PB95-964109
EPA/ROD/R05-95/281
February 1996
EPA Superfund
Record of Decision:
Refuse Hideaway Landfill
Middleton, WI
6/28/1995
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RECORD OF DECISION
Refuse Hideaway Landfill
Town of Middleton, Dane County, Wisconsin
FINAL ACTION FOR SOURCE CONTROL AND GROUNDWATER CONTROL
Site Name and Location
Refuse Hideaway Landfill is located in the SWW, NWW, Section 8, T7N, R8E of the Town
of Middleton. The 1.2 million cubic yard landfill containing municipal, commercial and
industrial waste is situated in a rural surrounding that is dominated largely by agriculture.
Statement of Basis and Purpose
This decision document represents the selected final remedial action-for both source and
groundwater control at the Refuse Hideaway Landfill located in the Town of Middleton. This
final remedial action was developed in accordance with the Comprehensive Environmental
Response, Compensation and Liability Act of 1980 (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act of 1986 (SARA), and to the extent practicable, the
National Contingency Plan (NCP). The attached Summary of Remedial Alternatives
identifies the information contained in the administrative record for this site upon which the
selection of the remedial action is based.
The State of Wisconsin and the U.S. Environmental Protection Agency (U.S. EPA) concur
with the selected final action.
Assessment of the Site
Actual or threatened releases of hazardous substances from the site, if not addressed by
implementing the remedial action selected in this Record of Decision, may present an
imminent and substantial danger to public health, welfare, or the environment.
Description of the Remedy
The selected remedies involve Alternative B, Limited Action for Source Control; Alternative
F, Groundwater Extraction and Treatment with Reinjection to Enhance In-situ
Bioremediation; and Alternative G, Supply Individual Water Treatment Units. These
alternatives protect the public from direct contact with waste, control emissions from the
landfill, remove and control contaminants within the aquifer and provide reliable potable
water if additional private home water supplies become contaminated. The following specific
actions are proposed:
Alternative B, Source Control Limited Action. Add deed restrictions/zoning and
perimeter signs to the Site. Maintain the existing soil cap and operate and maintain
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the existing gas/leachate collection system. Continue to monitor 21 groundwater
monitoring wells and 12 private homes for Volatile Organic Contaminants.
Alternative F, Groundwater Extraction and Treatment with Reinjection to Enhance
Natural Breakdown of Contaminants. Four groundwater extraction wells would be
installed on the west and south sides of the landfill and pump a total of 45 gallons per
minute (gpm). Water would be treated to meet discharge standards and would be
reinjected into the aquifer through two injection wells located east of the landfill. This
option avoids discharge of water into Black Earth Creek, an Outstanding Resource
Water and a Class 1, cold water trout fishery.
Alternative G, Supply Individual Water Treatment Units. This is a contingent option
if the area of groundwater contamination moves and additional homes become
contaminated. Point-of-entry (POE) treatment units would be installed at homes that
become contaminated or are imminently threatened with contamination. Currently,
POE systems are successfully treating water at two homes downgradient of the
landfill.
Statutory Determinations
i
This final remedy is protective of human health and the environment, complies with Federal
and State requirements that are legally applicable or relevant and appropriate to the remedial
action, and is cost effective. This remedy satisfies the statutory preference for remedies that
employ treatment that reduces the toxicity, mobility or volume as a principal element because
it reduces toxicity, mobility or volume.
Because this remedy will result in hazardous substances remaining on-site, a review will be
conducted to ensure that the remedy continues to provide adequate protection of human health
and the'environment within 5 years after the commencement of this source control and
groundwater control remedial action.
George Meye/A Secretary ^T Date
Wisconsin Department of Natural Resources
^Valdas V. Adamkus, Regional Administrator Date
U.S. EPA Region 5
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RECORD OF DECISION SUMMARY
REFUSE HIDEAWAY LANDFILL
Town of Middleton, Dane County
Wisconsin
June, 1995
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TABLE OF CONTENTS
RECORD OF DECISION
REFUSE HIDEAWAY LANDFILL
I. SITE DESCRIPTION i
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES . . 3
A. Site History 3
B. Response Actions • 4
C. Civil Actions/Suits 9
D. Remedial Investigation/Feasibility Study (RI/FS) 9
III. COMMUNITY PARTICIPATION 9
IV. SCOPE AND ROLE OF THE RESPONSE ACTION 12
V. SUMMARY OF SITE CHARACTERISTICS 13
A. Topography 13
B. Geology/Hydrogeology 13
C. Nature and Extent of Contamination 15
1. Source 15
2. Groundwater Contamination 16
3. Surface Water/Sediments . . . .21
4.- Air ,21
VI. SUMMARY OF SITE RISKS . . . ' " 21
A. Human Health Risk Assessment 21
1. Air . . . '. 22
2. Groundwater 23
3. Surface Water/Sediment Pathway 27
B. Ecological Risk Assessment 27
C. Rationale for Further Action 28
VII. DESCRIPTION OF THE REMEDIAL ALTERNATIVES 28
A. Remedial Action Objectives 28
B. Development of Alternatives 30
1. Source Control Alternative Development 31
2. Groundwater Remedy Alternative Development 32
3. Water Supply Alternative Development 37
C. Alternatives 37
1. Source Control Alternatives 37
2. Groundwater Extraction and Treatment Alternatives ... 40
3. Water Supply Alternatives 48
VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 50
A. Introduction 5.0
B. Evaluation of the Remedial Alternatives 51
THRESHOLD CRITERIA 51
PRIMARY BALANCING CRITERIA . ' 55
MODIFYING CRITERIA 63
IX. THE SELECTED REMEDY 63
X. STATUTORY DETERMINATION •. . 71
A. Protection of Human Health and the Environment 71
B. Attainment of ARARs 72
1. Action specific ARARs 72
2. Chemical Specific ARARs 74
3. Location Specific 76
C. Cost Effectiveness 75
D. Use of Permanent Solutions and Alternative Treatment
Technologies 77
E. Preference for Treatment as a Principal Element 77
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TABLE OF CONTENTS
p.2
Refuse Hideaway Landfill Reccrrd of Decision
ATTACHMENTS
Appendix A, Responsiveness Summary
Appendix B, Figures
# 1 Site Location & Topographic Map
# 2 Location of Black Earth Creek Drainage Basin
# 3 Land Use
# 4 Private Home Wells Contaminated by Refuse Hideaway Landfill
# 5 Regional Water Table Map
# 6 Physiographic Areas & Glacial Age Deposits
# 7 Well Locations
# 8 Potentiometric Surface Map
# 9 Geologic Cross-Section and Vertical Plume Location
#10 Total VOC Plume, Horizontal Location
#11 PAL Attainment Goals
#12 Surface Discharge Location Alternatives
#13 Location of Extraction Wells
#14 Groundwater Treatment System, ORW and Groundwater Discharge
Alternatives
#15 Groundwater Treatment System, ERW and Warm Water Fishery Discharge
Alternatives
#16 Suitable Soils for I'nfilitration Gallery
#17 Proposed Injection Well Locations
Appendix C, Tables
# 1 Summary of NR 140 Enforcement Standard Exceedances
# 2 Summary of VOC Detections in Private Wells
# 3 Highest Detected VOC Values in Landfill Gas
# 4 Compounds Evaluated for the Risk Assessment
# 5 Groundwater Clean up Standards for Refuse Hideaway Landfill
# 6 Preliminary Water Quality Effluent Limits
Appendix D, Administrative Record
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RECORD OF DECISION SUMMARY
Refuse Hideaway Landfill
Town of Middieton, Dane Councy, Wisconsin
I. SITE DESCRIPTION
Refuse Hideaway Landfill was listed on the National Priorities
List (NPL) by the U.S. Environmental Protection Agency (EPA) in
October, 1992. Refuse Hideaway Landfill (RHL) is located in the
SWM, NW1/*, Section. 8, T7N, R8E, Town of Middieton, Dane County,
Wisconsin (See Figure 1, Site location map). The 1.2 million
cubic yard landfill containing municipal, commercial and
industrial waste is located in a rural portion of the Town of
Middieton, 2 miles west of the City of Middieton and 4 miles east
of the Village of Cross Plains. According to the 1990 census,
there are 3,628 persons living in the Town of Middieton.
RHL is located in the easternmost section of the upper Black
Earth Creek drainage basin (Figure 2). The Black Earth Creek
drainage basin has an area of 46 square miles in Dane County.
The headwaters of Black Earth Creek flow to the west, essentially
originating at RHL, .although the drainageway exiting the RHL
property is intermittent!. Groundwater discharge accounts for 80%
of the total flow into Black Earth Creek. Most of the
groundwater discharge to Black Earth Creek occurs to the west -of
RHL, near the Village of Cross Plains. In the immediate vicinity
of the landfill, the water table and the potentiometric surface
configuration, as well as vertical gradient information confirm
that Black Earth Creek is not a regional divide and the creek is
not a major discharge point for groundwater in the area of the
landfill. The only other surface water bodies in the area are
the sedimentation basin at the landfill and several intermittent
tributaries terminating at the creek. These are hydraulically
connected to Black Earth Creek.
Black Earth Creek is a highly productive trout stream in southern
Wisconsin and is unique for its natural reproduction of wild
brown trout. The portion of Black Earth Creek nearest the
landfill is classified as a Class I, cold water trout fishery.
Class I trout streams support natural reproduction of wild trout
and do not require stocking of hatchery trout. Wild brown trout
comprise almost all of the trout population in the upper Black
Earth Creek. None of the fish in the creek are known to be
endangered or threatened. A 1985/86 study of Black Earth Creek
indicated that the stream ecosystem is being stressed. These
stresses include sediment accumulation, low dissolved oxygen
concentration, increased stream temperature, and dense macrophyte
growth.
Land use in the area surrounding the landfill is diverse. The
landfill property 'itself, outside the fill boundary, is currently
being rented by the landfill owner to a sand and gravel company
as a storage area for truck and construction equipment. The
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Refuse Hideaway Landfill ROD
north and west side of the landfill property are bounded by a
Christmas tree farm, while the- remaining area surrounding RHL is
predominantly agricultural with field corn and other dairy
support crops being the most common output. A small wetland area
is located southeast of the landfill. Several large dairy farms
and many other minor dairy farms are located in the vicinity of
the landfill. In addition, several residences are located near
the landfill. Most homes are located adjacent to County Highway
14 or in the Deer Run Heights Subdivision to the southwest of the
landfill. Figure 3 presents the local land use around the former
landfill.
Private water supply wells provide water for the residences and
agricultural uses in the RHL area. Approximately 53 homes are
within 1 mile of the Site. Three private wells downgradient of
the landfill have had Volatile Organic Compounds (VOCs) detected
in them. Figure 4 shows the locations of these wells. One of
these residences is currently vacant while two others have
treatment systems in place to treat the documented groundwater
contamination.
i
The Refuse Hideaway Landfill is located in an area which has been
glaciated, approximately 2.5 miles from the driftless area of
Wisconsin. Unconsolidated materials in the areas adjacent to the
landfill consist of Pleistocene glacial deposits, primarily till
and outwash. Lacustrine sediments, consisting of layered silt
and clay with a few sand layers, overlie the till and outwash
deposits in some valley areas. The thickness of the
unconsolidated deposits range from 5 feet thick on the north side
of the Site to greater than 250 feet in the valley, half-mile
southwest of the Site. Bedrock in the area consists of Cambrian
sandstones overlain in some areas by Ordovician dolomites. Up to
105 feet of dolomite is present on the bluff to the northwest of
the landfill. Beneath the Cambrian sandstone, the Precambrian
bedrock consisting of rhyolite, granite, and basalt occurs at
depths greater than 1,000 feet.
The Cambrian sandstone is the principal aquifer for Dane County.
Where the thick glacial outwash deposits are saturated, they are
also capable of producing large quantities of water and are the
principal aquifer for several private home and farm wells located
in the valley southwest of the landfill. The sandstone and the
sand and gravel of the outwash deposits appear to be
hydraulically connected. Figure 5 presents a regional water
table map. The direction of regional groundwater flow coincides
with the flow direction of Black Earth Creek Valley, flowing from
the northeast to the southwest. A regional groundwater divide
(separating the Wisconsin River and Yahara River watersheds) is
located approximately three-quarters of a mile to the east of the
RHL.
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Refuse Hideaway Landfill ROD
Immediately surrounding the landfill, • cr.ere appears to be a
localized radial component of grcundwacer flow from the landfill.
To the north of the landfill, groundwacer ac the water table
flows to the north, essentially against: -he regional flow
direction. The apparent radial flow pattern emanating from the
landfill to the north appears to be lirr.ired to the upper 50 feet
of the saturated strata. Groundwater flow at depth migrates to
the southwest, consistent with .the documented regional flow
pattern to the southwest.
Groundwater flow in the unconsolidated deposits to the south and
east of the landfill is to the south, while further off the Site
to the south, the flow direction changes and merges with the
regional flow direction which trends in a southwesterly
direction. This southwesterly direction of flow is also observed
within the topographic ridges to the west and southwest of the
landfill.
No endangered species are known to be located in the vicinity of
RHL. There are no historic landmarks that would be potentially
affected by RHL.
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II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
A. Site History
John DeBeck, the owner and operator of the Refuse Hideaway
Landfill, received a landfill license from the Wisconsin
Department of Natural Resources (WDNR) in 1974 to operate a 23
acre landfill. The main engineering requirement was that he
maintain at least 10 feet of soil between the waste and bedrock
and that he daily cover the waste. Numerous violations of the
daily cover requirements are noted in the WDNR file of the Site.
The Site was filled from south to north, but was not operated in
"phases". Therefore, the entire waste volume (approximately 1.2
million cubic yards) was exposed to leaching by rain and snow
melt throughout the operating history. The landfill owner
reported receiving a variety of commercial and industrial wastes
including: full barrels of glue and paint, barrels of ink and
ink washes, spray paint booth by-products and paint stripper
sludge, and spill residue containing VOCs. In addition, large
volumes of municipal wastes from cities and towns in Dane County
were also disposed of at the landfill.
John DeBeck closed the landfill under court order in May, 1988.
At that time, he covered the landfill in accordance with NR
504.07, WI Adm. Code, and placed a 6 inch grading layer of coarse
soil over the waste, followed by 2 feet of clay soils. Two and a
half feet of general soils were placed over the clay and 6 inches
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Refuse Hideaway Landfill ROD
of topsoil, seeded and mulched, finished the cap. The final
cover was completed in October, 1988. In January, 1989, John
DeBeck declared bankruptcy and was unable to undertake additional
remediation of the landfill or investigation of the degree and
extent of groundwater contamination.
Therefore,.in early 1989, the State of Wisconsin undertook the
continued remediation and investigation of the Site, as well as
all operation and maintenance activities. Costs for this work
were paid by the Environmental Fund which are monies from a
variety of sources, including fees paid by the owners and
operators of solid waste landfills, hazardous substance generator
fees, licensing fees for pesticide use and general tax revenues.
B. Response Actions
In Fall, 1989, the State began a number of actions designed to
remediate the immediate problems of:
1. methane gas and leachate migration from the landfill.
2. private watez* supply contamination at three wells.
3. groundwater contamination and possible involvement of
additional private wells.
The following actions were taken:
1. Ga^s and leachate extraction system. Construction of a gas
and leachate extraction system was completed in August,
1991. The system consists of 13 gas/leachate extraction
wells, header piping, blower, flow control systems,
electrical control systems, telemetry system, a ground flare
that meets all applicable air emission standards, and a
leachate holding tank. Leachate is extracted from 8 of the
13 wells. The other five wells have leachate heads of less
than 6 feet at the base of the wells. In Summer 1993, the
gas extraction system was extended in the southwest corner
of the landfill to control gas migration through the
landfill cap at that location.
2 . Long-term operation and maintenance of the gas/leachate
extraction system. A consulting firm (Terra Engineering and
Construction, Inc.) was hired in 1992 to operate and
maintain the extraction system and landfill surface for up
to 5 years. Besides actual O & M of the extraction system,
Terra monitors gas probes surrounding the landfill for
methane migration, analyzes leachate samples for compliance
with a wastewater permit for discharge to the Madison
Metropolitan Sewerage District, ensures subcontractors
(e.g., leachate hauler) perform all duties, inspect the
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Refuse Hideaway Landfill ROD
landfill cover for erosion problems, and ensure that
applicable air emission standards are met.
Repair of Final Cover Soils. The landfill cover experienced
significant erosion and in Fall, 1992 a cap repair and
restoration project was undertaken. Geomembrane and heavy
riprap was installed in the areas of worst erosion,
settlement cracks were repaired, an access road over the
landfill surface was constructed, top soil, seed and mulch
were .added to areas of sparse vegetation. At this time, the
landfill surface is in fairly good repair.
Methane gas monitoring at private homes. In 1989 and 1990,
private homes were monitored for the presence of methane
gas. The homes were all in excess of 1600 feet from the
landfill and no gas was ever detected in any of the homes.
Private Water Supply Wells. Three private' water supply
wells, serving three homes, were discovered to be
contaminated with VOCs in January, 1988. The compounds
exceeding Wisconsin NR 140 Enforcement Standards (Federal
MCLs) and their maximum concentration in the private wells
are:
Maximum Contaminant Concentration in Private Wells
COMPOUND
Tetrachloroethane
Trichloroe thane
Vinyl Chloride
(NOTE: Vinyl
chloride has not
been detected since
3/88)
CONCENTRATION
(ppb)
31
8.9
6.1
ES
(ppb)
5
•5
0.2
The landfill owner supplied bottled water until January,
1989 at which time the State took over payment for bottled
water deliveries. In Fall, 1989, .testing for design of a
point-of-entry (POE) water treatment system was undertaken.
The system, an activated carbon filtration system
manufactured by Hellenbrand Water Systems, was installed in
2 homes in April and May, 1990. The third home is no longer
•occupied and the water well has been shut down. The third
property (owned by Randall Swanson) is used as a business
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Refuse Hideaway Landfill ROD
and the State continues to supply bottled water to the
business.
The State maintained and tested the POE systems for two
years. In Summer, 1992, ownership of the POE systems was
transferred to the homeowners. Each homeowner is now
permanently responsible for maintenance and testing of the
POE system in that home. All testing to date indicates that
the filtration systems reliably produce safe, drinkable
water.
6 . Testing of Private Water Supplies Within One Mile of the
Landfill. In Fall, 1989, 43 private water supply wells
(serving 53 homes) were tested for the presence of Volatile
Organic Chemicals. Two testing rounds were conducted, in
October/ 1989 and January, 1990. The tests showed that all
private wells (except the 3 previously mentioned) were free
of VOCs. In one 'jf the testing rounds, toluene was detected
at approximately 1 ppb in several private wells. Laboratory
contamination is believed responsible for this. Subsequent
testing showed all' VOCs to be below detection at all the
homes.
7. Groundwater Monitoring Study. In Summer, 1990, the State
undertook an intensive groundwater investigation to
determine the degree and extent of VOC contamination.
Hydro-Search, Inc. of Brookfield, WI performed the
investigation. Twenty-seven groundwater monitoring wells
were installed. There were 30 existing monitoring wells at
the Site, for a total of 57 monitoring wells in the study.
(See Figure 7) The study evaluated the geology, the vertical
and horizontal groundwater flow, the average groundwater
velocity in each geologic unit, the extent of aquifer
contamination, the direction of plume movement,
preliminarily evaluated four remedial actions, and made
recommendations on future work at the Site. The study
showed that the groundwater plume has the potential to
contaminate the Deer Run Heights subdivision, located
approximately 1 mile southwest of the landfill. In January,
1991, the State began monitoring private wells in the
eastern portion of Deer Run Heights.
Contaminants' detected above '-r"NR Enforcement Standards
(Federal MCLs) and their maxx:.:um concentrations detected in
the groundwater at RHL, include:
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Refuse Hideaway Landfill ROD
Maximum Contaminant Concentration in Groundwater
COMPOUND .
Benzene
Chloroform
1 , 2 -Dichloroethane
cis-1 , 2-Dichloroethene
1 , 2 -Dichloropropane
Tetrachloroethene
Trichloroethene •
Vinyl Chloride
CONCENTRATION
(ppb)
20
37
41
1,900
21
150
160
525
HS
(ppb) '
5
6
5
70
5
5
5
0.2
8. Numerical Model Simulation and Assessment of Contaminant
Plume Migration. In Summer, 1991, a numerical model was
performed by Hydro-Search, Inc. (HSI) in an effort to
estimate movement of the plume front downgradient of the
landfill. A number of simulation scenarios were performed",
resulting in a range of possible outcomes. The modeling
effort provided an evaluation of the State's groundwater
monitoring strategy and suggested that at least one
additional monitoring well be installed in the Black Earth
Creek Valley. The study concluded that it is unlikely that
.the plume front will move beyond its present location,
however, the possibility of future plume movement could not
be ruled out. •
9. Testing for metals, semi-volatiles compounds, pesticides and
PCBs. In May and July 1993, 18 monitoring wells and 2 '
contaminated private wells were tested for the presence of
metals and semi-volatile compounds (SVOC). Three wells near
the landfill with high levels of VOCs were also tested
during the same period for the presence of pesticides and
PCBs. In general, metals were detected at background
levels, no PCBs were detected, a low level of one SVOC (bis
(2-ethylhexyl)phthalate) was confirmed at one well and one
low level pesticide (heptachlor) was confirmed at one well.
A low level of 4,4'-DDT was detected but not confirmed in
one well.
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Refuse Hideaway. Landfill ROD
10. Long term groundwater monitoring. The State has established
a long-term groundwater monitoring program that monitors the
movement of the plume and tests private wells closest to the
plume. Testing for VOCs is conducted semi-annually (in May
and October) on 21 monitoring wells and 12 private wells.
C. Civil Actions/Suits.
Several civil actions have been undertaken with regard to RHL.
The following summarizes these actions:
1. Action to Close the Landfill. On May 2, 1988, WDNR issued
Special Consent Order #SOD-88-02A requiring closure and
monitoring of RHL. John DeBeck stopped accepting waste on
May 16, 1988 and covered the landfill in accordance with NR
504.07, Wis. Adm. Code. On August 16, 1988, the WDNR
referred John DeBeck to the' Wisconsin Department of Justice
for non-compliance with Special Order #SOD-88-02A. On
December 30, 1988, DeBeck entered into a Stipulated
Agreement with the State of Wisconsin to complete specified
work at the landfi'll. On March 17, 1989, John DeBeck was
issued a Contempt Order for failing to comply with the
December 30, 1988 stipulated agreement. The Contempt Order
provided for DeBeck to liquidate all the assets of the
Refuse Hideaway Landfill Corporation and deposit the money
into the WDNR "Waste Management Fund" to pay for future
cleanup at the landfill.
2. John DeBeck v. WDNR. The WDNR issued a "Conditional Closure
Plan Approval Modification" on September 6, 1988. The
closure plan approval required John DeBeck to undertake
specific actions with regard to closure of the landfill. On
October 6, 1988, John DeBeck challenged the WDNR's authority
to issue the closure plan modification to him rather than
Refuse Hideaway, Inc. The trial court and appellate court
vacated the DNR orders by finding that Refuse Hideaway, Inc.
was the owner/operator of the landfill and that the State '
could not impose liability on John DeBeck, as a former
owner/operator under the State's Solid Waste Statute (WI
Stat. Sec. 144.44).
3. Stoppleworth. ex rel. . Schultz. ey:. rel. vs. Refuse
Hide---vay. Inc.. et. al. Two home owners (Al & Jean
Stoj. f.worth and Craig & Anita Schultz) whose wells were
contaminated by the landfill sued insurance companies for
Refuse Hideaway, Inc. in Summer, 1991 for damages they
suffered due -to loss of home value and possible health
effects from the contamination. The jury found for the
plaintiffs and an undisclosed settlement was reached with
the insurance companies involved.
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Refuse Hideaway Landfill ROD
4. Sunnyside Seed vs. Refuse Hideaway.Inc.. et.al. In Summer,
1993 Randall Swanson sued insurance companies ' for Refuse
Hideaway, Inc. for damages due to groundwater contamination
under much of his property and the•loss of use his water
well. The jury' found for the defendants. The verdict was
affirmed on appeal (1995) .
5. John Stoppleworth vs-. Refuse Hideaway. Inc.. et.al. In
Summer 1993, John Stoppleworth (son of Al Stoppleworth) sued
insurance companies for Refuse Hideaway, Inc. for health
impacts from using water at his parent's home. Stoppleworth
claimed that skin cancer he suffered was due to VOCs in the
home well water. The jury found for the defendants. The
verdict was affirmed on appeal (1995).
