is anticipated to be periodic
trespassers. This population group is small, because the Site is secured
from incidental trespass by a fence and because the location is in a rural
area which is not heavily populated. These individuals may incur
contaminant exposure by skin contact with waste and by incidental ingestion
of waste material adhering to hands.
Contaminants contained in the waste have affected groundwater in the
vicinity of the Site. Data obtained from on-Site groundwater indicates
that substantial amounts of contaminants have been released from the
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11
Waste/sub-Soils to the groundwater. Present risks from the groundwater are
unacceptable. As shown in Table 3, the contaminants in the on-Site
groundwater exceed Federal and State Standards. Continued leaching of
contaminants from the Waste/sub-Soils to the groundwater will result in
continued unacceptable risks. Should the contaminants migrate to existing
private wells, or in the unlikely event of future site development
involving the installation of a water supply well, contaminant exposure via
groundwater use and consumption may occur. More detailed evaluation of both
current and future potential human health and environment risks associated
with contaminated groundwater exposure will be addressed in subsequent
steps of GCCU.
Implementation of the selected remedy as presented by this SCOU will
reduce exposure to contaminated soils, control air emissions, and minimize
or reduce contaminant migration to the groundwater.
(C) Environmental Assessment
The natural habitat existing prior to sand and gravel mining operations at
the Site was destroyed. At present, the waste disposal area is covered
with a layer of soil material which supports vegetation primarily
consisting of grasses and other herbaceous plants, with some tall trees.
This area is likely frequented by wildlife including birds, small mammals
and deer. Although an inventory of plant and animal species has not been
performed, the Site is not known to be inhabited by rare or endangered
species. Land in the vicinity has been developed for agricultural, mining
and commercial purposes. Sensitive ecological habitats (e.g., wetlands)
are not in close proximity to the Site. The Site is not in a floodplain.
The potential adverse impacts of Site wastes on the sairrounding ecology are
not considered appreciable in comparison to the loss of habitat which
historically occurred during the active sand and gravel mining phase of the
Site.
VTI DOCUMENTATION OF SIQJIFICANT CHANGES
No significant changes have been made since the publication of the FS and
Proposed Plan in July 1990.
VIII DESCRIPTION OF ALTERNATIVES
Alternatives for the remediation of contaminated Waste/sub-Soils, were
developed to achieve the following goals:
- minimize the potential for direct contact with the contamination;
- minimize the potential for migration of waste/sub-Soils contaminants
into the groundwater.
A comprehensive list of appropriate remedial technologies was identified
for Source Control. These technologies were screened based on their cost,
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12
iirplementability and effectiveness, characteristics of the Site and the
characteristics of the contaminants. Technologies which satisfied the
initial screening requirements were refined to form remedial action
alternatives. The five alternatives developed are detailed below.
The source control alternatives are:
* Alternative 1: No Action;
* Alternative 2: Capping;
* Alternative 3: In-Situ Vapor Extraction and Capping;
* Alternative 4: Waste Consolidation with Biological Treatment, Vapor
Extraction and Capping; and,
* Alternative 5: Waste Excavation with on-Site Incineration, Vapor
Extraction and Capping.
A description of each of these options follows:
ATfTFRNATTVE It NO ACTION
This alternative is evaluated as required by the NCP to determine the
public health, public welfare and environmental consequences of taking no
further action.
2: CAPPING
Non-native materials (i.e., solid waste materials) as determined based on
visual inspection, located within disposal areas B and C would be
consolidated into disposal area A before cap construction begins, although
additional fill material may be required to satisfy minimum slope
requirements. Grading would be accomplished using conventional
construction equipment. The final grade would be constructed so that
precipitation would be directed away from the source waste. Drainage
swales would be constructed to direct runoff to match existing surface flow
patterns. After the desired slope is obtained, the necessary cap materials
would be placed.
In the FS, three types of caps were considered: capping to upgrade the
existing cover to meet the requirements for facilities without an operating
license (i.e., an NR 181.44(12) cap); upgrading the existing cover to meet
the requirements of a solid waste cap (i.e., an NR 504.07 or Subtitle D
cap) ; and upgrading the existing cover to meet the closure requirements for
facilities with an operating license (i.e., an NR 181.44(13) or Subtitle C
cap) . Figures 4 through 6 describe typical details of these caps.
Closure of the Site with a RCRA Subtitle C cap is a potentially relevant
and appropriate requirement, because RCRA wastes (i.e., F003 and F005
listed waste) were disposed of at the Site. Because this alternative does
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13
not involve any treatment to reduce the mobility, toxicity, or volume of
waste, it was determined that the more impermeable capping option afforded
by Subtitle C and NR 181 was both relevant and appropriate under this
alternative. Therefore, only the Subtitle C cap will be evaluated for this
alternative during the conparative analyses. No treatment of contaminants
is involved in this alternative.
The cap would be designed to cover disposal area A. The area to be capped
is approximately 240,000 sq ft (5.5 acres). The capital costs of this
alternative is approximately $2,751,000, and annual Operation and
Maintenance (O&M) cost is $8,899. The 30-year Present Worth (PW) cost is
$2,888,000. The amount of time necessary to implement this alternative
would be 7 months.
