United States         Office of
           Environmental Protection   Emergency and
           Agency           Remedial Response
EPA/ROD/R05-90/146
September 1990
<&EPA   Superfund
          Record of Decision:
          Master Disposal Service
          Landfill, Wl

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50272-101
 REPORT DOCUMENTATION
        PAGE
1. REPORT NO.
     EPA/ROD/R05-90/146
                                           3. Recipient's Accession No.
 4. TlUe and Subtitle
   SUPERFUND RECORD OF  DECISION
   Master Disposal Service Landfill,  WI
   First Remedial Action
                                           5. Report Date
                                                  9/26/90
 7. Author(s)
                                                                     8. Performing Organization RepL No.
 9. Performing Organization Name and Address
                                            10. Project/Taak/Work Unit No.
                                                                     11. Contract(C) or Grant(G) No.

                                                                     (C)

                                                                     (G)
 12. Sponsoring Organization Name and Address
   U.S.  Environmental  Protection Agency
   401 M Street,  S.W.
   Washington, D.C.  20460
                                           13. Type of Report & Period Covered

                                                800/000
                                                                     14.
 15. Supplementary Notes
 16. Abstract (Umlt: 200 words)

 The  26-acre Master Disposal  Service  Landfill site  is an inactive industrial landfill  in
 the  Town of Brookfield, Waukesha County,  Wisconsin.   The site  lies within the marshy
 floodplain of  the Fox River  and is partially surrounded by wetlands and drainage
 channels.  The site overlies a surficial sand/gravel and dolomite aquifer system, which
 has  been contaminated by onsite disposal activities.  Onsite disposal  of mainly
 industrial foundry sands and slags occurred between  1967 and 1982.  Onsite disposal of
 hazardous wastes  including inks, sludges,  and solvents was also observed during this
 period.   The site was partially closed in 1982, but  controlled burning of wood waste
 continued until 1985, when the site  was permanently  closed.  Investigations completed in
 1990 identified negative impacts on  surface water  and ground water from the landfill
 sources.  This Record of Decision  (ROD)  addresses  source control as a  final remedy and
 management of  migration of ground water as an interim remedy.   A subsequent ROD will
 address  the final restoration of the surficial aquifer system.   The primary contaminants
 of concern affecting the soil,  debris,  and ground  water are VOCs including benzene, TCE,
 toluene, and xylenes; and metals including arsenic,  chromium,  and lead.

 (See Attached  Page)
 17. Document Analysis a. Descriptors
    Record of Decision  -  Master Disposal Service Landfill,  WI
    First Remedial Action
    Contaminated Media:   soil, debris,  gw
    Key Contaminants: VOCs (benzene,  TCE, toluene,  xylenes).,  metals  (arsenic,  chromium,
                       lead)
   b. Identifiers/Open-Ended Terms
   c. COSATI Held/Group
 18. Availability Statement
                             19. Security Class (This Report)
                                    None
                                                      20. Security Class (This Page)
                                                      	None	
21. No. of Pages
    62
                                                                                22. Price
(See ANSI-Z39.18)
                                      See Instructions on Reverse
                                                       OPTIONAL FORM 272 (4-77)
                                                       (Formerly NTIS-35)
                                                       Department of Commerce

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EPA/ROD/R05-90/146
Master Disposal Service Landfill, WI
First Remedial Action

Abstract  (Continued)

The selected remedial action for this site includes capping the landfill with a clay/soil
cap and soil cover; installing  an active landfill gas venting system; pumping and
treatment of ground water in the surficial aquifer system using filtration and either air
stripping, carbon adsorption, ion exchange or chemical treatment, based on the results of
treatability studies; discharging the treated water onsite to surface water; restoring or
mitigating any wetlands impacted by this remedial action; conducting long term surface
water and ground water monitoring; and implementing institutional controls including
deed, land use, and ground water use restrictions, and site access restrictions such as
fencing.  The estimated present worth cost for this remedial action ranges from
$4,632,000 to $5,016,000,  which includes an annual O&M cost ranging from $142,730 to
$164,130 for 30 years, depending upon the selected ground water treatment.

PERFORMANCE STANDARDS OR GOALS: Effluent discharge limitations for treated ground water
were calculated from State discharge statutes, and specify weekly averages for metal
contaminants and monthly averages for VOCs, as well as maximum concentration levels.
Chemical-specific goals include benzene 8.5 Ibs/day, TCE 22 Ibs/day, toluene (daily
concentration level) 17 mg/1, arsenic 0.045 Ibs/day, chromium (total) 0.034 Ibs/day, and
lead 0.0096 Ibs/day.

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       RECORD OF DECISION

           ROD SUMMARY
MASTER DISPOSAL SERVICE LANDFILL
      BROOKFIELD,  WISCONSIN

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              DECLARATION FOR THE RECORD OF DECISION

Site Name and Location

Master Disposal Service Landfill
Brookfield, Wisconsin

Statement of Basis and Purpose

This decision document presents the selected remedial action for
the Master Disposal Service Landfill (MDSL) site, in the Town of
Brookfield, Wisconsin, which was chosen in accordance with the
requirements of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA), as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA)
and, to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP).  This decision is
based on information and documents contained in the
administrative record for this 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 threat to public health, welfare,  or the
environment.

Description of the Selected Remedy

This remedy is. the first operable unit for the MDSL site and
consists of a remedy for the waste mass and an interim action
for contaminated groundwater.  Capping of the waste mass in
conjunction with containment of contaminated groundwater is
considered as source control, both components are necessary since
the groundwater appears to be in contact with the waste mass.
Thus, "containment" will not be achieved through solely capping
the site.  A second and final remedy will be implemented for
groundwater, surface water and wetlands.  The combination of a
clay/soil cap with an active landfill gas venting system and a
groundwater extraction system with capability for both organic
and inorganic pollutant removal followed by stream discharge
constitutes the first remedy for the site.   The primary goals of
the remedial actions at the MDSL site are:

     to reduce infiltration into the landfill which is a source
     of groundwater contamination and to reduce the risks
     associated with exposure to contaminated materials; and

-    to contain known contaminated groundwater in the surficial
     aquifer.

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The HDSL Remedial Investigation identified contaminated
groundwater as the principal threat, with the waste materials
acting as the source of that contamination due to infiltration
and the probable contact between portions of the waste mass and
the groundwater.

The major components of the selected remedy consist of:

     Placement of a clay/soil cap and an active venting system
     over the fill material to reduce infiltration into the waste
     mass. (Constructed in accordance with NR 504.07 and NR
     506.08 Wis. Adm. Code).

     Installation of a groundwater extraction and treatment
     system to. remove both organic and inorganic contamination
     from a portion of the contaminated alluvium aquifer
     groundwater beneath the site.

     Conduct groundwater, surface water, water budget/hydrology
     and wetland monitoring to assess the quality and quantity of
   .  area groundwater, surface water and wetlands.

     Impose access and use restrictions.

Declaration of Statutory Determinations

The selected remedy is protective of human health and the
environment,  and is cost-effective.  The waste mass alternative
(clay/soil cap) will comply with all Applicable and Relevant and
Appropriate Requirements (ARARs), while the interim groundwater
remedy (containment of the plume) will comply with those
environmental standards directly associated with the limited
nature of this action.  The waste mass remedy utilizes permanent
solutions and alternative treatment technologies, to the maximum
extent practicable, given the limited scope of the action.
Treatment of the landfill waste mass is impracticable due to the
large volumes of wastes with low levels of contamination.

This interim groundwater action is protective of human health
and the environment, complies with Federal and State ARARs
directly associated with this action, and is cost-effective.  The
statutory preference for remedies that employ treatment that
reduces toxicity, mobility, or volume as a principal element will
be addressed by both this and the final response action.
Subsequent actions are planned to address fully the principal
threats posed by the conditions at this site.  Through employment
of treatment techniques such as adsorption, oxidation, etc.,
groundwater contaminant toxicity and mobility will be reduced.

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As required by SARA, when hazardous substances are left on site,
a review will be conducted within 5 years after commencement of
remedial/action to ensure that the remedies continue to provide
adequate/ protection/of human health and the environment.
Valdas V. Adamkus,
U.S. Env i ronmenta1
Regional Administrator
Protection Agency, Region V
Date

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       State of Wisconsin  \
            DEPARTMENT OF NATURAL RESOURCES
                                                Carroll D. Besadny
                                                      Secretary
                                                      Box 7921
                                          Madlton, Wisconsin S3707
September 18, 1990
                            IN REPLY REFER TO:  4440
Mr. Valdas V. Adamkus, Regional  Administrator
U.S. Environmental Protection Agency
230 S. Dearborn Street
Chicago, IL  60604
                                      0: WMD-
                                     CC: RF
                                         FREEMAN
    SUBJECT:     Selected  Superfund  Remedy
                Master  Disposal  Service  Landfill
Dear Mr. Adamkus:

The Department is providing you with this letter to document our position
on the proposed source control operable unit for the Master Disposal Service
Landfill.   The  proposal,  as  identified  in  the draft Record  of Decision
includes the following:
Alternative WM3/GW3:
Capping with Groundwater Extraction/Treatment
A  cap with  an  active gas  extraction  system,   in
compliance with NR504 Wis.  Adm.  Code,  will  be placed
over  the  waste mass.   In  addition,  a  groundwater
extraction and treatment system will  be  installed  to
contain groundwater  contaminants  from  leaving the
site.  The groundwater  system and the capping will  be
designed to have minimal impacts on the  surrounding
wetlands.
          Estimated  Costs  WM3:
          Estimated  Cost  GW3:
            Construction - $3,495,000
            Operation and Maintenance - $54,130
            30 Year Present Worth - $3,608,000

            Construction - $430,300
            Operation and Maintenance - $103,000
            30 Year Present Worth - $1,408,000
The total  30-year present net worth for the Master Disposal Service Landfill
source control operable unit is approximately $5,016,000.   The Department
concurs with Alternative WM3/GW3, as  described in the Record  of Decision for
this source control  operable unit.   The State of Wisconsin will contribute
10%  of the remedial  action costs  associated with  this  source  control

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operable unit at the Master  Disposal  Service  Landfill  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/wetlands/surface water  operable  unit at the Master Disposal
Service Landfill  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 Master Disposal Service Landfill site in  Brookfield.  If you
have any questions regarding this matter, please contact Mr.  Paul Didier,
Director of the Bureau of  Solid and Hazardous Waste Management, at (60S)
266-1327.
Sincerely,
C.D.


CDBrRS
cc: Lyman Wible - AD/5
    Linda Meyer - LC/5
    Paul Didier - SW/3
    Frank Schultz - SED
    Jim Schmidt/John Krahling - SED
    Doug Ballotti/Russ Hart/Beth Reiner - US EPA Region V (5HS/11)
    Mark Giesfeldt/Sue Bangert/Robin Schmidt - SW/3

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       RECORD OF DECISION

           ROD SUMMARY
MASTER DISPOSAL SERVICE LANDFILL
      BROOKFIELD,  WISCONSIN

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1.0  SITE NAME, LOCATION, AND DESCRIPTION

     The Master Disposal Service Landfill (MDSL) site is located
     at 19900 West Capitol Drive (Wisconsin Route 190),  Town of
     Brookfield, Waukesha County, Wisconsin.  The property is
     situated in the southwest quarter of the southwest quarter
     of Section 5, Township 7 North, Range 20 East of the
     Waukesha Quadrangle, Wisconsin.  (See Figure 1-1).   The site
     is bounded by Wisconsin Route 190 to the south, and
     otherwise is surrounded by wetlands.  The wetlands located
     around the landfill are privately owned parcels of land.
     The Fox River is located approximately 300 feet to the west.
     The site vicinity map is illustrated in Figure 1-2.

     The MDSL site is located in the marshy floodplain of the Fox
     River and is partially surrounded by drainage channels which
     discharge to the river.  The site occupies approximately 26
     acres of the 40-acre parcel.  The landfilling operations
     have created a raised plateau, confined by perimeter berms,
     that is surrounded by flat-lying lowlands.

     The 1980 population of the area surrounding the landfill
     (census tract 2008) is approximately 10,440,  and the area is
    . experiencing rapid growth.  Of the total, approximately
     8,530 persons are residents of the City of Brookfield.  The
     City of Brookfield is a western suburb of the City of
     Milwaukee.  It is a heavily urbanized area located
     approximately 3/4 mile east of the site.

     The nearest residential well is approximately one mile to
     the south of the site.  Groundwater flow is primarily to the
     south-southwest.  Within the wetlands surrounding the site,
     a substantial amount of peat is encountered.   The dolomite
     aquifer begins at approximately a depth of 55 feet below the
     ground surface.  Within the unconsolidated glacial till are
     two sand and gravel aquifer units at depths of 15 and 35
     feet.

     The MDSL site lies within a primary environmental corridor,
     as defined by the Southeastern Wisconsin Regional Planning
     Commission (SEWRPC).  SEWRPC defines those areas in
     southeast Wisconsin that have the highest concentrations of
     natural, recreational, historic, and scenic resources as
     "environmental corridors".  A primary environmental corridor
     is further defined as being at least 400 acres in size, two
     miles in length, and 200 feet in width.  Resources
     contributing to the area's ranking as a primary
     environmental corridor include the Fox River, the wetlands,
     and wildlife habitat areas.  There are no known records of
     endangered or threatened animal or plant species in or
     surrounding the site area.

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                              3 ROOK FIELD
                                       .  INC.
 ^	  _         .--i>i>r.ssw/r.vr_p/_-.;_s/
'b : - ~  -  - ~ C: ~ A-  SE R VI CE  L AN DFILL
            FIGURE  1-1

 V»'AUKESHA  QUADRANGLE  DETAIL

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      C^C'"-';1 Orive  Air-3Cr-t is  Located
      Apex -. /ina tely 3/^ Mil,? v?r. t-
      Sou* ---cst or' -.he s/-e
                                                AGRICULTURAL  LAND
       -MARSHLAND
MARSHLAND
                                                                   : , ' '    C:-.i.-.nel
                                                                          RGURE

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     The MDSL site is underlain by reworked glacial drift
     (alluvium)  and glacial till.  This glacial material is
     unconsolidated and rests atop the Niagara Dolomite, a
     consolidated Silurian unit 300 to 700 feet thick in the
     vicinity of the site.  Beneath the Niagara Dolomite lies the
     Maquoketa Shale and Ordovician/Cambrian Sandstones and
     dolomites.   Beneath these units lies the Precambrian
     basement bedrock.