D. Remedial Investigation/Feasibility Study (RI/FS)
In May 1991, the WDNR offered to enter into a contract with a
group of PRPs to undertake an remedial investigation and
feasibility study (RI/FS) at RHL. After being unable to secure
an agreement, and after'reviewing data from this Site, the WDNR
recommended to EPA that the Site be included on the National
Priorities List (NPL). The Site was listed on the NPL in October
1992. A Cooperative Agreement was signed between U.S. EPA and
WDNR in April 1993 allowing the WDNR to act as lead agency in
performing a RI/FS pursuant to s. 144.442, Wisconsin Statutes and
the Comprehensive Response, Compensation and Liability Act
("CERCLA"). The RI/FS for this Site was financed by the federal
Superfund program. The WDNR secured a consultant, Hydro-Search,
Inc., and the RI/FS officially began in October 1993.
The RI for RHL was completed September 1994 and the FS was
completed in February 1995. The WDNR issued a Proposed Plan in
February 1995. The Proposed Plan selected Alternatives B
(Limited Action for Source Control), Alternative.F (Groundwater
Extraction and Treatment with Reinjection to Enhance In-Situ
Bioremediation) and Alternative G (Supply Individual Water
Treatment Units) as the Final Remedy for the Site. Data
submitted during the public comment period caused WDNR to retain
the proposed plan. Factors considered by WDNR in making it's
decision are listed in Section III, Highlights of Community
Participation.
III. COMMUNITY PARTICIPATION
A Community Relations Plan for the Site was finalized in June
1994. This document lists contacts and interested parties
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Refuse Hideaway Landfill ROD
throughout the local and government community. It also
establishes communication pathways to ensure timely dissemination
of pertinent information. An information repository has been
established at the City of Middleton Library located at 7426
Hubbard Avenue, Middleton, WI. The administrative record is made
available to the public at the Department of Natural Resources,
101 S. Webster St., Madison, WI 53707.
The Proposed Plan (in the form of a Superfund Fact Sheet) for the
Refuse Hideaway Landfill was released to the public in February
1995. The notice of availability for the Proposed Plan and the
RI/FS was published in:
1. Cross Plains Arrow on February 2, 9 and 16, 1995.
2. Middleton Times-Tribune on February 2, 9 and 16, 1995.
3. Capital Times and Wisconsin State Journal, on February
11, 1995.
A public comment period was held from February 13 until March 14,
1995. In addition, a public meeting was held on February 23,
1995. At this meeting,'. members from WDNR and U.S. EPA answered
questions about problems at the Site and the remedial
alternatives under consideration. A response to comments
received during this period is included in the Responsiveness
Summary, which is part of this Record of Decision.
A chronology of other community relations activities for this
Site follows.
Public Meetings
All public meetings listed below were announced through a press
release and the distribution of a fact sheet.
November 13, 1989. This meeting discussed the Interim Remedial
Measures contract between WDNR and Warzyn Engineering, Inc. The
contract called for design of point-of-entry treatment systems._
for contaminated home wells, sampling of private wells for VOCs
within 1 mile of the Site and design of a gas/leachate extraction
system for the landfill.
February 28, 1990. This meeting updated the public on results of
the first 'sampling round of private wells/ installation of the
"partial gas/leachate extraction system" used to design the full
extraction system, and design of the point-of-entry treatment
systems for contaminated private wells.
July 10, 1990. This meeting discussed the contract for the
Groundwater Monitoring Study between WDNR and Hydro-Search, Inc.
of Brookfield, WI. The investigation goals included installation
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Refuse Hideaway Landfill ROD
of 22 additional monitoring wells, groundwater testing for VOCs,
determining degree and extent of aquifer contamination, and
evaluation of groundwater discharge to Black Earth Creek.
October 2, 1590. This meeting updated the public on emergency
erosion control measures undertaken at the landfill in July 1990,
preliminary work on the Groundwater Monitoring Study, and the
design and award of a construction contract for the full
gas/leachate extraction system for the landfill.
June 25, 199,1. This meeting concentrated on the results of the
Groundwater Monitoring Study and delineation of the contaminant
plume. Completion of the full gas/leachate was also discussed.
July 8, 1992. This meeting updated the public on on-going
operation and maintenance activities at the Site, including
operation of the gas/leachate extraction system and monitoring of
groundwater and private home wells. An Erosion Control contract
between Dames & Moore and WDNR was discussed. Proposal of Refuse
Hideaway Landfill for Superfund status was also discussed.
May 6, 1993. A Superfuad Fact Sheet was issued and a meeting was
held to provide a summary of the Site history, explain the
Superfund process and delineate the approved RI work plan. The
Wisconsin Department of Health and Social Services (WDHSS) also
participated to discuss their role in the RI/FS and the Health
Assessment that would be developed.
July 7, 1994. A Superfund Fact Sheet was issued and a meeting
was held to discuss on-going Superfund activities, including the .
draft RI and Alternative Array Document. Operation and
maintenance activities at the Site were also discussed. WDHSS
personnel attended and discussed the Preliminary Health
Assessment.
Technical Availability Sessions
December 19, 1989 and January 24, 1990. These two availability
sessions gave the public the opportunity to speak personally with
WDNR and engineering consultant staff. These were "drop-in"
sessions with no formal agenda. These were announced to the
public through press releases and mailings, but no fact sheets
were prepared. Approximately 10 to 15 people attended each
session. . '
Landfill Open House
October 14, 1993. An open house was held at the landfill to
allow the public to view the remedial activities that had been
completed on the landfill (e.g., gas/leachate extraction system
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Refuse Hideaway Landfill ROD
and cap repair and restoration work) as well as ask questions of
the key personnel from the WDNR and WDHSS. Approximately 30
people attended the open house.
Public Health Interviews
July, 1993 . As part of the Community Relations plan and Health
Assessment for the Site, WDNR and WDHSS personnel conducted
interviews in private homes of over 50 residents in the Towns of
Middleton and Cross Plains. Residents were notified of these
interviews and all who showed interest in participating were
interviewed.
Conclusion
The public participation requirements of s. 144.442(6) (f) ,
Wisconsin Statutes, and the community relations requirements in
the National Contingency Plan at 40 CFR s. 300.430(f) (3) have
been met in this remedy selection process. All the documents
listed above'are available in the Administrative Record at the
City of Middleton Public Library and the WDNR office (addresses
for both are listed above). (A copy of the Administrative Record
is also available at the U.S. EPA offices at 77 West Jackson
Boulevard (7th Floor Records Center), Chicago, Illinois.)
IV. SCOPE AND ROLE OP THE RESPONSE ACTION
The response actions selected by this ROD address the following
areas:
long-term source control at the landfill
control and treatment of contaminated groundwater
replacement of contaminated water supplies, if needed.
Previous actions taken by the State of Wisconsin have addressed
the threat posed to human health and the environment by the
-landfill itself. The methane gas and leachate extraction system
constructed in 1991 controls the movement of potentially
explosive gases and meets all applicable air emission standards.
This system also removes contaminated liquid from the landfill
and reduces the movement of contamination into the groundwater
beneath the landfill. The landfill cap has been repaired and
upgraded to prevent direct contact with waste. This ROD
addresses the long-term protectiveness of the landfill cap and
the long-term operation and maintenance (O&M) of the gas/leachate
extraction system.
The State of Wisconsin installed point-of-entry (POE) treatment
systems in two private homes to remove contaminants from the home
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Refuse Hideaway Landfill ROD
wells. The State also undertook a groundwater investigation co
define the degree and extent of groundwacer contamination. At
this time, contaminated grounawater at the Site poses a potential
future threat to human health and the environment because of
risks from possible ingestion of or dermal contact with the
groundwater should the groundwater contamination spread, should
the POE units not be maintained or should new wells be installed
in the contaminated zone.
The selected remedial actions, described as Alternative B,
Limited .Action for Source Control, Alternative F, Groundwater
Extraction and Treatment with Reinjection to Enhance In-Situ
Bioremediation, and Alternative G, Supply Individual Water
Treatment Units address the principal threats posed by Site
conditions by eliminating the potential for direct contact with
contaminants of concern, controlling and treating groundwater.
contamination and treating private water supplies in the event
they become contaminated in the future.
These combined actions are intended to address the entire Site
with respect to the current and potential future threats to human
health identified in the RI, FS and the Site Baseline Risk
Assessment.
V. SUMMARY OF SITE CHARACTERISTICS
A. Topography
Regional topographic variation is extreme in Dane County near RHL
(Figure 1). Local topographic relief in excess of 200 feet is
common in the vicinity of the landfill. Bluffs.with peak
elevations often greater than 1,150 feet mean sea level (msl) are
present along the north and west sides of the landfill, while the
south and east sides of the landfill have ground surface
elevations as low as 930 feet msl.
B. Geology/Hydrogeology
The geology in the vicinity of RHL is typical of the glaciated
portion of Dane County, Wisconsin. Unconsolidated deposits of
glacial origin consisting of till, outwash, and glacial lake
sediments cover the area, often reaching thicknesses of several
hundred feet. Bedrock in the area consists of Cambrian sandstones
overlain in some areas by Ordovician dolomites. Beneath the
Cambrian sandstone, the Precambrian bedrock consisting of
rhyolite, granite, and basalt occurs at depths greater than 1,000
feet. The Cambrian sandstone is the.principal aquifer for Dane
County. Saturated, thick glacial outwash deposits also produce
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Refuse Hideaway Landfill ROD
large quantities cf water and are the principal aquifer for
several wells located in the valley southwest of the landfill.
Figure 6 shows the physiographic areas and glacial-age deposits
in the area of RHL. Glacial materials include both outwash and
till; lacustrine sediments consist primarily of layered clay and
silt. Thickness of the unconsolidated deposits encountered at
RHL range from 5 feet thick on the north side of the landfill (at
P-17S location) to greater than 250 feet thick approximately &
mile southwest of the landfill (at P-31 location). (See Figure
7) The fine-grained lacustrine deposits overlie sandstone or
outwash and are primarily found east and southeast of RHL. The
grain size analysis shows the unconsolidated materials to be
quite variable in composition, ranging from fine-grained samples
with 98% clay and silt to coarse-grained samples with 46% gravel
and 48% sand. Most samples consisted of a mixture of fine and
coarse grains.
The bedrock in the RHL area consists of Ordovician Prairie Du
Chien dolomite, which caps the bluffs of the region but is absent
in the valleys. Up to io5 feet of dolomite is present at the P-
17 location (Fig. 7) on the bluff to the northwest"of the
landfill. Cambrian sandstone of the Trempealeau Group underlies
the dolomite. The bedrock is exposed at the ground surface in
some areas of the landfill property and at a road cut along U.S.
Highway 14, southwest of the landfill. Fracturing of the bedrock
is visible in the outcrops.
In the RHL area,, the water table can occur in the unconsolidated
deposits or in the bedrock. The sandstone of Late Cambrian age
and the sand and gravel of the outwash deposits appear to be
hydraulically connected. Groundwater occurs under unconfined
conditions in most of the area. Figure 5 presents a regional
water table map. Hydraulic properties of the outwash deposits
and the Cambrian sandstones are comparable. Hydraulic
conductivities of both units are high. Monitoring wells screened
in the. sand and gravel exhibited average hydraulic conductivity
values of 1.1 x 10"2 cm/sec., those screened in sandstone have
values of 2.2 x 10"3 cm/sec, and those in dolomite average 5.6 x.
10"3 cm/sec.
The direction of groundwater flow generally coincides with the
orientation of the Black Earth Creek Valley, flowing from
northeast to the southwest, 'immediately surrounding the
landfill, there appears to be a localized radial component of
flow from the landfill apparently due to groundwater mounding
beneath the landfill. To the north of the landfill, groundwater
at the water table flows to the north, essentially against the
regional flow, direction. Groundwater flow at depth (see
potentiometric surface maps, Figure 8) moves to the southwest,
14
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Refuse Hideaway Landfill ROD
consistent with the regional flow pattern. The apparent radial
flow pattern emanating from the landfill to the north appears to
be limited to the upper 30 feet of saturated thickness. An
unsaturated zone likely exists between the base of the. landfill
and the water table, based on significant elevation differences
between leachate•levels within the landfill and groundwater
elevations. The elevation difference between leachate elevation
and groundwater elevation is approximately 36 feet in the
northern portion of the landfill and 59 feet in the southwest
portion of the fill area.
Groundwater flow in the unconsolidated deposits to the south and
east of the landfill is to the south, while further off the Site
to the south, the flow direction changes and merges with the
regional flow direction which trends in a southwesterly
direction.
The Deer Run Heights subdivision is located over a mile southwest
of the landfill, in the Black Earth Creek Valley. The
subdivision is located on a "bedrock ridge" in the valley. The
groundwater elevations within the ridge tend to mirror that of
the surrounding valley. > In 1991, groundwater in the
unconsolidated valley deposits appeared to flow through the
bedrock of the Deer Run Heights ridge. The similarities of the
hydraulic conductivities between the sand and gravel and the
bedrock aquifers was thought to account for this observation. In
1993 groundwater elevations increased significantly and
groundwater flowed north and northeast into the valley from the'
Deer Run Heights ridge. The increased volume of water moving
through the valley appears to preferentially move from the
bedrock to the sand and gravel where the thick unconsolidated
deposits allow the water to migrate more easily than in the
bedrock.
C. Nature and Extent of Contamination
1. Source
K ravine in a bluff adjacent to and north of the Black Earth
Creek Valley was used to construct and operate the Refuse
Hideaway Landfill. (See Figure 1} The 1.2 million cubic yard
landfill operated between 1974 and 1988 and contains municipal,
commercial and industrial waste. Wastes that were disposed of at
the Site included full barrels of glue and paint, spray paint
booth by-products and paint stripper sludge, and spill residues
containing Volatile Organic Compounds. (Ref: State Hazard Ranking
System Narrative, WDNR). Source control actions, including
capping the landfill and gas/leachate extraction control direct
contact with waste, surface water contact, and air emissions from
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Refuse Hideaway Landfill ROD
the landfill. Previous and on-going contamination continues to
affect groundwater at the Site.
2. Groundwater Contamination
Lateral Extent of Contamination
Groundwater is the main pathway of concern for contaminant
migration at the Site. In general, groundwater flows beneath the
landfill and moves southwest to the Black Earth Creek Valley.
The main contaminant plume extends 3,800 feet southwest of the
landfill. Contamination extends radially from the landfill up to
1,500 feet north and east apparently due to groundwater mounding
beneath the landfill. Lateral extent and concentration of the
plume, with respect to total VOCs is delineated in Figure 10. The
1991 VOC .data were used to construct plume figures because all
functional wells were sampled in 1991 and more recent sampling
events have involved fewer wells. The groundwater modeling
completed in 1993/4 indicates that contaminant migration occurs
primarily within the sand and gravel deposits in the valley.
Bedrock migration of contaminants downgradient appears to occur
where fractures intersect the sand and gravel deposits within the
valley. The rate of groundwater flow near the landfill is much
greater than downgradient of the landfill due to the steep
gradients near the landfill. Flow rates near the landfill range
from 1.68-ft/day (sandstone) to 3.8 ft/day (sand & gravel).
Downgradient of the landfill, flow rates range from 0.11 ft/day
(sandstone) to 0.24 ft/day (sand & gravel).
Vertical Extent of Groundwater Contamination
The vertical extent of groundwater contamination is illustrated
in Figure 9. Vertical gradients are downward throughout the
aquifer in the study area. Near the landfill, contamination
extends to about 800 feet msl. The plume deepens to 700 feet msl
downgradient. In 1992, a new water supply well was drilled on
the Schultz property. The well extends to a depth of
approximately 500 feet msl and is cased to 600 feet msl. VOCs
were detected in the new Schultz well, indicating that
contaminants are present below 700 feet msl. The VOC impacts in
the Schultz well may be related to a preferential migration
pathway in the fractures of the bedrock. The contaminant plume
does not appear to extend below 700 feet msl in the
unconsolidated deposits. The vertical extent of the plume at P-
31 (located near the middle of Black Earth Creek Valley), does
not extend into the bedrock, which has an elevation of
approximately 700 feet msl, however it does extend into the
unconsolidated sand and gravel deposits, to an elevation of at
least 780 feet msl.
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Refuse Hideaway Landfill ROD
Water Quality Results
Groundwater has been sampled for inorganic compounds, metals,
volatile organic compounds (VOCs), semi-volatile organic
compounds (SVOCs), pesticides and PCBs. The primary contaminants
emanating from the landfill and which define the groundwater
plume are VOCs. (See Figure 9 and 10 for the vertical and
horizontal plume location.)
VOCs
A summary of U.S. EPA MCL and WDNR NR 140 exceedances is provided
in Table 1; locations of monitoring wells are shown in Figure 7.
Eight compounds, including benzene, chloroform, 1,2-DCA, cis-1,2-
DCE, 1,2-bichloropropane, PCE, TCE and vinyl chloride were
detected in concentrations which exceed the NR 140 ES. PCE is
the most pervasive of "the compounds in the groundwater.
Individual maximum chemical concentrations and well locations are
listed below.
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Refuse Hideaway Landfill ROD
Maximum VOC Groundwater Concentrations and Well Location
Constituent
Benzene
Chloroform
I , 2 -Dichloroethane
cis-1, 2-
Dichloroethene
1, 2-Dichloropropane
Tetrachloroethene
Trichloroethene
\
Vinyl Chloride
Concentration
20
37
41
1,900
21
150
160
525
Well
Location
P-9S
P-21S
P-9S
P-17S
P-9S
P-27S
P-17S .
P-21S
Metals
The only compounds detected above NR 140 ESs were manganese (21
wells) and iron (18 wells). The manganese concentrations ranged
from below the quantification limits to 2.6 ppm (ES =0.5 ppm).
The variation in manganese levels near the landfill appears to be
related to proximity to the RHL while at outlying wells no
landfill relationship to manganese is notable. Dissolved iron
levels near the landfill are high due to proximity to the RHL.
The highest concentration was observed at P-4S at 72 ppm.
Outlying wells had dissolved iron concentrations ranging from
less than 0.02 ppm to 5.42 ppm (ES = 0.3 ppm). The iron
concentrations in outlying wells are likely the result of
naturally occurring iron, based on normal background
concentrations and dissolved iron distributions.
In conclusion, iron and manganese levels beyond the landfill
property appear to reflect natural background concentrations in
the aquifer. Iron and manganese levels are elevated in
monitoring wells near the landfill due to the impact of landfill
leachate.
Semi-Volatile Organic Compounds
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Two sampling events, conducted in May and October 1993 positively
identified one SVOC - bis(2-ethylhexyl)phchalate at 3 ppb and 4
ppb in one well (P-21D). The Enforcement Standard for bis (2-
ethylhexyl)phthalate is 3 ppb, the PAL is 0.3 ppb. Because this
compound was detected in only one well, it is concluded that
semi-volatiles are not a contaminant of concern at the landfill.
However, the water treatment will be designed to remove any semi-
volatiles from extracted groundwater.
Pesticides/PCBs
Three wells were sampled for TCL (Target Compound List)
pesticides and PCBs in May and October 1993. No PCBs were
detected. Heptachlor was the only confirmed pesticide detected
in one well (P-21S) at 0.012 ppb and 0.010 ppb. These detections
are below the PAL for heptachlor (PAL = 0.04 ppb)• One other
pesticide, 4,4'-DDT, was detected once at 0.075 ppb at well P-
17S, but not confirmed. Pesticides and PCBs are not a contaminant
of concern at the landfill.
Private Wells
i
Private home wells serving 53 homes within 1 mile of RHL have
been tested for the presence of VOCs. Three private wells are
contaminated with VOCs. (See Figure 4 for locations) One well
(Swanson) has been shut down since early 1991. The other 2 wells
(referred to here as Schultz and Stoppleworth) have point-of-
entry treatment systems installed to treat VOC contamination.
Samples for metals and SVOCs were analyzed in May and. October
1993. All private well sample results have been sent to the
owners of the homes tested.
Metals
Both the Schultz and Stoppleworth wells exceeded NR 140 ES
for iron in October 1993. Manganese exceeded NR 140 PAL
levels for both samples collected at the Stoppleworth
residence. Iron and manganese are typically high in the
area and these detections are likely due to naturally
occurring iron and manganese.
The October 1993 sample from the Schultz well exceeded the
PAL for lead. Because the PAL for lead was not exceeded in
any of the monitor well samples, the detected lead.is likely
due to piping for the house and not to effects of the
landfill.
VOCs
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Numerous rounds of VOC sampling have been conducted on
various private wells. Table 2 summarizes the VOC
detections in the private wells. POE water treatment units
were installed in two of the wells (Schultz and
Stoppleworth)-while the third well was taken out of service
The compounds exceeding WDNR ES standards and Federal MCLs
are tetrachloroethene (PCE) and trichloroethene (TCE).
Maximum Concentrations Detected in Private Wells, Exceeding
Drinking Water Standards(ppb)
Name
Schultz
Stoppleworth
PCE
28
31
TCE
8.9
8.2
SVOCs
No SVOCs were detected in the May 1993 sampling round. In
October 1993, bis(2-ethylhexyl)phthalate was detected in
both well samples at concentrations of 92 ppb (Schultz) and
45 ppb (Stoppleworth). These detections are likely due to
introduced contamination during sample collection/handling
and not related to landfill effects.
Groundwater Modeling
In 1992, a groundwater flow model (MODFLOW) and contaminant
transport model (MT3D) were used to predict plume movement at the
leading edge of the plume in the Black Earth Creek valley. The
results of that modeling effort are reported in "Numerical Model
Simulation and Assessment of Contaminant Plume Migration, Refuse
Hideaway Landfill, Middleton, Wisconsin". A conclusion of the
report is that under the assumption that the source of impacts
-does not significantly increase (i.e., VOC concentrations within
the contaminant plume stay the same, decrease, or increase by
less than 1 order of magnitude), the plume will reach an
equilibrium condition after a period of approximately five years
(1996) due to dilution, dispersion, and,degradation processes.
Due to uncertainties within the model, there is a possibility the
plume will migrate beyond it's present location, however it -is
not expected to do so. The moceling provided the following
predictions: If the source of contamination is eliminated,
equilibrium will be achieved in about two years. If the source
of groundwater contamination is eliminated, these natural
processes (dilution, dispersion, and degradation) will remediate
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Refuse Hideaway Landfill ROD
the downgradient portions of the aquifer not remediated by
elimination of the source and chers will be no additional plume
migration.
3. Surface Water/Sediments
Sampling of surface water and sediments was not conducted during
the RI. In 1987, before the landfill cap was installed, 4
surface water samples were collected from the sedimentation basin
and drainage ditch near the landfill. There were no detectable
VOCs in 2 of the samples. The other samples contained detectable
levels of methylene chloride, 1,1-DCE, 1,2-DCE, bromoform, and
toluene below quantification limits. In addition MEK was
detected at up to 290 ppb. Capping of the landfill eliminated
the potential for precipitation to become contaminated by coming
in contact with exposed waste. In 1992, the sedimentation basin
was drained and.the sediment in the basin was removed. Together,
capping and sediment removal activities eliminated the
sedimentation basin as a potential source of contamination. In
July 1989, the WDNR collected surface water samples from Black
Earth Creek, two tributaries, and a drainage ditch near the
landfill. No VOCs were detected in any of these samples. These
sample results indicate that the landfill cap removed the
contaminated runoff source for surface water contamination.
Groundwater sampling in the water table wells located near Black
Earth Creek indicate that Black Earth Creek is currently not
being affected by the groundwater contaminant plume.
4. Air
No specific ambient air sampling has been conducted at the Site.
Source control has been undertaken at the Site in the form of
landfill containment (capping) improvements and maintenance,
thereby eliminating the potential for contaminated airborne dust
being released to the atmosphere. The landfill gas collection
and destruction system is tested in accordance with WDNR
administrative code requirements. The destruction system
(enclosed flare) meets all air emission standards. Thus, the
potential for contaminant vapor release to the atmosphere has
been eliminated.
VI. SUMMARY OF SITE RISKS :
A. Human Health Risk Assessment
A qualitative risk assessment was completed for the Site. The
purpose of the assessment was to identify human health hazards
posed by environmental contamination from the Site. The
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Refuse Hideaway Landfill ROD
qualitative risk assessment evaluates current as well as future
potential exposures to Site related contamination. Sample
results from the remedial investigation were used to evaluate all
environmental pathways with potential human exposure routes.
The reasons that a qualitative, rather than a quantitative, risk
assessment was completed include:
* state standards for air and water quality are protective of
human health and the environment
* the remedy must comply with state standards
* an EPA guidance document (Conducting Remedial
Investigations/Feasibility Studies for CERCLA Municipal
Landfill Sites, February 1991, OSWER Directive 9344.3-11)
states.that exceedances of state standards, as opposed to
the Site representing an unacceptable risk, are a cause for
action at Superfund municipal landfill sites.
A copy of the qualitative assessment is .in the RI report, and
includes standards of contaminants of concern, exposure
assessment and environmental assessment. Presented below is a
brief summary of the assessment and its conclusions.