ALTERNATIVE 3; IN-SITU VAPOR EXTRACTION AND CAPPING
In this alternative, the Waste/sub-Soils in disposal area A would be
treated using In-Situ Vapor Extraction (ISVE). Gas is extracted from the
Waste/sub-Soils through extraction wells placed strategically at the Site.
The gas travels from the wells through header pipes using a blower. The
off-gases would be treated and discharged to the atmosphere.
Vapor extraction is used primarily for treating VOC contamination. A vapor
extraction system is relatively inexpensive and allows for process
flexibility during remediation activities. The major costs for this
technology are the installation of extraction and injection wells. The
number of wells used may vary during operation to improve system
efficiency. By treating the Waste/sub-Soils in place without excavation,
release of untreated contaminants to the atmosphere is avoided.
Prior to the implementation of in-Situ Vapor Extraction, non-native
materials from disposal areas B and C will be consolidated to disposal area
A. Approximately 37,000 cubic yards of fill is needed to bring area A up
to required slopes before cap placement. Consolidation of solid waste
materials from areas B and C will provide some of the required fill
material and will ensure that all site waste materials are properly
confined. Then a low permeability cap, which meets the requirements of NR
504.07, WAC, will be installed over disposal area A (see Figure 5). The NR
504.07 cap would reduce leachate production by reducing infiltration and
would control moisture content in the Waste/sub-Soils to improve the Vapor
Extraction system performance.
As stated for Alternative 2, a RCRA Subtitle C cap would be potentially
relevant and appropriate. The U.S. EPA and WENR have determined that for
this particular Alternative, the Subtitle C cap, while relevant, is not
appropriate because construction of the ISVE system would impair the
integrity of a Subtitle C cap. An NR 504.07 cap will provide an adequate
level of protection when combined with treatment and can easily be
repaired after installation of the ISVE system.
For the discharge of off-gas emitted from the Vapor Extraction procedure,
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Chapter NR 445, WAG, Control of Hazardous Pollutants, is an ARAR. The off-
gases would be treated using a carbon adsorption system in order to meet NR
445, WAC. Spent carbon or other residues from the off-gases treatment
process will be sent back to the manufacture to be regenerated.
During full-scale ISVE implementation, a treatability study will be
performed to determine the feasibility of enhancing the natural
biodegradation of organic compounds. The treatability study would be
designed to determine the optimum amounts of nutrients (e.g., moisture,
oxygen, nitrogen, and phosphate) to be added to the Waste/Sub-soils to
promote biological activity without interfering with ISVE treatment.
The volume of waste to be treated is approximately 67,650 cubic yards, and
the volume of sub-surface soils to be treated is approximately 112,000
cubic yards. The cap would be designed to cover disposal area A within the
larger ADC. The area to be capped is approximately 240,000 sq ft (5.5
acres). The capital costs of this alternative is approximately $2,679,400,
based upon a vapor extraction system of 25 Injection/Extraction wells. The
average annual O&M cost is $29,530, and the 30-year FW cost is
approximately $3,299,000. The amount of time necessary to implement this
alternative, including ISVE, would be 5 years.
AUTERNAnVE 4; WASTE CONSOIJDATION WITH BIOLOGICAL TREATMENT. VAPOR
EXTRACTION AND CAPPING
This alternative involves consolidating waste from disposal areas A, B and
C into an upgraded facility within the AOC. The upgraded facility would be
used as a treatment/disposal cell. Waste would be consolidated using
conventional excavation equipment. Dewatering should not be necessary,
because the water table is below the predicted depth of refuse. Once the
treatment/disposal area has been upgraded, a high permeability soil cover
will be placed over the waste to allow infiltration of precipitation, and
to minimize direct contact risks during the implementation of this
alternative. Leachate produced in the cell would be recirculated back
through the waste to promote biological activity within the cell.
Nutrients and microorganisms may be added to leachate to enhance
biodegradation. The excess leachate produced during and at the end of the
implementation will be treated and discharged to a surface water. The RCRA
Subtitle C cap would be installed over the treatment cell after treatment
is completed.
Under this alternative, a large depression would be created by waste
excavation from disposal area A exposing contaminated subsurface soils.
This depression would be filled with imported clean fill materials followed
by a NR 504.07 solid waste cap. The remaining contaminated subsurface
soils would be treated with in-Situ Vapor Extraction.
For the construction of the retrofitted unit within the AOC, the State and
Federal hazardous waste landfill requirements, NR 181, WAC, and 40 CFR
264.301 were determined to be both relevant and appropriate. This
determination was made because an entirely new treatment/disposal cell
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would be constructed within a minimally contaminated area of the ADC. The
double lined treatment/disposal cell would provide maximum protection for
treatment of the contaminants. After completion of treatment, a RCRA
Subtitle C (NR 181, WAC) cap would be placed over the treatment/disposal
unit. Ihe Subtitle C cap would be relevant and appropriate because the
integrity of the cap could be maintained and it would provide maximum
protection to the treatment/disposal unit. The HSR requirements are not
ARARs for this alternative, because no "placement" of waste occurs.
Upgrading an existing landfill facility to consolidate wastes within the
ADC does not constitute placement, according to the NCP.