     There are two aquifer systems at the MDSL site:  an upper
     unconfined aquifer consisting of the glacial till and the
     Niagara Dolomite formation; and a deeper confined aquifer
     beneath the Maquoketa Shale consisting of the
     Ordovician/Cambrian sandstone formation.


2.0  SITE HISTORY AND ENFORCEMENT ACTIVITIES

     The MDSL site was operated from 1967 until 1982  when it was
     partially closed.  At that time, wastes no longer were
     received for disposal with the exception of wood wastes
     which were burned in a controlled air-pit burner known as an
     air curtain destructor.  The ash from this operation was
     disposed of on-site.  During the active life of  the landfill
     (1967-1982), disposal of industrial and non-industrial solid
     wastes and drummed liquids and solids occurred on site.

     During the fall of 1966, the site was purchased  by Master
     Disposal, Inc. and began its operation as MDSL.   Waste was
     initially accepted in 1967.

     In April 1967, after the Wisconsin Department of Natural
     Resources (WDNR) received legislative authority  to regulate
     solid waste facilities, the WDNR inspected the MDSL
     facility.  At that time, the WDNR noted that the site was
     located entirely in a swampy, peat area.  The WDNR
     subsequently advised Master Disposal, Inc. that  adequate
     diking be maintained.  The WDNR also chose at that time not
     to license the site due to the poor setting of the site.
     The WDNR routinely inspected the site during the years of
     the site's operation.

     A WDNR inspection in August 1973, indicated that the on-
     site operations consisted primarily of industrial waste
     disposal.  Foundry sands and slags constitute the largest
     class of wastes accepted for disposal.  Some evidence of
     hazardous waste (including inks, sludges,  solvents, and
     other industrial compounds) reportedly was present at the
     site.

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The WDNR performed approximately 19 inspections of the MDSL
site during the period from December 1976, though August
1977.  The inspections generally consisted of visual
observations of disposal operations in the industrial waste
disposal area, wood burning area, refuse disposal area, and
salvage area.  Most WDNR inspection reports noted that
hazardous substances were being accepted.  A summary report
of the WDNR site inspections noted that operational
violations included the following:

          continuous open burning,
          inadequate waste covering,
     -    lack of surface water drainage,
     -    acceptance of some hazardous wastes, and
     -    deposition of waste materials directly into ponded
          waters.

Under contract to the site owner, Warzyn Engineering, Inc.
completed a study in June 1977, which assessed the
hydrogeologic and geotechnical feasibility of continued
disposal operations at MDSL.  Warzyn recommended a phased
abandonment over time based on the poor site setting,
potential increase of contaminants to ground and surface
waters, lack of on-site borrow materials, and difficult
operating conditions.

In August 1977, the WDNR and the State Department of
Justice (DOJ) entered into a stipulated agreement with
Master Disposal Corporation.  As a result, a State license
was issv.ed; however, the agreement called for site
abandonment within 2-1/2 years as well as the development of
a groundwater monitoring program at the site.

By 1982, MDSL was partially closed.  The only known wastes
which were received after partial closure were wood wastes
which were burned in the air curtain destructor; the ash
from the burning was disposed of on site.  MDSL ceased this
activity and closed in 1985.

In 1984, U.S. EPA placed the MDSL site on the National
Priorities List (NPL).  In 1985, U.S.  EPA sent notice
letters to potentially responsible parties (PRPs) informing
them of an opportunity to engage in negotiations with the
Agency over the need to evaluate extent of contamination at
the MDSL site.  In 1986, approximately 20 PRPs entered into
an agreement with U.S. EPA and WDNR for the purpose of
performing this study.

The Remedial Investigation/Feasibility Study (RI/FS) was
performed by the PRPs who were a party to the Consent
Order.  A goal of the RI/FS was to determine the effect of
the MDSL site on the surrounding environment through the

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     collection of various samples (e.g. - surface water,
     groundwater, etc.) RI sampling results showed that the MDSL
     site has had demonstrable negative effects on both the
     nearby groundwater and surface water.  An FS Report to
     identify remedial action alternatives for the MDSL site was
     completed by the PRPs in June 1990.
3.0  COMMUNITY RELATIONS

     In 1986, a public meeting was held at the Brookfield City
     Hall as a "kickoff" to the PRP-lead RI/FS process. The RI/FS
     Report and the Proposed Plan for the Master Disposal Service
     Landfill were released to the public for comment on July 9,
     1990.   These two documents were made available to the public
     in both the administrative record and an information
     repository maintained at the U.S. EPA Docket Room in Region
     V and at the Brookfield Library.  Another repository was
     established at the Brookfield City Hall.  The notice of
     availability for these two documents and the scheduled July
     16,  1990 public meeting was published in the Milwaukee
     Journal on June 27, 1990.  A public comment period on the
     documents was initially set for July 9,  1990 to August 8,
     1990.   However, in response to a request for an extension of
     the comment period, U.S. EPA extended the comment period
     until  September 7, 1990.  On July 16, 1990, U.S. -EPA
     conducted a public meeting at the Brookfield City Hall
     concerning the Proposed Plan.  Written and oral comments
     were accepted.  At this meeting, representatives from U.S.
     EPA and WDNR answered questions concerning problems at the
     site and the remedial alternatives under consideration.
     Responses to the comments received during the meeting as
     well as during the public comment period are included in the
     Responsiveness Summary, which is part of this ROD.


4.0  SCOPE AND ROLE OF OPERABLE UNIT

     The environmental setting at the MDSL site contributes to
     the complexity of environmental problems.  As a result, U.S.
     EPA organized the work into two operable units (OUs).   This
     ROD addresses the first of two planned operable units for
     the site.  The operable units are as follows:

          OU One:   Source Control - Containment of the waste
                    mass consisting of a cap on the site to
                    prevent infiltration of water through the
                    landfill.  In addition, since groundwater is
                    believed to be in direct contact with the
                    waste materials, a groundwater containment
                    system to control the migration of the
                    contaminant plume is required.

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     OU Two:   The second of two planned operable units will
               focus on the restoration of the groundwater
               (both upper alluvium aquifer as well as the
               dolomite aquifer which underlies the
               alluvium) to comply with state and federal
               ARARs, and on impact to the wetlands and the
               Fox River and the environment. (U.S. EPA and
               WDNR will issue a subsequent Proposed Plan
               when they determine the recommended option
               for those media).

U.S. EPA seeks a course of action which will contain the
groundwater plume and also restore the aquifer throughout to
federal and state groundwater standards.  However, the
presence of the surrounding wetlands poses a problem.  These
wetlands are of environmental significance, and an overly
aggressive groundwater restoration effort may have the
undesired effect of drying out and destroying these
wetlands.

Therefore, for this first of two planned operable units, the
primary focus will be to control the source of contamination
(the landfill) and contain known portions of the
contaminated groundwater that is likely in direct contact
with the waste materials.  Because this is an interim
groundwater remedy, attainment of federal/state groundwater
criteria throughout the aquifer is not a goal of this
operable unit.  For groundwater protection measures,
pertinent federal/state regulations would encompass
groundwater restoration criteria, location-specific
construction measures and effluent limitations upon
treatment.  This interim measure will attain regulations on
the latter two points. The goal of this action is
containment rather than to attain groundwater restoration
quality standards.

The second operable unit will consider aquifer response and
wetlands effects, and will seek to optimize both groundwater
restoration and wetlands preservation.  It will also consist
of an extensive monitoring system to better evaluate the
impact to the wetlands quality and both surface water
quality and quantity.  It will be the goal of the second
operable unit to define the remediation standards and the
restoration timeframe of the contaminated aquifer.

The remedy for the first operable unit at the MDSL site was
selected by combining aspects of source control, treatment
and long-term monitoring.  The MDSL site received primarily
industrial wastes of a non-hazardous nature.  While such

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wastes contain hazardous substances, they are not RCRA hazardous
wastes, and waste mass contamination is at relatively low levels.
Therefore, the selected remedy for the MDSL site includes a
clay/soil cap of the waste mass with an active gas venting system
and a groundwater pump and treat system to contain and treat
groundwater as well as prevent contaminants from leaving the site
in the shallow alluvium aquifer.  A RCRA Subtitle C cap is not
technically appropriate because of contact between the waste mass
and groundwater.  More vigorous means of reducing infitration is
not justified because such a cap would not preclude waste mass
contact with groundwater.  In accordance with NR 504.07 and NR
506.08 Wisconsin Administrative Code, the cap/cover system will
be composed of a minimum 2-foot thick clay cap that will minimize
water from infiltrating through the landfill; covered by a 1-1/2
to 2-1/2-foot thick soil frost-protection layer; covered by a
layer of top soil at least 6 inches thick to promote vegetation
growth.  The cap will be slightly sloped to promote precipitation
runoff.  In addition, an active venting system, in accordance
with Wisconsin NR 504.05, will be installed to reduce gas buildup
from decomposition within the landfill, and to monitor or
control emissions from the vents.  The selected remedy will also
include site fencing, sign placement, and site deed
restrictions.  Part of the first operable unit will be to
conduct treatability studies, including a pump test, on the
groundwater to determine which of the combination
organic/inorganic treatment technologies are best suited for the
groundwater contamination to comply with discharge limitations.

Key direct pathways at MDSL are contact with the waste mass as
well as ingestion of groundwater if no further action is taken.
The selected remedy will address these threats by containing the
plume of contaminated groundwater, and by halting deterioration
of existing cover materials which could result in subsequent
exposure of the waste mass.  Waste materials in contact with the
groundwater will continue to impact the groundwater, thus
groundwater containment is a necessary component of the overall
waste mass containment alternative.

The groundwater medium has been identified as the principal
pathway of exposure from chemicals at the site.  The primary
chemicals of concern are as follows:  1,1-dichloroethene,
trichloroethene (TCE), cadmium, toluene, and benzene.  It should
be noted that vinyl chloride was not detected in samples from the
MDSL site.  However, multichlorinated species such as TCE may
undergo degradation to vinyl chloride.

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                                             MAX. CONTAMINANT
     Compound            Max. Cone. Detected   LEVEL (MCL)

     1,1-dichloroethene          28                7
     trichloroethene            190                5
     cadmium                     15               10
     toluene                   1100               —
     benzene                     91                5
5.0  SITE CHARACTERISTICS

     The RI consisted of sampling and subsequent laboratory
     analysis to determine the nature and extent of
     contamination at the site and affected areas.  During the
     RI, samples were taken from surface and subsurface soils,
     monitoring wells, residential/municipal wells, surface
     water, and sediment.  An assessment of wetlands surrounding
     the site was not included in the RI.

     Geophysical investigation of the MDSL site did not reveal
     areas which may be construed as "hot spots" requiring
     treatment of that segment of the waste mass.  The largest
     class of wastes at the MDSL site includes foundry sands and
     slags, along with plastic wastes and certain solvents
     associated with their usage.  The RI report for the first
     operable unit was completed in June 1990.  The results of
     the RI are summarized below.
5.1  Groundwater

     Eighteen monitoring wells were installed at nine locations
     around the MDSL site.  All of the monitoring wells were
     screened either in the sand and gravel or the dolomite
     aquifers.  For most of the monitoring wells, three rounds of
     sampling were conducted and samples were compared to samples
     taken from wells considered upgradient of the site.  The
     sampling revealed elevated concentrations of both organic
     and inorganic compounds in both the sand and gravel and the
     dolomite aquifers. The reader is referred to Figures 5-1, 5-
     2 and 5-3 for sampling results.  The highest levels of
     organic contaminants were found in the second round of
     sampling.  Due to drought conditions that existed during
     most of the RI, the second round of sampling occurred during
     more typical weather conditions.

     No contamination attributable to the MDSL site,  however, was
     found in the seven residential and two municipal wells
     sampled.

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       FIGURE 5-1
       ROUND 1  -
       GROUND-WATER SAMPLING HIGHLIGHTS
                                                                  B-40
                                                                  B-41
                                                                  B-42
                                                                 KEY:

                                                                  EXISTING SHALLOW WELL    ^

                                                                  EXISTING INTERMEDIATE WELL O

                                                                  NEW SHALLOW WELL        ^
                                                                  NEW INTERMEDIATE WELL    •
                                                                  NEW DEEP WELL            •
nickel
cadmium
benzene
iron
dichloro-
melhane
(methylene
chloride!
                              Southern Drainage
                                  Channel
                                                                    Eastern Drainage
                                                                        Channel
                                                                       iron      26200
                                                                       toluene     360
                                                                       cadmium   15
                                                                       nickel     102

-------
        FIGURE 5-2
       ROUND 2-
       GROUND-WATER SAMPLING HIGHLIGHTS
                                                                                       iron
                                                                                      iron
                                                                                             1500
                                                                                             116
trichlorethene  17
iron       6000
                                                                     KEY:
                                                                      EXISTING SHALLOW WELL     ^
                                                                      EXISTING INTERMECNATE WELL O

                                                                      NEW SHALLOW WELL         A
                                                                      NEW INTERMEDIATE WELL     •
                                                                      NEW DEEP WELL             •
                                                                                 ;*.1-dichlorethene   11
                                                                                 richlorethene     38
                  trichlorethene  6
                                                                         Eastern Drainage
                                                                            Channel
;                                                                           Benzene
                                                                           oluenp
                                                                                  1,1-dichlofethene
                                                                                  trichlorethene
trichlorethene
1.1-dichlorethene
                                Southern Drainage
                                    Channel
                              cadmium
                              iron
                                          Main Drainage
                                            Channel
trichlorethene     190
1,1 -dichlorethene   18

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         FIGURE 5-3
     ROUND 3-
     GROUND-WATER SAMPLING HIGHLIGHTS
A B-40
                                                                8-41

                                                                B-42
                                                              KEY:
                                                               EXISTING SHALLOW WELL     ^

                                                               EXISTING INTERMEDIATE WELL O

                                                               NEW SHALLOW WELL         A
                                                               NEW INTERMEDIATE WELL     •
                                                               NEW DEEP WELL             •
benzene
nickel
                                                                  Eastern Drainage
                            Southern Drainage
                                Channel
                                     Main Drainage
                                       Channel

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5.2  Surface Water

     During the RI, sampling of the Fox River, dredge pond and
     drainage channels surrounding the landfill was conducted to
     determine whether contamination had occurred as a result of
     site activities.  Two rounds of surface water samples were
     collected.  On comparing upstream river and drainage channel
     results to downstream locations, it is clear that the site
     has had a demonstrable and detrimental effect upon surface
     water quality.  For example, at the upstream Fox River
     sampling point, iron levels were 624 and 597 ug/1 for the
     first and second rounds of sampling, respectively.  At a
     downstream Fox station, located just after the confluence
     with the main drainage channel, iron levels had increased to
     842 and 971 ug/1, from the first to second rounds of
     sampling, respectively.  East, or upgradient of the site,
     the main drainage channel showed iron concentrations of 633
     and 700 ug/1, respectively.  At a point in the main drainage
     channel just prior to entry into the Fox River, iron levels
     had increased to 1,900 and 3,090 ug/1, respectively.
     Additionally, at this same point, a cadmium level of 44 ug/1
     was detected.  Cadmium was not detected at any upstream
     point.  The detected levels of cadmium exceed federal and
     state ambient water quality criteria.


