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.
                        i

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.

                                8

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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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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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 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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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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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,

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 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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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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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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     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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 Refuse Hideaway Landfill  ROD
      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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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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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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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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Refuse Hideaway  Landfill  ROD

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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 Refuse Hideaway Landfill ROD

 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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 Refuse Hideaway Landfill ROD

 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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Refuse  Hideaway Landfill  ROD

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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 Refuse Hideaway Landfill ROD

 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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 Refuse Hideaway Landfill ROD

 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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Refuse Hideaway  Landfill ROD

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


                                32

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 Refuse  Hideaway Landfill  ROD

 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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Refuse Hideaway Landfill ROD

     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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Refuse Hideaway  Landfill  ROD

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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 Refuse  Hideaway Landfill  ROD

 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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 Refuse  Hideaway Landfill  ROD

 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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 Refuse  Hideaway Landfill ROD

 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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Refuse Hideaway  Landfill ROD

     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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Refuse  Hideaway Landfill  ROD
               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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 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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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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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.
                                74

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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]


                               75

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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,


                                76

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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.
                                77

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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
ROD

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
ROD

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.

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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.

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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.

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                        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

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                       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

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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

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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

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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

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                  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.

-------