For the discharge of excess leachate produced from this alternative, the NR
105, WAC, Surface Water Quality for Toxic Substances, is an ARAR. The
excess leachate would be treated in order to meet NR 105 standards. A
toxicity characteristics leaching procedure ("TCLP") test will be conducted
for the treatment sludge to determine whether further treatment is
necessary for disposal in a RCRA compliant landfill in order to comply with
Land Disposal Restrictions ("LCRs").
The volume of waste to be consolidated and treated is approximately 67,650
cubic yards from disposal area A and non-native materials from disposal
areas B and C. The capital costs of this alternative is approximately
$12,894,000. The average annual O&M cost is $82,300, and the 30-year PW
cost is approximately $14,129,000. The amount of time necessary to
implement this alternative would be 10 years.
ALTERNATIVE 5; WASTE EXCAVATION WITH ON-SITE INCINERATION. VAPOR EXTRACTION
AND CAPPING
This alternative incorporates waste excavation with on-site incineration
and disposal. The excavation activities are the same as described in
Alternative 4. On-Site materials handling, staging, and storage may also
be required. Waste would be characterized prior to incineration.
Treatment residuals, such as ash and scrubber water, would be further
treated, if necessary, and disposed of off-Site in accordance with the
LCRs.
Under this alternative, a large depression would be created by waste
excavation exposing contaminated sub-surface soils in disposal area A.
This depression would be filled with imported clean fill materials and the
non-native materials from disposal areas B and C, followed by a Solid Waste
cap. The contaminated sub-surface soils would be treated with ISVE.
For this alternative, incineration would be done in an incinerator which
meets the design requirements of 40 CFR Part 264 Subpart O. A TCLP test
will be conducted for the treatment residuals, such as ash and scrubber
water, to determine whether further treatment is necessary for disposal in
a RCRA compliant landfill in order to comply with LCRs requirement.
The volume of waste to be incinerated is approximately 67,650 cubic yards
from disposal area A. The capital costs of this alternative is
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16
approximately $59,410,000. Hie average annual O&M cost is $22,800, and
the 30-year PW cost is approximately $59,858,000. The amount of time
necessary to implement this alternative would be 5 years.
IX SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
A detailed analysis was performed on the five alternatives using the nine
evaluation criteria in order to select a source control remedy. The
following is a summary of the comparison of each alternative's strength and
weakness with respect to the nine evaluation criteria. These nine criteria
are:
1) Overall Protection of Human Health and the Environment
2) Compliance with Applicable or Relevant and Appropriate Requirements
(ARAR's)
3) Long-Term Effectiveness and Permanence
4) Reduction of Toxicity, Mobility, or Volume through Treatment
5) Short-Tterm Effectiveness
6) Implementability
7) Cost
8) State Acceptance
9) Community Acceptance
1. Overall Protection of Human Health and the Environment
Alternative 1, No Action, will not provide protection from risks associated
with site contaminants. Groundwater will continue to degrade due to
release from the source. Therefore, it will not be discussed any further,
since it is not protective and thus, not an acceptable alternative.
Alternatives 2 through 5 will reduce contaminant migration from the waste
and minimize any future direct contact threats. Alternative 3 through 5
also provide treatment, thus reducing the amount of contaminants available
to move into the groundwater. Continued groundwater impacts from Site
contaminants will be reduced by varying degrees by Alternatives 2 through
5. Alternative 3, In-Situ Vapor Extraction, would provide protection from
exposure to the waste during implementation because treatment would be in-
situ and excavating the waste is minimized. Direct contact exposure to
contaminated waste and soils may occur in Alternative 4 and 5 during
excavation of disposal area A.
It is not the intent of the proposed alternatives to provide protection
from risks which may be associated with contaminants currently existing in
the groundwater. Existing groundwater contamination will be addressed in
the GCCU.
2. Compliance with ARARs
The alternatives would comply with all applicable or relevant and
appropriate federal and state environmental laws. No waiver would be
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17
necessary to implement these alternatives.
For Alternative 2, a RCRA Subtitle C multi-layer cap would be installed in
order to comply with RCRA cap design standards.
Alternatives 3 and 5 would meet the State landfill closure requirements
(i.e., MR 504.07, MAC). Alternative 4 would meet State (MR 181, MAC) and
Federal (40 CFR 264.301) hazardous waste landfill requirements.
Alternative 4 also would meet the Federal RCRA Subtitle C cap requirement.
NR 445, Control of Hazardous Pollutants, is an ARAR for Alternatives 3, 4
and 5. The extracted off-gases should be treated in order to meet NR 445
emission limit requirements.
Toxic Substances Control Act ("TSCA") is not an ARAR for this site because
PCBs detected at the Site, at a maximum level of 300 ppb, is less than 5
ppm.
The full listing of ARARs for the Site is contained in the FS.
3. loncr-Term Effectiveness and Permanence
Residual risks associated with direct contact with wastes will be reduced
by each alternative through capping, which will minimize direct exposure to
wastes. Alternatives 3, 4 and 5 will reduce these risks further by
removing and treating, biodegrading or incinerating contaminants. Risks
associated with direct contact with waste materials in the future will be
minimized through implementation of institutional controls.