During the RI, samples were taken of landfill gas, leachate, and
groundwater. Surface water and sediment samples were not
collected during this investigation because the clay cap ,
installed over the landfill in 1988, is expected to contain
contaminants and prevent surface water from coming in contact
with wastes. Sediments originating at the landfill collected in
the sedimentation basin located in the southeast corner of the
landfill property. These•sediments were excavated and removed,
thus eliminating this environmental pathway from the pathways of
concern. The results of the RI sampling as it relates to each
environmental exposure pathway are summarized below.
1. Air -
Landfill gas, consisting primarily of methane, has the potential
to migrate from the Site and is a potential explosive hazard to
persons living and/or working in buildings near the Site.
Monitoring throughout 1990 did not reveal any landfill gas in
nearby homes, though it was detected at potentially explosive
levels in a commercial building on the Site, adjacent to the
landfill.
Other toxic substances such as VOCs can co-migrate from the
landfill with the methane. On-site landfill gas samples were
analyzed for constituent VOCs as part of planning and designing a
gas extraction system to control the migration of gas away from
the landfill. The following VOCs were detected in the on-site
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Refuse Hideaway Landfill ROD
landfill gas: benzene, PCE, toluene, TCE, and vinyl chloride.
No gas samples for VOC analysis were collected from the building
chat contained potentially explosive methane concentrations.
The highest detected VOC values in the landfill gas are presented
in Table 3. The VOC concentrations detected in the landfill gas
samples are not necessarily indicative of the levels that could
exist in ambient air. When gas migrates to the ambient air,
concentrations drop rapidly due to dilution, dispersion, and
degradation.
Benzene, PCE, toluene, TCE, and vinyl chloride are all potential
contaminants of concern for the air pathway because the highest
detected levels exceed the comparison value for these compounds.
The air pathway has been addressed with the installation and
operation of a ground flare. The design temperature and gas
residence time (1,500° F for 0.5 seconds) ensures that the toxic
compounds are destroyed. Emission stack testing has shown that
the flare meets applicable ambient air standards, in accordance
with NR 445, Wis. Adm. Code.
2. Groundwater
i
Residents living near the Site rely on groundwater for their
drinking water and other domestic uses. Three nearby private
wells have VOC impacts; two of the wells have point of entry
treatment systems. The third well supplied a home and business.
The well has been shut down and the home is unoccupied. The
business receives bottled water. Thus, groundwater does not
currently pose a public health hazard to nearby residences who
obtain their drinking water from private wells. Residents using
untreated contaminated groundwater could ingest contaminants when
drinking water, inhale contamination released from the water
during domestic uses (cooking, showering, etc.) and absorb
contaminants through their skin while bathing and washing in
contaminated water. The point-of-entry treatment units must be
properly maintained to ensure removal of all contaminants from
the water.
The standard used for selecting contaminants of concern for
groundwater is the WDNR NR 140 Enforcement Standard (ES). This
is a health based standard developed by the Wisconsin Division of
Health (WDOH) and the WDNR to be protective of human health. The
preventive action level (PAL) is used to identify potential
contamination problems. An exceedance of the PAL is not
necessarily an indication of short or long term health hazards.
Past Groundwater Exposure
In July 1986, the Stoppleworth home well was tested by WDNR for
the presence of VOCs and none were detected. In August 1987,
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Refuse Hideaway Landfill ROD
testing of the Stoppleworth, Schultz and Swanson wells by the
landfill owner discovered the presence of VOCs above ES limits.
A supply of bottled drinking water was provided to the three
households in early 1988. It is estimated that eight people
living in the three households were exposed to contaminated
groundwater. Additionally, three employees at a seed business on
the Swanson property may have been exposed to contaminated
groundwater during their working hours. The exposure routes from
the domestic use of contaminated groundwater includes ingestion,
inhalation, and dermal adsorption.
In December 1989, the tenant occupying the Swanson home moved out
and the well was shut down. The business at that location
continues to receive bottled water. To eliminate all exposures
to contaminated groundwater, the WDNR installed a granular
activated carbon (GAG) POE water filtration system in May 1990 at
the Stoppleworth and Schultz homes. Subsequent monitoring has
shown the POE treatment system effectively removes all detectable
VOCs. VOCs are still being detected in the unfiltered water.
The POE treatment systems have become permanent water systems for
these homes and the homeowners have been responsible for
maintenance of the POE systems since summer, 1992. It is
estimated that contaminant exposure took place for no more than
four years (1986 to 1990). (See the Public Health Assessment for
Refuse Hideaway.) Table 2 contains a summary of water quality
data for the 3 private contaminated wells. A summary of the
maximum concentrations detected follows:
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Refuse Hideaway Landfill ROD
Maximum Concentration of VOCs in Private Wells (ppb)
Compounds
Chloroe thane
Dichlorodifluoro-
methane
1,1-
Dichloroe thane
cis-1, 2-
Dichloroethene
trans-1 , 2 -
Dichloroethene
1,2-
Dichloropropane
Tetrachloroethene
1,1,1-
Trichloroe thane
1,1,2-
Trichloroe thane
Trichloroethene
Trichlorof luoro-
methane
Vinyl Chloride
Schultz
3.2
17.2
6.9
33
47
1.34.
i
284
1.5
1.5
8.9
20
6.1s
Stoppleworth
19.5
9.73
4.9
30
21
<0.5
30.1
2.2
ND
8.2
16.8
5.5s
Swanson
ND1
. ND
ND
ND
1.5
ND
3.5
ND
ND
1.2
2.3
ND
PAL2-
80
200
85
7
20
0.5
0.5
40
0.06
0.5
698
0.02
ES5
400
100
0
850
70
100
5
5
200
0.6
5
349
0
0.2
= Not Detected
2PAL = Preventive Action Limit
3ES = Enforcement Standard = Federal MCL for these compounds
4Shaded = Exceedances of NR 140 ES
5Vinyl Chloride was last detected 3/88
Future Potential Exposure ' .
The two residences with GAC POE filter systems maintain those
systems themselves. The systems must be properly maintained to
avoid future potential exposure. If the third well is brought
back into service, or, if a new well is drilled on the property,
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the pumped wa-.-r will require adequate treatment, to avoid
exposure to c"~::aminants .
Groundwater ; .; w indicates that contaminated groundwater has the
potential to clow through the wells in the Deer Run Heights
neighborhood, located approximately one mile west-southwest of
the Site. Selected wells in the Deer Run Heights neighborhood
are. sampled every 6 months in addition to semi-annual monitoring
of 21 groundwater monitoring wells. This monitoring program will
alert the.WDNR to any changes in the location of groundwater
contamination and provide advance warning of potential threats to
nearby residents.
It is likely that new private homes and wells will be developed
near the Site in the future. At this time (1995) there is a
proposal to develop more than 200 private homes on the parcel of
land adjacent to Refuse Hideaway to the east and northeast.
Private wells would be placed upgradient of the existing
contamination, however, some of the proposed homes would be as
close as 100 feet to the existing groundwater contamination. It
is possible that additi6nal development could take place on other
nearby parcels.
Groundwater modeling performed in 1992 suggests that it is
unlikely that the groundwater contamination will migrate to the
Deer Run Heights neighborhood. However, inherent uncertainties of
the model make it impossible to conclusively determine that the
Deer Run Heights neighborhood will not be impacted. If the Site
is not remediated and the contaminant plume continues moving away
from the Site, contaminated groundwater might reach the Deer Run
Heights neighborhood sometime in the future. There are an
estimated 80 people living in 25 homes in the Deer Run Heights
neighborhood. The closest home in the neighborhood is
approximately 1,300 feet from the edge of the contaminant plume.
The highest detected concentrations of each contaminant detected
in the groundwater were evaluated as a worst case future exposure
scenario. Table 4 summarizes the compounds which have been
detected above the ES and other contaminants of concern detected
in groundwater and their highest concentrations. Benzene,
chloroform, 1,2-DCA, cis-l,2-DCE, 1,2-dichloropropane, PCE, TCE,
and vinyl chloride were all detected at .concentrations exceeding
the ES. Trans-1,2-DCE was evaluated because it was detected
above NR 140 ES levels in pre-1989 samples. Bis(2-
ethylhexyDphthalate (an SVOC) , heptachlor and 4,4'-DDT
(pesticides) were the only detected compounds of their classes
and were retained in the risk assessment.
The primary toxicity of the contaminants is related to their
carcinogenic health effects. A water supply well installed
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directly in the most contaminated portion of the groundwater
'plume would experience this worst case scenario. Two known
carcinogens, benzene and vinyl chloride, and several suspected
carcinogens, chloroform, 1,2-DCA, 1,2-dichloropropane, PCE, TCE,
bis(2-ethylhexyl)phthalate, heptachlor, and 4,4'-DDT have'been
detected above health based standards. Persons, who, over.a
lifetime, were to daily drink groundwater contaminated at the -
highest concentration levels detected in the plume may have an
increased risk of getting cancer.
Non-carcinogenic health effects could be experienced from cis-
1,2-Dichloroethene and trans-1,2-Dichloroethene, both of which
have potential hepatic toxicity.. Elevated iron and manganese
levels associated with the landfill have no direct health effects
but standards associated with these compounds are based on
aesthetic qualities of water.
3. Surface Water/Sediment Pathway
Contaminants were detected in surface water in 1987 before the
landfill clay cap was in place. Installation of the cap prevents
surface water from becoming contaminated. Sampling of Black
Earth Creek and the ditch south of the landfill found no VOCs in
1989. Surface water is not currently considered to be a pathway
of concern. The sedimentation basin was drained.and dredged in
1992, removing any accumulated sediment and eliminating sediment
as a pathway of concern.
Currently, groundwater flow is such that groundwater contaminants
are not discharging into Black Earth Creek. Without control, the
groundwater plume has the potential to discharge contaminants
into Black Earth Creek. If this occurred, the health effects
would be the same as exposure to the contaminated groundwater.
B. Ecological Risk Assessment
Five VOCs were detected in surface water at the Site in 1987.
These VOCs included: acetone, bromoform, 1,2-DCE, MEK, and
toluene. Most of these chemicals are dangerous to aquatic life
in high concentrations (percentage ranges) but do not concentrate
in the food chain. Capping of the landfill in 1988 removed the
potential for surface water to come in contact with waste
materials. Surface water samples collected in the drainage ditch
south of the landfill and in Black Earth Creek in 1989 detected
no VOCs. The sedimentation basin was drained and dredged in
1992, eliminating it as a possible source of contaminants.
Therefore, the greatest potential for environmental effects would
be from the release of contaminated groundwater to Black Earth
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Creek, the primary surface water body in the area. The current
groundwater flow regime indicates that groundwater is not
discharging into Black Earth Creek. The potential exists for a
future discharge if groundwater flow gradients change. The
compounds detected in groundwater that could have an affect on
aquatic organisms include: benzene, bromomethane, chloroform,
1,2-DCA, cis-l,2-DCE, trans-1,2-DCE, and TCE. The acute and
chronic ambient water quality criteria for all these compounds is
one to two orders of magnitude above the maximum concentration
found in the groundwater at RHL. These compounds do not
concentrate in the food chain.
Based on the results of the environmental evaluation, the current
risk posed to environmental receptors is low. The groundwater
contaminant concentrations are not likely to have any acute
environmental effects. Because of the carcinogenic nature of
some of the contaminants of concern, and because the chronic
effects of exposure to most of these compounds is not known,
environmental receptors may be affected if the flow of impacted
groundwater is not controlled.
i
There are no known endangered or threatened species or critical
habitats on or near the Site. (Ref: WDNR Endangered Resources
Letter, in Administrative Record)
C. Rationale for Further Action
Actual or threatened releases of hazardous substances from this
Site, if not addressed by the response action selected in this
ROD, may present an imminent and substantial endangerment to
public health, welfare, or the environment.
VII. DESCRIPTION OF THE REMEDIAL ALTERNATIVES
-A. Remedial Action Objectives
Remedial action objectives were developed for this Site to
address the landfill as a long-term source of contamination, to
address groundwater contamination, to ensure private water
supplies are protected, to provide short and long-term protection
of human health and the environment, and to meet applicable or
relevant and appropriate requirements.
The main concern driving this cleanup is the existence of
contaminants exceeding Federal MCLs and WDNR NR 140 ESs up to
3,800 feet downgradient of the landfill. These contaminants pose
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a future risk to existing and future private home wells in the
area.
The Site specific remedial action objectives for this Site, are:
Source Control RAOs
• Prevent direct contact with landfill contents;
• . Minimize contaminant leaching to groundwater;
• Prevent the migration of landfill gas;
• Control surface water run-off and erosion; and,
• Attain compliance with all identified Federal and State
ARARs.
Groundwater RAOs
• Attain the NR 140 PALs for all groundwater impacted by the
RHL at and beyond the landfill boundary. NR 140 PALs are the
most stringent of the groundwater standards that apply to
this Site and are the primary goal on which this action is
based. State groundwater goals are consistent with Section
300.430(a)(1)(iii)(F) which states that U.S. EPA expects to '
return groundwater at the Site to beneficial use wherever
practicable, within a time frame that is reasonable given
particular circumstances of the Site. The contaminants of
concern in the RHL groundwater are VOCs including: benzene,
chloroform, 1,2-DCA, cis-l,.2-DCE, 1,2-chloropropane, PCE,
TCE and vinyl chloride. All of these contaminants of
concern exceed NR 140, Wis. Adm. Code Enforcement Standards
(equal to Federal MCLs) beyond the landfill boundary. Iron
and manganese also exceed NR 140 Enforcement Standards,
however, exceedances beyond the landfill boundary are
primarily due to high concentrations occurring naturally in-
this area.
• Reduce the potential for exposure to contaminants in
groundwater; and,
• Attain compliance with all identif-ied Federal and State
ARARs.
Water Supply RAOs
• Provide potable water to residences with contaminated water.
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3. Development of Alternatives
Alternatives developed in the FS for the Remedy considered all
prior remedial actions implemented by the owner and State of
Wisconsin for this Site. These actions included: installation
and maintenance of a final soil cover over the waste that meets
all applicable State requirements for solid waste landfills;
installation and maintenance of a gas and leachate extraction
system on the landfill that meets all applicable State landfill
and air requirements; installation and maintenance of point-of-
entry (POE) GAC treatment systems on contaminated private home
wells (homeowners have provided maintenance since 1992) and the
installation and sampling of monitoring wells to identify and
track movement of the groundwater contamination.
The remedial alternatives were assembled from applicable remedial
technology options. A wide range of technologies and remedial
options were reduced by evaluating them with respect to technical
implementability, effectiveness, and cost. The alternatives
surviving the initial screening were evaluated and compared with
respect to the nine criteria required by the NCP. In addition to
the remedial action alternatives, the NCP requires that a no-
action alternative be considered for the Site. The no-action.
alternative serves primarily as a point of comparison for other
alternatives.
-The strategy used to develop alternatives was to provide general
response actions (GRAs) that address each medium of interest in
order to satisfy the RAOs. The GRAs are:
Source Control GRAs
In order to meet the RAOs for source control, the following are
the proposed GRAs:
• No Action
• Limited Action (Fencing and Deed Restrictions)
• Improve the Existing Landfill Cap with a Flexible Membrane
Liner (FML)
Groundwater GRAs
In order to prevent the migration of contaminated groundwater
beyond the edge of waste and treat the groundwater to remove the
contaminants found at the Site and specified in the RI, the
following are the proposed GRAs:
• No Action
• Pump and Treat Groundwater
• In-Situ Treatment of Groundwater
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Alternate Water Supply GRAs
In order to provide an alternate water supply fcr nearby
residences, the following are the proposed GRAs:
• Provide Bottled Water
• Treat Groundwater with In-Home Water Treatment Systems
• Install a Community Well Off-Site
• Deepen the Existing Wells
These general response actions describe a variety of
institutional and remedial actions intended to satisfy the
Remedial Action Objectives. These general actions were screened .
based on effectiveness (degree to which the alternative protects
human health and the environment and meets federal and state
ARARs), implementability (degree to which an alternative is
technically feasible), and cost (including construction and long-
term operation and maintenance costs) prior to comparison to the
NCP criteria.
1.' Source Control Alternative Development
i
The U.S. EPA guidance for CERCLA municipal landfill Sites
indicates that:
• Containment (capping) is generally the most practicable
remedial alternative. Cap materials can range from
soil cover to a multi-component impermeable cap..
• Treatment of soils and waste may be practicable for
"hot spots".
• Extraction and treatment of contaminated groundwater
and leachate may be required to control off-site
migration of wastes.
• Constructing an active landfill gas collection and
treatment system may be required to prevent off-site
migration.
JThe RHL is not known to contain hot spots of hazardous waste.
Therefore, removal and disposal of waste from the RHL was not
considered further. Active gas and leachate extraction and
treatment systems have been in place since August 1991.
Therefore, technologies screened for source control actions
included access restrictions and containment.
Two types of access restrictions used most, often at landfills
were evaluated: deed restrictions/zoning modifications and
fencing. Deed restrictions and zoning modifications are intended
to prevent or limit future Site use and development. The
effectiveness of .deed restrictions and zoning modifications
depends on state and local laws, enforcement and maintenance.
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The goal of a deed restriction and zoning modification at the RHL
would be to protect the integrity of the cap. Fencing and/or
gates physically limit access to the landfill. Signs warn
potential trespassers that there may be a health threat
associated with entering the Site.
Containment technologies include surface water controls and
capping. The existing landfill cover at RHL complies with NR
504, Wis. Adm. Code and consequently, surface water controls and
capping are currently in place at RHL. Consideration was given
to the use of a partial geosynthetic cover at the landfill to
further limit surface water percolation into the waste. Because
no known hazardous waste has been disposed of in the landfill, a
composite-barrier cap according to. the Resource Conservation and
Recovery Act (RCRA) is not required, but was used as a model for
evaluating a composite cap at the Site.
The Source Control Alternatives developed for RHL include:
Alternative A ^ No Action
Alternative B - Limited Action
Alternative C - Composite Cover
2. Groundwater Remedy Alternative Development
The purpose of the groundwater portion of the remedy is to return
groundwater beyond the landfill boundary to its beneficial use,
as an actual or potential groundwater source, within a reasonable
period of time. Contaminated groundwater will be returned to its
beneficial use when the concentrations of groundwater meet the
groundwater cleanup standards found in NR 140, Wis. Adm. Code.
The groundwater cleanup standards are the PALs. The groundwater
cleanup standards are applicable requirements for the groundwater
cleanup. These groundwater standards are listed in Table 5.
The location of the point of compliance for the groundwater
cleanup standards is the waste boundary. Groundwater cleanup
standards shall be attained throughout the contaminated plume
(excluding the area underneath the landfilled waste). This area
of attainment includes areas outside the property as well as the
area within the property, up to the waste boundary (Figure 11)
Groundwater Extraction ' .
Technologies screened to control groundwater included groundwater
containment and groundwater recovery. Containment technologies
usually involve the use of impermeable barriers and in-situ or
ex-situ treatment in order to reduce the volume and concentration
of contaminants. The depth of contaminants at RHL and the lack
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of an underlying impermeable zone precludes the use of these
technologies.
Groundwater recovery is used to reduce contaminant mass and
prevent migration by removing the groundwater from the aquifer.
Two options were -considered for RHL - groundwater interception
trenches and groundwater extraction wells. Interception trenches
are generally used where contamination is limited to 25 feet
below the surface. Groundwater contamination extends
approximately 100 feet beneath the surface adjacent to the
landfill and is located in sandstone bedrock. Therefore,
interception trenches can not be used at this Site.
Two options for groundwater extraction were evaluated for RHL:
a. Limited Extraction and Treatment of Groundwater. This option
includes extraction and treatment of groundwater near the
landfill to capture the groundwater with contaminant
concentrations in excess of 200 ppb while minimizing the
amount of water requiring treatment and discharge. This
technology will effectively remove the source of the
contaminant plume 'because all areas with impacts below 200
ppb would be cut off from the landfill. Groundwater
modeling contained in a Technical Memorandum titled
"Numerical Evaluation and Design of a Well Field for
Contaminant Capture and Ground-Water Control." was used to
determine optimum well locations and discharge rates for
this technology.
Additionally, 1992 modeling of the front edge of the plume
indicates that the plume will reach equilibrium within five
years due to natural attenuation processes and continue to
degrade and decline after the source is removed. Cutting
off the source of contamination would increase the ability
of the natural attenuation processes to reduce VOC
concentrations within the plume downgradient of the
landfill.
b. . Extraction and Treatment of Groundwater at the Source and
Throughout the Plume. The second extraction option
evaluated pumping and treating groundwater from near the
landfill as well as along the axis of the plume. It is
estimated that groundwater extraction of the entire plume
would likely generate 200 gallons per minute (gpm) of
groundwater which would require treatment and subsequent
discharge. Discharge options for 200 gpm are extremely
limited. As discussed later, the primary difficulty at RHL
is lack of discharge options for treated groundwater. The
surface water bodies in the area do not have the
assimilative capacity to handle a 200 gpm flow. An
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infiltration gallery would require many acres of premium
crop land. Finally, multiple injection wells (at least 8 or
more) would be required and controlling the injected water
is not likely feasible. Preliminary cost estimates for this
option include: capital costs - $1,450,000; annual O&M -
$340,000 with a 20 year present worth of $5,800,000 (cost
error estimates are +100% and -60%) . Estimated cleanup time
for pumping and treating the whole plume is 10 to 20 years
verses 20 to 40 years for pumping at the landfill source,
assuming a feasible .discharge location existed. Therefore,
extraction, treatment and discharge of 200 gpm water was
determined to not be a feasible option because of lack of a
discharge alternative. This option was not carried through
the nine criteria evaluation.
Groundwater Treatment
Two major groundwater treatment options were considered - ex-situ
treatment and in-situ treatment. Contaminated water extracted
from the plume would be treated above ground in a "treatment
train". In-situ treatment is an innovative technology and is
considered as part of the overall treatment train, "not as a stand
alone option.-
1. Ex-situ treatment options. These options include treatment
for organics and inorganics. Treatment for organic contaminants
includes carbon adsorption for providing a high level of removal
of "non-specific" organic materials and air stripping for
treating VOCs. These two technologies may be used together for
the greatest efficiency of organic cdntaminant removal. Carbon
absorption requires disposal or regeneration of the. carbon.
Biological treatment was also evaluated. Biological treatment
requires sufficient organic material to sustain treatment and may
be less appropriate for dilute groundwater streams. All
contaminants confirmed at the landfill can be successfully
treated with carbon and/or air stripping, so biological treatment
was not retained for evaluation.
Options evaluated for treating inorganic compounds include
chemical precipitation and ion exchange. Chemical precipitation
converts a wide variety of metals in the groundwater from a
soluble to an insoluble form. This process generates sludges
which require subsequent disposal as either a solid or hazardous
waste, depending on the chemical makeup of the sludge. Ion
exchange removes dilute concentrations of metals from the water
stream and can be used to "polish" the water after chemical
precipitation. Regeneration of ion exchange resins usually
produces a metal concentrate that requires disposal.
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2. In-situ treatment options. In-situ groundwater treatment
technologies are considered innovative by EPA. Technologies
considered include air sparging with vapor recovery, in-situ
bioremediation and in-situ chemical oxidation. The depths of
groundwater contamination near the Site (greater than 100 feet)
render air sparging infeasible. The main constituent in the
groundwater, PCE, does not lend itself to treatment by chemical
oxidation, so this option was not carried through the evaluation.
In-situ bioremediation includes aerobic biodegradation and co-
metabolism. Ideally, in-situ bioremediation stimulates
subsurface microorganisms to degrade contaminants within the
aquifer to carbon dioxide and water. In-situ bioremediation is
carried through the evaluation for RHL. However, the specific
techniques for stimulating native microorganisms to degrade these
contaminants will have to be determined by bench scale studies.
Groundwater Discharge
Groundwater which is removed from an aquifer and treated to
remove contaminants requires discharge. Methods typically used
to discharge treated groundwater include discharge to: surface
waters, Publically Owned1Treatment Works (POTW), infiltration
galleries, injection wells, or use of water for irrigation
purposes.
1. Discharge to Surface Waters. The nearest surface water body
is Black Earth Creek, a Class I trout stream classified as
an Outstanding Resource Water (ORW) by the WDNR. Water could
also be discharged to the headwaters of the adjoining water
shed, Pheasant Branch Creek. Preliminarily identified water
quality based discharge limits could be met through
treatment. Four potential surface water discharge locations
exist (see Figure 12) :
a. Black Earth Creek via Intermittent Drainage Ditch. The
ditch is located 200 feet from the southeast corner of
the landfill.
b. Black Earth Creek at Twin Valley Road. This location
• is 2/3 mile southwest of the landfill. The creek flows
year round at this location.
c. Black Earth Creek at Cross Plains. This location is
approximately 5 miles west of the landfill in the City
of Cross Plains. Black Earth Creek is classified as
an "exceptional" resource water (ERW) at this location.
d. East Fork of Pheasant Branch Creek. This is an inter-
basin transfer of water and would require lifting the
water 220 feet and conveying it 1 mile north of the
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landfill. Pheasant Branch Creek is classified as a
"warm water fishery".