5.3  Conclusion

     With regard to the contaminants and figures noted above,
     carcinoaenic substances encountered in the groundwat.er or
     surface water at the MDSL site include but are not limited
     to, benzene, arsenic, 1,1-dichloroethene and
     trichloroethene.  The RI describes groundwater movement as
     being generally to the south-southwest, and notes that there
     are residential well users located approximately 1 to 2
     miles away in that direction.   Furthermore, compounds such
     as 1,1-dichloroethene and trichloroethene are heavier than
     water and may in time extend their vertical migration
     further into the dolomite aquifer.


6.0  SUMMARY OF SITE RISKS

     As part of the RI, a baseline risk assessment was initiated
     to determine whether the contaminants of concern identified
     at the site pose a current or potential risk to human health
     and the environment in the absence of any remedial action.
     It provides information used in determining whether remedial
     action is necessary and is one justification for performing
     remedial actions.  The Superfund baseline risk assessment
     process may be viewed as consisting of an exposure
     assessment component and a toxicity assessment component,

                                8

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     the results of which are combined to develop an overall
     characterization of risk.  As indicated above, these
     assessments are site specific and therefore may vary in the
     extent to which qualitative and quantitative analysis are
     utilized.

     The risk assessment concluded that the site presently poses
     a risk to human health through ingestion of contaminated
     groundwater and, if untreated, the contaminated groundwater
     would continue to pose future risks.  The risk assessment
     considered both soil ingestion and dermal contact pathways
     as regards to adult populations,  but did not take into
     account the use of the site by children, as the site is
     partially fenced.  However, it should be noted that dirt
     bike tracks were found at the site during subsequent site
     visits, indicating that children may have access to the
     site.
6.1  Introduction

     Water,  soil and sediment samples were analyzed for chemicals
     on the  U.S. EPA Target Compound List (TCL)  and Target
     Analyte List (TAL).   As discussed in the RI Report,  the risk
     assessment process allows for the massive list of compounds
     detected at the MDSL site to be pared down to a more
     manageable list of chemicals of concern.  The inclusion of
     each chemical of concern was based on its relative
     concentration,  frequency of detection,  and toxic effects,  as
     well as whether an environmental standard or criteria (such
     as federal drinking-water standard)  exists for the
     chemical.   Compounds found in the upstream or upgradient
     samples in the same frequency and magnitude, or greater, as
     the downstream or downgradient samples were eliminated from
     this assessment.  Inclusion of a compound on the list of
     chemicals of concern indicates that remedial controls that
     may be  applied to a site should mitigate exposure to the
     compound in groundwater, soil, surface water and sediments.

     The chemicals of concern are classified as non-carcinogens,
     or as potential or known human carcinogens (cancer-causing
     agents).  Acute (short-term at high concentrations)  or
     chronic (long-term at low concentrations) exposure to each
     of the  chemicals of concern leads to various toxic effects.
     The following chemicals of concern were selected for the
     MDSL site (using the Superfund Public Health Evaluation
     Manual  (SPHEM;  U.S.  EPA 1986a):

-------
                       CHEMICALS OF  CONCERN

          Inorganic                  Organic

          Arsenic                    Methylene Chloride
          Cadmium                    1,1-Dichloroethene
          Chromium                   Trichloroethene
          Copper                     Benzene
          Lead                       Toluene
                                     Xylene

     All of the above noted chemicals were found in groundwater
     and/or surface water at the site.
6.2  Exposure Assessment

     The primary exposure pathways of concern evaluated for the
     MDSL exposure assessment are incidental ingestion of
     contaminated surface water,  ingestion of contaminated fish,
     and groundwater ingestion.   Dermal contact with soils was
     also considered in this assessment.

     The potentially exposed populations include adult and child
     groundwater users (via drinking water), fishermen and other
     consumers of potentially contaminated fish, and recreational
     surface water users who may incidentally ingest water.

     The risk assessment made the following assumptions
     concerning duration and freguency of exposure,  and
     concentrations of pollutants (no direct contact with the
     waste mass was assumed):

          For adult carcinogenic risk associated with ingesting
          groundwater:
               365 days/year frequency
                25 years duration
                 2 liters/day

          For recreational users of surface water:
               10 instances of exposure per year

          The maximum concentrations and the geometric means were
          calculated for the chemicals of concern.   For worst
          case calculations, the maximum concentrations of a
          compound detected were assumed to equal the exposure
          concentration.   For most probable cases of exposure,
          the geometric mean concentration of a pollutant was
          utilized.
                               10

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     Group B - Probable Human Carcinogen (Bl - limited evidence
               of carcinogenicity in humans; B2 - sufficient
               evidence of carcinogenicity in animals with
               inadequate or lack of evidence in humans).
     Group C - Possible Human Carcinogen (limited evidence of
               carcinogenicity in animals and inadequate or lack
               of human data).
     Group D - Not Classifiable as to Human Carcinogenicity
               (inadequate or no evidence).
     Group E - Evidence of Noncarcinogenicity for Humans (no
               evidence of carcinogenicity in adequate studies).


6r4  Summary of Risk Characterization

     Excess lifetime cancer risks are determined by multiplying
     the intake level with the cancer potency factor.  These
     risks are probabilities that are generally expressed in
     scientific notation (e.g., 1 X 10-6 means that an individual
     has an additional one in one million chance of developing
     cancer as a result of site-related exposure to a carcinogen
     over a 70-year lifetime under the specific exposure
     conditions at a site).

     Potential concern for noncarcinogenic effects of a single
     contaminant in a single medium is expressed as the hazard
     quotient (HQ) (or the ratio of the estimated intake derived
     from the contaminant concentration in a given medium to the
     contaminant's reference dose).  By adding the HQs for all
     contaminants within a medium or across all media to which a
     given population may reasonably be exposed, the Hazard Index
     (HI) can be generated.   The HI provides a useful reference
     point for gauging the potential significance of multiple
     contaminant exposures within a single medium or across
     media.

     The reasonable worst case hazard index was calculated as
     part of the Risk Assessment and was calculated to be 1.2 for
     adults, based primarily on the contributions from lead,
     toluene and 1,1-dichloroethene.  A hazard index of greater
     than one indicates an unacceptable risk.  The worst case
     hazard index calculated for children at the MDSL site was
     4.0.  (See assessment tables 5-2 and 5-3 as presented here).

     The sum of the carcinogenic risks for adults and children
     were calculated to be 4 X 10-4 and 1 X 10-3 respectively.
     The NCP established acceptable levels of risk for Superfund
     sites at between one in 10,000 and one in one million excess
     cancer cases.  This translates to a risk range of between
     1 X 10-4 and 1 X 10-6.   Site specific factors will be used
     to determine the level  of risk acceptable at a particular
     site.  The risk levels  at the Master Disposal site exceed

                                12

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                                                               ';.'•.!!!.£ i-2
                                          A!ii;;.T I'. ISK  CHARAC'l'tH! .'ATION (1) KOH  1NCESTION
                                          :>>•• GHOUNOWATER:  NONr.-.ncifocENir  EFFECTS
                              wo:.!-.  on"'       :'.oat  i'robablo                                             HAZARD INDEX
                                       ; I              C n ii is CD!      A(A'r.lJTA:j;.F:  DOSE       	
                             (.•tiy/v.y.'.l.iy,           ( :r.y/Kg/day!                   (2)         WORST CASE         MOST PROBABLE CASE
                                                       4.9E-C1.                6  E-02              7.7E-03               8.2E-04
                                                     1  9.0E-ai                9  E-03              1.9E-01               l.OE-02
                                  •>. 'j:-: • G 3               7.8E-Ob            Not  Given                   (3)                   (3)


                                  ?.(,K-03               f>.5E-OS            Not  Given                   (3)                   (3)


                                  3.?i:-02               B.4E-05                3 E-01              1.1E-01               2.8E-04


                                  1.1F-02               7.5E-05                2 E«00              5.5E-03               3.8E-05


                                  4.4K-04               9.6E-05                5 E-04              8.8E-01               1.9E-01


                                  2.VK-04               i.2E-05            Not  Given                   (3)                   (3)
                                          Sum of  Ills - Worot.  C/nitj • 1.2E«0
                                          Sum o!  HlB - Moat.  Pir.:iablo Caao  -  2.0E-1
:'•••:
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                                                                      TABLE  5-3
                                                 CHILD RISK  CM/-. '.ACTERI ZATION (1) FOR  INGESTION
                                                 OK CKOUNDWATE1-    NONCAHC INOCEN I C EFFECTS
                                                       Moil'.  IT.  i.'iljlo
                                                             ::/.-. •• CD i
                                                          (::-.q/K.  -lay)
ACCEPTAULE
      DOSE
        12:
     HAZAJID INDEX  (1)
WORST CASE    MOST PROBABLE CASE
                                                              :   K - 01
                                                                                    6 K-02
                                                                                                         2.7E-02
                                                                                                                         2.8E-03
                                                              J  . K-04
                                                                                    9  E-03
                                                                                                         6.3E-01
                                                                                                                         3.4E-02
                                                              2. 'K-04
                                                                                 Not Given
                                                                                                             (3)
                                                                                                                             (3)
                                                                                 Not Given
                                                                                                             (3)
                                                                                                                             (3)
                                        i. IE-OI
                                                              2.9E-04
                                                                                    3  E-01
                                                                                                         3.7E-01
                                                                                                                         9.7E-04
                                        3.7E-02
                                                              2.6E-04
                                                                                    2 E'OO
                                                                                                         1 .9E-02
                                                                                                                         1.3E-04
                                                              3. IE-04
                                                                                       E-04
                                                                                                         3.0E-00
                                                                                                                         6.6E-01
                                        9. 4E-01
                                                              1 . UE-04
                                                                                 Not Given
                                                                                                             (3)
                                                                                                                             (3)
                                                 SU.TI of His  -  v.'-.jrat Csso  •  4.0 E'O
                                                 Sum o( Hie  -  F.ost Probable Case = 7.0  E-l
:-:(.•: i!:  lo  Tablu  3-6  .'or Exposuru  Souuu
      r'.a't. c.lflracier 1 zat lor.  .'or  r.r.::cnrt Inoqer.s  IB presented ae a Hazard  Index which  la the
      : ft'.: Q o' : .'.«j UMI 1 ^i» lor; 'CX^:,M.IO C!OBR  to  acceptable*  dor.o.
      /•• ! i:;.: nlili- !c.iin  •• /-. 1 l'.>w«!/li- ::.\n'r.i: -  Ciunnlr: (AIC)  n:\ ;n uacntucl  In Tallin 5-1.
 ;.    7:m  t!a'^/i:t: I :.C(.v.  cannot  t,«j  f/i: t:.: i /i'_ cd  ulncu an accopt.-.tjle doee  haa not been  eutabllahed.

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                                                   TABLE  5-4
                                            i  MMJI.T  INCREMENTAL  .'AKCINOCKNIC  RISK (i) ASSOCIATED
                                           -ii  :;:;;i;sT!Nc; CONTAM;-.ATED. CROUNDWATER
                                                                     .'••.en!, i'ruriaulo   Carcinogenic      Worat Caae        Moat  Probable Caae
                                             .1/1.•••,•              '  '        C'rfHo  CDI Potency  Factor     Incremental                Incremental
                                               : .• i      (ixj / X ^ I d .•>  .     (mg/kg/day)  (mg/kg/day)-1            Rlak                       Rlek



                                              'J.ll,         i.l,K-  :          •l.OE-Ob        7.5E-03           1E-06                       1E-07



                                              0.16         1.7E-  ;          9.0E-05      •     6E-01           4E-0^                       2E-05



•:ci!LOI!OK7liENE                               0.36         5.5E-  i          7. 8E-05      Not Given              (3)                         (3)


.:--/.r.HK                                        0.36         2.6E-'. 1          5.5E-05        2.9E-02           3E-05                       6E-07


!/%n                                           0.36         2.7E-CJ          5.2E-05      Not Given              (3)                         (3)



                                                   Sum of Incre::'intal Risk  -  Worot Caao -                  4E-4


                                                   Sum of Increi-.intal Rlak  -  Moat Probable Caae            2E-5
.-;«::  lu "aolcj 3-L  for exposure dorn..1!!.

    :.-.c;.'".':::i!:-.ial Orel :iou'-'.'i !c  Rluk •  Ku •_ 1 ;;ia too Lifetime Douu   CDI x Frequency) x  Carcinogenic  Potency Factor

    r': i:qi:i'.';cy * KnLlnfllutl  KxpoHuM: iJ6^>  tlayii/ycar  x  25 yfsflij,  70 yi;nr  1 1 t'nt imc) .