Residual risks associated with migration of contaminants from the source to
groundwater were considered greatest.for Alternative 2, because the wastes
are only contained and not treated or destroyed. Alternatives 3 through 5
provide the lowest residual risks to groundwater since the source of
groundwater contamination is being treated.
Effectiveness is exclusively dependent on maintaining the integrity of the
cap over the long term for Alternative 2. Alternative 2 will not remove
contaminants within the waste which could ultimately migrate to the
groundwater. Therefore, maintenance of the cap is key to the long-term
effectiveness and permanence of this alternative.
Alternative 2 through 4 will be effective in achieving remedial objectives
through installation of multi-layer cap, which will limit the infiltration
of precipitation through the landfill and preclude the leaching of
contaminants into the groundwater.
Alternative 3 will be effective in removing VDCs in the Waste/sub-Soils
through vapor extraction. In addition, the installation of the solid waste
cap will minimize the leaching of contaminants into the groundwater.
Alternative 4 is anticipated to be effective in achieving remedial
objectives through biological degradation. Tests at other sites have
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demonstrated that bioremediation is a premising technology. However, its
application to this site would have to be verified. Alternative 5 is
anticipated to be effective in removing contaminants in the landfill
through contaminant destruction (incineration) permanently. Each of
Alternatives 2 through 5 are anticipated to require system monitoring and
maintenance of the integrity of the landfill cover materials.
4. Reduction of toxicity. mobility or volume fTMVl through Treatment
Alternative 2 does not provide treatment of contaminants to reduce the
mobility, toxicity or volume of either the waste or the sub-waste soils.
Alternative 3 through 5 will reduce toxicity, mobility, or volume of the
contaminants through treatment of Waste/sub-Soils. Alternative 3, in
addition to the multi-layer cap, is estimated to remove as much as 90
percent of the VOCs from the Waste/sub-Soils through the implementation of
ISVE, but will not address chemicals with low volatility (e.g. , phenols and
barium) . Because semi -volatiles are not treated by ISVE, treatability
tests for degradation of semi-volatiles by microbial methods will be
explored during full-scale ISVE implementation. For alternatives 3, 4 and
5, the extracted VOCs in the air stream will eventually be destroyed
through the regeneration of the carbon.
Alternative 4 uses leachate recirculation in the waste to promote
biological degradation of the contamination. Leachate recirculation could
potentially reduce 100 percent of the VDCs contamination, if the process is
given enough time. During treatment, the waste will be within a RCRA-
type cell where migration of contaminants into the groundwater will be
minimized to the extent possible.
Alternative 5 will destroy the VDCs and senii-VOCs present in the Waste
permanently through incinerating the waste mass.
5. Short— t^nn Ef fectiveiv^s
Alternative 2 and 3 can be implemented shortly after design approval
because there are no substantive permit requirements. Alternatives 4 and 5
will require the longest time to inplement due to the need to meet
substantive permit requirements to site new disposal and treatment
facilities. At least one, and as many as two to three years, may be
required to comply with air and water quality discharge requirements, and
perform the necessary treatability studies and test burns. Ihese steps
would likely require several years to complete before a full scale system
would be operational.
A low risk would be posed to remediation workers and the ccrttunity during
the implementation of Alternative 5 related to potential exposure to
incinerator off-gases. This risk is anticipated to be low because
monitoring of air contaminants at the Site boundary will be oonductPri to
ensure that acceptable levels are maintained. Alternatives which require
excavation of site wastes (Alternatives 4 and 5) may pose a potential risk
to remediation workers via direct exposure to wastes, dusts and VOCs.
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Alternative 5, Waste Excavation with on-site Incineration, may pose added
risks to the community and workers due to increased air emissions.
However, the levels of potential contaminant exposure to remediation
workers could be minimized by the use of personal protective equipment and
standard dust control measures in each alternative. Alternatives 2 and 3
are anticipated to pose minimal risks to remediation workers and the
community because they do not involve excavating the waste. Additional
risks to the surrounding ecology were not considered appreciable for any of
the alternatives.
6. Implem^ntability
Alternatives 2 is the easiest to technically implement compared to the
other three alternatives. Alternative 3 is somewhat easier to implement
than Alternative 4 and 5 because it involves less construction at the Site.
The most difficult alternative to implement would be Alternative 5.
Difficulties associated with this alternative include accessing a
supplementary fuel source on-site, disposing of the ash, supplying
sufficient water needed for the scrubbers, and treating and disposing the
contaminated scrubber water. Alternatives 3 and 4 would both be relatively
straightforward to implement technically. Administratively, alternatives 2
and 3 are easier than alternatives 4 and 5 because they involve less
coordination with relevant agencies.
Alternatives 2 through 4 require services and materials that should be
available. It is assumed that appropriate material to perform cap
construction could be obtained from a borrow source located within four
miles of the Site. For Alternative 5, materials and services are
available, but their availability is more restricted than the other
alternatives.
7. Cost
Alternative 2 involves a capital costs of $2,751,000, annual Operation and
Maintenance (O&M) costs of $8,899 and a 30-year Present Worth (PW) cost of
$2,888,000.
Alternative 3 involves a capital costs of $2,679,400, average annual O&M
cost of $29,530, and a 30-year PW cost of $3,299,000.