2. Discharge to a POTW. The nearest POTW connection is 2 miles
east of RHL in the City of Middleton. The Madison
Metropolitan Sewerage District (MMSD) serves the cities of
Madison and Middleton. Discharge to the POTW would require
that MMSD install a conveyance system to the landfill. MMSD
has indicated it does not anticipate construction of such a
. system and second parties are not allowed to build
conveyance systems to MMSD.
3. Discharge to an Infiltration Gallery. An infiltration
gallery would allow treated'water to percolate .through the
soil, recharging the aquifer. U.S. EPA requires that the
design percolation rate be 4% of the minimum soil
permeability. Therefore, the area of the infiltration
gallery would be -approximately 76,400 square feet for a sand
Site..
4. Reinjection to the1 Aquifer via Injection Wells. Treated
water injected into the aquifer upgradient of the plume
would help increase the rate of remediation by flushing the
area with clean water and stimulating in-situ degradation
through the addition of dissolved oxygen to the aquifer.
5. Use of Treated Water for Irrigation Purposes. Treated
groundwater could be used to irrigate agricultural areas in
the vicinity of the Site. This option can only be used on a
seasonal basis and does not provide for on-going disposal of
the treated water. It is not carried through the nine
criteria. However, if an irrigation user wanted water
seasonally, was willing to construct and maintain the
conveyance system and could obtain a Wisconsin Pollution
Discharge Elimination System (WPDES) permit, the water could
be used for irrigation purposes.
The Groundwater Extraction and Treatment Alternatives developed
for RHL include:
Alternative A - No Action
Alternative D - Groundwater Extraction and Treatment
with Discharge to Surface Waters
Alternative E -• Groundwater Extraction and Treatment
with Discharge to an Infiltration
Gallery
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Alternative F - Groundwater Extraction and Treatment
with Reinjection for Enhanced In-Situ
Bioremediation.
3. Water Supply Alternative Development
While the groundwater contamination is not expected to move
beyond the presently defined plume boundaries, a risk to users of
private wells does exist. Therefore, the following alternate
water supply options were considered: bottled water, deepening
existing wells, individual point-of-entry (POE) treatment units,
and installation of an off-site community well.
Bottled water is generally a short-term action that does not
address non-ingestion impacts of contaminated water (inhalation
and dermal contact). Therefore, this was not considered further.
Deepening existing wells has been tried by the WDNR at the
Schultz home. A water supply well was drilled to 448 feet below
ground and cased to 359 feet. VOC impacts were detected in two
water samples collected after well development. Based on this
experience, deeper wells' do not appear to be a viable option at
this Site.
POE systems have been installed in two homes M mile southwest of
RHL and have removed all VOCs from the home water for 5 years. A
community water supply well could be installed several thousand
feet down gradient of the plume and a water distribution system
could be provided to residences most likely to be affected
(estimated at 25 homes).
The Water Supply Alternatives developed for RHL include:
Alternative A - No Action
Alternative G - Supply Individual In-home Water
Treatment Units
Alternative H - Construct a Community Well
C. Alternatives
A complete description of the1 various alternatives is provided in
the Feasibility Study. A brief narrative description of each
alternative is provided below:
1. Source Control Alternatives
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Alternaf- ive A: No Action
The No Action alternative is developed to act as a baseline to
compare against all other alternatives. This alternative-
consists of operation and maintenance of all actions currently
implemented, including, the gas/leachate extraction system,
maintenance of the soil cap and long-term monitoring for VOCs at
21 existing groundwater monitoring wells and 12 privates wells.
This action meets all required State and Federal standards for
closed landfills. This alternative does not, by itself, meet NR
140 groundwater standards. No capital costs are involved in this
alternative.- Annual O&M cost is $100,000 with a 30 year present
worth cost of $1,376,000.
An analysis of the effectiveness of the existing clay cap was
made by using the U.S. EPA HELP model to estimate the percolation
rate through the cap. This analysis showed that 1.1 inches/year,
or 670,000 gallons of water per year move through the landfill
cap. The average leachate extraction rate per year is
approximately 187,000 gallons, therefore 483,000 gallons of
leachate currently has the potential to percolate to the
groundwater each year.
Based on 1988 data, the average VOCs in leachate is about 500
ppb. It was assumed that the average quantity of VOCs which
percolates to the groundwater is a maximum of approximately:
483,000 galIons/year x 500 ppb VOCs = 0.2 galIons/year VOCs
Over time, the concentration of VOCs in the leachate should
reduce as VOCs are' flushed from the waste and removed through the
gas and leachate extraction system.
Alternative B: Limited Action (Selected Alternative for Source
Control)
This includes all actions under Alternative A. This alternative'
adds deed restrictions and zoning modifications to protect the
integrity of the landfill cap into the future. A fence and gate
have already been constructed along the southern edge of the Site
at the access road to limit access. Topography (steep vertical
rock walls and thick woods) restricts access to the landfill from
the north, west and east. Signs would be•posted along the
property boundaries at regular intervals to warn potential
trespassers of the potential risk of entering the Site. This
alternative does not, by itself, meet NR 140 groundwater
standards. The capital cost of this option is $7,000 with an
annual O&M cost of $100,000. The 30 year present worth cost is
$1,383,000.
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Alternative C: Composite Cover
This alternative involves the construction of a composite cover
over the flatter top slope areas cf the -landfill (approximately
20 acres). The existing vegetation would be removed and the .
topsoil and general soil would be removed and stockpiled. The 2^
feet of compacted clay would remain in place and a geosynthetic
liner and drainage layer would be placed over the clay. The
general soils and topsoil would be replaced and graded and the
Site would be revegetated. The final top cover of the landfill
would consist of (from top to bottom):
A 6 inch topsoil layer, seeded and fertilized to
sustain a dense vegetative growth of native plants;
A minimum 18 to 30 inch thick general soil layer to act
as frost protection and a rooting zone layer;
'- A drainage layer of either 6 inches, of sand or a
geonet/geofabric drainage layer;.
A 40 or 60 mil thick low density polyethylene (LDPE)
geomembrane; and
The existing 2% foot thick low permeability clay layer,
constructed in 1988 in accordance with NR 504.07(4),
Wis. Adm. Code.
The basic benefit of the composite cover would be to reduce
leachate production and the subsequent release of contaminants to
the groundwater. U.S. EPA's HELP model was used to estimate a
percolation rate of 0.01 inches/year, or 9,300 gallons of water'
entering the waste each year through the composite cover.
Because of the low leachate generation rates, it can be expected
that leachate pumping would eventually be eliminated.
Alternative C would result in significantly less leachate
generation when compared with the other source control options.
Alternative C would result in reduced leachate percolation to
groundwater and ultimately lower levels of aquifer contamination.
However, it is unlikely that NR 140 PAL levels would be met by
this alternative alone because VOCs will continue to enter the
groundwater even with reduced leachate volumes percolating to the
groundwater. The mass of contaminants in the waste does not
change under any source control alternative, therefore, the total
release of contaminants through time can be expected to be the
same for all source control alternatives. Alternative C would
have the lowest release rate, thus maintaining the smallest plume
volume, but may result in releases for the longest period of time
(that is, contaminants flush from the landfill more slowly for a
longer time), thus resulting in a longer plume persistence than
any of the other source control alternatives.
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Alternative C, by itself, does r.cc -eet NR 140 groundwater
standards. Capital cost of this option is $2,876,000 with an
annual O&M cost of $75,000. The 30 year present worth cost is
$3,908,000.
All Source Control Alternatives result in the waste mass being
left in place. Therefore, EPA and WDNR will review the data at 5
year increments to determine if the remedy is still protective,
or whether additional Source Control measures need to be taken.
2. Groundwater Extraction and Treatment Alternatives
Alternative A: No Action
Under Alternative A, no additional corrective action besides that
of Source Control Alternative B would be taken at the- Site to
address groundwater contamination. This would result in a
continued off-site migration of existing contaminants in the
groundwater. This remedy would allow the Site to remain as it
exists today. Therefore, contamination within the aquifer would
be addressed primarily (through natural attenuation processes such
as dilution, dispersion, and degradation. These processes are
expected to cause the plume to stop migrating further from the
landfill within a period of five years from 1991, when the
information for the contaminant transport model was collected.
The No Action Alternative does not meet the standard of providing
protection of human health and the environment because the
landfill is likely to leak contaminants for a very long period of
time and the only protections under the No Action Alternative are
institutional controls (e.g., water supply wells can not be
placed within 1,200 feet of a landfill) or addition of point-of-
entry treatment systems to contaminated private wells. Both of
these protections are subject to failure. Alternative A does not
meet the Remedial Action Objective (RAO) of restoration of
groundwater quality to WDNR NR 140 cleanup standards.
-There is no cost associated with the No Action Alternative.
Alternative D: Groundwater Extraction and Treatment with
Discharge to Surface Water
A single groundwater extraction and treatment approach has been
developed for RHL. The following description of this approach
applies to extraction and treatment of Alternatives D, E and F.
The difference in the alternatives involves groundwater discharge
options.
Groundwater E-xtractinn Component
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Groundwater extraction scenarios were modeled using the U.S.
Geological Survey's MODFLOW, a three-dimensional model that
simulates drawdowns using the finite difference method. PATH3D
was used in conjunction with MODFLOW to perform capture zone
analysis and particle tracking Calculations. Because grouhdwater
discharge options are quite limited at RHL, the goal of the
modeling effort was to define the groundwater pumping scenario
that effectively captures the groundwater contamination emanating
from the landfill (greater than 200 ppb total VOCs) while
minimizing the volume of water requiring treatment and discharge.
Based on the results of the modeling, four recovery wells would
be installed on the south and west sides of the landfill. The
wells would be installed at various depths (from 29 feet below
the water table to 87 feet below the water table) and would pump
between 10 and 15 gallons per minute (gpm) to achieve optimal
capture of the' highest observed contaminant concentrations
(greater than 200 ppb total VOCs, Figure 13). Total pumping rate
would be 45 gpm. Pumping 45 gpm of groundwater with an average
concentration of 200 ppb VOCs will remove 5 gallons of VOCs per
year from the groundwater. As stated above, it is estimated that
the landfill contributes 0.2 gallons of VOCs to the aquifer
yearly. Therefore, 25.times more contaminant will be removed
each year than leaches to the groundwater. Over time, the amount
of VOCs leaching from the waste to the groundwater should reduce
(as the mass of VOCs in the waste is reduced) and the volume of
VOCs removed by the extraction wells will reduce as the mass of
"contaminants in the aquifer reduces.
The extraction wells will provide hydraulic control of
groundwater at the waste boundary within a matter of days of
beginning to extract groundwater. Extraction of impacted
groundwater currently underlying the landfill would be achieved
within approximately 5 years. Additional flushing (by continued
groundwater extraction) of. non-impacted water would be required
to remove VOCs from the aquifer beneath the landfill to return
the groundwater to NR 140 standards. Based on aquifer conditions
and the fact that the aquifer beneath the landfill is the most
highly contaminated area of groundwater, 2 to 4 pore volumes are
estimated to be required to flush VOCs from the aquifer. It is
estimated that the landfill's contribution of contaminants to the
groundwater plume would end after 15 to 20 years of pumping.
This assumes that significant leaching of VOCs from the landfill
ceases after 15 to 20 years. It is impossible to know when VOCs
will be effectively flushed from the waste mass, therefore
pumping of wells near the landfill boundary may be required for a
considerably longer period of time than represented by the 15 to
20' year estimate.
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With implementation of groundwater extraction, the source of
further groundwater contamination will be eliminated and natural
processes will begin to eliminate the plume extending
downgradient of the landfill. As non-impacted water is flushed
through the aquifer, contaminants will be subject to natural
attenuation processes of dilution, dispersion and degradation.
Based on travel time for contaminant movement from the landfill
to private wells and groundwater model estimates, it is estimated
that one flushing of the aquifer between the landfill and the
edge of the plume will take 20 years. It is estimated that it
will take one to two flushings of the aquifer to achieve
groundwater standards downgradient of the landfill, therefore
cleanup time is estimated to be 20 to 40 years.
Groundwater Treatment Component
To define a treatment system, it is necessary to know both the
influent concentrations and effluent levels that must be
attained. It was assumed that the influent concentrations are
equal to the worst case conditions measured at monitoring wells
at the Site. The discharge requirements vary depending on the
discharge method and location-. The preliminary water-quality
based effluent standards have been developed by the WDNR. Table
6 summarizes the highest measured influent groundwater
concentrations and the treatment goals based on various discharge
alternatives. The treatment system has been designed based on
the highest estimated influent concentrations. Because it is
unlikely that actual influent concentrations will be as high as
estimated, actual treatment system design should be modified
during Remedial Design after aquifer testing and groundwater
analysis is completed. ' :
Development of the treatment system began with the preliminary
discharge standards•for surface water and NR 140 PALs for
groundwater. Best Available Technology (BAT; 40CFR125 and NR
220, Wis. Adm. Code) requirements were the assessed. Figures 14
and 15 present the conceptual flow diagrams of the proposed
groundwater treatment system of each potential discharge
location. Both treatment approaches include:
A flow equalization tank to provide uniform quality and
quantity of groundwater prior to treatment;
A chemical precipitation tank would be used for
precipitation of inorganic compounds. Bench scale
treatability tests are required to determine the chemical
additives needed. Possible additives include: hydroxides,
sulfides, ferrous sulfate, inorganic sulfides, organic
sulfur precipitants, and other metal precipitants. Chemical
precipitation generates sludge that requires disposal as
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' either a solid waste or hazardous waste, depending on the
chemical analysis of the sludge.
A flocculation tank and a clarifier-would be added to remove
metal precipitates that did not settle in the chemical
precipitation tank.
An air stripping tower would be used to remove the
strippable VOCs from the water stream. According to the FS,
the projected effluent concentrations of VOCs from the
stripper would be at concentrations less than one part per
billion. Based on a water flow rate of 45 gpm, an emission
rate of 0.12 pounds per hour is expected. Vapor control.
equipment is not expected to be required.
Air stripping will treat all VOCs .detected at RHL except for
bromomethane. Bromomethane was detected only during the
January 1991 sampling period and has not been confirmed in
any monitoring wells. Therefore, bromomethane is not likely
to be a concern. If it is detected during future studies,
additional treatment, such as biological or chemical
oxidation will need, to be evaluated.
A carbon absorption unit is BAT for removal of the detected
SVOCs and pesticides. These compounds and projected
influent concentrations are: 4,4'-DDT at 0.075 ppb, bis (2-
ethylhexyl)phthalate at 95 ppb, and heptachlor at 0.012 ppb.
An 800 Ib. liquid-phase carbon absorption system is expected
to not require change out more frequently than once a year.
Carbon absorption may not be required if the influent
groundwater in the proposed treatment system contains non-
detectable SVOCs and pesticides.
Ion exchange would be added as a metal polishing unit for
discharges to the ORW segment of Black Earth Creek
(Alternatives. Dl and D2) and for groundwater discharges
(Alternatives E and F). Other approaches include sulfide
precipitation or other polishing steps to achieve the low
metal concentrations of the ORW discharge.
Testing of groundwater has not been done for conventional
pollutants (e..g., BOD5, chloride, phosphates, nitrates and
nitrites). Possible treatments options, such as reverse osmosis,
for these constituents have not been included in the cost
comparisons of the alternatives. In addition, a heat exchanger
and pH adjustment may be necessary to adjust the temperature and
pH of the final effluent stream, if the effluent is discharged to
the ORW segment of Black Earth Creek.
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Alternative Dl: Groundwater Extraction and ~~°ar:ment with
Discharge to Black Earth Creek via a Drainage
D;Ltch at 5E Corner of Landfill
An agricultural ditch system in the upper Black Earth Creek
Valley provides drainage to surrounding farm fields and
constitutes the headwaters of Black Earth Creek (Figure 12) . The
drainage ditch begins at the southeast corner of the RHL
property. A 200 foot discharge pipe would be built from the
treatment plant at the landfill to the drainage ditch. Flow in
the ditch is intermittent so discharge of treated groundwater at
this point would constitute almost 100 percent of the flow in the
ditch.
Black Earth Creek is a Class I trout stream, a cold water fishery
and is classified as an Outstanding Resource Water (ORW) by the
WDNR. As an ORW, the creek is given the highest protection by
the State. The creek is assumed to have no assimilative capacity
for contaminants. Any effluent discharged to an ORW must meet
all background water quality conditions. In 1947 the WDNR
established Black Earth Creek as a Habitat Demonstration Area
(now called the Black Earth Creek Fishery Area). It was chosen
as a priority watershed in 1987. Cold water, naturally
reproducing trout streams are very rare in southern Wisconsin.
Black Earth Creek is a regionally and nationally important
resource and was named one of the top 100 trout streams in the
country by Trout Unlimited. Black Earth Creek is a fragile
resource that is very sensitive to temperature fluctuations.
Black Earth Creek experiences periods when temperatures exceed
lethal limits for brown trout during the summer. Trout reproduce
during the late fall and winter and a discharge with a different
temperature regime could impair reproduction. In addition, a
change in water volume could adversely affect the fishery of
Black Earth Creek. (Ref: July 8, 1994 WDNR memo from Scot Stewart
to Steve Fix.) ' .
A drainage district has been established in the upper Black Earth
Creek Valley for maintenance of the agricultural drainage ditch
system. The upper valley is prone to flooding. The increased
flows caused by a discharge to the ditch system would likely
exacerbate the high water conditions during wet periods of the
year. (Ref: Telephone conversation of T. Evanson with Richard
Heinrich, Drainage District President) Therefore, any discharge.
proposed for the upper Black Earth Creek would require a
hydrologic and ecological evaluation to determine what impact the
discharge would have on the stream and the surrounding land. Any
impact whatever would likely result in the WDNR denying approval
for discharge to the ditch system. Under Superfund, this would
be an "on-site" action and no administrative permits are
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required, however compliance with the substantive portions of the
permit is required.
Capital cost for Alternative Dl is $706,000 with an annual O&M of
$164,000 and a 30 year present worth of $2,965,000.
Alternative D2 : Grour.dwater Extraction and Treatment with
Discharge to Black Earth Creek at Its
Intersection with Twin Valley Road
This proposed discharge is approximately two thirds of a mile
southwest of the landfill (Figure 12). This location is within
the Black Earth Creek drainage district and is included in the
ORW classification. Here, discharge of the treated groundwater
would comprise approximately 10% of the creek's flow. All other
issues described in Alternative Dl, namely water quality, water
temperature, water volume and overall ecological environment
concerns apply to this discharge location. In-addition, it is
likely that a discharge at this distance from the landfill would
be considered "off-site" and would require a Wisconsin Pollution
Discharge Elimination System (WPDES) permit. Construction of a
discharge pipe would disturb more land and require more easements
than Alternative Dl. Estimated costs are: capital costs -
$903,000; O&M - $164,000; and a present worth cost of $3,160,000.
•
Alternative D3: Groundwater Extraction and Treatment with
Discharge to Black Earth Creek at Cross
Plains
This alternative involves construction of a discharge pipe to
Black Earth Creek downstream of the Cross Plains POTW,
approximately 5 miles west of the landfill (Figure 12}. Below
the Cross Plains POTW, WDNR's classification of Black Earth Creek
changes to an Exceptional Resource Water (ERW). Very stringent
water quality restrictions also apply to ERWs, although some
assimilative capacity, for contaminants is allowed. The treatment
scheme for this discharge would likely not require an ion
exchange polishing step. In addition, the treated groundwater
discharged at this point would make up much less of the total
flow of the creek than under Alternatives Dl and D2. Concerns
for impacts on water temperature and flow are lessened compared
to the ORW discharges of Alternatives Dl and D2.
Construction of a discharge line over 5 miles in length would be
difficult to implement with considerable disturbance of land and
many easements required. This action would be considered "off-
site" and would require a WPDES permit from the WDNR. Capital
costs are estimated to be $1,474,000 with O&M of $162,000 and a
present 30 year worth of $3,704,000.
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Alternative D4: Groundwa-^r Extraction and Treatment with
Discharge to che East Fork of Pheasant Branch
Creek
A separate watershed exists to the north of RHL which drains to
the East Fork of Pheasant Branch Creek. For this interbasin
transfer, water would need to be conveyed a distance of
approximately one mile with an elevation rise of 220 feet.
Discharge would be to an intermittent stream and the treated
groundwater discharge would make up approximately 100% of the
creek flow at the discharge point. Pheasant Branch Creek is
classified as a Warm Water Fishery, and as such, does not merit
the-same water quality protection as an ORW or ERW
classification. However, because the discharge would make up
100% of the flow, the projected water quality based effluent
limits from WDNR are somewhat more stringent than those of the
ERW segment of Black Earth Creek. The water treatment scheme
developed for the ERW would be used for the East Fork of Pheasant
Branch Creek.
This option would likely be considered an "off-site" action and
would require a WPDES permit. Considerable disturbance of land
and several easements would be required to construct the •
discharge line. The estimated capital costs are $750,000 with an
annual O&M of $162,000. The 30 year present worth costs are
$2,980,000.
Alternative E: Groundwater Extraction and Treatment with
Discharge to an Infiltration Gallery
Treated groundwater would be discharged to an infiltration
gallery. The treatment scheme would be the same as that proposed
for the ORW discharges. For cost estimation purposes, it was
assumed the infiltration gallery would be 6 feet deep, 275 feet
wide by 275 feet long, with a surface area of 76,000 square feet.
Groundwater would be pumped into the infiltration gallery and
discharge to gravel-filled trenches where the treated water would-
infiltrate down to the shallow aquifer. The infiltration gallery
would be surrounded by a clay berm to minimize run-on of surface
water.
The infiltration gallery must be placed in suitable permeable
soils for proper discharge of water. Figure 16
shows those areas that may be suitable. Most of the suitable
soils are along Black Earth Creek. Any hydrologic connection of
the infiltration gallery to Black Earth Creek would have to be
investigated to ensure that the creek would not be affected by
the discharge. For cost estimation, it is anticipated that the
infiltration gallery would be 3,500 feet from the landfill.
Construction would require land disturbance, easements and likely
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land purchase for the gallery. Capital costs are estimated to be
$1,115,000 with annual O&M of $154,000 and a 30 year present
worth of $3,236,000.
Alternative F: Groundwater Extraction and Treatment with,
Reinjection to Enhance In-Situ Bioremediation
(Selected Alternative)
In Alternative F extracted groundwater would be treated with the
treatment system as proposed for the ORW discharge locations.
Treated groundwater would be piped to two 55 feet deep injection
wells located approximately 400 feet east of the landfill (1,600
feet upgradient of the proposed groundwater extraction wells,
Figure 17) . Groundwater injection is essentially the reverse
process of groundwater extraction - groundwater would be pumped
into the wells and flow into the aquifer through the screened
zone of the wells. Periodic treatment (usually acid treatment)
of the injection wells would be required to remove scale and
metal precipitates which may clog the injection well screens.
The treated groundwater will be oxygenated due to the air
stripping process and injecting this water would oxygenate the
aquifer. Oxygen should stimulate naturally-occurring
microorganisms in the aquifer to degrade contaminants within the
aquifer. Only some of the contaminants are subject to
degradation through oxygenation alone (such as benzene and vinyl
chloride). The chlorinated compounds (particularly PCE and TCE)
would likely require other additives, such as co-metabolites, to
stimulate"their natural degradation. Treatability studies to
evaluate the addition of other materials (besides oxygen) to. the
injected groundwater would need to be conducted during Remedial
Design. Additionally, injection of treated groundwater
upgradient of the groundwater plume would help increase the rate
of remediation by flushing the aquifer with clean water.
Alternative F will likely result in a quicker aquifer cleanup
time than Alternatives D and E. However, the time reduction can
not be quantified at this time. The total time savings over
Alternatives D and E could range from months to a few years.
Groundwater modeling indicates that groundwater flow during
reinjection should remain essentially the same as at present.
The modeling indicates that the injected water should help
remediate the contamination beneath the landfill as well as
contamination in the plume that has moved southwest of the
landfill. It is not expected that reinjection will have any
impact on Black Earth Creek or on home wells in the area. Land
disturbance will result during construction of the discharge line
and injection wells. An easement on the property adjoining RHL
would be necessary. Estimated capital costs for Alternative F
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are $57.6,000 with an annual C&M of $157,000 and a 30 year present
worth of $2,737,000.
3. Water Supply Alternatives
Water supply alternatives are included in addition to. Source
Control and Groundwater Extraction and Treatment Alternatives in
the event the contaminant plume contaminates or imminently
threatens private residential wells in the future.