    ; : • : ••:•-•( n I .-i I It ; t\r.  . -/H-ii-.:  !ni . /i i • 'i ] /i I t»l H 1 IM •)  n  i-t\ i i; 1 n"t|i-: '. r (.1 '! n:ic. y  ' MC t.cjl In lii'l. i.;i t. vt t> 1 1 Illltsil .

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                                              TAflt.E  5-b
                              K::riMATr:i)  CHILD INCREMENTAL CARCINOGENIC RISK in ASSOCIATED
                                   WITH  INGESTING CONTAM!NATED CROUNDWATER
wo:nt. C« .1:   KOSI Probable   Carcinogenic     Worst  Caae
        (."•:        Caae  CD! Potency Factor    Incremental
        i.;     (mg/Kg/day)  (ng/kg/day)-1            RlaK
                                                                       1.7E-4
                                                                                      7.5E-03
                                                                                                         4E-6
                                                                                                                     Moat Probable  Case
                                                                                                                            Incremental
                                                                                                                                    Rlak
                                                                                                                                    5E-7
                                         0. 36
                                                                       3. 1E-4
                                                                                        6E-01
                                                                                                         1E-3
                                                                                                                                    7E-5
                                         0. 36
                                                                       2.7E-4       Not Given
                                                                                                          (3)
                                                                                                                                     (3)
                                         0. 36
                                                       9 . 1 E •• 3
                                                                       1.9E-4
                                                                                      2.9E-02
                                                                                                         1E-4
                                                                                                                                    2E-6
                                         0.36
                                                       9.4E-4
                                                                       1.BE-4       Not Given
                                                                                                          (3)
                                                                                                                                     (3)
                                              Sum of  Incremental  Risk - Worat  Case -
                                                                                                         1E-3
                                              Sum  of  Incremental  Rlak - Moat  Probable Caae
                                                                                                         7E-5
 '•. 'i'/il.l«-  :  i, '. ' n >:/ ;-i>iiu Mi il(.i-.«-ii.

i::c-:i.T.nr;liil  Cn i c'. noguii 1 c Risk  •  Eii'_ 1 nateri Lifetime DOBI.-  (CDI  x  Frequency)  x  Carcinogenic  Potency Factor

F: i:<;ii<;:ic:y  •  Kn L l:nn tui!  t'x [JODIJ : n  (JOI, dnyu/yoar  x  2i ycinin/VO  yuar lifetime).

:.-.r : ,::r.-:. •. *i :  J( : n * CM:I:H.:.  t>n CM., ulnltn] ti: r!f:o  tt  eft I c 1 noqi::. 1 c potuncy fnct-Or  In :iol outabllunod.

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          The ingestion quantity of fish was estimated at 6.5
          g/day both for an adult and child.  The fraction of the
          fish diet obtained from the immediate vicinity of the
          landfill was estimated at 20%.


6.3  Toxicity Assessment

     Cancer potency factors (CPFs)  have been developed by U.S.
     EPA's Carcinogenic Assessment Group for estimating excess
     lifetime cancer risks associated with exposure to
     potentially carcinogenic chemicals.  CPFs, which are
     expressed in units of (mg/kg/day)-1,  are multiplied by the
     estimated intake of a potential carcinogen, in mg/kg/day, to
     provide an upper-bound estimate of the excess lifetime
     cancer risk associated with exposure at that intake level.
     The term "upper bound" reflects the conservative estimate of
     the risks calculated from the CPF.  Use of this approach
     makes underestimation of the actual cancer risk highly
     unlikely.  Cancer potency factors are derived from the
     results of human epidemiological studies or chronic animal
     bioassays to which animal-to-human extrapolation and
     uncertainty factors have been applied (e.g., to account for
     the use of animal data to predict effects on humans).

     Reference doses (RfDs) have been developed by EPA for
     indicating the potential for adverse health effects from
     exposure to chemicals exhibiting noncarcinogenic effects.
     RfDs, which are expressed in units of mg/kg/day, are
     estimates of lifetime daily exposure levels for humans,
     including sensitive individuals.  Estimated intakes of
     chemicals from environmental media (e.g., the amount of a
     chemical ingested from contaminated drinking water) can be
     compared to the RfD.  RfDs are derived from human
     epidemiological studies or animal studies to which
     uncertainty factors have been applied (e.g., to account for
     the use of animal data to predict effects on humans).  These
     uncertainty factors help ensure that the RfDs will not
     underestimate the potential for adverse noncarcinogenic
     effects to occur.

     Table 4-5 presents the summary of the toxicity values for
     ingestion for the chemicals of concern.

     U.S. EPA weight-of-evidence classification for carcinogens
     are as follows:

     Group A - Human Carcinogen (sufficient evidence of
               carcinogenicity in humans).
                                11

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                                                          TAEiI.E  '. -•
                                         •"i   ;•'  i :;::• :;•.":i>:i TCX : t! •; •  .'/\LU:-
                                         \/:-  '"i!F  ::•:- ICATOR  COKPI.: .:;s
                                                                                                      PF  (3)
                                                                                                     '.5  E-3
                                                                                                       6  E-l
                                                                                                 '  '•">'. C 1 v o n
                                                                                                                                 EPA
                                                                                                                          WEIGHT OF
                                                                                                                           EVIDENCE
                                                                                                                                 B-2
                                                                            '. it. Given
                                                                                                     2.9  E-2
                                                      E-l
                                                                                3  E-l
                                                                                                   :ot Given
                                                   1  E-0
                                                                                2  E«0
                                                                                                   Not Given
                                                    1  E-3
                                                                                1  E-3
                                                                                                   Not Given
.V;O!-::UM
                                               Not Clvon
                                    1 E-3  (Food)
                                   5 E-4  (Water)
                                                                                                          N/A
                                                                                                                                 N/A
CliHOMIUM
 1 E-l  (Trlvalent)          1 i:-0 (Tilvalent)
2 E-2  (llexavalent)         5 E-3  ( Hex.-iva len t)
                                                                                                          N/A
                                               Not Given
                                                                            N  it Given
                                                                                                   Not Given
                                               Not Given
                                                                            N  :. Given
                                                                                                   Not Given
                                                                                                                                  82
!     A .' j c  A : 1 C -• & r.: u  : r. t a K o  -  S L ^c.':: :- r. 1:.'
     /• : f •   A : i fjw/i:. ] rj  ;r:'.rtKf:  -  C;i:<-:;U:
     ;j  •   '':lcliy valuua,  l.o.,  AIS, AIC  nnil  i'F, obtained  (rom  1:10 1906 Super fund  Public  Health  Evaluation Manual  and 1967  U.S.  EPA Memorandum
 ';;i::.'i : i- I  Mr.-.' o: HCOJ  Oo-.n:  /uui  Cflnc.-ci  i'Ol u:;;.11/ :U:i:i:)t.'r*n  loi1 UMU  In HlHk AtiutjiiQllien 111 ) .

     )•!  :,,:  t i li-:i:i.:tii!l!n-:i>!  wl tin!! .-i..-:. '. :•.  .:  i'; •;  I'lH'J
      .i::f::  il: i nk ! ::•;  -.iif:  n:/m.!/i: •:  : "  '.   ' :•••:.".;  liiinKliu) w.i'i;:  c: i  • IM I ,i  l)oi:i]inr.T i  (:<.>:iclud(!il t.oxlclty data unro  Inadequato  foi

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     this range and, therefore, require that remedial action be
     taken. (See assessment tables 5-4 and 5-5 as presented
     here).

                CALCULATED RISKS AT THE MDSL SITE

                         Adults              Children

HAZARD INDEX (HI)          1.2                 4.0
  (Noncarcinogenic)

CARCINOGENIC             4 X 10-4            1 X 10-3

     NOTE:     HI greater than 1 indicates an unacceptable risk.
               Carcinogenic risk greater or equal to 1 X 10-4
               exceeds the NCP upper range.


6.6  Potential Future Risks

     Actual or threatened releases of hazardous substances from
     this site, if not addressed by implementing the response
     action selected in this ROD, may present an imminent and
     substantial endangerment to public health, welfare, or,  the
     environment.
6.7  Uncertainties

     There are a number of uncertainties existing at the site
     with respect to the extent of contamination such as the lack
     of assessment information on contact with the waste mass and
     dermal contact risk involving children.  Additional data may
     be gathered for the final operable unit that addresses the
     wetlands, surface water and groundwater pathways.


7.0  DOCUMENTATION OF SIGNIFICANT CHANGES

     The U.S. EPA has reviewed and responded to all relevant
     comments received from the interested parties, including
     those from the State and community, during the public
     comment period.  Comments were made on the selected
     alternatives as well as other  remedial alternatives.  Based
     on the public comments, the U.S. EPA has determined that
     there is no need for any significant changes to Waste Mass
     Alternative 3 and Groundwater Alternative 3.

     In the event that additional data or information during the
     design of the remedy reveals the need for a modification,
     the U.S. EPA will notify the public of any changes to the
     remedy presented here in this Record of Decision in

                                13

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     accordance with applicable law, the NCP and U.S. EPA
     guidance.
8.0  DESCRIPTION OF ALTERNATIVES

     The Feasibility Study developed two sets of remediation
     alternatives that were subject to "detailed analysis."
     Four alternatives were developed to address contaminated
     groundwater, and five alternatives addressed the landfill
     itself (referred to as "waste mass").

     As noted above, groundwater will be dealt with in two
     operable units or distinct actions.  This ROD addresses the
     first groundwater operable unit, which is an interim action
     for source control.  It is expected that the remedy for the
     waste mass in conjunction with source control efforts will
     be a final remedy.  The alternatives for the MDSL site are
     presented below.  To the greatest degree possible, the
     interim groundwater action will be consistent with the final
     remedy.

8.1  Waste Mass Alternatives
8.1.1  Waste Mass Alternative 1 rWMll - No Action

     The National Contingency Plan (NCP) requires that a No
     Action Alternative be evaluated for every site as a baseline
     of comparison for the other alternatives.  Under this
     alternative, nothing would be done at the site regarding
     the waste mass.  The site would continue to exist in its
     present condition.

     Time to Implement:            None
     Capital Cost:                 $0.0
     Annual O & M Cost:            $0.0
     Total Present Worth Cost:     $0.0


8.1.2     Waste Mass Alternative 2 (WM2) - Monitoring/Maintenance

     This alternative would consist of limiting access to the
     site, routine inspection and maintenance of the existing
     cover, consisting of native soils, and implementing
     institutional controls (deed restrictions).

     Monitoring during this alternative would include inspections
     of the landfill cover and security systems, and sampling of
     existing wells.  The need for the installation of additional
     monitoring wells would be determined during the remedial
     design, and be installed as necessary.  Deed restrictions

                                14

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     would alert future land owners of the presence of hazardous
     substances, and the prohibition of excavation into the
     waste mass.  This alternative would only be chosen if
     active response measures are not practicable, as specified
     in the NCP.

     Time of Implement:            2 months
     Capital Cost:                 $107,500
     Annual O & M Cost:            $ 42,130
     Total Present Worth Cost:     $505,000


8.1.3     Waste Mass Alternative 3 (WM3) - Capping
  ^
     This alternative provides for the covering of the waste mass
     with a clay/soil cap.  Capping will reduce the potential
     migration of contaminants into the groundwater, prevent
     direct contact with the waste mass, and reduce potential
     impact to surface water bodies from storm-
     water/precipitation run off.  The cover system would be
     designed to meet State of Wisconsin specifications per the
     Wisconsin Administrative Code, NR 504.07 and NR 506.08.
     This cap will consist of a grading layer, a minimum of two
     feet of compacted clay, a 1-1/2 to 2-1/2 foot frost
     protection layer, and a minimum of 6 inches of cover
     topsoil.  Dust production during construction of the cap
     will be minimized.  The cap construction will be conducted
     to minimize wetlands impacts.  Wetlands adversely impacted
     by the remedy will be repaired or mitigated.  In addition,
     an active gas extraction system will be installed as a part
     of the cap system (see figure 8-1).

     After installation of the cap, the area would be fenced,
     signs erected and a long-term monitoring program initiated.
     Deed restrictions would be required to prevent future
     construction on the property.  Monitoring and maintenance
     would be the same as in Alternative WM2.

     Time to Implement:            6 months
     Capital Cost:                 $3,495,000
     Annual O & M Cost:            $   54,130
     Total Present Worth Cost:     $3,608,000


8.1.4     Waste Mass Alternative 4 (WM4) - In-Situ Vitrification

     This alternative would vitrify the entire waste mass through
     the use of a high intensity electrical current.  Heat from
     the electric current would melt the soil and decompose
     organic materials.  During the process, metallic and other
     inorganics would dissolve into or are encapsulated in the
     vitrified mass.  Gasses evolved from the melt would be

                                15

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Gas Venting
 vstemfes needed)!!
         Slope: 5% (min.)-4:1 (max.)

         Cover Vegetation
         Topaoft: 6 inches
         Cow Soil: 18-30 Inches
         Compacted Clay; 24 inches
         Grading Layer: 6 Inches
               Mass
FIGURE 8-1

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     recovered by an off-gas collection system placed over the
     area.  These off gasses would then be routed through a
     scrubber system for treatment.  Scrubber effluent would then
     require treatment to meet state emission standards prior to
     discharge.  To the degree possible, such treatment could be
     accomplished as outlined herein for alternatives GW3 and
     GW4.  When the electric current ceases, the molten mass
     cools and solidifies into a glass-like material that will
     permanently retain its physical and chemical integrity.

     Approximately 5 tons per hour would be expected on the
     average to be vitrified.  Generally, operations are
     conducted 24-hours per day, seven days per week utilizing
     four crews.  Normally, on a large scale job, an area
     selected for vitrification is processed (vitrified) for four
     days then the equipment is moved to a different location on
     the site (requiring about 16 hours) and operations re-
     initiated.  Given the size of the site (26 acres), and based
     on the mobilization rate, it would take well over 20 years
     to complete the vitrification.  Once the vitrified mass
     cools, the area would be backfilled.