Alternative 4 involves a capital costs of $12,894,000, average annual O&M
cost of $82,300, and a 30-year PW cost of $14,129,000.
Alternative 5 involves a capital costs of $59,410,000, average annual O&M
cost of $22,800, and a 30-year PW cost of $59,858,000.
8. State Acceptance
Ihe State of Wisconsin is in agreement with the U.S. EPA's analyses and
recommendations presented in the RI/FS and the proposed plan. The State
concurs with the selected alternative (presented in Section X, below).
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9. Community Acceptance
The specific comments received and U.S. EPA's responses are outlined in the
Attached Responsiveness Summary.
X THE
As provided in CERCLA and the NCP, and based upon the evaluation of the
RI/FS and the nine criteria, the U.S. EPA, in consultation with the WCNR,
has selected Alternative 3 as the source control remedial action at the
Kagen Farm Site.
The major components of Alternative 3 include the following:
* Within the larger AOC, the non-native material from the disposal areas B
and C will be consolidated in disposal area A. All waste movement will
be done within the ADC. No placement will occur. The excavated
depression areas within disposal areas B and C will be filled with clean
soil and landscaped with vegetation native to the area.
* The Cap will be placed on disposal area A in compliance with the current
requirements of Ch. NR 504.07, WAC for closure of solid waste disposal
facilities. The cap will consist of a grading layer, a minimum 2-foot
clay layer (compacted to a permeability of 1 x 10~7 cm/s or less) , a
gravel drainage layer, a frost protective soil layer, and a minimum 6
inches top soil layer (see Figure 5) . The cap will be constructed
prior to the pilot-scale test and full-scale implementation of the in-
Situ Vapor Extraction. The integrity of the cap will be maintained
during the ISVE implementation and for many years afterwards.
* In-Situ Vapor Extraction will be implemented in the contaminated waste
refuse and sub-surface soils of disposal area A. Prior to the full-
scale implementation of the ISVE, a pilot-scale test will be conducted
at the Site to determine the remedial design parameters (i.e. , number of
extraction and injection wells, the spacing between wells, pumping rate)
to achieve maximum removal of the VOC's. The goal of the ISVE
extraction will be 90 percent removal of VOCs in the Waste/sub-Soils.
Daring the full-scale ISVE implementation, a treatability study will be
performed to examine the feasibility of adding essential nutrients
(e.g. , moisture, oxygen, nitrogen, and phosphate) to the Waste/sub-Soils
in order to enhance the natural microbial degradation of organic
compounds. The study will be designed to determine the optimum amounts
of nutrients to be added to the Waste/sub-Soils in order to promote the
microactivities, without decreasing the mass removal of the VOCs by
ISVE. If determined to be feasible, this treatment will be implemented
as part of the remedy.
* Off -gas emitted from the extraction wells will be treated using a carbon
adsorption system in order to meet the air quality standards of the
State, NR 445, WAC. The spent carbon or any other residues from this
off -gas treatment process will be sent back to the manufacturer to be
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regenerated, thus they are not subject to ITRs.
* Institutional controls would be relied upon to provide additional
effectiveness to the remedy. These include zoning restriction, deed
notice, and construction of a fence.
XT STATUTORY DhTEHMINATIONS
The selected remedy must satisfy the requirements of Section 121 of CERdA
to:
a. protect human health and environment;
b. comply with ARARs;
c. Be cost-effective;
d. Utilize permanent solutions and alternate treatment technologies to
the maximum extent practicable; and,
e. Satisfy the preference for treatment as a principle element of the
remedy or document in the ROD why the preference for treatment was
not satisfied.
The implementation of Alternative 3 at the Site satisfies the requirements
of CERdA as detailed below:
a. Protection of Human Health and the Environment
Implementation of the selected alternative will reduce and control
potential risks to human health posed by exposure to contaminated waste and
air emission by treating contaminated Waste/sub-Soils.
Capping the landfill, in addition to reducing any potential risks posed by
direct exposure to contaminated waste, will reduce the infiltration of
precipitation through the landfill. Groundwater contaminant loading will
thus be reduced. In-Situ Vapor Extraction of the contaminated Waste/sub-
Soils will also reduce the groundwater contaminant loading.
No unacceptable short-term risks will be caused by implementation of the
remedy. The site workers may be exposed to noise and dust nuisances during
construction of the cap. ISVE should not present short-term risks due to
VOC emission if properly designed and monitored. A Standard Safety program
will manage any short-term risks. Dust control measures and off-gas
treatment would reduce those risks as well.
b. Compliance with ARARs
An NR 504.07 Solid Waste cap is an ARAR for Alternative 3. A RCRA Subtitle
C cap, while relevant, is not appropriate, as described in Section VIII of
this ROD. NR 445, WAC, Control of Hazardous Pollutants, is an ARAR for the
discharge of off-gas from the vapor extraction procedure.
Compliance with Wisconsin Statute, Chapter 160 and NR 140, WAC, will be
achieved through the selection of the final remedy for the GOOU for this
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site.