Definition of a "contaminated or imminently threatened" private
well: To receive an-alternate water supply system, a home well
must have confirmation (at least 2 sampling rounds) of
contaminants originating from the RHL that are equal to or
greater than the Federal MCLs or WDNR NR 140 Enforcement
Standards. A well will be considered "imminently threatened" and
will receive an alternate water supply 'if neighboring water
supply wells or groundwater monitoring wells indicate that
contamination is likely to extend.to the "imminently threatened"
well and to exceed the federal MCL or NR 140 ES.
Likely area to be served: It is projected that 25 existing
residences located in a one-mile radius downgradient of the
existing groundwater plume may require installation and operation
of an alternative water supply. Projected costs for supplying
alternative water are based on an estimate of 25 homes. However,
a proposed subdivision northeast (upgradient) of the landfill has
the potential to require alternative water supplies. This
development will consist of 200+ residential homes, with one
water supply well per every 4 homes. In addition, it is
anticipated that a golf course will be built in the midst of the
development and a 500 gpm high capacity well is proposed to
provide water to the golf course. It is possible that home wells.
could become contaminated by being placed too close to the
existing plume or by pumping the high capacity well and drawing.
the contamination upgradient of its present location.
Alternative G: Supply Individual Water Treatment Units (Selected
Alternative)
This alternative involves the installation and operation of
granular activated carbon (GAG) point-of-entry (POE) treatment
systems at each residence with a groundwater supply well that is
contaminated or imminently threatened with' contamination. The
POE systems would treat the entire household water supply prior
to distribution throughout the residence. For the protection of
human health, the POE systems would treat the groundwater to no
detect for VOCs. GAG POE units are currently in use at two homes
whose water wells have been contaminated with VOCs from the
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Refuse Hideaway Landfill. These unics have been very effective
in removing the contaminants and providing a reliable supply of
potable water. The units can be installed one ac a time and are
readily available. The drawback to FOE systems is that they must
be maintained to be effective. The homeowners at the two
residences using POE systems near RHL are responsible for
maintenance of the POE units in their homes.
It is expected that at least one POE system .would be installed at
the Randall Swanson property (known as Sunnyside Seed Farm) south
of U.S. Highway 14, approximately 3,800 feet southwest of the
landfill. The home on this property is not currently in use and
the driven-point well supplying the home and business has been
shut down. The Swanson well does not meet State well
construction requirements. However, if the well is upgraded or
if a complying well is constructed on the'property, a POE
treatment system will be required to ensure clean water is
delivered to the residence. It is expected that a 35 foot deep
well with a POE system would meet the requirements of the Swanson
house. Given the State's experience with trying to replace the
Schultz well, a deep.well would not likely provide clean water at
this location. >
As mentioned above, no more than 25 home wells located southwest
of the landfill in Deer .Run Heights and near U.S. Highway 14 and
Rocky Dell Road are expected to need replacement water supplies.
It is possible that the well supplying water to two homes at
"Summer's Tree Farm northwest of the landfill may require a POE
system if that well becomes contaminated as a result of radial
groundwater flow near the landfill. An unknown number of homes
in the proposed Hidden Oaks subdivision northeast of the landfill
could possibly require alternative .water supplies.
The estimated capital cost for 25 home POE systems is $220,000
with an annual O&M cost of $62,500.' The 30 year present worth
cost is $1,080,000.
Alternative H: Construction of a Community Well
This Alternative involves construction and operation of a
community water supply well located several thousand feet
downgradient of the impacted groundwater, beyond the anticipated
future reach of the contaminant plume. The well would be
constructed southwest of the landfill and would be screened at
greater than 150 feet below ground surface. A 50,000 gallon
elevated water tank would be used to store the pumped water and
water.would be distributed to each affected residence via a water
main with an approximate length of 10,000 feet. This Alternative
would be highly reliable and does not depend upon home owner's
maintenance for effectiveness. It is not cost effective to
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construct a community water supply well to serve a few homes.
However, a community well should be constructed if the number of
private home wells requiring replacement makes it cost effective
to use a community well rather than point-of-entry systems. The
estimated cost of Alternative H is: capital cost, $783,000;
annual O&M costs, $50,000; and a 30 year present worth of
$1,471,000.
VIII. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
A. Introduction
U.S. EPA has established in the NCP nine criteria that balance
health, technical, and cost considerations to determine the most
appropriate remedial alternative. The criteria are designed to
select a remedy that will be protective of human health and the
environment, attain ARARs, utilize permanent solutions and
treatment technologies to the maximum extent practicable, and to
be cost effective. The relative performance of each of the
remedial alternatives listed above has been evaluated using the
nine criteria set forth in the NCP at 40 CFR 300.430(e) (9) (iii)
as the basis of comparison. These nine criteria are summarized
as follows:
THRESHOLD CRITERIA - The selected remedy must meet the threshold
criteria.
1. Overall Protection of Human Health and the Environment
A remedy must provide adequate protection and describe how
risks are eliminated, reduced or controlled through
treatment, engineering controls or institutional controls.
2. Compliance with Applicable or Relevant and Appropriate
Requirements
A remedy must meet all applicable or relevant and
requirements of federal/state laws. If not, a waiver may
apply.
PRIMARY BALANCING CRITERIA are used to compare the effectiveness
of the remedies.
3. Long-term Effectiveness and Permanence
Once clean up goals have been met, this refers to expected
residual risk and the ability of a remedy to maintain
reliable protection of human health and the environment over
time.
4. Reduction of Toxicity, Mobility or Volume Through Treatment
The purpose of this criterion is to anticipate the
performance of the treatment technologies that may be
employed.
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5. Shore-term Effectiveness
This refers to how fast a remedy achieves protection. Also,
it weighs potential adverse impacts on human health and the
environment during the construction and implementation
period.
6. Implementability
This criterion requires consideration of the technical and
administrative feasibility of a remedy, including whether
needed'services and materials are available.
7. Cost
Capital, operation and maintenance, and 30 year present
worth costs are addressed.
MODIFYING CRITERIA deal with support agency and community
response to the alternatives.
8. Support Agency Acceptance
After review of the Focused Feasibility Study and the
Proposed Plan, support agency's concurrence or objections
are taken into consideration.
9. Community Acceptance
This criterion summarizes the public's response to the
alternative remedies after the public comment period. The
comments from the public on the Proposed Plan, for this Site
are addressed in the Responsiveness Summary attached to this
ROD.
B. Evaluation of the Remedial Alternatives
THRESHOLD CRITERIA
The threshold criteria are CERCLA statutory requirements that.
must be satisfied by any alternative in order for it to be
eligible for selection as a CERCLA-quality remedy. These two
criteria are discussed below:
1. Overall Protection of Human Health and the Environment
Source Control Alternatives: All three landfill cap
alternatives, including the No Action Alternative, prevent direct
contact with waste and address air and surface water media. All
source control alternatives, including No Action, include:.
continued operation and maintenance of the existing landfill .gas
collection system and would prevent migration of landfill gas
from the Site; operation and maintenance of the leachate
extraction system with off-site treatment and disposal;
inspection and maintenance of the existing cap to control surface
water run-off and erosion; and testing of existing groundwater
monitoring wells and private wells.
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Alternatives B and C include placement of a deed
restriction/zoning modification and warning signs around the
disposal area and are therefore more proteccive than Alternative
A at protecting the landfill integrity into the future.
The expected percolation rate through the geosynthetic membrane
cap of Alternative C is 0.01 inches/year versus 1.1 inches/year
for the existing clay cap specified in Alternatives A and B.
Therefore, Alternative C provides the greatest reduction of
infiltration of leachate to groundwater. A reduction of the
contributions of leachate to groundwater would result in a
decrease in contaminant concentration within the groundwater
plume and likely a reduction in plume extent with time. The
reduction in groundwater contaminant concentration and plume
extent resulting from Alternative C would be more protective of
human health and the environment than either Alternatives A or B.
However, Alternative C by itself will not remove existing
contamination from the groundwater nor restore groundwater to NR
140 standards beyond the waste boundary. Alternative B, in
combination with a groundwater extraction alternative would be
more protective than any source control option'by itself.
Alternative C, in combination with a groundwater extraction
alternative would be as protective as Alternative B in
combination with groundwater extraction/treatment.
Extraction and Treatment Alternatives
The qualitative risk assessment indicates that there is a future
risk to human health and the environment from contaminated
groundwater from the Refuse Hideaway Landfill. Three private
water supply wells are currently impacted by contaminants
emanating from RHL. Two of these wells have point-of-entry (POE)
treatment systems installed and are not coming in contact with
contaminants. The third home/business is not currently occupied
and the water supply well has been shut down. Bottled water is
provided to the business. Therefore, there is no current risk to
human health or the environment at the Site.
Based on groundwater modeling performed in 1992, natural
attenuation processes appear to be controlling the extent of the
groundwater plume and the plume is expected to reach equilibrium
within a period of five years' from the time of the model run.
However, flow and solute transport predictions can not be
considered unique because they are based on limited data and
approximations of the actual physical/chemical systems.
Therefore, we can not be sure that the groundwater contamination
will not move beyond its present boundary.
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Based on the 1992 groundwater modeling, the No Action Alternative.
(Alternative A) is expected to prevent further migration of
contaminated groundwater into the Black Earth Creek valley.
However,, the No Action Alternative does not prevent migration of
contaminated groundwater from the landfill boundary.
Alternatives D, E and F include a groundwater extraction system
designed to minimize the groundwater volume which requires
extraction while maintaining hydraulic control of the most
contaminated (greater than 200 ppb total VOCs) grcundwater at the
Site. Alternatives D, E, and F would meet the Remedial Action
Objective (RAO) of preventing migration of contaminated water at
the landfill boundary.
The discharge standards for Alternatives D and E and the
reinjection standards for Alternative F are based on Wisconsin
Administrative Codes which are intended to protect human health
and the environment. Therefore, all the pump and treat
alternatives are equally protective of human health and the
environment and are more protective than Alternative A.
Alternative F provides additional protectiveness due to the
increased speed of remediation associated with the reinjection of
treated groundwater to ehhance in-situ bioremediation of the
contaminated aquifer.
Water Supply Alternatives
As mentioned above, the three wells currently affected by
contaminants from RHL have POE systems maintained by the home
owners or bottled water supplied by WDNR. Currently, groundwater
is monitored semi-annually at 21 monitoring wells and annually at
12 private home wells. The RAO includes provision of potable
water to residents of properties with well water that may be
contaminated in the future. Both Alternative G and H would
supply safe, reliable water to private.wells that may be
contaminated in the future and are therefore highly protective of
human health. Treatment or replacement of private water supplies
does not address the contamination within the aquifer and by
themselves, Alternatives G and H are not protective of the
environment. However, in conjunction with Source Control and
Groundwater Extraction and Treatment remedies, Alternatives G and
H meet the objective of overall protection of human health and
the environment.
2. Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
Source Control Alternatives
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Alternatives A (No Action), B, and C would meet the Wisconsin
Administrative Code requirements for closed landfills and would
provide a landfill cover in strict conformance with NR 504.07,
Wis. Adm. Code. The addition of a synthetic membrane provided by
Alternative C is not required by existing state or federal
requirements.
These alternatives rely upon the landfill cap to reduce
contaminant loading (percolation of leachate) into the
groundwater with periodic monitoring to provide information on
changing groundwater conditions at the Site. Alternative C
achieves the greatest reduction of contaminant loading to the
aquifer. By themselves, however, Alternatives A, B, and C do not
restore groundwater to NR 140 PALs within a reasonable period of
time. . In conjunction with a groundwater extraction and treatment
alternative, che Source Control Alternatives do meet ARARs.
Groundwater Extraction "and Treatment Alternatives
Alternatives D, E, and F involve extraction and treatment of the
highest observed concentrations of contaminated groundwater. The
unextracted groundwater (less than 200 ppb total VOCs) would
exceed WDNR Enforcement Standards (ESs). However, groundwater
extraction will remove the source of the contaminant plume
allowing natural attenuation processes to remediate the remaining,
VOCs in the groundwater within a reasonable period of time. It
has been determined that 20 to 40 years to meet PAL standards at
this Site is a reasonable period of time because:
1. The extent and degree of groundwater contamination at
the Site is known and continued plume migration is not
expected.
2. A.municipal water supply has not and is not expected to
be affected by this Site.
3. Water supplies have been provided for the 3 affected —
residences and these alternative water supplies will be
available for the expected time period .of the remedy.
4. Additional private wells are not expected to be
impacted by this Site. If additional private wells are
affected by the Site, a contingency is in place to
treat the water supplies so that residents would not be
exposed to contaminants.
5. Considering the geologic environment and contaminant
type and concentration at the Site, it is expected that
the proposed remedy will restore groundwater quality
over the time frame stated.
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6. . This time frame is less than' the 100 year clean-up time
frame -stated in EPA guidance (SPA/540/G-88/003 ,
Guidance on Remedial Actions for Contaminated Ground
Water at Superfund Sites) and draft DNR guidance (Draft
Guidance on Implementing Wisconsin's Groundwaner Code,
Chapter NR 140) on grcundwater remedies.
It is expected that one to two flushings (equivalent to 20 to 40
years) of the aquifer will be required to achieve NR 140 PAL
standards in the aquifer downgradient of the extraction system.
The No Action Alternative does not return groundwater contaminant
concentrations to within the NR 140 requirements within a
reasonable period of -time and therefore does not comply with
ARARs.
Water Supply Alternatives
The groundwater contaminant plume at RHL appears to be at
equilibrium. This means the plume does not appear to be moving
because incoming contamination is balanced by natural attenuation
processes throughout the,, plume. It is not believed that
additional home wells will be affected by the plume. However,
the possibility that the plume will move in the future or that .
future residential development will be affected by the plume can
not be ruled out. If home wells become contaminated in the
future, action must be taken to protect the residents. Both
Alternatives G and H provide effective, reliable approaches for
alternative water supplies.
PRIMARY BALANCING CRITERIA
Alternatives which satisfy the two threshold criteria are then
evaluated according to the five primary balancing criteria.
3. Long- term Effectiveness and Permanence
Control Alternatives
Alternatives A, B, and C satisfy the primary balancing criteria
of long-term effectiveness and permanence by maintaining the
existing (Alternatives A and B) or improved (Alternative C)
landfill cap, removing landfill gases for 'destruction and
leachate for off -site treatment and disposal. Alternatives B and
C provide additional long-term effectiveness and permanence
compared to Alternative A by placing deed restrictions and zoning
modifications and warning signs which restrict the present and
future use of the landfill.
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Alternative C provides the best long-cerm effectiveness and
permanence for cap performance because it does the most to reduce
percolation of water through the cap, thus reducing the amount of
leachate that can percolate to the groundwater. However, under
all source control options, groundwater extraction and treatment
would be required to address the risk associated with percolation
of residual leachate to groundwater.
With a groundwater extraction and treatment system, the existing
clay cap provides long-term effectiveness and permanence because
VOC concentrations in the leachate will be significantly reduced
over time as contaminants are removed through the gas/leachate
extraction system 'and flushed from the waste and removed by the
groundwater extraction system.
All the source control remedies provide long-term effectiveness
and permanence when implemented with any of the groundwater
extraction alternatives. With the implementation of groundwater
extraction, the time required for the downgradient groundwater
plume to reach NR 140 PAL standards (approximately 20 to 40
years) is the same for Alternative A, B, and C.
Groundwater Extraction and Treatment Alternatives
Alternatives D, E, and F equally reduce the magnitude of residual
risk through groundwater extraction and treatment. NR 140 PALs
are the cleanup goal throughout the plume and this goal can be'
met in 20 to 40 years with Alternatives D, E, and F. The No
Action Alternative may eventually meet this goal, but only after
a much longer period of time. It is not possible to estimate how
long it will take for the landfill to stop leaching contaminants
above NR 140 ESs (Federal MCLs), therefore it can be expected
that the No Action Alternative would take many decades to reach
cleanup standards.
Alternatives D, E, and F provide hydraulic control of source area
groundwater, preventing contaminant migration beyond the extent
"of the current plume. The 1992 modeling indicates that the plume
should reach equilibrium within a few years indicating that the
No Action Alternative would also prevent the contaminant plume
from moving beyond its current Boundary. However, groundwater
models contain a significant level of uncertainty so confidence
t.-~,.t No Action will result in overall plume control is much less
certain than \-.--h Alternatives '-., E, and F. Therefore,
Alternatives D, E, and F provide the greatest adequacy and
reliability of controls while Alternative A does not provide the
desired adequacy and reliability of controls.
Alternatives D, E, and F provide long-term effectiveness by
improving existing groundwater quality through treatment.
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Alternative F provides additional long-term effectiveness and
permanence by enhancing in-situ bioremediation of the groundwater
thus increasing the rate at which the groundwater would meet the
WDNR cleanup standards.
Water Supply Alternatives
Alternatives G and H would provide long-term effectiveness by
providing a potable water supply to residences whose water supply
wells are impacted in the future.. Alternative H (community well)
is more effective in the long-term than Alternative G (POE
systems) because under Alternative H only clean water would be
pumped and distributed to residences resulting in a lower
potential for exposure to contaminated water than POE systems
offer. Alternative G requires that individual home owners
properly maintain the POE systems which presents the potential
for failure of the POE systems.
4. Reduction in Toxicity, Mobility or Volume Through Treatment
Source Control Alternatives
Alternatives A, B, and C provide the identical landfill gas
collection and destruction system and leachate collection and
off-site treatment and disposal system. Therefore, they each
provide equal reduction of toxicity and mobility through
treatment. The volume of leachate to be treated would be lower
under Alternative C due to decreased cap percolation than under
Alternatives A and B.
Groundwater Extraction and Treatment Alternatives
Alternatives D, E, and F include groundwater extraction and
treatment to address areas of groundwater exceeding 200 ppb total
VOCs. The 1992 groundwater model indicates that intercepting the
source of the plume would result in dissipation of the remainder
of the plume as the result of natural attenuation processes.
Natural processes are not treatment, however they do result in a
reduction- of toxicity, mobility and volume of contaminants in the
groundwater. Alternatives D, E, and F as well as the No Action
Alternative rely on natural attenuation processes such as
dilution, dispersion and degradation of contaminants in the
groundwater. However, NR 140 PAL standards will not be reached
at the landfill boundary within a reasonable period of time under
the No Action Alternative. Alternatives D, E, and F will reduce
toxicity, mobility and volume by removing contaminants from the
groundwater and treating them. Alternative F is expected to
provide the most efficient method of restoration of groundwater
quality since the injection of treated groundwater will enhance
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in-situ.degradation of degradable compounds due to the addition
of dissolved oxygen.
Reduction of tcxicity of the groundwater is achieved by removing
VOCs with an air stripper, heavy metals with chemical oxidation
(and perhaps icn exchange), SVOCs and Pesticides with activated
carbon adsorption. Ion exchange is proposed to meet the very
strict discharge standards of the ORW portion of Black Earth
Creek. This treatment step may or may not be necessary for
Alternatives E (infiltration gallery) and F (reinjection wells),
depending on final effluent limits and maintenance requirements
of the galleries or injection wells.
Discharge of VOCs into the air is not expected to increase the
potential risks to human health and the environment. All
pertinent air standards are expected to be achieved with the
proposed groundwater treatment system. If VOCs exceed air
standards, off-gas treatment would be installed. The treatment
system will also produce heavy metals, solids, and sediments that
would form a sludge which would need to be disposed of in a
permitted solid waste or1, hazardous waste landfill, as required by
the sludge characteriaation. The activated carbon ~and ion
exchange resin would require occasional regeneration to remove.
contaminants from those materials.
Water Supply Alternatives
Only Alternative G includes treatment of groundwater prior to use
as potable water. This treatment will reduce toxicity, mobility,
and volume of contaminants similar to the groundwater extraction
and treatment alternatives because it will remove the
contaminants from the groundwater. The amount of reduction
achieved by individual POE units is much less than that achieved
by the groundwater extraction and treatment alternatives.
5. Short-term Effectiveness
Source Control Alternatives
»
Implementation of Alternatives A, B or C will provide protection
to the community through groundwater monitoring, landfill gas
control and monitoring and leachate control and monitoring.
There is no substantial risk associated with construction of any
of the landfill cap alternatives because the clay cap containing
the waste will remain in place under all source control
alternatives so there will be no direct contact with waste.
Under Alternative C, physical risks associated with construction
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will be present, but these should not significantly affect the
protection of human health or the environment.
Groundwater Extraction and Treatment Alternatives
Construction and implementation of Alternatives A, D, E, and F
would not result in risks to human health and the environment
from the waste or groundwater. Physical risks are present at any
construction project. Construction of Alternatives D and E would
entail much greater land disturbance than Alternatives A and F.
Construction of Alternative F will be largely limited to the Site
property boundary with some construction on the property
immediately adjacent and east of the Site. The clay cap will not
be disturbed under any groundwater extraction and treatment
alternative. Extreme caution and appropriate health and safety
precautions would be employed during any activities where there
is potential for exposure to contaminated water.
Alternative F would be more effective in the short-term than
Alternatives D and E because Alternative F would enhance in-situ
bioremediation of the contaminated groundwater...
i
Water' Supply Alternatives
There is currently one contaminated private home well (the
Randall Swanson property) that is not in use. However, if a new
well is installed or the existing well is upgraded, a POE system
will be required to treat the contaminated groundwater. At two
other residences with contaminated well water, POE systems are
effectively treating the well water. If additional homes become
contaminated in the future, POE treatment systems (Alternative G)
are more effective in the short-term than a community water
supply well (Alternative H) because POE systems can be installed
quickly while a community water supply system, including a well,
elevated storage and distribution system would need to be
designed and constructed. In addition, POE units can be
installed in individual homes while several homes would likely
need to be threatened or affected before it would be practical
and cost effective to install a community water supply system.
Implementation of Alternative G or H would not result in risk to
human health or the environment from contact with waste or
groundwater. All construction projects involve physical risks,
however the physical construction risks associated with
Alternative G are minimal.
6. Implementability
Source Control Alternatives
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Required materials, services and equipment are available to
implement each source control alternative. Operation and
maintenance of the existing systems at the Site have already been
implemented. Alternative A involves no construction and is the
easiest to implement. Alternative B involves placement of
warning signs and deed restrictions and is only marginally more
difficult to implement than Alternative A. Alternative C
involves placement of a composite cover (and warning signs and a
deed restriction) and would require care in construction to
minimize potential damage to the existing leachate and gas
recovery system.
Groundwater Extraction Alternatives
Required materials, services and equipment are available to
construct each of the groundwater extraction and treatment
alternatives. Alternative A involves no construction and is
easiest to implement. Construction of the groundwater extraction
and treatment system proposed in Alternatives D, E, and F would
be easily implemented from a technical and administrative
standpoint. The major difference for these alternatives is the
implementation of the discharge or reinjection system, as.
follows:
Discharge to the ERW segment of Black Earth Creek
(Alternative D3) would be easiest to implement
administratively. The ERW segment has the greatest
assimilative capacity for the discharge of. treated
groundwater and it would be easier to receive WDNR approval
for a discharge to this segment 'of the creek. However, it
is likely the most difficult to implement technically
because it involves building a 5 mile discharge pipe. Many
easements through private property and through the City of
Cross Plains would be required as well as significant
disturbance of land.
Discharge to Alternative D4 (East Fork of Pheasant Branch
Creek) would be somewhat more difficult to implement
administratively than D3 because this "warm water fishery"
water has less assimilative capacity than the ERW portion of
Black Earth Creek. This alternative would be somewhat
difficult to implement from a technical standpoint because
it requires a system to lift the treated water 220 feet
vertically and then discharge it one mile north of the
landfill.
Discharge to Alternatives Dl and D2 (ORW portion of Black
Earth Creek) are the most difficult to'implement
administratively. The ORW is very sensitive environmentally
and a discharge to this segment is unlikely to be approved
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by the WDNR. Water temperature and volume concerns as well
as water quality concerns must be addressed for any
discharge to these locations. These locations are closest
to the landfill and require the least land disturbance for
building a discharge line.
Alternative E (infiltration gallery) may be difficult to
•implement administratively. The only acceptable gallery
locations are downgradient of RHL and location is further
limited by roadways and surface water bodies. It is
estimated that a minimum 250 foot -setback from a surface
water body or roadway is necessary to minimize potential
disturbances between the discharge location and these other
areas. A minimum of 2 acres of land is needed for the
gallery as well as access to the property.
Alternative F may be difficult to implement technically.
Alternative F is an innovative technology -and has more
unknowns associated with it than the other alternatives'.
Pump tests in both the extraction and injection well areas
are needed as well as treatability studies associated with
enhancing the in-s±tu biodegradation. Alternative F has
additional O&M issues compared to surface water discharge
alternatives. It is likely that Alternative F would be
considered an on-site action and no permits would be
necessary (under federal authority). '
Water Supply Alternatives
All water supply alternatives are implementable. Alternative A,
No Action, is easiest to implement. Alternative G is next
easiest from a technical standpoint because it involves
installation, operation and maintenance of small scale treatment
systems which are readily available and have been demonstrated to
effectively treat the contaminated groundwater. Alternative H
would be more difficult to implement because larger scale
construction would be required for a community well and a piping
network system.