     Following vitrification, contaminant mobility would be
     sharply curtailed, thereby reducing risk associated with the
     MDSL site.

     Time to Implement:            22+ years
     Capital Cost:                 $255,510,000
     Annual O & M Cost:            $          0
     Total Present Worth Cost:     $255,510,000


8.1.5     Waste Mass Alternative 5 (WM5) - Complete Removal with
          Disposal at Off-Site Landfill

     This alternative provides for the complete excavation of the
     waste mass and transportation to an approved facility for
     disposal.  Disposal would have to be in accordance with
     applicable state and federal regulations.

     During operations, worker dermal and respiratory protection
     equipment would be required.  Special dust suppression
     measures would have to be implemented to reduce the
     potential for off-site migration of contaminated
     particulate.  The estimated 668,000 cubic yards of waste
     would be excavated and loaded using conventional excavation
     equipment (i.e. dozers, backhoes and front-end loaders).

     Due to the volume of material to be disposed of, the bulk
     solid waste would have to be disposed of at a number of
     different landfills.  Landfill capacity would be a major
                                16

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     concern in this alternative.  If 60 loads were dispatched
     per day, approximately 760 work days would be required to
     complete the excavation.

     To sustain a removal rate of 60 loads per day,
     approximately 180 trucks need to be in the load-transport-
     unload cycle.

     Alternative WM5 involves "clean closure" of the site by
     completely excavating wastes and landfilling them off-site.
     Major environmental requirements with which this alternative
     would have to comply include the Resource Conservation and
     Recovery Act (RCRA), and State of Wisconsin regulations
     governing solid waste handling and transport.

     The U.S. EPA does not believe that Land Disposal
     Restrictions (LDRs) are an ARAR for this site, because the
     contaminants present do not appear to be among those so
     restricted.  However, no toxicity tests were conducted on
     the waste.  If this alternative were chosen, however, the
     wastes would be tested by the toxic contaminant leachate
     procedure (TCLP) to determine if the wastes are hazardous.
     Cost calculations assumed non-hazardous wastes.

     Time to Implement:            3 years
     Capital Cost:                 $142,816,320
     Annual O & M Cost:            $          0
     Total Present Worth Cost:     $142,816,320


8.2  Groundwater Alternatives

     As an interim action for groundwater, and a component of the
     source control operable unit, the remedial goal for the
     groundwater remedy in this ROD is to contain known
     contaminated groundwater in the surficial aquifer.
     Information derived from this operable unit concerning the
     effects of a groundwater extraction system on the
     surrounding wetlands and the hydrogeology of the site will
     aid in the selection of remedy for the final groundwater
     operable unit.   U.S. EPA could expect, through pumping tests
     and evaluation of containment achieved by extraction wells
     to learn more about aquifer response.  This information can
     then be utilized to evaluate the need for other extraction
     components, wetlands mitigation measures, and whether
     extraction measures should be augmented.


8.2.1.    Groundwater Alternative 1 (GW1) - No Action

     The NCP requires that a No Action Alternative be evaluated
     for every site as a baseline of comparison for the other

                                17

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     alternatives.  Under this alternative no work would be done
     at the site regarding the waste mass or the groundwater.
     The site would continue to exist in its present condition.
     Risks posed as noted earlier in this document would be
     unabated.

     Time to Implement:            None
     Capital Cost:                 $0.0
     Annual O & M Cost:            $0.0           ,
     Total Present Worth Cost:     $0.0
                                    (GW2) -
8,2.2     Groundwater Alternative 2	
          Monitoring/Maintenance

     This alternative would consist of long-term for at least 30
     years groundwater monitoring and deed restrictions over the
     area of the contaminant plume to prevent use as a drinking
     water source.

     Monitoring during this alternative would include such
     sampling as a network of existing and potential new
     monitoring wells, surface water, and wetlands.  The need for
     the installation of additional monitoring wells would be
     determined during the remedial design.  Deed restrictions
     would alert future land owners of the presence of hazardous
     substances and the prohibition of installation of
     residential wells into the contaminated groundwater plume.
     However, compliance with such restrictions cannot be
     assured.  Risks posed as noted earlier in this document
     would be unabated.  Pertinent regulations to be attained by
     this alternative include federal/state regulations on proper
     landfill post-closure monitoring.

     Time to Implement:            2 months
     Capital Cost:                 $107,500
     Annual O & M Cost:            $ 42,130
     Total Present Worth Cost:     $505,000
8.2.3     Groundwater Alternative 3 (GW3) - Groundwater
          Extraction Well Systems

     This alternative consists of a groundwater extraction and
     treatment system for the purpose of plume containment, as
     part of source control with discharge of treated groundwater
     to the Fox River.  Within this alternative, the following
     four treatment technologies will be discussed:
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          o    Air Stripping
          o    Carbon Adsorption
          o    Ion-Exchange
          o    Chemical Treatment

     Treatability studies during the remedial design will
     determine the appropriate technology or combination of
     technologies for groundwater treatment.  The technology
     selected must comply with discharge limits as well as Best
     Developed Available Technology (BOAT) for this type of
     discharge.  Attachment A indicates the effluent limitations
     that the system must meet for surface water discharge based
     on NR 102, NR 105, NR 106 and NR 207 of the Wisconsin
     Administrative Code.

     The extraction system itself will be designed to pump
     groundwater hydraulically downgradient of the waste mass and
     upgradient of the Fox River to prevent discharge of the
     contaminant plume into the wetlands and river.  The number
     of extraction wells, location, depths and average extraction
     rates will be determined during the remedial design stage.
     The pump system will be designed to contain contaminated
     groundwater emanating from the site while not having a
     negative impact on the wetlands.   If wetland impacts occur,
     mitigation of wetlands will be necessary.

     In addition to the groundwater extraction and treatment
     system, this alternative would include continuous extensive
     groundwater monitoring, temporary deed restrictions over the
     area of the contaminant plume, assessment of the effects of
     the interim remedy on the surrounding wetlands, and long-
     term operation and maintenance of the extraction system.

     The presence of 1,1-dichloroethene and trichloroethene,
     because of their ability to sink, may pose a long-term
     challenge to cleaning up the aquifer.  The second operable
     unit will address potential problems associated with aquifer
     clean up.  U.S. EPA estimates that 1 to 2 years of operation
     of this alternative would generate sufficient information in
     order to reach a decision on components of a final operable
     unit regarding groundwater and impact to wetlands.

     Costs for each of the technologies have been estimated.  The
     following is a discussion of each of the groundwater
     treatment technologies with their respective costs.


8.2.3.1   Groundwater Collection with On-Site Air Stripping
          Followed by Discharge

     Following recovery, the groundwater would be pumped through
     a filter system to remove suspended particulates that could

                                19

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     cause operational problems and decrease system efficiencies
     (unserviceable filter elements or backwash from cleaning
     filters must be collected and properly disposed of).
     Effluent from the filter system would be injected at the top
     of a packed air stripper column. Treated effluent in
     compliance with state NPDES requirements, would pass through
     an effluent monitoring station and then be piped to an
     outfall at a drainage channel adjacent to the site.

     Monitoring would be performed at the outset of operations to
     define effluent variability and to assure compliance with
     required limits.  An air quality risk assessment may be
     required as part of this alternative.
 ^
     If volatile air emissions exceed standards, emission
     controls will be required to be in compliance with NR 445
     Wisconsin Administrative Code.  Any additional requirements
     necessary as part of Chapter 144.391 and 144.393 pertaining
     to non-attainment areas would also need to be met.  In
     addition, the substantive requirements of a Wisconsin
     Pollutant Discharge Effluent Standards (WPDES) permit would
     have to be met prior to discharging the effluent to the
     drainage channel. Operation and maintenance costs are
     projected over a thirty year period.

     Time to Implement:            1 year
     Capital Cost:                 $  183,300
     Annual O&M Cost:              $   88,600
     Total Present Worth Cost:     $1,024,000


8.2.3.2   Groundwater Collection with On-Site Carbon Adsorption
          Followed by Discharge

     Following recovery, the groundwater would be pumped through
     a filter system to remove suspended particulates that could
     cause operational problems (e.g., plugging of the carbon
     bed).  (Note: Plugged filter elements or backwash from
     cleaning filters must be collected and properly disposed
     of).  Effluent from the filtration unit would flow to
     carbon adsorption units (one to serve as a spare during
     carbon replacement).  Treated effluent would be discharged
     to the drainage channel adjacent to the site.

     The substantive requirements of a WPDES permit would have to
     be met prior to discharging the effluent to the drainage
     channel.   Effluent monitoring/analysis would be needed.

     Time to Implement:            1 year
     Capital Cost:                 $  195,000
     Annual O&M Cost:              $   91,400
     Total Present Worth Cost:     $1,063,000

                                20

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8.2.3.3   Groundwater Collection with On-Site Ion-Exchange
          Treatment Followed by Discharge

     This system would be identical to the air stripping or
     carbon adsorption system except that in lieu of the stripper
     or carbon adsorption unit a fixed-bed, counter-current ion
     exchange unit would be utilized.

     As with the other systems, the treated effluent would be
     discharged to the drainage channel adjacent to the site.
     Prior to discharge, the substantive requirements of a WPDES
     permit would have to be met.

     When exhausted, the resin would be regenerated by
     backwashing.  The backwash would be stored for off-site
     disposal..

     Time to Implement:            1 year
     Capital Cost:                 $  293,800
     Annual O&M Cost:              $  110,000
     Total Present Worth Cost:     $1,337,000


8.2.3.4   Groundwater Collection with On-Site Chemical Treatment
          Followed by Discharge

     Recovered groundwater would be pumped to a pH adjustment
     •t-ank where lime would be added to raise the pH.   Fro~ this
     tank the liquid would flow to a mixing tank where
     flocculating polymers would be added and mixed.   The liquid
     would then be pumped to a sedimentation tank where the
     flocculated solids would settle out and be removed for
     disposal at an off-site facility.  The treated effluent
     would flow to a tank for final pH adjustment prior to
     release to the drainage channel adjacent to the site.

     Since this system would be effective only for inorganic
     compounds, it would have to be integrated with other
     treatment systems to address organic contaminants.
     The substantive requirements of a WPDES discharge permit
     must be met prior to initiation of treatment.

     Time to Implement:            1 year
     Capital Cost:                 $  430,300
     Annual O&M Cost:              $  103,070
     Total Present Worth Cost:     $1,408,000
                                21

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8.2.4     Groundwater Alternative 4 (GW4) - Groundwater
          Collection with Barrier

     This alternative would involve the design and implementation
     of a groundwater extraction system with a barrier system
     4,076 feet long installed around the perimeter of the
     landfill.  This barrier system would be anchored to a soil
     layer approximately 40 feet below the ground's surface or to
     the dolomite bedrock layer.  This barrier would be either a
     slurry wall, composed of a mixture of low-permeable clay and
     soil, or would be made of other material.  The barrier would
     prevent uncontaminated ground water from moving through and
     from the landfill and becoming contaminated.  The
     contaminated groundwater within the barrier would be
     extracted and treated.  The projected cost for this
     alternative would be up to $1.8 million, in addition to the
     cost of well installation and treatment, described above.

     Time to Implement:              1 year
     Capital Cost (barrier only):    $1,983,112
     Annual O&M Cost (barrier only): $   88,000
     Total Present Worth Cost:       $3,100,000
     (barrier + GW treatment)


9.0. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

     The alternatives are evaluated against the nine criteria
     recommended by U.S. EPA  (U.S. EPA, 1987).  The criteria are
     as follows:

     1)   Overall protection of human health and the environment
          addresses whether or not an alternative provides
          adequate protection and describes how risks are
          eliminated, reduced or controlled through treatment and
          engineering or institutional controls.

     2)   Compliance with Applicable or Relevant and Appropriate
          Requirements  (ARARs) addresses whether or not an
          alternative will meet all of the applicable or relevant
          and appropriate requirements or provide grounds for
          invoking a waiver.

     3)   Long-term Effectiveness and Permanence refers to the
          ability of an alternative to maintain reliable
          protection of human health and the environment, over
          time, once cleanup objectives have been met.

     4)   Reduction of Toxicity, Mobility, or Volume  is the
          anticipated performance of the treatment technologies
          an alternative may employ.
                                22

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     5)    Short-term Effectiveness involves the period of time
          needed to achieve protection and any adverse impacts on
          human health and the environment that may be posed
          during the construction and implementation period until
          cleanup objectives _are achieved.

     6)    Implementability is the technical and administrative
          feasibility of an alternative, including the
          availability of goods and services needed to implement
          the solution.

     7)    Cost includes capital costs, as well as operation and
          maintenance costs.

     8)    State Acceptance indicates whether, based on its
          review of the RI/FS and Proposed Plan, WDNR agrees on
          the preferred alternative.

     9)    Community Acceptance indicates the public support of a
          given alternative.  This criteria is discussed in the
          Responsiveness Summary.


9.1  Overall Protection of Human Health and the Environment

     The No Action and Monitoring/Maintenance alternatives (WM1,
     WM2,  GW1, GW2) are not protective of human health and the
     environment because they do not eliminate, reduce or
     control risks through various combinations of treatment and
     enaineerina controls and/or institutional controls.  Taking
     no action to address the groundwater would allow unabated,
     unmonitored movement of contaminants whose ingestion poses
     an unacceptable risk.  The no action alternatives are also
     unacceptable because the existing site cover is showing
     signs of disrepair and erosion, which may increase human
     contact with the contaminants.  Further, the alternatives
     also would not protect the surface water and wetlands from
     continued deterioration.  The monitoring/maintenance
     alternatives are not protective of human health and the
     environment.  They may reduce the potential for human
     contact with site contaminants and portions of these
     alternatives may be a component of other alternatives, they
     would not stop the deterioration of the landfill cover or
     halt the movement of the ground-water contamination.  As the
     no action and monitoring/maintenance alternatives do not
     provide protection of human health and the environment,  it
     is not eligible for selection and shall not be discussed
     further in this document.
                                23

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     Alternatives WM3, WM4,  and WM5 all provide adequate
     protection of human health and the environment by reducing
     contaminants moving into the groundwater,  and by reducing
     human contact with the waste mass.  Contaminant movement
     would be reduced by either capping, in-situ vitrification,
     or excavation and removal of the waste mass.