The selected remedy will attain all Federal and State applicable or
relevant and appropriate environmental requirements.
c. Cost—Effectiverv^^s
Alternative 3 is a cost-effective alternative providing for protection of
human health and the environment and long-term effectiveness. Alternative
2 is somewhat less expensive than the selected remedy, but provides a
lesser degree of long-term effectiveness because no treatment of
contaminants is involved. Because there is no treatment, there is a
greater risk of contaminants entering the groundwater with Alternative 2
over the long term. Alternative 4 is four-times more expensive than
Alternative 3 without providing proportional effectiveness. Alternative 5
(Incineration) is the most expensive remedy. Although Alternative 5
provides complete destruction of the contaminants at the Site, Alternative
3 provides similar effectiveness through a combination of treatment and
containment of the residuals at far less cost.
d. Utilization of Permanent Solutions and Alternative Treatment
Technologies or Recovery Technologies to the Maximum Extent Practicable
U.S. EPA and the State of Wisconsin believe the selected remedy represents
the maximum extent to which permanent solutions and treatment technologies
can be utilized in a cost-effective manner for the SOOU remedy at the
Hagen Farm site. Of the alternatives that are protective of human health
and the environment and conply with ARARs, U.S. EPA and the State have
determined that the selected remedy provides the best balance of tradeoffs
in terms of long-term effectiveness and permanence, reduction in toxicity,
mobility or volume achieved through treatment, short-term effectiveness,
iirplementability, cost, also considering the statutory preference for
treatment as a principal element and considering State and community
acceptance.
Alternative 3 reduces the toxicity, mobility, and volume of the
contaminants in the Waste/sub-Soils; complies with ARARs; provides long-
term effectiveness; and protects human health and the environment equally
as well as Alternatives 4 and 5. In terms of short-term effectiveness,
Alternative 3 has the shortest time to ijtplement because there are no
substantive permit requirements, as needed for Alternatives 4 and 5.
Alternative 3 also poses minimal risk to remediation workers and the
community during the implementation period because it does not involve
excavating the waste. Alternative 3 will be easier to iitplement
technically because it requires less construction, and administratively
because it will require less coordination with relevant agencies. Finally,
Alternative 3 costs the least of the protective alternatives that utilize
treatment. The major tradeoffs that provide the basis for this selection
decision are short-term effectiveness, inplementability, and cost. The
selected remedy is more reliable and can be implemented more quickly, with
less difficulty and at less cost than the other treatment alternatives and
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is therefore determined to be the roost appropriate solution for the
contaminated Waste/sub-Soils at the Hagen Farm site.
The State of Wisconsin is in concurrence with the selected remedy. A
public comment was received concerning the cost of the remedy, and this
eminent is fully addressed in the Responsiveness Summary.
e. Preference for treatment as a princif
The groundwater contaminant plume will be addressed in a second operable
unit. Because the selected alternative treats the VDCs, which are the
continuing source of groundwater contamination, it will address the
principal threat for the SOCU at the Site through treatment and satisfies
the preference for treatment as a principal element. In addition, duriir;
full-scale implementation of ISVE, enhanced biological treatment of semi-
VOCs will be investigated and if feasible, implemented as part of this
remedy.
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Figure 1
Site Location Map
Hagen Farm Site
Dunkirk Township, Wisconsin
f'Not To Scale)
Stoughton
V M
Hagen
Farm Site
o >
(A Z
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figure 2
Site Diagram
Hagen Farm Site
Dunkirk Township, Wisconsin
( Not To Scale)
Gravel Pit
Ponds
Limit of Area of
Contamination
Disposal
Areas
•B&C"
Disposal
Area'A
Sundby Sand
and Gravel
K-Way
Insulation
JE
Prepared by Jacobs Engineering Group Inc. Chicago
for the U.S. Environmental Protection Agency, 7/22/90
Drawn
Checked
AH
OS
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F10CRE 3
op NR 181.44(12) CAP
VEGETATED
TOP LAYER-
^s ^
te
\i/ \*X
CLAY CAPPING LAYER
6\ ,t
^"-;
c
CM
GRADING LAYER
(O'-IO1)
-EXISTING
- SOIL COVER
WASTE
SCALE: 1" =
WARZYN
STRUCTURE OF CAP REPAIR
PER NR 111.44 (12)
REMEDIAL WVESTIGATION AND
FEASIBILITY STUDY
HAGEN FARM SITE
Revisions
13452
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FIGORE 4
OF NR 5O4.07 SOLID IASIE CM»
VEGETATED ..
1UH LAYER *>
COVER LAYER ^-<
{
CLAY CAPPING
LAYER j
4 ^ ^
COMMON EARTH
SAND DESICCATION LAYER
CLAY CAPPING LAYER
6\ ,1
>^,
c
CO
KJ
4
GRADING LAYER
(O'-IB1)
EXISTING
SOIL COVER
WASTE
** THE COVER LAYER WAS SPECIFIED AT 30 IN. AS A WORST CASE SCENARIO
• TO ADDRESS THE CONCERNS OF NR 50^.07 (5).