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7. Costs
Cost Summary
Description
Total
Direct
Cost ($)
Annual
O&M ( $ )
Present
Worth ($)
SOURCE CONTROL ALTERNATIVES
A. No Further Action
B. Limited Action1
C. Construct a Composite
Cover on Landfill
0
7,000
2,876,000
100, 000
100,000
75,000
1,376,000
1,383,000
3, 908,000
GROUNDWATER EXTRACTION, TREATMENT, AND DISCHARGE ALTERNATIVES
Dl Discharge to BEC via
Drainage Ditch, SE,of
landfill
D2 Discharge to BEC at Twin
Valley Road
•
D3 Discharge to BEC at Cross
Plains
D4 Discharge to East Fork of
Pheasant Branch Creek
E. Discharge to an
Infiltration Gallery
F. Discharge by Injection
Wells
706, 000
903,000
1,474, 000
750,000
1,116, 000
576,000
164,000
164, 000
162, 000
162,000
154, 000
157,000
2,963,000
3, 160,000
3,704, 000
2, 980,000
3,236,000
2,737,000
WATER SUPPLY ALTERNATIVES
G. Supply Individual Water
Treatment Units
H. Construct Community Well
TOTAL, SELECTED ALTERNATIVES
220,000
(ea.
6,000)
783, 000
810,000
62,500
(ea.
2,500)
50, 000
319,000
1,080,000
1,471,000
5,207,000
1Shading = Selected Alternatives
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MODIFYING CRITERIA
Alternatives which satisfy the Threshold and Primary Balancing
Criteria are then evaluated according to'the Modifying Criteria.
8. U.S. EPA Acceptance
The WDNR is the lead agency on this case and authors this ROD.
EPA has been the support agency for the RI/FS and has reviewed.
this ROD. This RI/FS has been a fund financed action and
therefore, EPA's concurrence is necessary. EPA concurs with this
action and the letter of concurrence is attached.
9. Community Acceptance
A Proposed Plan was prepared and released to the public on
February 6, 1995. A 30 day public comment period was conducted
between February 13, 1995 and March 14, 1995. A public hearing
was held on the proposal on February 23, 1995. The substantive
concerns of the public included: the innovative nature of the
Alternative F, the possible impacts of a residential development
adjacent and upgradient 'of the Site, concerns for any discharge
to Black Earth Creek, and possible effects of the proposed
groundwater extraction causing dewatering of private wells in the
area. Comments and responses to those comments are described in
greater detail in the Responsiveness Summary attached to this
ROD. All comments to the Proposed Plan have been considered and
the concerns are adequately satisfied without changes to the
proposed remedy.
IX. THE SELECTED REMEDY
Based upon consideration of. the requirements of CERCLA, as
amended by SARA, and the NCP, the detailed analysis of the
alternatives and public comments, the Wisconsin Department of
Natural Resources, in consultation with EPA, believes that
Alternatives B, F, and G, the selected remedy, will be the most
appropriate remedy for this Site. The selected remedy will be
protective of human health and the environment, comply with
ARARs, be cost effective, and will use permanent solutions to the
maximum extent possible. The selected remedy for the Site
includes the following:
Source Control Alternative B:,
Deed restrictions and zoning modifications,
Warning signs posted around the perimeter of the property,
Maintenance of the existing single barrier (clay) cap,
vegetation and surface run-off controls,
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Operation and maintenance of the existing landfill gas
extraction and destruction system and leachate extraction
and off-site treatment and disposal system, and
Groundwater monitoring of selected monitoring wells and
private home wells.
Groundwater Extraction and Treatment Alternative F:
Extraction of the most highly contaminated groundwater
(greater than 200 ppb total VOCs) in the vicinity of the
landfill and treatment of groundwater to meet applicable
groundwater discharge standards,
Injection of the treated water into the aquifer upgradient
of the landfill to stimulate in-situ biodegradation of
degradable components of the contamination, and
Monitoring and evaluation of the effectiveness of the
groundwater extraction, treatment and reinjection system in
achieving progress-toward cleanup standards.
Water Supply Alternative G:
Supply a point-of-entry treatment system for any private
well exhibiting contaminants originating at the Refuse
Hideaway Landfill with concentrations exceeding NR 140
Enforcement Standards (Federal MCLs) or that are believed by
the WDNR and EPA to be imminently at risk for exceeding
those standards.
Construct a community water supply well if the number of
homes requiring replacement water supplies makes Alternative
H cost effective.
With the exception of the deed restriction/zoning modification
and warning signs, Alternative B has already been implemented at
the Refuse Hideaway Landfill. Therefore, once the deed
restriction/zoning modification and warning .signs are in place,
the primary Source Control activity will be operation and
maintenance of the existing clay cap and surface vegetation cover
and leachate and gas extraction system. Monitoring of these
systems may indicate that changes/additions to these systems are
needed in the future to optimally run the extraction systems and
protect human health and the environment. At this time the
landfill has a fairly good vegetative cover. Any necessary
reseeding of the cover should include consideration of plant
species that would provide wildlife habitat on and near the
landfill, within the constraints of the cap integrity, and post-
remediation land uses.
In performing this remedy, all preliminary field testing (such as
aquifer pump tests) and all construction activities for remedial
support activities and groundwater treatment facilities (e.g.,
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roads, pipelines, staging areas) will be accomplished by avoiding
impacts'Co fish and wildlife habitats. If any fish or wildlife
habitat is negatively affected, the damage will be
restored/replaced to the extent practicable.
Alternative F will require, at minirr.uin, two aquifer pumping tests
to determine the proper placement and design of -the projected
four extraction wells on the west and south sides of the landfill
and the two injection wells on the east side of the landfill.
Aquifer and groundwater samples will be necessary for conducting
bench scale treatability tests for optimizing the above ground
treatment plant design and the in-situ degradation component .of
the remedy. It is likely that field pilot tests of the
extraction, treatment' and injection system will be necessary.
Design of the field testing program will need to address
treatment and discharge of water (both clean and contaminated
water) during the aquifer pumping tests and other field
activities that may generate waste water. All waste waters
generated are likely to require containerization and testing'for
contaminants with approval for a short term discharge to Madison
Metropolitan Sewerage District or some other discharge location.
i .
After design and required agency approvals, Alternative F will
require installation of four extraction wells at the landfill
pumping groundwater at approximately 45 gallons per minute with a
goal of capturing all groundwater contaminated above 200 ppb
total VOCs. It is expected that this will adequately contain the
source of the contamination and cut off the downgradient plume
from additional contaminant input. A monitoring system will need
to be designed to evaluate the effectiveness of the capture
system. The estimates for cleanup of the plume downgradient of
the landfill (20 to 40 years) depend upon completely severing the
escaped plume from the source of the contamination. Natural
attenuation processes of dispersion, degradation and adsorption
should remediate the plume, downgradient of the landfill in 20 to
40 years (the equivalent of one to two aquifer flushings). It is
difficult to determine how long it will take to clean up the
contaminated aquifer beneath the landfill because it is not known
how long the landfill will continue to leach contaminants into
the groundwater.
Design of the treatment plant will be based on the influent
contaminant concentrations from the aquifer pump test for the
extraction wells as well as on final water quality effluent
limits and BAT for discharge into groundwater as determined by
the -WDNR. It is expected that the treatment system will consist
of:
a flow equalization tank,
a chemical precipitation step,
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a flocculation tank, clarifier and in-line filter to
remove the metal precipitates from the chemical
precipitation treatment,
an air stripper for VOC removal,
an activated carbon adsorption system for removal of
SVOCs and pesticides, if necessary, and
an. ion exchange .step to remove trace metals, if
necessary.
Because only one SVOC and two pesticides were detected at low
levels in groundwater, it is possible that further analysis will
show that activated carbon adsorption is not necessary. In
addition, ion exchange may not be necessary depending on the
influent concentrations, the effectiveness of the. chemical
precipitation step and the.effluent limits. The goal of the
final groundwater treatment system is to reduce contaminants in
groundwater such that human health and the environment are
protected, ensure that ARARs are met and ensure that the
injection system functions as. effectively as possible. Special
treatment approaches may be necessary to keep the injection wells
from clogging with precipitates, suspended solids, bacteria, etc.
Therefore, the final design of the .treatment plant and the
technologies used may differ from those listed above.
In addition, treatability studies may indicate that materials
other than oxygen would be useful to stimulate in-situ
degradation of the groundwater contaminants. If this is the
'case, the treatment plant may include feed systems to add the
appropriate concentrations of materials to the effluent water
before injection into the groundwater.
Alternative F will require the installation, operation and
maintenance of an injection well system. It is proposed that two
injection wells be installed upgradient (east) of the landfill
and that 45 gpm of treated water be pumped into these wells. An
aquifer pump test(s) will be required to properly site these
injection wells such that the sand and gravel aquifer can
reliably and over time accept the anticipated flow volume. It is"
possible that more than two injection wells will be needed or
that their location will need to be adjusted. A monitoring
system will need to be designed that monitors the effect of the
injection of treated water on the aquifer flow system and
confirms that treated groundwater does not significantly alter
aquifer flow patterns, as projected in the 1994 groundwater
modeling study (Numerical Evaluation and Design of a Wellfield).
The injection wells will need maintenance to prevent excessive
head build up, this would likely require acid treatment of the
wells on a periodic- basis.
It is not expected that the groundwater plume will move beyond
its present boundaries. However, private home wells may become
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contaminated in the future if the plume does move or if wells are
developed in the existing plume. In addition, one home/business
well is currently contaminated but not in use. If the
home/business owner wishes to put the well back in use or install
a new well on the property, treatment of the water would be
necessary. This remedy calls for installation of point-of-entry
(POE) treatment systems at private wells that are impacted with
contaminants from the Refuse Hideaway Landfill above NR 140
Enforcement Standards (Federal MCLs) or that are imminently at
risk of becoming contaminated above NR 140 ESs. If. it appears
that the number of residences likely to be affected by the
contamination from RHL would make it cost effective to install a
community water supply well, then WDNR and EPA should consider
installing a community water supply well (Alternative H) to serve
the homes.
Periodic reviews (usually every 5 years) of remedy performance
will be necessary to evaluate all remedial actions undertaken at
the Site compared against the cleanup objectives. These reviews
will provide recommendations on implementing additional remedial
actions, such as installation of additional groundwater or
gas/leachate extraction'wells and/or adjusting current system
operations. This review will also help evaluate time frames to
reach cleanup objectives.
The remedial action objectives (RAOs) and clean-up goals for this
remedy are presented in Section VII of this ROD. The remedial
action objectives include:
Source Control RAOs:
Prevent direct contact with landfill contents;
Minimize contaminant leaching into groundwater;
Prevent migration of landfill gas;
Control surface water run-off and erosion; and,
Attain compliance with all identified Federal and State
ARARs.
Groundwater RAOs:
Attain NR 140 PALs for all groundwater affected by RHL
at and beyond the landfill boundary;
Reduce the potential for exposure to contaminants in
groundwater; and,
Attain compliance with all identified - Federal and State
ARARs.
Water Supply RAOs:
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Provide potable water to residences with impacted
private well water.
WDNR and EPA believe the selected remedy will achieve the
remedial action objectives. The remedy is protective of human
health and the environment, meets ARARs, is cost effective and is
permanent.
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COST SUMMARY FOR THE SELECTED REMEDY
Capital Costs Estimated Cost
Source Control. Alternative B
Deed Restrictions $ 1,000
Zoning Modification $ 5,000
Construct & Install Warning Signs $ 1,000
Groundwater Extraction & Treatment.
Alternative F
GW Extraction/Treatment System $ 376,000
Install Injection Wells $ 8,000
Subsurface Pipeline to Injection Wells $ 15,000
Property Acquisition $ - 10,000
Mobilization/Demobilization $ 41,000
Other Direct Costs
i
Permitting & Design . $ 45,000
Construction Oversight $ 36,000
Contingency $ 45,000
Supply Individual Water Treatment Units.
Alternative G
Purchase/Install Individual Water Treatment
Units (25 @ $6,000 ea.) . $ 150,000
Purchase & Set up -Computer & Software to
Track & ID New Wells in Area $ 6,000
Mobilization/Demobilization $ 16,000
Other Direct Costs
Permitting & Design (10% of Capital Costs) $ 17,000
Construction Oversight (8%of Capital Costs) $ 14,000
Contingency (10% of Capital Costs) $ 17,000
TOTAL CAPITAL COST $ 810,000
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COST SUMMARY FOR THE SELECTED REMEDY
(continued)
Operation & Maintenance Costs Annual Cost:
Source Control. Alternative B
Annual Inspection of Landfill Cap
O&M Leachate/Gas Collection System
LF Gas Sampling & Analysis
Off-Site Disposal of Leachate $ 75,000
Semi-annual Groundwater Monitoring
(21 wells)
Annual Private Well Monitoring (12 wells) $ 25,000
Groundwater Extraction & Treatment.
Alternative F
Groundwater Extraction & Treatment System $ 140,000
Maintenance of Injection Wells $ 5,000
Monthly Water Discharge Sampling &
Analysis $ 12,000
Supply Individual Treatment Units.
Alternative G
Equipment O&M $ 62 , 500
TOTAL ANNUAL O&M $ 319,000
TOTAL COSTS $ 5,207,000
(Net Present Worth calculated using
a 6% discount rate)
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Refuse Hideaway Landfill ROD
X. STATUTORY DETERMINATION
The selected remedy-must, satisfy the requirements of Section 121
Of CERCLA to:
a. protect human health and the environment,
b. comply with ARARs,
c. be cost effective,
d. use permanent solutions and alternate treatment
technologies to the maximum extent practicable, and
e. satisfy the preference for treatment that reduces
mobility, toxicity, and. volume as a principal element
of the remedy or document in the ROD why the preference
for treatment was not satisfied.
The implementation of Alternative B, F and G satisfies the
requirements of CERCLA as detailed below:
A. Protection of Human Health and the Environment
The selected remedy provides protection of human health and the
environment by addressing source control of landfilled wastes,
groundwater contamination and providing alternate water supplies
if private water supplies in the area become contaminated.
Source control includes waste containment, leachate treatment,
control and destruction of landfill gases and operation and
maintenance of these systems. In addition, warning signs and a
deed restriction/zoning modification will protect potential
trespassers and future use of the Site.
Groundwater extraction, treatment and injection for in-situ
biodegradation will contain the source of the groundwater plume,
allow the downgradient plume to dissipate due to natural
attenuation, flush the aquifer with clean water and stimulate
natural microbes to break down contaminants in the aquifer.
Treatment of groundwater will ensure that the air media as well
as the groundwater are protected into the future. By avoiding
any discharge or impact on Black Earth Creek, this remedy
protects a fragile environmental resource while addressing the
contaminated aquifer.
The remedy provides a contingency in case private water supplies
become contaminated in the future. Point-of-entry treatment
systems have proven effective at two homes near the RHL.
Installation of POE systems on any well that becomes contaminated
above NR 140 ES (Federal MCL) limits will ensure the protection
of public health. It is expected that a POE system will be
installed at the Randall Swanson residence if a State-complying
water supply well is installed on the property.
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Refuse Hideaway Landfill ROD
B. Attainment of ARARs
The selected rsrnedy will be designed to meet all applicable, or
relevant, and appropriate requirements under federal and state
environmental laws. Because the Refuse Hideaway Landfill will be
conducted under federal authority, a CERCLA on-site permit
exemption is available. Only the substantive aspects of permits
and approvals required to implement the remedy must be complied
with. The primary ARARs that will be achieved by the selected
alternative are:
1. Action specific ARARs
Resource Conservation and Recovery Act, as amended [42 U.S.C.
Sec. 6901 et seq.]; Wisconsin Environmental Protection Law,
Hazardous Waste Management Act [Wis. Stat. Sec. 144.60-74]
Most RCRA requirements are administered under the State of
Wisconsin's implementing regulations. WDNR does not have
sufficient evidence to demonstrate that listed RCRA wastes were
disposed of at the Site.1 RCRA requirements are therefore not
applicable to the Site, except to the extent that new hazardous
wastes (such as treatment residuals) are generated during the
course of the remedy. This remedy will comply with the following
applicable requirements:
Wis. Adm. Code NR 605; 40 CFR 261 - Identification of Hazardous'
Wastes. This code provides requirements for determining when a
waste is hazardous. The substantive requirements of these
regulations will apply to any on-site TCLP testing of treatment
residuals which may be disposed of off-site: No waste excavation
is anticipated during this remedy.
Wis. Adm. Code NR 615; 40 CFR 262 - Standards Applicable to
Generators of Hazardous Waste. This code provides requirements
for the shipment of wastes to treatment, storage or disposal
facilities. These requirements may apply to on-site preparations
for off-site shipment of treatment residuals and other wastes.
Wis. Adm. Code NR 620; Department of Transportation Hazardous
Materials Transportation Act [49 U.S.C. Sec. 1801]; 40 CFR 263 -
Standards Applicable to Transporters of Hazardous Waste. This
code requires record keeping, reporting and manifesting of waste
shipments. These requirements may apply to on-site preparations
for off-site shipment of treatment residuals and other wastes.
Wis. Adm. Code NR 630.10-17; 40 CFR 264, Subpart B - General
Facility Requirements. This code establishes substantive
requirements for security, inspection, personnel training, and
materials handling which are relevant and appropriate to on-site
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Refuse Hideaway Landfill ROD
activities involving handling of hazardous materials. These
requirements may apply to on-site preparations for off-site
shipment of treatment residuals and other wastes.
Wis. Adm. Code NR 630.21-22; 40 CFR 264, Subpart D - Contingency
Plan and Emergency Procedures. This code establishes substantive
requirements for emergency planning which are relevant and
appropriate for on-site activities which may involving handling
of hazardous substances.
Wis. Adm. Co'de NR 675; 40 CFR 268 - Land Disposal Restrictions.
This code requires that hazardous wastes cannot be land disposed
unless they satisfy specified treatment standards and imposes
record keeping requirements on such wastes. These requirements
apply to on-site activities related to off-site disposal of any
treatment residues or other hazardous wastes.
Wisconsin Environmental Protection Law, Subchapter IV - Solid
Waste [Wis. Stat. Sec. 144.43-47]
Wis. Adm. Code NR 504; RCRA Subtitle D - Landfill Location,
Performance, and Design Criteria - This code specifies
locational criteria, performance standards and minimum design
requirements for solid waste disposal facilities.
Wis. Adm. Code NR 504.04, 506.08(6), 506.07, 508.04 - Landfill
_Gas Control - These codes establish standards for landfill gas
control and monitoring practices. These requirements apply to
the landfill gas recovery operations at the Site.
Wis. Adm. Code NR 506". 08 - Additional Closure Standards - This
code requires runoff control from closed portions of a landfill.
These requirements are relevant and appropriate during
construction activities at the Site. Also establishes hazardous
air contaminant control for facilities over 500,000 cubic yards.
Wis. Adm. Code NR 504.07, 506.08, 514.07, and 516 - Landfill
Closure Requirements - These codes establish substantive
requirements for design, operation and maintenance of landfill
caps which are relevant and appropriate to the long-term
maintenance of the existing cap.
Wis. Adm. Code NR 508 - Landfill Monitoring, Remedial Actions and
In-field-Conditions Reports - This code specifies monitoring
requirements for groundwater, leachate, gas, surface water and
air.
Wis. Adm. Code NR 700-736 - Investigation and Remediation of
Environmental Contamination - This code specifies standards and
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Refuse Hideaway Landfill ROD
procedures pertaining to the identification, investigation, and
remediation of sites.
Occupational Safety and Health Administration (OSHA) - Regulates
worker safety.
Clean Water Act of 1977, as amended [33 U.S.C. Sec. 1317]
Wis. Adm. Code 108 and 211; 40 CFR 403 - Pretreatment Standards -
These codes prohibit discharges to POTWs which pass through or
interfere with the operation or performance of the POTW. The
substantive requirements of these regulations apply to the
leachate which is collected and discharged to Madison
Metropolitan Sewerage District.
Wis. Adm. CodeNR 147, NR 214- Pollution Discharge Elimination -
These codes require point source discharges to obtain a permit
from the WDNR. Substancive requirements of this permit would
have to be met.
Safe Drinking Water Act
Wis. Adm. Code NR 812.05; 40 CFR 144-148 - Underground Injection
- This code specifies requirements pertaining to groundwater
injection to remediate soil and groundwater; also specifies
private well construction.
Wis. Adm. Code NR 812.37; 40 CFR 144-148 - Water Treatment - This
code specifies requirements for point-of-entry treatment systems.
Wisconsin Department of Industry, Labor, and Human Relations
(ILHR 84) specifies plumbing product requirements for use of POE
systems.
2. Chemical Specific ARARs
Clean Air Act [42 U.S.C. Sec. 7401 et seg;]; Wisconsin
Environmental Protection Law, Subchapter III - Air Pollution
[Wis. Stat. 144.30-144.426]
Wis. Adm Code 404, 415-449; 40 CFR 50 - Emissions Standards.
These codes establish standards for emission of pollutants into
ambient air and procedures for measuring specific air pollutants.
Groundwater treatment requires removal of VOCs before injection.
The need for treatment of air emissions produced by this process
would be evaluated based on substantive requirements of Wis. Adm.
Code NR 445. If emissions are expected to exceed those
standards, the selected remedy, will include treatment of air
emissions.
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Refuse Hideaway Landfill ROD
OSWER Directive 9355.0-28
This directive controls of air emissions from superfund air
strippers at superfund groundwater sites. The emission
thresholds are: 3 Ib/hr or 15 Ib/day or a potential rate pf 10
tons/yr of total VOCs.
Resource Conservation and Recovery Act (RCRA), as amended [42
U.S.C. Sec. 6091 et seg.]; Wisconsin Environmental Protection
Law, Hazardous Waste Management Act [Wis. Stat. Sec. 144.60-74]
The following RCRA regulations are not applicable but are
relevant and appropriate.
40 CFR 265.1032-33 - Air emission standards for process vents.
This regulation establishes emission standards for certain air
stripper operations. Air stripper emissions at RHL are expected
to meet applicable standards under these regulations. As with
the Clean Air Act standards described above, treatment of these
air stripper emissions would be included if necessary to meet
RCRA air emission standards.
Safe Drinking Water Act [40 U.S.C. Sec. 300 et seq.]
Wis. Adm. Code NR 109; 40 CFR 141 - Maximum Contaminant Levels
(MCLs) -. MCLs establish drinking water standards for potential
and actual drinking water sources. MCLs have been exceeded at
the Refuse Hideaway Landfill property, for a distance up to 1,500
feet upgradient of the Site and a distance approximately 3,800
feet downgradient of the landfill. Three private water supplies
have been affected by contaminants from the Site. The selected
remedy is intended to achieve compliance with MCLs and non-zero
Maximum Contaminant Level Goals.
Wis. Adm. Code NR 140 - Groundwater Quality Standards - This code
provides for groundwater quality standards including Preventive
Action Limits (PALs), Enforcement Standards (ESs) and (Wisconsin)
Alternative Concentration.Limits (WACLs). The selected remedy is
intended to achieve compliance with PALs at and beyond the waste
boundary (edge of waste). To the extent it is subsequently
determined that it is not technically or economically feasible to
achieve.PALs, NR 140.28 provides substantive standards for
granting exemptions from the requirement to achieve PALs. Such
exemption levels may not be higher than the ESs.
Clean Water Act of 1977, as amended [33 U.S.C. Sec. 1311-17];
Wisconsin Environmental Protection Law, Subchapter II - Water and
Sewage [Wis. Stat. Se. 144.02-27]
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Refuse Hideaway Landfill ROD
Wis. Adm. Codes NR 102, 105, and 220 - Surface water quality
standards. NR 102 prohibits toxic substances in surface waters
at concentrations which adversely affect public health or
welfare, present or prospective water supply uses, or protection
of animal life. NR 105 sets compound-specific surface water
quality standards. The selected remedy will achieve compliance
with any substantive requirements of these regulations that
constitute ARARs for discharge to on-site groundwater, including
NR 220, Wis. Adm. Code WPDES Best Available Technology (BAT)
requirements at the point of injection to groundwater.
Wis. Adm. Code NR 207; 40 CFR 131 - Ambient Water Quality
Criteria. Establishes pollutant concentration limits to protect
surface waters. These and other water pollution discharge limits
are administered under the Wisconsin Pollutant Discharge
Elimination System (WPDES) permit program. The selected remedy
would satisfy both general and specific substantive requirements
for discharge to on-site groundwater through injection wells'.
Any waste discharged to a surface water must, if necessary, be
treated to satisfy these standards prior to discharge. These
treatment requirements are administered under NR 200 and 220,
Wis. Adm. Code. Any new discharge to an ORW or ERW classified
stream must meet the requirements of NR 207, Wis. Adm. Code,
Water Quality Antidegradation. The substantive requirements of
these regulations will apply to extracted groundwater to be
discharged.