     Alternatives GW3 and GW4 are protective of human health and
     the environment.  They would not necessarily eliminate all
     releases; however, they would contain such releases.
     Therefore, these alternatives are considered protective.
     Both of these alternatives would collect and treat
     contaminated groundwater to state-established effluent
     limitations followed by discharge to a surface water body.
     One of several groundwater treatment methods would be chosen
     during the remedial design.  The treatment methods to be
     considered include: on-site air stripping; on-site carbon
     adsorption; on-site ion-exchange; and on-site chemical
     treatment.  Alternative GW4 would utilize a barrier system
     in conjunction with the recovery system.  These 2
     alternatives, at present, are not intended to restore
     groundwater to federal and state standards.

     Alternatives WM3, WM4,  and WM5 will provide adequate
     protection of human health and the environment over time.
     The groundwater alternatives GW3 and GW4 will provide
     adequate protection particularly with respect to short-term
     impact.


9.2. Compliance with Applicable or Relevant and Appropriate
     Requirements (ARARs)

     SARA requires that remedial actions meet legally applicable
     or relevant and appropriate requirements (ARARs) of other
     environmental laws.  These laws may include: the Safe
     Drinking Water Act, the Clean Air Act, the Clean Water Act,
     the Resource Conservation and Recovery Act  (RCRA), and any
     state law which has stricter requirements than the
     corresponding federal law.

     A "legally applicable" requirement is one which would
     legally apply to the response action if that action were not
     taken pursuant to Sections 104, 106 or 122 of CERCLA.  A
     "relevant and appropriate" requirement is one that, while
     not "applicable," is designed to apply to problems
     sufficiently similar and that their application is
     appropriate.

     Waste Mass alternatives 3,4, and 5 will comply with all
     applicable or relevant and appropriate federal and state
     environmental standards.  The ground water  interim action

                               24

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     would need to comply with only those action-specific and
     chemical-specific ARARs associated with the technologies
     utilized for ground water collection,  treatment,  discharge,
     and residuals management.  As provided for in EPA's
     "Guidance on Remedial Actions for Contaminated Ground Water
     at Superfund Sites (OSWER Directive No. 9283.1-2; December
     1988)," "Clean-up levels for the site typically are not
     established since interim actions are not final.   Thus, an
     interim ground-water action need not achieve chemical-
     specific ARARS in groundwater." Therefore no chemical-
     specific cleanup standards will be established at this time
     for the existing contaminant plume.  The final operable unit
     for ground water at this site will ensure that the federal
     clean-up standards or the more stringent State of Wisconsin
     ground water quality standards established in Chapter 160,
     Wisconsin Statutes, and Chapter NR 140, WAC will be complied
     with for the entire site, or justification provided if
     either the federal or State standards are waived.

9.3. Long-Term Effectiveness and Permanence

     The alternatives considered for the MDSL site vary in their
     ability to provide long-term effectiveness and permanence.

     Waste Mass Alternative 4 (WM4) provides the greatest degree
     of permanence.  In-situ vitrification of the waste mass
     would melt the soil and decompose organic wastes.  When the
     mass cooled, metallic and other inorganic substances would
     be trapped in the glass-like mass.

     Waste Mass Alternative 5 (WM5) would offer a somewhat higher
     degree of permanence than WM3.  WM5 consists of excavation
     of the entire waste mass and disposal of in three RCRA-
     permitted facilities, which offer more rigorous protection
     against infiltration than WM3.  The waste mass would be
     landfilled without treatment.  However, off-site disposal of
     wastes without treatment is defined in SARA as a least
     preferred alternative.

     Alternative WM3 should provide an effective, long-term
     method for preventing infiltration to or contact with the
     waste mass if the cover is properly maintained.  The
     clay/soil cap would be constructed in accordance with the
     Wisconsin Administrative Code, NR 504.07 and NR 506.08.  It
     would consist of a minimum two foot thick clay cap with a
     minimum 1.5 to 2.5 foot thick frost protection layer and a
     final soil cover layer for vegetation.

     Groundwater Alternatives GW3 and GW4 provide the same
     amount of protection.  Both of these groundwater
     alternatives consist of a groundwater recovery system
     followed by treatment of the groundwater to State-

                               25

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     established effluent limitations.  Alternative GW4 provides
     a barrier in conjunction with the groundwater
     recovery/treatment system, which takes into consideration
     the long-term impact extraction may have on the river and
     wetlands.
9.4. Reduction of Toxicity. Mobility, or Volume Through
     Treatment

     The only Waste Mass Alternative that reduces the toxicity,
     mobility, or volume through treatment is in-situ
     vitrification (WM4).   In-situ vitrification melts the waste
     mass and solidifies it into a glass-like structure.

     The other two Waste Mass Alternatives do not provide
     treatment of the waste mass and therefore do not meet this
     criteria.  A clay/soil cap is not considered to be
     treatment, nor is excavation and disposal to an off-site
     landfill.

     Both of the groundwater alternatives are expected to reduce
     the toxicity and possibly mobility of groundwater
     contaminants through treatment.  Both alternatives consist
     of a groundwater recovery system in conjunction with
     treatment to state-established effluent limitations.
     Neither GW3 nor GW4 would address the full extent of
     groundwater contamination from this site.


9.5  Short-Term Effectiveness

     Alternative WM3 would require approximately 6 months to
     implement and should effectively prevent contact with
     contaminants within two months of initiation.  There is the
     potential for site personnel to be exposed through direct
     contact with materials during initial cleanup activities,
     although these exposures could be reduced by following
     standard health and safety and emission control procedures.
     Alternative WM5 is expected to require at least 3 years to
     implement, but should result in a fairly rapid removal of
     exposure pathways to the public, except for the increased
     opportunity of airborne emissions during excavation and
     transport.  These potential exposures would be reduced by
     instituting proper health and safety procedures.  Exposure
     from transportation of materials off site also may be a
     concern.  Alternative WM4,  however, would not be effective
     in the short term.  It could require up to 22 years to
     implement, during which time exposure routes to humans and
     the environment would remain.
                                26

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     Alternatives GW3 and GW4 are estimated to have a 1 year
     installation time for the extraction and treatment system.
     The specific short-term effectiveness of these alternatives
     would depend on the treatment system chosen during the
     remedial design.

     The groundwater recovery system could have adverse impacts
     on the surrounding wetlands if the extraction rate exceeds
     the groundwater recharge rate.  In addition, this system
     could have impacts on the river and effluent standards for
     downstream dischargers because it is a waste load allocated
     river.  The barrier associated with groundwater alternative
     4 could have a substantial adverse impact on the surrounding
     wetlands depending on construction techniques used to
     implement it.


9.6  Implementabilitv

     While all of the alternatives considered are implementable,
     some alternatives are technically easier to implement than
     others, based on their design and complexity.

     Alternative WM3 could be readily implemented because the
     technology for landfill capping is well established.
     Alternatives WM4 and WM5 present serious implementation
     difficulties.  There are relatively few vendors that offer
     the technology that comprises Alternative WM4; this would
     delay implementation.  While in-situ vitrification has been
     selected as a remedy on other sites in Region V, no project
     approaches the magnitude of material proposed for treatment
     in this fashion as at the MDSL site.  Alternative WM5 poses
     potential difficulty in obtaining sufficient landfill
     capacity to dispose of the waste mass, and implementation
     also may be delayed.  As noted in Section 8 of this
     document, the sheer logistics of dedicating a large fleet of
     trucks (180)  to this project will be difficult to implement.

     Alternatives GW3 and GW4 should be readily implementable
     because the technology for groundwater recovery and
     treatment is well established.  The need to conduct
     treatment studies before the system is implemented may cause
     some delay.  The barrier associated with Alternative GW4 may
     not be easily implementable due to potential detrimental
     impacts the construction may have on the surrounding wetland
     areas.
9.7  Cost

     The estimated present worth value of each alternative and
     option is as follows:

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     Waste Mass Alternatives

          WM3       $  3,608,000
          WM4       $255,510,000
          WM5       $142,816,320

     Groundwater Alternatives

          GW3       $2,000,000
          GW4       $3,800,000
9.8  State Acceptance

     WDNR concurs on the selected final and interim remedies
     presented in this ROD.  The WDNR predicates this concurrence
     on the interim nature of the response action planned for the
     groundwater and the implementaion of measures required to
     mitigate impacts to the wetlands the groundwater action may
     have.

9.9- Community Acceptance

     Community acceptance of the preferred alterative will be
     discussed in the Responsiveness Summary in this Record of
     Decision.
10.0 THE SELECTED REMEDY

     Based on the findings of the Remedial Investigation and
     Feasibility Study, and the evaluation of the nine criteria,
     U.S. EPA and WDNR have identified the combination of
     Capping, landfill gas venting (Waste Mass Alternative WM3)
     and Groundwater Extraction Well Systems and treatment
     (Groundwater Alternative GW3) to be the preferred
     alternatives.  These alternatives involve a combination of
     site capping and ground-water extraction with the capability
     to remove both inorganic and organic pollutants, followed by
     discharge of the treated groundwater.  The combined cost of
     these two alternatives is approximately $6 million.

     Based on the information available at this time, U.S. EPA
     and WDNR believe that the selected remedies would be
     protective of human health and the environment, would attain
     ARARs, and would be cost effective.  These actions use
     permanent solutions and alternative treatment technologies
     to the maximum extent practicable.
                                28

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Wetlands

The concern for the welfare of the wetlands surrounding the
MDSL site is the primary reason for the interim ground water
remedy approach for this first operable unit.  The potential
for an overly aggressive ground water extraction system
adversely impacting the wetlands exists in large measure.
The goal for the interim ground water remedy is to contain
the ground water contaminant plume to prevent its discharge
into the Fox River with minimal adverse impact to the
surrounding wetlands.  During the operative life of the
interim ground water remedy component, the wetlands
surrounding the site will be monitored to determine any
changes in conditions.  Prior to implementation of the
ground water remedy, delineation and inventory of the
wetlands will be undertaken.

It is expected that this monitoring effort will emphasize
delineation of the wetland-upland boundary, as opposed to
the lower boundary between wetlands and aquatic habitats.
In conducting such monitoring, it will likely be important
to consider frequency of occurrence of hydrophytic
vegetation (such as obligate wetland plants), soils which
are saturated or ponded frequently enough such that they
develop anaerobic  conditions, and hydrology of the area
under consideration.

At any point during the operation of the ground water
extraction system where it has been determined that the
wetlands have been adversely impacted, the system will be
shut down and reevaluated for further action.
Source Control

Source control is a primary remedial goal for this first
operable unit.  Capping of the waste mass is a component in
the effort of source control.  It is believed that portions
of the waste mass are in contact with the ground water
table.  Consequently, ground water contamination will
continue to emanate from the waste mass to some degree.  The
interim ground water remedy component will also function as
a component of source control.

After a period of monitoring the performance of the first
operable unit, additional source control measures may
involve the construction of an upgradient cut-off wall to
the landfill.  The cap for the waste mass will not be
affected by any additional measures contemplated.  It should
be pointed out that in circumstances of extreme flooding
events, the cap and waste mass may be subject to erosion.
                           29

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     This will be monitored indefinitely over the lifetime of the
     remedy.


1.1.0 STATUTORY DETERMINATIONS


11.1 The Selected Remedy is Protective of Human Health and the
     Environment

     Based on the risk assessment developed for the site,  dermal
     contact with the waste mass, ingestion of contaminated
     groundwater, incidental ingestion of contaminated surface
     water and ingestion of contaminated fish are identified as
     the primary risks with the site.  Implementation of the
     clay/soil' cap and an active venting system in accordance
     with Wisconsin Administrative Code NR 504.07 and NR 506.08
     will serve to reduce groundwater infiltration and eliminate
     the potential for dermal contact with the waste mass.  The
     interim groundwater recovery and treatment system will
     contain the groundwater plume thereby preventing further
     migration of the contaminant plume.  The selected remedy
     should assist in improving surface water quality near the
     site.


11.2 The Selected Remedy Attains ARARs

     The waste mass alternative, clay/soil cap, will meet or
     attain all applicable or relevant and appropriate Federal
     and state requirements directly associated with the actions.
     The interim groundwater alternative will meet the ARARs
     pertinent to the scope and purpose of the interim action.

     The following is a description of the environmental laws
     which are legally applicable or relevant and appropriate to
     different components of the remedy.


     o    Clay/Soil Cap

     Regulations are found in Chapter NR 504 of the Wisconsin
     Administrative Code, which governs solid waste disposal
     facilities which did not accept hazardous wastes after 1980.
     While both solid and hazardous waste regulations are
     potential ARARs, it was determined that an NR 504.07 cap
     provides adequate protection.  Subtitle C landfill
     requirements, while relevant were determined not to be
     appropriate.  It is likely that waste is in contact with the
     groundwater, making a synthetic cap ineffective in
                               30

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minimizing leaching.  In addition, because large volumes of
non-hazardous industrial wastes and some municipal wastes
were disposed of at MDSL, a large amount of settling will
continue to occur due to decomposition of wastes, making the
synthetic membrane subject to damage over the long term.
Section NR 504.07 seeks to minimize infiltration by
specifying clay type, slope and topsoil requirements for a
final cover for the landfill.  The regulations require a gas
venting system, to relieve gas build-up beneath the cap (NR
445, NR 504.07, NR 506, NR 508, NR 514.07 Wis. Adm. Code).
Furthermore, Wisconsin Statute Chapter 160 and Chapter NR
140, WAC indicate that for final action one must prevent the
continued release of contaminants to groundwater, at or
above state groundwater quality standards.

o    Groundwater Extraction and Treatment

As discussed previously, the groundwater remedy is an
interim and not a final remedy.  The purpose of this interim
remedy is to contain the plume of contaminated groundwater
while U.S. EPA, in consultation with the State of Wisconsin,
determines how best to address the groundwater contamination
while maximizing protection of the wetlands.  Because
restoration of the aquifer is not a goal of this operable
unit, the interim groundwater remedy will not meet all
ARARS,  specifically National Primary and Secondary Drinking
Water Standards (40 CFR 141, 143) and Wisconsin Groundwater
Quality Standards (NR 140, Wis. Stats. Wis. Adm. Code).
After gaining some experience with this interim remedy, the
issue of aquifer restoration will be addressed and these
ARARS will addressed in the final ROD.