SCALE: 1" *
WARZYN
STRUCTURE OF SUBTITLE O CAP (NR SOO)
PER NR $04.07
Orp»n
REMEDIAL WVESTlGATlON AND
FEASIBILITY STUDY
HAGEN FARM SITE
Revisions
13452
-------
FZGORE 5
SPBOPICWICW OP RCRA SDHTTHJE C Of
VEGETATED j
TOP LAYER *-| COMMON EARTH
??vrcAGE • SAND * GRAVFL DRAINAGF
LATtR "-«— gi
PER/LABILITY f
LAYER r CLAY CAPPING LAYER
-4
CO
s
V
••^ ^^"^
^VS. •
X"*^,
x_
s
1 -* TOPSOIL
FABRIC
/-SAND BEDDING
\ MLMBRANL
^-SAND BEDDING
LOWER
COMPONENT
— UPPER
COMPONENT
GRADING LAYER
(0'-36')
WASTE
^W— EXISTING
- --- • SOIL COVER
(O'-A1)
* THE DRAINAGE LAYER WAS SPECIFIED AT 24 IN. TO MEET THE REQUIREMENT
THAT THE UPPER COMPONENT OF THE LOW PERMEABILITY LAYER BE LOCATED AT LEAST
12 IN. BELOW THE MAXIMUM RECORDED DEPTH OF FROST WHICH WAS ESTIMATED
TO BE 36 IN.
SCALE: 1" s 4'
WARZYN
STRUCTURE OF SUBTITLE C CAP (MR 111) Qrp»n
fER MR 181.44 (13) [
REMEDIAL INVESTIGATION AND R«v,s,cms
FEASIBILITY STUDY
HAGEN FARM SITE
13452 AE
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TOHLE 1
Groundwater Quality Summary
VOCs and Semi-VOCs at Source Characterization Wells
Hagen Farm FS
Concentrations (ug/L)
No. Wells With
Maximum AverageU) Detection(?)
VOCs
2-Butanone 4,400,000 2,620 3
Toluene 20 20 1
Ethylbenzene 2,400 99 3
Xylenes 35,000 1,066 5
Tetrahydrofuran 630,000 5,695 5
Semi-VOCs
Benzoic Acid 29,000 780 2
2,4-Dimethylphenol 330 153 2
4-Methylphenol 6,100 243 2
-Phenol 5,600 3,816 1
1,4-Dichlorobenzene 10 10 1
Benzyl Alcohol 26 26 1
Bis(2-Chloroisopropyl)Ether 19 19 1
Naphtalene 8 8 1
4-Chloro-3*Methylphenol 7 7 1
Diethylphthalate 5 4.5 1
Bis(2-Ethy'lhexyl)Phthalate 34 18 3
Di-n-Octyl Phthalate 5 5 1
Notes
(1) Geometric averages for positive detects at each well are calculated for
duplicate analysis and multiple rounds, where applicable. Geometric average
were then calculated using one single or, where more than one sample was
obtained from a given well, average value for each well (5 wells).
(2) Out of five wells. Some wells had more than one sample analyzed as
indicated in (1).
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TABLE 2
Source Characterization Suwnary
Analytical Results of Refuse Samples
Nagen Fara FS
Concentration
Compound
Inorganic (mg/kg)
Aluminum
Arsenic
Barium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Pottasium
Sodium
Vanadium
•
Zinc
Semivolatiles (ug/kg)
1,4-Dichlorobenzene
Naphthalene
Oiethylphthalate
Oi-n-Butylphthalate
- Fluoranthene
Butylbenzylphthalate
bis(2-Ethylhexyl)Phthalate
Di-n-Octyl Phthalate
Phenanthrene
Unknown SemivolatilesU)
Geometric
Mean
7,690
3.1
96.8
1.3
23,100
10.7
296
15.6
11,100
24.4
14,800
329
0.12
21.6
659
1,550
18.4
74.8
280
46
48
130
67
220
3,410
320
53
2,120
Number ofU)
Maximum Samples
13,000
4.6
2,550
1.8
43,900
16
296
160
15,900
107
26.500
660
0.42
387
1,140
4,920
29.8
499
280*
46*
48*
690
67*
18,000
120.000
5,300
67*
1,261,985
10
10
10
8
10
10
1
10
10
10
10
10
6
10
10
2
10
10
2
1
1
3
1
8
9
7
2
10
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TABLE 2
(Continued)
Compound
Concentration
Geometric
Mean
11.6
18.2
11.9
19.2
104.8
338
222
Maximum
11.6
18.2
128
19.2
284
338
222
Number ofO)
Samoles
1
1
4
1
4
1
1
Pesticide/PCB's (ug/kg)
Oieldrin
4.4'-DDE
4,4'-DDD
4,4'-DDT
PCB-1242
PCB-1248
PCB-1254
Notes
(1) Out of 10 total sampling locations (Test Pits RS01 to RS10), excluding
RS08 duplicate.
(2) Sum of tentatively identified compounds.
* Indicates concentration is below method quantitation limit. Value is
estimated.
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TOHLE 3
CCMPRRISCK OP SHE CCNCa«3WnCN DKDt
FEDERAL AND SJ3OX, STONDAKDS
^x ••• y • nv^e ^V*yy>ont t*s>fr \ ffB^
^^JifcJy^m X4& j"^g* P^
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RESPONSIVENESS SUMMARY
HAGEN FARM SITE
SOURCE CONTROL OPERABLE UNIT
DANE COUNTY, WISCONSIN
PURPOSE
This responsiveness summary, required by the Superfund Law,
provides a summary of citizen's comments and concerns identified
and received during the public comment period, and U.S. EPA's
responses to those comments and concerns. All comments received
by U.S. EPA during the public comment period will be considered
in the selection of the remedial alternative for the Site. The
responsiveness summary serves two purposes: It provides U.S. EPA
with information about community preferences and concerns
regarding the remedial alternatives, and it shows members of the
community how their comments were incorporated into the decision-
making process.