3. Location Specific
Clean Water Act of 1977, as amended [33 U.S.C. Sec. 1344]
Wis. Adm. Code NR 103 - Water Quality Standards for Wetlands;
Executive Order 11990 and 40 CFR 6 - Protection of Wetlands -
These requirements provide protection against loss or degradation
of wetlands. A wetland is located southeast of RHL. the
proposed remedy should not have an adverse impact on the nearby
wetland.
C. Cost Effectiveness
The selected remedy provides for overall cost effectiveness. The
combination of source control using the existing clay cap and
groundwater extraction and treatment provides overall protection
of human health and the environment into the future and achieves
this in a cost-effective manner. The estimated time for clean up
of the downgradient- groundwater contamination is 20 to 40 years
under all landfill capping/groundwater extraction scenarios
considered. The estimated cost of the selected remedy,
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Refuse Hideaway Landfill ROD
$5,207,000, is the mosc cost effective combination of the
Alternatives evaluated.
D. Use of Permanent Solutions and Alternative Treatment
Technologies
The selected remedy represents the best balance of alternatives
with respect to the nine evaluation criteria described in Section
VIII and utilizes permanent solutions and treatment technologies
to the maximum extent practicable. The selected remedy includes
the innovative technology of in-situ biological treatment of
aquifer contaminants in an effort to speed groundwater
remediation and limit overall impact on surrounding environmental
resources.
E. Preference for Treatment as a Principal Element
The remedy provides for extraction and treatment of leachate and
landfill gas from the landfill. Contaminated groundwater will
also be extracted and treated and injected back into the aquifer
to stimulate additional treatment in-situ. Therefore, the
selected remedy satisfies the statutory preference for treatment
as a principle element to permanently and significantly reduce
toxicity, mobility, or volume of hazardous substances.
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APPENDIX A
RESPONSIVENESS SUMMARY
Refuse Hideaway Landfill Record of Decision
Town of Middleton, Dane County, Wisconsin
This responsiveness summary has been prepared to meet the
requirements of sections 13.3 (k) (2) (iv) and 117 (b) of the
Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (CERCLA) , as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), which requires a response
". . .to each of the significant comments, criticisms, and new
data submitted in written or oral presentations" on a Proposed
Plan for remedial action. The Responsiveness Summary addresses
concerns expressed by the public, potentially responsible parties
(PRPs), and governmental bodies, in comments received regarding
the Proposed Plan for the remedial action at the Refuse Hideaway
Landfill.
Public Comment Period
A public comment period Was held from February 13, 1995 through
March 14, 1995, to allow interested parties to comment on the
Proposed Plan, in accordance with section 117 of CERCLA. On
February 23, 1995, a public meeting was held at the Town of
Middleton Town Hall, at which the Wisconsin Department of Natural
Resources (WDNR) and the U.S. Environmental Protection Agency
(U.S. EPA) presented the Proposed Plan, answered questions and
accepted comments from the public. Comments received during this
period are included in this Responsiveness Summary.
The Remedial Investigation Report (RI), Feasibility Study (FS)
and the Proposed Plan for the Refuse Hideaway Landfill Site were
released for public review in February, 1995. The Administrative
Record was made available to the public prior to the comment
period, at the City of Middleton Public Library, the WDNR central
office in Madison, Wisconsin, and at U.S. EPA's .Region 5 office
in Chicago, Illinois.
Community Interest
There is a great deal of public interest in the Refuse Hideaway
Landfill. The WDNR conducted an extensive public information
program for several years before Refuse Hideaway became a
Superfund Site. Public concern centers on protection of
groundwater quality and private well water, protection of Black
Earth Creek as a high quality fishery, and the effect the
landfill has on land values in the area.
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Appendix A - Responsiveness Summary - Refuse Hideaway Landfill
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Summary of Comments Recieved and Agency Responses
The following summarizes comments received from the public during
the February 23, 1995 public hearing or received in written form
during the 30 day public comment period (February 13 to March 14,
1995) .
Comment: A deed restriction should be placed on the landfill
property, the Site should be condemned and all activities not
related to cleanup (including equipment storage and shop
operations) should be prohibited at the Site.
Reply: The recommended remedy for Refuse Hideaway Landfill
includes a deed restriction to limit development or future
activities that may disturb the landfill cap or disturb remedial
actions taken to protect the public and the environment. The
property is currently owned by John DeBeck who rents the non-
landfill portion of the property to Speedway Sand & Gravel for
truck/equipment storage and repair. The property is occupied
everyday by employees of Speedway Sand & Gravel. The Speedway
employees maintain the access road to the property, including
snow removal, and their presence helps deter potential
trespassers. In addition, Speedway Sand & Gravel pays rent on
the property to John DeBeck which is deposited into a WDNR
account that goes toward paying for cleanup activities at the
landfill. When the groundwater remedy is in place, the
activities of Speedway Sand & Gravel may need to be more limited
than at this time due to space constraints and the possibility of
interference with operation of the wastewater treatment system.
At this time, the activities of Speedway Sand & Gravel do not
interfere with management of the landfill Site and the landfill
poses little risk to the employees of Speedway.
Comment: Speedway Sand & Gravel is believed to be removing rock
and sand & gravel from the landfill property. This should be
stopped immediately.
Reply: Contractors for the WDNR have worked at the landfill for
the past 5 years. At no time have the contractors ever reported
mining of the bedrock ridge immediately northeast of the waste
mass or removal of any sand and gravel or other natural materials
from the property. In addition, there is 'no physical evidence of
quarrying on the Site - the exposed bedrock is weathered.
Removal of rock or sand and gravel materials from the landfill is
not allowed and would be stopped if undertaken.
Comment: More cover soil and grass seeding should be added to
the landfill cover as well as tree plantings.
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Appendix A - Responsiveness Summary - Refuse Hideaway Landfill
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Reply: The cover is maintained to eliminate, to the extent
possible, soil erosion. A good vegetative cover is essential to
this goal. Additional topsoil and seeding will be added in any
areas of the. landfill requiring this maintenance. Currently, the
landfill cover is healthy and preventing erosion. Trees are
usually not planted on alandfill surface because the deep tree
roots can penetrate the clay cap and create channels for surface
water to directly seep into the waste. To the extent practical,
efforts would be made to use plant species native to southern
Wisconsin that would provide good soil cover and wildlife
habitat.
Comment: All residential wells in the area, particularly south
of the landfill, should be tested for VOCs annually.
Reply: The groundwater flow and the VOC plume emanating from the
Refuse Hideaway Landfill have been well delineated. The private
homes that are in the path of the contaminated groundwater will
be tested annually under the proposed remedy. Testing of
additional private homes would be done if groundwater
contamination appears to 'threaten additional homes. - The
groundwater monitoring that is in place at the landfill should
adequately monitor the groundwater plume, making testing of non-
threatened homes unnecessary.
Comment: The Record of Decision should restrict quarry and
asphalt activities across the valley from the Refuse Hideaway
Landfill.
Reply: The Record of Decision can only address activities
directly related to the Superfund Site. The quarry and asphalt
operations are not within the scope of this decision.
Comment: Development plans within the vicinity of the landfill
should be restricted.
Reply: Again, the ROD can only address activities directly
related to the Superfund Site. Development near the landfill is
controlled by the Town of Middleton and other governmental
authorities.
Comment: Will private home wells that are currently monitored
for VOCs continue to be monitored under the proposed remedy?
Reply: Yes. All monitoring currently conducted near the
landfill Site will continue to be carried out under the proposed
remedy. The WDNR will continue all operation and maintenance
activities and well testing programs until an agreement is
reached whereby Potentially Responsible Parties take over these
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ADDendix A - Responsiveness Summary - Refuse Hideaway Landfill
ROD
activities. There will not be a gap in the O&M or monitoring
activities.
Comment: No potential date has been mentioned as to when the
remedy will be put in place. Homeowners near the landfill expect
that the "red tape" will be cut through so that the cleanup will
occur as soon as possible.
Reply: We do not know at this time when the proposed remedy will
be undertaken. The time frame is dependent upon negotiations
with the Potentially Responsible Parties and agreement on a
Consent Decree. The WDNR and U.S. EPA will work to ensure that
the remedy is put in place as soon as possible.
Comment: We would like additional information regarding deed
restrictions on the landfill property and any deed restrictions,
rules or regulations that might affect property in the vicinity
of the landfill. This should include any applicable state,
federal or local restrictions.
i
Reply: The deed restrictions would constrain future owners of
the landfill from disturbing the landfill cap or interfering with
the gas/leachate collection system or any other aspect of the
cleanup. The deed restrictions will only apply to the specific
parcel of property where the landfill is located and would not
directly affect surrounding properties. The only State rule
affecting property near a landfill is a restriction on developing
water supply wells within 1,200 feet of a landfill boundary. The
Town of Middleton or other governmental bodies may choose to
restrict certain development near a landfill. We know of no
local government restrictions applying to the Refuse Hideaway
Landfill.
Comment: The cost of discharging water to the ditch south of the
Site seems excessively high. In addition, if the treated water
is safe for human use, it should not present a problem if
disposed into the creek.
Reply: The cost for discharge to the ditch south the landfill
includes monitoring and investigation costs for the Outstanding
Resource Water portion of Black Earth Creek. These costs are
high because of the sensitive nature of the resource and the
monitoring effort that would be required to ensure protection of
the creek. The treated water will be very clean and would meet
discharge standards set by the WDNR. However, the restrictions
on discharge to the ORW portion of Black Earth Creek are due to
possible impacts on the cold water fishery - these include water
temperature and volume concerns as well as water quality
concerns. In addition, flooding potential in the upper watershed
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Appendix A - Responsiveness Summary - Refuse Hideaway Landfill
ROD
may-increase with a discharge to the ditch south of the landfill.
The selected remedy, Alternative F, Reinjection of Treated Water
to Enhance In-Situ Bioremediation, will avoid any impact to Black
Earth Creek and will not impact flood potential in the upper
watershed.
Comment: The existing municipal water supply in the City of
Middleton should be considered for replacing any drinking water
supplies around Refuse Hideaway Landfill.
Reply: The City of Middleton must make the determination to
extend their water supply system to the Town of Middleton. On
March 20, 1995, Toby Cinder, the Assistant Director and Manager
of the Water Utility for the City of Middleton indicated that the
Utility Master Plan would need to be amended to allow extension
of a water supply main from the City of Middleton to the Town of
Middleton. The water main would need to be approximately 2.5
miles long and would require several lift stations. The cost for
building this extension would be quite high. In addition, Mr.
Cinder indicated that a City of Middleton ordinance does not
allow utility service outside the city limits. Therefore, all
land served by the water main would be required to be annexed to
the City of Middleton. Finally, the City of Middleton would not
extend and annex land 2.5 miles from the city limits and then try
to in-fill. Rather, development is done incrementally.
The WDNR and U.S. EPA do not control whether a municipality will
extend its water supply, nor can the agencies dictate the
conditions of that extension. Therefore, the individual water
treatment devices or community water supply well have been
proposed as approaches to replace water supply wells that could
become contaminated in the future.
Comment: The proposed development on Airport Road might be a
site for a community well serving the development and any
contaminated home Site.
Reply: Development of a water supply well approximately 1 mile
north or northeast of the landfill may be a good location for a
water supply well for the proposed development northeast of the
landfill. The major.concern for threatened water supplies is
about 1 mile southwest of the landfill, in the Deer Run Heights
subdivision. A community water supply well to serve this area
would most likely be placed in the valley, several thousand feet
beyond the furthest expected extent of the groundwater
contamination.
Comment: While the chosen remedy is the best option from a
practical and engineering stand point, the $5,207,000 cost is
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Appendix A - Responsiveness Summary - Refuse Hideaway Landfill
ROD
outrageous and it's doubtful that this amount of money will be
available to actually complete the project.
Reply: The cost of the proposed remedy is quite reasonable
compared to the average cost of Superfund cleanups - which is $15
million to $20 million. WDNR and U.S. EPA will attempt to
negotiate an agreement with users of the landfill to pay the
cleanup cost. If an agreement cannot be reached, the Site will
be cleaned up using federal Superfund money.
Comment: Has the developer of the proposed 200 lot subdivision
and golf course located northeast of the landfill contacted the
WDNR about the proposal?
Reply: Yes, the developer did contact the WDNR about the
development. The developer was told that there is a risk that
the proposed 500 gpm high capacity well for the golf course will
affect the groundwater contamination and may draw contamination
upgradient of its present location. If the groundwater
contamination does spread due to pumping by the golf course well
or because of the density of private wells in the development,
the developer may be liable under Superfund laws for the movement
of the contamination and might therefore be considered a
Potentially Responsible Party. This means the developer could be
held liable for the cleanup of groundwater contamination in the
'vicinity of the landfill.
Comment: If it is necessary to re-introduce water upgradient to
flush the plume, why was the cap placed on the landfill?
Reply: It is important to understand the functions of the cap
verses the proposed groundwater pump and treat system. The cap
limits, to the extent possible, surface water percolation into
the waste and the subsequent formation of leachate. The leachate
moves through the waste and is either removed from the landfill
(by pumping to the leachate tank), is held in the landfill as
part of the "field capacity" of the waste, or moves through the
waste and into the groundwater. Without the cap, a much greater
volume of contaminated leachate would move into the groundwater.
The proposed groundwater remedy will remove contaminated
groundwater from the aquifer, treat it, and inject the treated
water back'into the aquifer, upgradient of the landfill. There.
is a significant amount of contamination in the aquifer at the
present time. The landfill cap slows the volume of contamination
that continues to move into the aquifer. By cleaning and
reinjecting the groundwater, overall cleanup time should be
faster because the reinjected water will help flush contaminants
out of the aquifer and will stimulate natural microbes in the
aquifer to degrade ("eat") the contaminants within the aquifer.
.6
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Appendix A - Responsiveness Summary - Refuse Hideaway Landfill
ROD
Therefore, groundwater is being treated above ground as well as
below ground.
Comment: Why are the cost of the POE treatment systems at the
Refuse Hideaway Landfill considerably more expensive than at
other Superfund Sites?
Reply: Treatment systems are developed for each Site
independently and the design of the treatment system depends upon
the contaminants involved and the chemistry of the natural
groundwater. For instance, iron and hardness (naturally
occurring compounds in groundwater} can significantly affect the
operation of a water treatment unit. While the WDNR has
installed Granular Activated Carbon POE units at homes near
Refuse Hideaway Landfill, other treatment units would be
acceptable if the units acceptably treat the VOC contamination to
no detection and provide reliable results over'a long term
period.
Comment: Will nearby private wells become dry because of pumping
of groundwater at the Refuse Hideaway Landfill? If private wells
do "dry up" because of the pumping, what will the WDNR do?
Reply: The pumping at Refuse Hideaway Landfill should have no
effect on private wells in the area. The proposed 45 gpm pumping-
rate will affect groundwater flow within a short distance of the
landfill and will not result in significant "drawdown" of the
water table. We have made every effort to limit the amount of
water pumped because excess water makes the extraction and
treatment system less efficient (that is, a higher pumping rate
pumps clean water which then must be treated and discharged).
The closest well to the proposed pumping wells is 1,600 feet
northwest of the landfill. Groundwater levels will drop no more
than 1 foot at 600 feet from the landfill. Areas beyond 600 feet
from the landfill will be negligibly affected by the pumping
system.
If a private well became dry or had some other deleterious effect
believed to be due to the extraction system, the WDNR and EPA
would investigate to determine the exact circumstances of the
problem. If it was determined that the extraction system was
causing the problem, then action would be taken to rectify the
problem. These actions could range from adjusting the extraction
system at the landfill to taking action at .the private well to
fix the problem.
Comment: The owner of the Sunnyside Seed Farm (Randall Swanson)
feels that he's been discriminated against by the WDNR because a
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Appendix A - Responsiveness Summary - Refuse Hideaway Landfill
ROD
POE system has not been put in the home on his property, even
though the WDNR has confirmed contamination in his well.
Reply: The WDNR designed a POE system for the Swanson property
when systems were designed for the Stoppleworth/Schultz
properties. Unfortunately., the well on the Swanson property did
not meet WDNR standards. . Mr. Swanson shut off the well rather
than bring the well up to standards. The proposed remedy calls
for a POE system to be installed at the home on the Swanson
property if the existing well is brought up to standards or if a
new well is constructed on the property. The WDNR has a "Well
Compensation Program" that provides for reimbursement of up to
75% of costs for well replacement when a private well becomes
contaminated. Mr. Swanson may be eligible for reimbursement of a
portion of the cost of his new well under this program.
Comment: Black Earth Creek should not receive discharged treated
water. The upper Black Earth Creek valley has wet soils and
flooding problems already without an added discharge.
i
Reply: The proposed remedy calls for injecting treated water
back into the aquifer, thus avoiding a discharge of water to
Black Earth Creek. •The proposed remedy should not have any
effect on Black Earth Creek.
Comment: Has injection of treated water been used elsewhere?
Are the places it has been used similar to the area near Refuse
Hideaway Landfill?
Reply: Injection of treated water is an innovative technology in
Wisconsin. There are a few cleanup projects that reinfiltrate
(i.e., discharge the water to trenches and let the water
percolate through the soil) groundwater back into the aquifer.
Injection wells have been used in a number of states around the
country, including Florida and Texas. Wisconsin has not used
this technology in the past because WDNR regulations prohibited
the use of injection wells. In October 1994, the regulations
were changed to allow the use of injection wells for remediation.
of contaminated soils and groundwater. The Refuse Hideaway
Landfill is the first Site where this technology is being
proposed. Because injection wells are allowed in other states,
there are consultants qualified in using this technology.
Injection wells are essentially the reverse of extraction wells,
so the two types of wells are designed similarly. The greatest
problem is finding the best place to install the injection wells
to ensure that treated water flows freely into the aquifer
throughout the remediation.
-------
Appendix A - Responsiveness Summary - Refuse Hideaway Landfill
ROD
Comment: How will the WDNR know the extraction and injection
system is working?
Reply: The primary control will be monitoring wells placed
around the extraction and injection locations. The flow rate and
water quality will, of course, be monitored. The greatest
concern will be whether the extraction wells are removing water
from the most highly contaminated portion of the aquifer as
projected and whether the injection wells are flowing freely such
that pressure does not build up in the injection wells. Water
level will be measured around the extraction and injection wells.
These water level measurements will help determine whether the
system is functioning properly and if adjustments in flow or
maintenance of wells is needed.
Comment: Why was the synthetic cap not chosen as a remedy?
Reply: It was judged that the synthetic cap was not a cost •
effective remedy for this Site. The synthetic liner would reduce
the production of leachate and eventually result in less or no
leachate being pumped by the leachate extraction wells. However,
leachate will continue to be produced by the. landfill and some
leachate will leak into the groundwater regardless of the cap
option chosen. The synthetic cap would not result in groundwater
cleanup or in the groundwater meeting state standards
significantly earlier than will be the case without the synthetic
cap. The groundwater extraction and treatment system will
eventually meet state groundwater standards - it is estimated to '
take 20 to 40 years to meet standards downgradient of the
landfill. The type of capping system does not effect this
cleanup time. Therefore, while the synthetic cap does produce
less leachate, the cost (over $2.8 million) is not justified
because it does not result in a quicker groundwater cleanup.
Comment: Will the FRPs pay operation and maintenance costs for
the existing POE systems at the two residences where the systems
currently installed?
Reply: Currently two home owners rely on POE systems to remove
VOCs from their home wells. The systems were installed and paid
for by WDNR. In 1992, operation and maintenance of the POE
systems was turned over to the home owners. Operation and
maintenance- of all existing systems at the landfill is expected
to be included in any consent' agreement signed between the WDNR,
EPA and PRPs . If a consent agreement is signed, we expect that
this contract will also include a provision for the PRPs to take
over operation and maintenance of the existing POE units at the
two homes in question.
-------
Appendix A - Responsiveness Summary - Refuse Hideaway Landfill
ROD
Comment: Why is the DNR and EPA so concerned with protecting the
landfill cap at the Refuse Hideaway Landfill but are allowing
1,100 pilings to be driven through a landfill at Lake Monona for
building of the Madison Convention Center?
Reply: The representatives of WDNR and EPA for the Refuse
Hideaway Landfill are not familiar with the issues surrounding
the Madison Convention Center. The Convention Center is not a
Superfund site. WDNR has reviewed the land the Convention Center
is being constructed on and has issued the required approvals for
construction of the Center.
10
-------
APPENDIX B
LIST OF FIGURES
Refuse Hideaway Landfill Record of Decision
FIGURES
# I Site Location & Topographic Map
# 2 Location of Black Earth Creek Drainage Basin
# 3 Land Use
# 4 Private Home Wells Contaminated by Refuse Hideaway
Landfill
# 5 Regional Water Table Map
# 6 . Physiographic Areas & Glacial Age Deposits
# 7 Well Locations
# 8 Potentiometric Surface Map
# 9 Geologic Cross-Section and Vertical Plume Location
#10 Total VOC Plume, Horizontal Location
#11 PAL Attainment Goals
#12 .Surface Discharge Location Alternatives
#13 Location of Extraction Wells
#14 Groundwater Treatment System, ORW and Groundwater
Discharge Alternatives
#15 Groundwater Treatment System, ERW and Warm Water
Fishery Discharge Alternatives
#16 Suitable Soils for Infilitration Gallery
#17 Proposed Injection Well Locations
-------
^C£WA=SSs=§
SCALE
FEET
5000
QUADRANGLE LOCATION
National Geodetic Vertical Datum of 1929
Contour Interval 10 Feet
N
Sase map from U.S.C.S. 7.5' MIOOLETCN. .vi
topographic quadrangle map. photorevised *97t.
simon
Brookfleld Lakes Corporate Center XII
175 N. Corporate Drive, Suite 100
Brookfield, Wisconsin 53045
Psgn.
: Chk. by: . • - '? JApprv. by:TC\-
PROJECT: 301483135 j DATE 12/02/93
Wl DEPT OF NATURAL RESOURCES
REFUSE HIDEAWAY LANDFILL
SITE LOCATION and
LOCAL TOPOGRAPHY
DRAWING.- 1367-4 Figure #1, RHL RC
-------
270©
270 o
270 -o-
270 A
EXPLANATION
DRAINAGE BASIN BOUNDARY
DRAMAGE SUB8ASN BOUNDARY
MUMCFAL or INDUSTRIAL WELL
DOMESTIC or STOCK WELL
OTHER WELLS
STREAM GAGE
N
SCALE
i=
MILES
Base map from Cline. 1963.
HSI simon
Brookfleld Lakes Corporate Center XO
175 N. Corporate Drive. Suite 100
Brookfieid, Wisconsin 53045
Dsgn. t>r-f24&> Chlc *>*
PROJECT: 301483135
Apprv. by:
DATE 03/28/94
Wl DEPT. OF NATURAL RESOURCES
REFUSE HIDEAWAY LANDFILL
BLACK EARTH CREEK
DRAINAGE BASIN
DRAWING:
Figure #2, RHL ROD
-------
EXPLANATION
AGRICULTURAL
RESIDENTIAL
WOODED
CHRISTMAS TREE FARM
SOD FARM
[1. | truck & equipment storage
fiT] restaurant
L3-J Madison Gas & Electric facility
"4?] quarry
"sTl ski hill
SCALE
FEET
5000
HSI simon
Brook field Lakes Corporate Center XD
175 N. Corporate Drive, Suite 100
Brookfield, Wisconsin 53045
Dsgn.
Chk. by:
Apprv. by: ..
PROJECT: 301483135
DATE: 03/28/94
Wl DEPT. OF NATURAL RESOURCES
REFUSE HIDEAWAY LANDFILL
LOCAL LAND USE
DRAWING:
Figured, RHL ROD
-------
EXPLANATION
FIL LIMITS
. REFUSE HDEAWAY PROPERTY
BOUNDARY
• PRIVATE RESDENCE
jPW-1 PRIVATE WELL LOCATION
rSWAN80N AND DESIGNATION
i
t
SCALE
Feet
2000
Hydro-search, me.
A Ttltt Toil Comply
MTOSOtOCISIX-GEOlIJCIStl-tHGINtCRS
PROJECT: 301483133 | DATE: 08/18/84 •
W1 DEPT OF NATURAL RESOURCES
REFUSE HDEAWAY LANFILL
PRIVATE WELL
LOCATIONS
305-bW Figure #4, RHL ROD
-------
-960-
EXPLANATION
WATER TABLE CONTOUR (ft msl),
25 ft INTERVAL
WATER TABLE LESS THAN 10 ft
BELOW LAND SURFACE
\\
SCALE
MILES
Base n-.co modified from P.G. OleoH. 1973.
BrookfieW Lakes Corporate Center
175 N. Corporate Drive, Suite 100
Brookfield, Wisconsin 53045
I Dsgn.