Groundwater which is extracted, treated and subsequently
discharged must meet the substantive requirements of the
National Pollutant Discharge Elimination System (NPDES, 40
CFR 122, 125)  and the Wisconsin Pollutant Discharge
Elimination System (WPDES).  Discharge of treated
groundwater to the drainage channels adjacent to the site,
and ultimately to the Fox River, shall meet the substantive
requirements of Section 402 of the Clean Water Act and shall
not exceed discharge limits established by the State of
Wisconsin (NR 102, NR 105, NR 106, and NR 207 Wis. Adm.
Code).   Groundwater extraction and monitoring will be done
in compliance with Wisconsin Groundwater Monitoring and
Recovery Requirements (NR 141, NR 181, Wis. Admin. Code)
Effluent limitations are noted in Attachment A.

If groundwater treatment occurs through air stripping, air
emissions must not exceed the limits set by U.S. EPA (40 CFR
50, 61)  and the State of Wisconsin (NR 404, NR 415, NR 445
Wis. Adm. Code).
                           31

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o    Floodplain Wetlands Policy

U.S. EPA has a floodplain and wetlands policy which
regulates construction in a floodplain (similar to RCRA 40
CFR 270.14(b)(ii)(iv) and filling of wetlands (40 CFR 230).
Impacts to both the wetlands an floodplain will be
considered and minimized to the maximum extent possible
during the design phase of this operable unit as directed in
Executive Order 11990 and 11988, respectively.  The State of
Wisconsin also has policies on protection of wetlands (NR
1.95, NR 115, NR 117 Wis. Adm. Code), protection of lakes
and streams  (NR 102, NR 103 Wis. Adm. Code), and floodplain
management (NR 116 Wis. Adm. Code). Assessment of floodplain
impacts will be undertaken during the remedial design phase.


The following ARARs are associated with the preferred remedy
chosen in this ROD:

Chemical Specific

*    Water Quality Criteria (AWQC).  40 C.F.R. Part 131
     Quality Criteria for Water, 1986.

*    Surface Water Quality Standards  (NR 102, NR 105, NR 106
     Wis. Adm.  Code)

*    Prohibition of Air Contaminants which Adversely Affect
     Human Health and the Environment (NR 404, NR 415, NR
     445 Wis. Adm. Code)
Action Specific

*    National Pollutant Discharge Elimination (40 C.F.R.
     Part 125); includes best available technology

*    Standards Applicable to Generators of Hazardous Waste
     (40 C.F.R. Part ,262), treatment residuals generation

*    Standards for Owners and Operators of Hazardous Waste
     Treatment, Storage, and Disposal Facilities,  (40 CFR
     264.90-101), Subpart F

*    Groundwater Monitoring and Recovery Well Requirements
     (NR 141, NR 181, Wis. Adm. Code)
                          32

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     *    Requirements and Standards for Pollution Discharge
          Systems (NR 108, NR 102, NR 104, NR 200, NR 207, NR
          218, NR 219, NR 220  Wis. Adm. Code)

      *   Standards for Landfill Cap Design (NR 181, NR 504
          Wis. Adm. Code); NR 181.48 for "other" facilities

     *    Standards for Emissions Controls (NR 400-499  Wis.
          Adm. Code)
 *
     *    Requirements for Collection and Control of Landfill Gas
          (NR 504, NR 506, NR 508, NR 181  Wis. Adm. Code)


     *    Standards Applicable to Generators of Hazardous Waste
          (NR 181 Wis. Adm. Code)

     *    Resource Conservation and Recovery Act (RCRA 42 U.S.C.
          6924(u),  (v) and 6928(h)).


     Location Specific

     *    Protection of Wetlands  (Exec. Order No. 11,990, 40
          C.F.R. 6.302(a) and Appendix A)

     *    Guidelines for Specifications of Disposal Sites for
          Dredged or Fill Material (40 CFR 230)

     *    Floodplain Management  (Exec. Order No. 11,988, 40
          C.F.R. 6.302(b) and Appendix A; CWA Sect. 404)

     *    Protection of Wetlands  (NR 1.95, NR 115, NR 117  Wis.
          Adm. Code)

     *    Protection of Lakes and Streams (NR 102, 103  Wis. Adm.
          Code)

     *    Floodplain Management  (NR 116  Wis.  Adm. Code)


11.3 The Selected Remedy is Cost Effective

     Waste Mass Alternative 3 (WM3) and Groundwater Alternative 3
     (GW3) represent a cost-effective remedy for the MDSL site.
     Waste Mass Alternative 3, clay/soil capping of the waste
     mass, will reduce the amount of leachate production in the
     fill, thus reducing potential for groundwater contamination.
     Waste Mass Alternative 4, in-situ vitrification, and
                               33

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     Alternative 5,  complete removal of the waste mass,  compare
     highly unfavorably to WM3 in terms of capital cost.

     Groundwater Alternative 3,  an extraction well system with a
     combination organic/inorganic treatment system,  and
     Alternative 4,  groundwater collection with a barrier,  are
     both cost-effective remedies.  Both alternatives will
     contain the groundwater plume.  Since Alternative 3 will be
     less disruptive to the wetlands area surrounding the site,
     U.S. EPA and WDNR have chosen it as the preferred
     groundwater alternative.


11T4 The Selected Remedy Utilizes Permanent Solutions and
     Alternate Treatment Technologies or Resource Recovery
     Technologies to the Maximum Extent Practicable.

     U.S. EPA and WDNR 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 waste mass  remedy at the MDSL site.  Of the  alternatives
     that are protective of human health and the environment and
     comply 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,
     implementability, cost, as well as satisfying the statutory
     preference for  treatment as a principal element  and
     considering State and community acceptance.

     Since capping the waste mass will not achieve a  reduction in
     toxicity, -mobility or volume, the major trade offs  that
     provide the basis for this selection decision are long-term
     effectiveness,  short-term effectiveness,  implementability,
     and cost.  Long-term effectiveness and implementability were
     key factors in  selecting this remedy.  Waste Mass
     Alternative 3 can be implemented and completed quicker with
     less difficulty and at less cost than the other  alternatives
     considered.  Waste Mass Alternative 3 is therefore
     considered to be the most appropriate solution to
     contamination at the site.

     Neither of the  groundwater interim remedies will meet short-
     term effectiveness.  Both of these alternatives  will meet
     all of the remaining criteria, with alternative  GW3  being
     slightly more cost effective than GW4.   Groundwater
     Alternative 3 is considered to be the most appropriate
     solution for an interim remedy because it will be least
     disruptive to the surrounding wetlands.  The short-term
     effectiveness criterion was a key factor in selecting this
     remedy.

                                34

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11.5 The Selected Remedy Reduces Toxicity. Mobility,  or Volume of
     Waste Materials as a Principal Element.

     Treatment of the waste mass to permanently and significantly
     reduce toxicity, mobility,  or volume of  contaminants was not
     found to be practicable or cost effective for remediation of
     the site.  The selected interim groundwater alternative,
     however, satisfies the statutory preference for remedies
     that employ treatment of the principal threat which
     permanently and significantly reduces the toxicity of
     contaminants by oxidation and adsorption of organic and
     inorganic hazardous substances.
                               35

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                                                     STATE OF WISCONSIN

                            Attachment A

CORRESPONDENCE / MEMORANDUM	

DATE:   August  14,  1990

   :     Mark Giesfeldt -  S'W/3

FROM:   Duane Schuettpelz - WR/2

SUBJECT:      Projected Water Quality-Based Effluent Limits for  the
              Master Disposal Superfund  Project                          ^

The  purpose  of this  memo  is  to summarize the  water  quality-based
effluent limitations recommended  for the proposed direct discharge
from the Master Disposal  Superfund  site to  the Fox  (Illinois)  River  in
Waukestta County.  Effluent limitations were calculated for each of the
substances detected  in any of the  groundwater samples from the Master
Disposal site.   Those limitations  were calculated using chapters NR
102,  105, 106  and 207 of  the Wisconsin Administrative Code and are
discussed below.  Based on our review,  the  following  recommendations
are  made on  a  water  quality  basis  for a direct discharge to  the Fox
River:
1) If the discharger is  able to  make the necessary
   demonstrations  required in s.  NR 207.04 (l)(d),
   limitations are as  follows  (based on  1/3 of  the
   assimilative  capacity in the  Fox River) :
                                                         alternative
                                                         the  effluent
                                                         available
Substance:
Antimony
Arsenic
Cadmium
Chromium (+3 or total)
Chromium (+6)
Copper
Lead
Mercury
Nickel
Zinc
Benzene
Chloroform
Dichlorobromomethane
1,1-Dichloroethylene
1,2 -D i chIoroethyIene
Ethylbenzene
Methylene Chloride
Toluene
1,1,1-Trichloroethane
Trichloroethytene
Bis(2-ethylhexyl)Phthalate
Aluminum
Effluent Hardness
                               Daily        Weekly
                               Maximum      Average
                               (mg/L)       (mq/L)
                               13
                               0.73 *
                               0.22 *
                               9.7 *
                               0.028 *
                               0.1 *
                               1.5 *
                               0.0031 *
                               5.1 *
                               0.57 *
                               22
                               29

                               30
                               130
                               45
                               220
                               17
                               70
                               41
                               11
                               1.5 *
                               (Monitoring only)
Weekly
Average
(lbs/d)
0.045 *
0.0004
0.034 *
0.0029
0.0081
0.0096

0.043 *
0.0047
Monthly
Average
(lbs/d)
480
           8.5
           5.3
           5.3
           2.9
           920
           610
           220

           2000
           22
Li!J
 ??Efv1EC!/M_ i ENFORCEMENT
    RFSPOi-iSE  BRANCH

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2) If the discharger is  not able to  satisfactorily demonstrate the
   alternatives  required in s. NR 207.04 (1)(d),  the effluent
   limitations are as follows (based on the  full  available
   assimilative  capacity in the Fox  River):
                              Daily        Weekly       Weekly      Monthly
                              Maximum       Average      Average      Average
Substance:                        (mg/L)       (mg/L)       (Ibs/d)      (Ibs/d)
Antimony                         13         _                     1400
Arsenic                         0.73 *                 0.14 *
Cadmium                         0.22 * .                 0.0012 *
Chromium (+3 or total)                9.7 *                  0.10 *
Chromium (+6)                      0.028 *                 0.0086 *
Copper                          0.1 *                  0.024 *
Lead                           1.5 *                  0.029 *
Mercury                         0.0031 *                           #
Nickel                          5.1 *                  0.13 *
Zinc                           0.57 *                 0.014 *
Benzene  "                       22                               26
Chloroform                        29                               16
Dichlorobromomethane            •                                     16
1,1-Dichloroethylene                 30                               8.8
1,2-Dichloroethylene                 130                              2700 '
Ethylbenzene                      45                               1800
Methylene Chloride                  220                              660
Toluene                         17
1,1,1-Trichloroethane                70                               6000
Trichloroethylene                   41                               66
Bis(2-ethylhexyl)Phthalate             11
Aluminum                         1.5 *
Effluent Hardness                   (Monitoring only)

*  -  For these substances,  effluent limitations may  be  reported  in the
"total  recoverable"  form if  such  a test  is  reasonably  available.

#  -  For mercury,  the monthly average  limitation is  equal to the 2 ng/L
wild and domestic animal criterion because  mercury  was detected in
background sampling  of the Fox  River  at  a  concentration in excess of
the  criterion.

Annual  maximum mass  limitations based  upon  the recommended daily
maximum limits listed above  are not provided at this time because of
uncertainty over  the actual  discharge  rate.

It  is  recommended that the set  of the  above limitations which is
deemed  appropriate based on  the s.  NR 207.04 (1)  (d)  evaluation  should
be  accompanied by a  requirement to perform,  at a minimum, monthly
testing for a period of up to six months following  commencement of
discharge.   Following the  conclusion  of  that sampling  period, effluent
limitations for.individual substances  may  be removed from the
recommended list  if  those  substances  are not detected  at levels of
detection equal to or less than 1/5 the  calculated  limits for those
substances.  If the  level  of detection exceeds 1/5  of  the applicable
limitation or if  the substance  is detected in the discharge to  surface
water,  the need for  limitations and/or monitoring should be re-
evaluated by this Bureau using  the procedures in NR 106.

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3) Whole Effluent Toxicity Testing Recommendations:

Based on the  absence of biological  data leading to the  overall
uncertainty regarding the potential for whole effluent  toxicity and
the proposed  water quality-based  chemical-specific effluent
limitations derived for several toxicants identified_in the
contaminated  groundwater, the  following recommendation  is  provided:

Acute:  Acute toxicity test batteries are recommended rfith three
freshwater species at a frequency and duration of once  each three
months  upon commencement of discharge for the duration  of  the permit.

Due to  the highly contaminated nature of the wastewater from the
Master  Disposal Superfund Project,  it is further recommended that the
discharge be  ceased immediately upon the failure of any one acute
toxicity test battery.

Chronic:  Monitoring for chronic  whole effluent toxicity is not
recommended at this time.

The above limitations should be compared to Best Available Technology
limitations,  where available,  prior to final recommendation to the
discharger.

