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
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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
:':
-------
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.
-------
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 .
-------
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.
-------
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
-------
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
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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
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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
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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.
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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.
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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
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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-
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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.
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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.
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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.
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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
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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).
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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)
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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
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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
-------
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
-------
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.
-------
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
-------
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
-------
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
-------
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.
-------
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)
-------
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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