This document summarizes one written comment received during the
public comment period of July 11 to August 10, 1990. The public
meeting was held at 7:00 p.m. on August 2, 1990 at Dunkirk Town
Hall, Stoughton, Wisconsin. No comments were submitted during
the public meeting.
OVERVIEW
The preferred alternative for the Hagen Farm site was announced
to the public just prior to the beginning of the public comment
period. The preferred alternative includes:
* Installation of a WDNR required NR 504 solid waste cap
over disposal area A after consolidation;
* In-Situ Vapor Extraction of the waste refuse and sub-
surface soils in disposal area A;
* Off-gas treatment through carbon adsorption.
PUBLIC COMMENT AND AGENCY RESPONSE
COMMENT: It is unwise to spend more than $2 million of the
taxpayers' money to remediate the Hagen Farm site which will not
affect anyone. The money should be spent to control cigarette
smoking which kills thousands of people each year. In addition,
the commentor stated U.S. EPA should be active in alleviating
"drunk drivers."
RESPONSE: It is believed that the wastes in the Hagen Farm
landfill have been contaminating the groundwater at the site. If
the Agency does not remediate this contaminated landfill now, the
landfill would contaminate the groundwater continuously in the
future, and people who use this groundwater as their drinking
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water will be affected. Therefore, it is important and wise to
remediate the contaminated landfill. We expect that the funds to
remediate this site will come from the parties determined to be
potentially responsible for the contamination, not from the
taxpayers. The issue of a referendum concerning smoking in
public places is not within the scope of the Superfund program.
Instead, this is a local matter and should be addressed to the
city council. U.S. EPA also cannot address the commentor's
statement on "drunk drivers" because that subject is not within
the scope of the Superfund program. Such concerns should be
brought to the attention of State or Local lawmakers.
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State Of Wisconsin \ DEPARTMENT OF NATURAL RESOURCES
Ctrroll D. 8«Mdny, Secretary
Box 7921
Utdlton, Wltcontln 53707
DNP TELEFAX NO. 608-267-3579
TDD MO. 608-267-6897
SOLID WASTE TELEFAX NO. 608-267-2768
September 6, 1990 IN REPLY REFER TO: 4440
Mr. Valdas V. Adamkus, Regional Administrator 0: WMD
U.S. Environmental Protection Agency CC: RF
230 S. Dearborn Street FREEMAN
Chicago, IL 60604
SUBJECT: Selected Superfund Remedy
Hagen Farm Site
Dunkirk Township, Dane County, WI
Dear Mr. Adamkus:
The Department is providing you with this letter to document our position on
the proposed source control operable unit for the Hagen Farm Site. The
proposal, as identified in the draft Record of Decision, includes the
following:
Alternative 3: In-Situ Vapor Extraction and Capping
Non-native waste materials from disposal areas B and C
would be consolidated to disposal area A. The waste and
contaminated sub-soil materials in disposal area A would
be treated using In-Situ Vapor Extraction (ISVE). A low
permeability cap meeting the Wisconsin requirements for
capping municipal landfills will be placed over disposal
area A.
Estimated Costs: Construction - $2,679,400
Operation and Maintenance - $29,530
30 Year Present Worth - $3,299,000
The total 30 year present net worth for the Hagen Farm Source Control Operable
Unit is approximately $3,299,000. The Department concurs with Alternative 3,
as described in the Record of Decision for this operable unit.
RECEIVED
SEP 1 2 1990
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Mr. Adamkus - September 6, 1990 2
The State of Wisconsin will contribute 10% of the remedial action costs
associated with this source control operable unit at the Hagen Farm Site if
the potentially responsible parties (PRPs) do not agree to fund the remedy.
This assurance assumes that EPA will pursue all legal action against the PRPs;
including issuance of a unilateral order and litigation of such order, prior'
to expending the Fund.
We also understand that our staff will continue to work in close consultation
with your staff during the remaining Remedial Investigation/Feasibility Study
work associated with the groundwater control operable unit at the Hagen Farm
Site, as well as during the design and construction of the source control
operable unit remedy.
Thank you for your support and cooperation in addressing this contamination
problem at the Hagen Farm Site in Dunkirk Township. If you have any questions
regarding this matter, please contact Mr. Paul Didier, Director of the Bureau
of Solid and Hazardous Waste Management, at (608) 266-1327.
Sincerely,
C. D.(Jtes>dny
Secretary
CDB.-SB
cc. Lyman Wible - AD/5
Linda Meyer - LC/5
Paul Didier - SW/3
Joe Brusca - SOD
Pat McCutcheon/Mike Schmoller - SOD
^/flae Lee - EPA Region V (5HS/11)
Mark Giesfeldt/Sue Bangert/Terry Evanson - SW/3
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