Chemical-Specific Discussion;

Effluent limitations for a direct discharge to the Fox  River from the
Master  Disposal Superfund Site were calculated for each of the
substances detected in any of  the groundwater monitoring wells at the
Master  Disposal site that have water quality criteria in ch. NR 105,
Wis. Adm. Code.  In addition,  hardness data used in calculating water
quality criteria and associated effluent limitations for metals were
generated from calcium and magnesium data collected in  those
monitoring wells.  Finally, since background information was collected
in the  Fox River for several of those parameters, that .information was
also used in  the effluent limit determinations for Master  Disposal.
The general information used in calculating effluent limitations at
this location is summarized in the  following table:
   EFFLUENT LIMIT CALCULATIONS FOR:    Master Disposal Superfund Site
   RECEIVING WATER:      Fox (Illinois) River
   RECEIVING WATER INFORMATION:
   CLASSIFICATION: Warmwater Sport Fish, Non-Public Water Supply
   RECEIVING WATER FLOWS (cfs):   7010   702    Gave

                       0.66   1.8     34
   RECEIVING WATER HARDNESS  =    250 PPM

   EFFLUENT INFORMATION:
   EFFLUENT HARDNESS       =    330 PPM
   EFFLUENT DILUTION
    DUE TO ZID          =      not available

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Daily maximum effluent limitations were calculated based on  twice the
NR 105  (or  EPA,  for aluminum)  acute toxicity criteria  (ATC)  where
available,  pursuant to s.  NR 106.06 (2).   If,  for a given  substance,
an NR 105 criterion is not available, the  daily maximum effluent
limitation  equals the lowest species mean  LC50 value for aquatic
species  considered among  the warmwater sportfish community
subcategory,  which represents the classification of the Fox  River
pursuant to s.  NR 102.04  (3).   Those"limitations are summarized in the
following table:
   CALCULATION OF EFFLUENT LIMITATIONS BASED ON  ATC    (in ug/L)

SUBSTANCE
NR 105 Criteria:
Arsenic
Cadmiun
Chromium (+3)
Chromium (+6)
Copper
Lead
Mercury
Nickel
Zinc
EPA Criteria:
Aluminum
REF.
HARD. ATC

363.8
330 111.31
319 4838.65
14.2
330 51.06
330 772.9
1.53
274 2528.06
330 283.94

748
MAX. EFFL.
LIMIT

727.60
222.62
9677.30
28.40
102.12
1545.80
3.06
5056.12
567.88

1496.00
   Limitations Based on LCSO Data (s. NR 102.04 (1)):
   Antimony                         13000
   Ethylbenzene                       45000
   Toluene                          17000
   1,2-Dichloroethylene                 135000
   1,1,1-Trichloroethane                 70000
   Bis(2-ethylhexyl)Phthalate              11000
   Benzene                          22000
   Chloroform                        29000
   1,1-Dichloroethylene     -             30000
   Methylene Chloride                  224000
   Tfichloroethylene                    41000


Since a specific effluent  discharge rate  was not proposed,  the weekly
and monthly average  effluent limitations  were calculated based on the
available assimilative  capacity in the  Fox River which, based  on the
definition in s. NR  207.02 (1), is the  difference between the
applicable water quality criterion for  a  substance and the  existing
concentration of that substance in a surface water.  The
antidegradation provisions in ch. NR 207  are applicable at  Master
Disposal  since this  represents a new discharge.   As a result,  the
assimilative capacity of the Fox River  is converted from a
concentration into an allowable mass loading in pounds per  day using
the appropriate streamflow pursuant to  NR 106.

Weekly  average limitations based on NR  105 chronic toxicity criteria
(CTC) and monthly average  limitations based on NR 105 wild  and
domestic  animal criteria  (WDAC), human  threshold criteria  (HTC), and
human cancer criteria  (HCC),  are summarized in the following tables

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using the full  assimilative capacity  of  the Fox River and 1/3 of that
capacity.  For  each of the various criteria,  limitations are
calculated to address two alternatives based on the implementation  of
NR 207.  The discharger is required to make a series of demonstrations
if the proposed discharge would result in a significant lowering of
water quality as defined in NR 207.   Those demonstrations are
contained in s.  NR 207.04 (l)(d) and  are based on the availability  of
pollution control -and treatment technology alternatives, including
alternative discharge locations.  If  the discharger is able to
demonstrate that there are no alternatives available that would
satisfy the appropriate portions of s. NR 207.04 (1)(d), the
recommended effluent limitations would be based on the full
assimilative capacity of the receiving water.  On the other hand, if
the demonstrations in s. NR 207.04  (l)(d)  show that alternatives are
available, the  recommended limitations would be based upon 1/3 of the
available assimilative capacity in the Fox River.

Since the discharger is required to make the s. NR 207.04 (1)(d)
demonstration,  effluent limitations shall be recommended here based on
both of the possible results of that  demonstration.  Therefore, two
sets of weekly  and monthly average limitations shall be recommended.
Those alternative limitations are summarized below and on the
following page.
CALCULATION OF EFFLUENT LIMITATIONS BASED ON CTC (in ug/L)
RECEIVING WATER


SUBSTANCE
Arsenic
Cadmium
Chromium (+3)
Chromium (+6)
Copper
Lead
Nickel
Zinc
FLOW (cfs) =

REF.
HARD.

250
250

250
250
250
250
0.165


CTC
153
1.32
IK. 49
9.74
27.3
32.39
K3.56
107.8

MEAN
BACK-
GRD.

0
0
0
0
0

92

ASSIMILATIVE CAPACITY
FULL FULL X 1/3
(ug/L) (Ib/d) (Ib/d)
153.00 0.13601 0.04533
1.32 0.00117 0.00039
114.49 0.10177 0.03392
9.74 0.00865 0.00288
27.30 0.02426 0.00808
32.39 0.02879 0.00959
143.56 0.12761 0.04253
15.80 0.01404 0.00468

   CALCULATION OF EFFLUENT LIMITATIONS BASED ON WDAC (ug/L unless shown
   	      otherwise)
   RECEIVING WATER FLOW (cfs) =   1.53     	
   SUBSTANCE

   Mercury (ng/L)
WDAC

  2
MEAN    ASSIMILATIVE CAPACITY
BACK-   FULL  FULL  x 1/3
 GRO.   (ug/L)  (Ib/d)  (Ib/d)
 200
0.00

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  CALCULATION OF EFFLUENT LIMITATIONS BASED ON  HTC


  RECEIVING WATER FLOW (cfs) =     34
          (in ug/L)
  SUBSTANCE
                        HTC
MEAN    ASSIMILATIVE CAPACITY
BACK-   FULL   FULL   X 1/3
 GRD.   (ug/L)  (Ib/d)  (Ib/d)
Antimony
Cadmium
Chromium (+3)
Chromium (+6)
Lead
Mercury
Nickel
Ethylbenzene
Toluene
1,2-Trahsdichloroethylene
1,1, 1-Trichloroethane
Bis(2-ethylhexyt)phthalate

7800
82
9500000
9000
50
0.08
460
10000
110000
15000
33000
30000


0
0
0
0
0.2







7800
82
9500000
9000
50
0
460
10000
110000
15000
33000
30000

1429
15
1740208
1649
9.16
0
84
1832
20150
2748
6045
5495

476
5
580069
550
3.05
0
28
611
6717
916
2015
1832

   CALCULATION OF EFFLUENT LIMITATIONS BASED ON  HCC (ug/L unless shown
   				      otherwise)
   RECEIVING WATER FLOW (cfs) =     34      	
SUBSTANCE
Arsenic
Benzene
Chloroform
Dichlorobromomethane
1,1-Dichloroethylene
Methylene Chloride
Trichloroethylene
MEAN
BACK-
HCC GRD.
50
140
87
87
48
3600
360
ASSIMILATIVE CAPACITY
FULL FULL x 1/3
(ug/L) (Ib/d) (Ib/d)
50
140
87
87
48
3600
360
9
25.65
15.94
15.94
8.79
659
66
3
8.55
5.31
5.31
2.93
220
22
It should  be noted that  in  the above tables,  there is no assimilative
capacity available for mercury based on both  the WDAC and HTC.   No
capacity is  available because the background  concentrations measured
at Master  Disposal exceeded those criteria.   When existing background
conditions exceed water  quality criteria and  the source of at  least
90% of the discharge is  groundwater, s. NR  106.06 (3)(e)3 states that
the effluent limitation  shall equal the water quality criterion.   For
mercury, the limit would equal the lowest criterion available,  namely
the 2 ng/L wild and domestic animal criterion (WDAC).

For each of  the substances  evaluated at Master Disposal and detected
in at least  one of the groundwater samples, the recommended effluent
limitations  (rounded) are summarized at the beginning of this  memo.
Where the  calculated monthly average limitations exceed the weekly
average limitations, only the weekly average  limitations are
recommended.  Finally, where the acute toxicity criteria are lower
than all of  the remaining criteria, only a  daily maximum limitation  is
recommended  based on that acute toxicity criterion.

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Wetland  Discharge;

The proposed discharge also included an alternative involving
discharge to a wetland along the  Fox River.  It  is  recommended  that
such a proposal should be discouraged because of the direct discharge
alternative to the  Fox River that is available.   It is felt that  a
wetland  discharge at  this location would be contrary to the wetland
preservation goals  in s.  NR 1.95,  Wis.  Adm. Code, especially since the
proposed discharge  could potentially contains high  levels of heavy
metals as well as persistent, bioaccumulating substances.  However,
since direct discharge could potentially result  in  dewatering of  the
wetland,  effluent limitations shall be provided  for that alternative.
In this  case, due to  the lack of  dilution in the wetland (no
"upstream" flow), weekly average  limitations for those substances with
chronic  toxicity criteria in NR 105 (CTC) shall  be  the same as  those
criteria as listed  in the CTC table above, essentially resulting  in
application of chronic toxicity criteria at "end-of-pipe."  Daily
maximum  limitations based on acute toxicity criteria and monthly
average  limitations' based on the  remaining criteria shall be the  same
as proposed above for the direct  discharge to the Fox River.  Although
human threshold and human cancer  criteria are available for waters
classified for "limited aquatic life," which include wetlands at  this
time, those criteria  are much greater than those applicable to
warmwater sportfish communities.   Since the waters  would eventually
flow into the Fox River,  the uses of the Fox River  must be considered
as well,  pursuant to  s. NR 207.03 (5)(a)l.  As a result, effluent
limitations for discharge to'the  wetland tributary  to the Fox River
are as follows:

1) If the  discharger is able  to make the  necessary  alternative
   demonstrations  required  in s.  NR 207.04  (1) (d) ,  the  effluent
   limitations  are as  follows (based on  1/3  of the  available
   assimilative capacity  in the Fox River):
                             Daily       Ueekly       Weekly      Monthly
                             Maximum      Average      Average     Average
Substance:                       (mg/L)       (mg/L)       (Ibs/d)     (Ibs/d)
Antimony                        13                              480
Arsenic                         0.73 *       0.15 *
Cadmium                         0.22 *       0.0013 *
Chromium (+3  or total)               9.7 *       0.11 *
Chromium (+6)                     0.028 *      0.0097 *
Copper                         0.1 •       0.027 *
Lead                          1.5 *       0.032 *
Mercury                         0.0031 *                           tt
Nickel                         5.1 *       O.K »
Zinc    .                      0.57 *       0.11 •
Benzene                         22                              8.5
Chloroform -                      29                              5.3
Oichlorobromomethane                                                5.3
1,1-Dichloroethylene                30                              2.9
1,2-Dichloroethylene                130                              920
Ethylbenzene                      45                              610
Methylene Chloride                 220                              220
Toluene                         17
1,1,1-Trichloroethane       .       70                              2000
Trichloroethylene                  41                              22
8is(2-ethylhexyl)Phthalate            11
Aluminum                        1.5 *
Effluent Hardness              •    (Monitoring only)

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2) If the  discharger is not able  to satisfactorily demonstrate the
   alternatives required  in s. NR 207.04  (l)(d),  the effluent
   limitations, are  as follows  (based on the full  available
   assimilative capacity  in the Fox River) :
Substance:
Antimony
Arsenic
Cadmium
Chromium (+3 or total)
Chromium (+6)
Copper
Lead
Mercury
Nickel
Zinc     f
Benzene
Chloroform
Dichlorobromomethane
1,1-Dichloroethylene
1,2-Dichloroethylene
Ethylbenzene
Methylene Chloride
Toluene
1,1,1-Trichloroethane
Trichloroethylene
Bis(2-ethylhexyl)Phthalate
Aluminum
Effluent Hardness-
                               Daily
                               Maximum
                               (mq/L)
                               13
                               0.73 *
                               0.22 • ..
                               9.7 *
                               0.028 *
                                .1 *
                                .5 *
                                .0031 *
                                .1 *
                                .57 *
                               22
                               29
     Weekly
     Average
     (mq/L)

     0.15 *
     0.0013 *
     0.11 *
     0.0097 *
     0.027 -
     0.032 *
                                                     Weekly
                                                     Average
                                                     (Ibs/d)
                                                                 Monthly
                                                                 Average
                                                                 (Ibs/d)
                                                                 1400
                               30
                               130
                               45
                               220
                               17
                               70
                               41
                               11
                               1.5 *
                               (Monitoring only)
                                            14
                                            11
                                                                 26
                                                                 16
                                                                 16
                                                                 8.8
                                                                 2700
                                                                 1800
                                                                 660

                                                                 6000
                                                                 66
The  recommendations  regarding daily  maximum mass limitations  and
monitoring  frequency and the  footnotes involving "total recoverable"
reporting and the mercury limitation are the  same as  previously
addressed regarding  the direct discharge to the Fox River.

If there are  any questions  or comments,  please contact Jim Schmidt
(608)  267-7658 regarding chemical-specific determinations; Bob Masnado
(608)  267-7662 regarding whole effluent toxicity testing; or  either
John Sullivan (608)  267-9753  or myself (608)  266-0156 regarding
general issues.
jws/wp3/master . sf/
PREPARED BY:
                                     APPROVED BY:
James  W. Schmidt
Jo
Sur
                                       tfn^ 'R^S
                                       rface  W
                                               il 1 ivan
                                              Water Standards  Unit
Robert G. Masnado

cc:   Water' Resources  Supervisor
      Lee Liebenstein  - WR/2
      Mike Witt - WW/2
                                    - SED

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