Chk. by:
PROJECT: 301483135
Apprv.
DATE: 03/28/94
Wl DEPT. OF NATURAL RESOURCES
REFUSE HIDEAWAY LANDFILL
REGIONAL
WATER TABLE MAP
DRAWING:
Figure #5, RHL ROD
-------
•;.-:fe>v;::;p|BillI§SS81l
/
• VTN*
EXPLANATION
MARSH DEPOSITS
GLACIAL LAKE DEPOSITS
OUTWASH AND ALLUVIUM
MORANAL DEPOSITS
UNDFFERENTIATED GLACIAL DEPOSITS
mainly ground moraine
SCALE
PRE-QUATERNARY ROCKS
MILES
Base mop modified from Alden (1918) and Cline (1955}
HSI simon
Brookfield Lakes Corporate Center XQ
175 N. Corporate Drive, Suite 100
Brookfield, Wisconsin 53045
Dsgn.
Chk. by:
|Apprv. by;
PROJECT: 30U83135
DATE 03/28/94
Wl DEPT. OF NATURAL RESOURCES
REFUSE HIDEAWAY LANDFILL
PHYSIOGRAPHIC AREAS AND
DEPOSITS of QUATERNARY AGF
DRAWING:
Figure #6, RHL ROD
-------
:V"-'if:-^-ij^^L:'":M
tnii) 3'Mlll'l'l^- •' •'•//' ' '; '" ^
E; PLANATK3N
* P-w(2)
km?
^E^JJ •;-,:!
••v" : H, •/..•.;-.^v- j r.HmWTO3.9 .^-.inhn \ll r '•-. -T -,,;.
,.; •^^^Il^-C.rl- ,;»-,
pwU^P-^S™^v-^
'•^•''•''^''-^^''•''••iita^-
SCALE
EXISTING CONDITIONS
MARCH 1991
DATE: 02/02/95
oeswcn "'..,'.
"'
* Figure / 7. RHL ROD
I
-------
EXPLANATION
FILL LIMITS
< .-.._T_ REFUSE HIPE VWAY PROPERTY
BOUNDARY
• PRIVATE RrS.OENCE
j.P-34d MONTTOR WEI L LOCATION.
^(9*88) DESIGNATION AND POTENTIOMETRIC
WRMJ SURFACE ELEVATION (ft. msl)
^ 912 -- POTENTIOMI5T 9IC SURFACE
-^'fc CONTOUR (It. mal)
Hole: Wells used for potc-illometrlc surface
mop include P-8br. P-21br P-23d
P-2Sbr. P-26d. P-27d. P-30d P-JM
P-32d, P-33d. P-.Md. P-35d, P-360
P-40d. P-4ld. All Deluded wells ore '
completed In bedrtxk except P-JJd
and P-4td which o e completed
In uneonsolldaled d. posits 70(1 or
more below the w-il T (able.
SCALE
2000
I mop compilfld from U.S.G.S. 7.5' Uiddlo'on. Wt topoarophic quodrnngU' mop. I96.f.
'our inlervol 10 feel No'ional Gvodeltc Verllcoi Datum ot 1929
Hydro-Search, inc.
A T«trt T«A Qonmny
MrDROLaGISTS-GCOLOGIStS-CNGINttPJ
Dsgn. by: (^/^ [Chk. by:
PROJECT: 301-183135
06/2V94
^SOURCES
LAM3F1L
POTENTIOMETRJC
t SURFACE MAP
-(JANUARY :«. 1991)
RHLROD -I
-------
BOREHOLE LEGEND
EXPLANATION
E J ""'SOIL - r|LL
CLAY
[ | SAHD
[| SILT - SIURTONE
Ij SAHO AND GOAVEL
DOLOMITE/DOIOSTONE
- LIMESTONE
SHAI E
I I SANDS IOME
GEOLOGIC
CROSS SECTION
A - A'
UMCOMSOLIDATEO DEPOSITS
#9, RHLROD
-------
EXPLM ATION
FILL LIMITS
. _REFUSE HIDi;/>WAY PROPERTY
BOUNDARY
PRIVATE RE ill €NCE
35« MONITOR WIIL . LOCATION
AND DESIGN \. ION
RESIDENCES V HIGH HAVE THE
POTENTIAL C REQUIRE AN
ALTERNATE V\ \TER SUPPLY
. VOC ISOCOr C iNTRATION
CONTOUR (pot i
(Dashed whe e Inferred)
o
0
... _
2000
TOTAL VOLATILE
ORGANIC COMP DI IND
MAP
.n.ip Lolled from H5c;
-------
EXPLANXTIQN
FILL LIMITS
_™ REFUSE HIDEA VAY PROPERTY
BOUNDARY
PRIVATE RESIDENCE
P-35s MONITOR WB.L LOCATION
AND DESIGNATION
RESIDENCES V HIGH HAVE THE
POTENTIAL TC REQUIRE AN
ALTERNATE WATER SUPPLY
„«. VOC ISOCONC -INTRATION
A0° CONTOUR (pot)
(Dashed whe e Inferred)
Area Where PA . Standards
Will be Attaint
SCALE
Feet
2000
}.:->c r,ap ,;,;np>e.J f- :n IJSG y 75" M'lMleton. '.VI Lcp-:'J^ ?p1'C q-
'•:;Hoi,r Inter-^l :o feet. Nat'onat Cecdetic Vertical "o^-i of lc
TOTAL VOLATLE
ORGANIC COMI^C'UND
ISOCONCENTRAT;OX MAP
DATE: 12/02/94
RAG
BJK
Jlf
RAG
PROJL-
, RHLROD
-------
£;iV£W^™^wH
4 ^XP [s^tftf^ •'•• "iliL.:-;'^
NI /i° >-^~>^^'A!
-------
EXTRACTION
PROPOSED EXTRACTION V/E .L LOCATION
Note : Screen locations lor p oposed
extraction weds.
1) 67 IMI below w; K table
2) 85 feet betow w.itr • table
3) 65 feet below w -t< table
4) 29 leet betow w l< table
Hydro-Search, inc.
A TtM T»* Comp«i»
Wl DEPT OF N/J JRAL LANDFILL
REFUSE HIDE A V AY LANDFILL
GROUND-WATiEU EXTRACTION
WELL LOCATIONS
PROJECT: 3014B3135 [PATE 06/08/94 '
-------
45 GPM
GROUND
WATER
. FLOW
EQUALIZATION
TANK
RECYCLE
GROUND WATER
AS NECESSARY
TO TREATED
GROUND WATER
CHEMCAL
PRECIPITATION
TANK
(WELL MIXED)
FLOCCULATION
TANK
(AGITATION)
CLARIFER
5UOUND
V ATER
VOC3
SLUDGE & SOLIDS
COLLECTED FOR
OFF-SITE DISPOSAL
DISCHARGE
SYSTEM
FLOW
CONTROL
VALVE
ION
EXCHANGE
ACTIVATED
CARBON
ADSORPTION
AR
STRIPPER
IN-UNE
FILTER
AIR
BLOWER
NCT'IE
ORW BLACK EARTH
CREEK & NV40 PAL
DISCHARGE STANDARDS
Wl DEPT. OF NATURAL RESOURCES
REFUSE HIDEAWAY LANDFILL
PROPOSED GROUND WATER
TREATMENT SYSTEM
CONCEPTUAL FLOW DIAGRAM I
D/Tlj 12/OV92
CtBXED:
AfPIIOVED:
DFA'W
RAG
BJK
JLF
RAG
PFOL- 30t483t35
A Tetra Te
Figure #14, PKL ROD
-------
CHFMICAI
ADDITIVE FLOG
STORAGE AGENT
TANK
1
45 GPM
GROUND CHEMICAL FLOCCULATION
WATER FLQW PRECSftTION T^K1™
EQUALIZATION IANIV
TANK
(WELL MIXED) / GENTLE \
\ AGITATION/
J
CLARIFIER
1
RECYCLE vnr« SLUDGE & SOLE
GROUND WATER VCfS ^pLLECTED FO
AS NECESSARY i OFF-SITE DISPOS
1 IN-
TO TREATFD i A
GROUND WATER ^ STpj
DISCHARGE FLOW CARBON0
SYSTEM CONTROL CARBON
VALVE ADSORPTION
GRCU4D
WA'n-R
>S
R
AL
UNE
FILTER
f^
IR |
PPER L
AIR
J£!Er-r-\
~*^tT) ER
v^x ft 1
BLOWER BR
ST
Wl DEPT. OF NATURAL RE?
REFUSE HIDEAWAY LAN
PROPOSED GROUND V\
TREATMENT SYSTl
CONCEPTUAL FLOW DIA
/
NOT =
W BLACK E XRTH CREEK
EAST FORIC PHEASANT
ANCH CREBC DISCHARGE
ANDARDS.
SOURCES cvrE 12/01/94
IDFILL c=8K3NH): RAG
/ATER l^*0^ BJ^
1ATER /TROVEtt JLF
^ C lAVWt RAG
GRAM JL f 10JL- 30148305
|g| W» Figure #15, RHLROD «
-------
/- LOCATION OF
REFUSE HIDEAWAY LANDFILL
EXPLANATION
SHADED AREAS INDICATE THOSE
AREAS WHICH MAY BE SUITABLE
"FOR AN INFILTRATION GALLERY
BASED ON SOIL SURVEY DATA.
SCALE
Mies
1/2
Note : Soi classification data and
properties are provided on
Table FS 6-2
5ese mac from : Soil survey of Dane Counry, W;sconsin; Soii Conservario.™ $erv'cs:
w.S. Oesor*nent of Agriculture
I Hydro-Search, inc.
A T«tra Tech Company
Dsgn. br.
JChk. by:
Apprv. by://^/
PROJECT: 301483135 DATE: 09/06/94
Wl DEPT OF NATURAL RESOURCES
REFUSE HIDEAWAY LANDFILL
SURFICAL SOIL
MAP
DRAWING: 3135-A Figure #16, RHL ROD
-------
IXTRAC11C N
PROPOSED E TRACTION WELL LOCATION
• PROPOSED IN ECTION WELL
Nola : Injecio. wels are screened
•t •) p> ixlmalely 55 feel below
the \ 'a >r labla.
Hydro-Search, inc.
A T«»«
nrORCH.GGIStJ-GEOLnOISTS-ENGINEr.BS
'•"•Vor^ruH."'..Hn^te. •••*
l^i/^^-lfhJl-ly: 3>s l*w™
:^r.^^i.mh^_i_: :.. f i—"—^ -i^X
PROJECT: 30t48313S [DATE 06/08/94 '
1300
Wl DEPT 0 T ^ATUHAl I ikincn i
_REFU8E2 ID^A^UNDFILL
PFKIPOSED"
INJECTION WELl
JLC'C:ATIONS
313S-61'
ligure#17. RHLROD
-------
APPENDIX C
LIST OF IAO.LJ.C.D
. Refuse Hideaway Landfill Record of Decision
TABLES
# 1 Summary of NR 140 Enforcement Standard Exceedances
# 2 Summary of VOC Detections in Private Wells
# 3 ' Highest Detected VOC Values in Landfill Gas
# 4 Compounds Evaluated for the Risk Assessment
# 5 Groundwater Clean up Standards for Refuse Hideaway
Landfill
# 6 Preliminary Water Quality Effluent Limits
-------
TABLE 1, RHL ROD
Page 1/4
SUMMARY OF NR 140 GROUNDWATER ENFORCEMENT STANDARD EXCEEDANCES1
Constituents
Benzene
Chloroform
1,2- Dichloroethane
cis- 1 , 2-Dichloroethene
1,2- Dichloropropane
Tetrach.loroethene
Ti. i.ch 1 oroel.liPiin
Vinyl Chloride
ES
5
6
5
. 70
5
5
5
0.2
PAL
0.5
6.6
0.5
7
0.5
0.5
0.5
0.02
P-3S
1/91
40
P-8S
1/91
7
16
160
P-9S
1/91
20
41
21
16
9
440
P-9D
1/91
32
P-16D
1/91
7
19
P-17S
1/91
7
5
10
14
28
68
6/91
9
14
18
51
57
10/91
16
65
57
5/92
. 420
15
18
54
24
'Only post 1989 data is used in this table because pre-1989 data was not validated. The history of
well testing varies for each well - some wells were monitored between 1987 and 1991 while others were
monitored between 1990 and 1993.
-------
TABLE 1, RHL.ROD '
Page 2/4
SUMMARY OF NR 140 GROUNDWATER ENFORCEMENT STANDARD EXCEEDANCES
Constituents
Benzene
Chloroform
1 , 2 -Dichl oroethane
cis- J , 2 • Dichloroethene
1,2- Dichloropropane
Tetrachloroethene
Tr ichloroethene
Vinyl Chloride
ES
5
6
5
70
5
5
5
0.2
PAL
0.5
0.6
0.5
7
0.5
0.5
0.5
0. 02
P-17S
10/92
5.7
1, 900
17
18
54
24
5/93
150
13
20
160
25
10/93
- 350
9
1.4
49
10
P-18S
1/91
5
P-20SR
11/91
7
5/92
6
12/92
6
10/93
8
-------
TABLE 1, RHL ROD
Page 3/4
SUMMARY OF NR 140 GROUNDWATER ENFORCEMENT STANDARD EXCEEDANCES
Constituents
Benzene
Chloroform
Trichloroethene
Vinyl Chloride
ES
5
6
5
0.2
PAL
0.5
0.6
0.5
0.02
P-21S
1/91
9
7
525
6/91
7
6
470
11/91
37
<250
5/92
5
56
11/92
6
41
5/93
9
10/93
5
P-21D
1/91
14
Constituents
Tetr. achloroethene
ES
5
PAL
0.5
P-22S
1/91
9
6/91
8
10/91
12
5/92
12
10/92
12
5/93
7
10/93
6
Constituents
Tetr achloroethene
ES
5
PAL
0.5
P-22D
1/91
6
6/91
6
10/91
8
5/92
7
10/92
8
5/93
5
10/93
8
Constituents
Tetr achloroethene
Tricn loroethene
ES
5
5
PAL
0.5
0.5
P-26S
1/91
38
7
P-26D
1/91
28
P-27S
1/91
114
12
6/91
130
17
10/91
150
21
5/92
120
16
10/92
130
15
5/93
64
8
10/93
50
6
-------
TABLE 1, RHL ROD
Page 4/4
SUMMARY OF NR 140 GROUNDWATER ENFORCEMENT STANDARD EXCEEDANCES
Constituents
Tetrachl oroethene
Trichloroethene
ES .
5
5
PAL
0.5
0.5
P-27D
1/91
99
11
6/91
120
14
10/91
150
21
5/92
130
17
10/92
54
15
5/93
72
32
10/93
91
12
Constituents
Tetraclil oroethene
ES
5
PAL
0.5
P-31IA
11/90
9
12/90
12
1/91
11
6/91
13
5/92
13
10/92
15
5/93
15
10/93
13
1 Constituents
Tetrachloroethene
ES
5
PAL
0.5
P-31IB
11/90
17
12/90
14
1/91
11
6/91
13
10/91
12
5/92
10
10/92
16
.5/93
14.
JO/93
14
Constituents
Tetrach] oroethene
ES
5
PAL
0.5
P-40I
12/90
10
1/91
12
6/91
13
5/92
14
10/92
15
5/93
16
10/93
1.0
-------
Table #2, RHL ROD
Chemicals Detected in Private Wells, Refuse Hideaway Landfill
CO
3
D
3D
O
i
CO
Compounds
Chloroclhnnc
Dichlorodifluoromethnne
1,1-Dichloroethane
1,2-Dichloroethanc
cis- 1 ,2-DichIoroethene
trans- 1 ,2-Dichloroethene
1 ,2-Dichloropropane
Tetrachlorocthenc
Toluene
1,1,1-Trichlorocthane
1.1,2-Trichloroethane
Trichloroethene
Trichloronuoromethane
Vinyl Chloride
Schultz Well
RMT
1/21/89
3.2
NA
6.3
NA
NA
28
NA
24
ND
ND
1.5
8
0.64
3.6 .
RMT
2/29/88
ND
NA
6.2
NA
NA
46
NA
27
ND
ND
ND
8
0.76
6
RMT/DNR
2/29/88
ND
NA
6.3
NA
NA
47
NA
28
ND
1.2
0.5
7.7
0.85
6.1
DNR
3/14/88
ND
NA
3
NA
13
ND
NA
27
ND
1.2
ND
4.6
11
ND
DNR
3/16/88
ND
NA
6.9
NA
32
ND
NA
26
ND
1.8
ND
8.9
11
ND
DNR
8/5/88
ND
NA
5.4
NA
33
ND
NA
21
ND
2.3
ND
8.7
20
ND
Warzyn
10/89
ND
17.17
2.91
< 0.500
19.6
ND
0.941
10.3
<0.500
0.513
NA
5.78
0.957
ND
Warryn
1/90
(19.0)
9.80
3.30
< 0.500
27.3
ND
1.34
17.5
ND
0.739
NA
8.03
1.23
(0.842)
JHS-I.4-7
Page 1 of 3
-------
able #2, RHL ROD Chemicals Detected in Private Wells, Refuse Hideaway Landfill (Cont'd.)
CD
3
Compounds
Cltloroethane
Dichlorodifluoromethane
l,|-Dichloroelhane
cis-1.2 Dichloroethene
trans- 1 ,2-Dich!oroelhenc
1 ,2-Dichloropropane
Melliylene Chloride
Naphthalene
Telrachloroelhene
Toluene
1,1.1 -Trichloroethane
Trichloroelliene
Trichlorofluoromelhane
Vinyl Chloride
Stopplewoith Well
DNR
2/29/88
ND
NA
2.1
NA
21
NA
NA
NA
31. Q
ND
I.I
3.6
0.95
5.5
DNR
3/14/88
ND
NA
4.9
30
ND
NA
NA
NA
24
ND
1.2
8.2 *
14
1.5
DNR
3/16/88
ND
NA
3
13
ND
NA
NA
NA
28
ND
1.4
4.8
9.6
ND
DNR
8/5/88
ND
NA
3.2
12
ND
NA
NA
NA
22
ND
2.2
4.6
16.8
ND
Warzyn
10/89
ND
7.32
2.56
8.82
ND
< 0.500
0.888
0.562
14.1
< 0.500
0.619
2.04
1.14 '
ND
Warryn
1/90
(19.5)
9.73
2.43
8.03
ND
< 0.500
17.4
ND
ND
ND
0.765
2.78
1.23
(0.507)
llcllentirnnd
8/93
ND
ND
1.4
6.6
ND.
< 0.500
NA
ND
15
ND
ND
2.2
ND
ND
a
3J
o
I
en
3)
3J
-------
Table #2, RHI, RODchcmica|s Detected in Private Wells, Refuse Hideaway Landfill (Cont'd.)
Compounds
trans- 1 ,2-Dichloroelhene
Tetrachloroethene
Toluene
Trichlorocthcne
Trichlorofluoromelhane
Swanson Well
DNR
3/16/88
1.5
2.9
ND
1
ND
DNR
3/22/88
1.5
2.8
ND
ND
1.1
DNR
8/5/R8
1.4
3.5
ND
1.2
2.3
Wanyn
10/89
ND
0.613
< 0.500
NA
NA
m
en
3
D
3D
O
i
CO
m
3)
3D
O
Motes: NA = Not analyzed
ND = Not detected
() = Sample contains a compound that elutes UPC the gas chromatograph earlier/later than the indicated compound.
The result is calculated ngainst the internal standard response.
< 0.500 =• Indicates the compound was detected below the quantitation limit.
All concentrations in pg/£.
- 1988 data from "Remedial Action Report" (RMT. 1988b).
1989 and 1990 data from "Sampling and Analysis of Residential Wells, Interim Remedial Measures" (Warzyn, 1990b).
31"-!. ••'
Page 3 of 3
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Table #3, RHL RODVOC Contaminants of Concern in Landfill Gas
Compound
Benzene
Tetrachloroethylene (PCE)
Toluene
Trichloroethylene (TCE)
Vinyl chloride
Highest Level Detected in
On-Site Gas*
(ppb)
2,000
26,000
26,000
23,000
61,000
EPA Risk-Based
Concentration in Ambient
Air"
(ppb)
0.22
3.1
420
1
0.021
Notes: All values in parts per billion (ppb)
* Warzyn Engineering, Inc. Gas and Leachate Extraction System.
Refuse Hideaway Landfill, Town of Middleton, Dane County,
Wisconsin. Engineering Design 13928.48. Prepared for the Wisconsin
Department of Natural Resources. Madison, Wisconsin: Warzyn,
August 1990.
and
Mostardi-Platt Associates, Inc. Landfill Gas System Destruction
Efficiency Tests. A Gaseous Study Performed for Warzyn Engineering,
Inc. Refuse Hideaway Landfill. Middleton, Wisconsin. Bensenville,
Illinois: Mostardi-Platt, September 30, 1991.
** EPA Region III risk based concentration table, April 20, 1994.
H3I Simon HYDRO-SEflRCH
-------
Table #4, RHL ROD Ground-Water Contaminants of Concern
Compound
Benzene
Bromomethane
Chloroform
1,2 Dichloroethane (1,2-DCA)
cis- 1,2 Dichloroethene (cis-l,2-DCE)
trans- 1,2 Dichloroethene (trans- 1,2-DCE)
1,2-Dichloropropane
Tetrachloroethene (PCE)
Trichloroethene (TCE)
Vinyl Chloride (VC)
Iron
Manganese
Bis(2-ethylhexyl)phthalate
Heptachlor
4,4-DDT
Units
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppm
ppm
ppb
ppb
ppb
ES
5
NL
6
5
70
100
5
5
5
0.2
0.3
0.05
NL
NL
NL
PAL
0.5
NL
0.6
0.5
7
20
' 0.5
0.5
0.5
0.02
0.15
0.025
NL
NL
NL
Highest
Detected
Concentration
24
250
37
41
1900
640
21
530
320
525
1.45
2.28
92
0.012
0.075
Notes:
ppb =
ES
PAL
NL
parts per billion
parts per million
Enforcement Standard
Preventive Action Limit
WDNR has not established an ES or PAL for this compound
HSIHYDRO-SEflRCH.inC ATetraJech Company
-------
Table #5, RHL ROD
Groundwater Clean Up Standards for the Refuse Hideav/ay Landfill
COMPOUND
Benzene
Chloroform
1 ,2-Dichloroethane
cis-1 ,2-Dichloroethene
>
1 ,2-Dichloropropane
Tetrachloroethene
Trichloroethene
Vinyl Chloride
Preventative Action
Level
(ppb)
0.5
0.6
0.5
7
0.5
0.5
0.5
0.02
-------
Tabled, RHL ROD
Sunmary of Highest Measured Influent Ground-Utter Characteristics and UDNR Proposed Water Quailty-Based Effluent Standards (Page 2 of
2)
x
a
31
o
i
CO
m
ID
3J
o
X
Constituent
VDUIUE OMSIIIUENTS
Semene
Bromodichtorontthana
Bromonethane
Chtoroethane
Chloroform
1,1-Dlchloroethane
1,2-Dlchloroethane
Dlchlorodifluoromethane
1,4-Dichlorobe'niene
1,1-Dlchloroethene
cis-1,2-Dichloroethene
trans -1,2-Dichloroethene
1,2-Dichloropropane
Ethylbemene
Methylene Chloride
1.1,1-Trichloroethane
Irlchloroelhylene
Irlchlorof luorome thane
toluene
Perchloroethylene
Vinyl Chloride
Xylenes
Total
Highest
Measured
Influtnt
Concentrations
ORU*
Effluent
Quality
61
8.9
250
SO
J7
72
41
260
7.6
3.J
1,900
640
21
95
74
17
320
190
200
530
525
480
5,783
-
OKU*
X
Removal'
Required
ERU
Effluent
Duality
1,500
1.033
1,033
No limit
1,033
No limit
1,800
1,033
1.000
500
No limit
1.800
105,000
90,630
46,671
3.667
3,667
1,033
45,600
500
123
No limit
ERU
X
Removal
Required
NR140
Effluent
Quality
-
phthalate
4,4'-DDJ
Heptachlor
92
0.075
0.012
2.967
0.0014
0.14
0
98. IX
0
Mo limit
No limit
0.04
0
0
0
10,000
0.0001
0.00047
0
99. 9X
96. IX
o
3-
o
o
01
3
Not •*: All units are MB/< (ppb) unless otherwise noted.
• , = Discharge to the ORU segment of Black Earth Creek would meet all discharge standards in Appendix C, Attachment B. limits for
substances that do not occur naturally in Black Earth Creek (VOCs, SVOC, and Pesticides) are icro.
• = No data is available
•• = Limits depend on naturally occurring conditions in Black Earth Creek.
NO = Not detected
ERU = Exceptional Resource Uater
ORU - Outstanding Resource Uater
pH and temperature data include the lowest and highest observed —lues.
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