Superfund Record of Decision Hechimovich Sanitary Landfill Site Williamstown WI


                                    EPA/ROD/R05-95/279
                                    1995
EPA Superfund
     Record of Decision:
     HECHIMOVICH SANITARY LANDFILL
     EPA ID: WID052906088
     OU02
     WILLIAMSTOWN, WI
     09/06/1995

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RECORD OF DECISION

FINAL REMEDY

LAND AND GAS RECLAMATION LANDFILL

Site Name and Location

Land and Gas Reclamation Landfill
(Listed on the National Priorities List as the Hechimovich Sanitary Landfill)

Located in the Town of Williamstown, Dodge County, Wisconsin (approximately 3.5 miles east of the City of
Horicon and approximately 2 miles south of the City of Mayville)

Statements of Basis and Purpose

This document presents the decision of the Wisconsin Department of Natural Resources (WDNR) on the final
source control and groundwater remedy that is necessary at the Land and was Reclamation Landfill site in the
Town of Williamstown, Dodge County, Wisconsin. This remedy was chosen in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980, as amended by the Superfund Amendments and
Reauthorization Act, and to the extent practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP). The attached Decision Summary identifies the information
contained in the administrative record for this site upon which this decision is based.

Description of the Selected Remedy

The final remedial action for this site consists of the existing NR 504 Wis. Adm. Code clay cap and, if
necessary, an expansion of the current operating gas extraction system. The details of the proposed action
are contained in Section VII. The cap and gas extraction system installed in 1992 as an interim source
control measure form the backbone of the final remedial action. The additional actions proposed in this
Record of Decision (ROD) will increase the landfill gas extraction rate. The increased gas extraction rate
will be accomplished either by adding additional gas extraction wells in the waste or by increasing the gas
flow rate through the existing well system. The intent will be to, as rapidly as possible, reduce the
volatile organic chemical (VOC) concentration in the landfill wastes and conseguently reduce the VOC loading
from the landfill to groundwater. This reduced loading, in conjunction with the
natural contaminant attenuation processes already occurring in groundwater, should reduce the existing
groundwater contamination levels at a satisfactory rate.

Groundwater monitoring will be reguired to track improvement in water guality. The WDNR may reguire
additional active remedial measures in the future if water guality does not improve at an acceptable rate.
Specific goals for the rate and extent of expected water guality improvements are detailed in this ROD.

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Declaration Statement

The WDNR has determined that the landfill waste and groundwater contaminants pose a limited current and
potential threat to human health or the environment.  Exposure to waste and contaminated soil has been
eliminated and the potential release of contaminants from the landfill waste to the groundwater has been
minimized with the installation of the improved landfill cap and gas extraction system.  This potential for
release to groundwater will be further reduced by the measures described in this ROD.  Potential exposure to
methane and volatile organic compounds in the landfill gas has been eliminated with the installation of the
active gas collection and incineration system.  The remedy selected in this ROD constitutes the final remedy
for this site.  The selected remedy is protective of human health and the
environment, attains state and federal regulations and is cost effective.  The remedy uses permanent
solutions and treatment technologies to the extent practical for this site.  Because hazardous substances
remain on site, a review will be conducted within five years after the implementation of the final remedy to
ensure that the implemented actions continue to provide adeguate protection of human health and the
environment.

              George E. Meyer, Secretary                        Date
        Wisconsin Department of Natural Resources

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DECISION SUMMARY

FINAL REMEDY

LAND AND GAS RECLAMATION LANDFILL

I. SITE NAME, LOCATION AND DESCRIPTION

The Hechimovich Sanitary Landfill was listed on the National Priorities List (NPL) by the U.S. Environmental
Protection Agency (USEPA) in March of 1989. The site, now known as the Land and Gas Reclamation Landfill
(LGRL), does not include the active landfill ("the new Hechimovich Sanitary Landfill") which is located
immediately to the north of the closed Land and Gas Reclamation Landfill. The new landfill meets current
state design and operation reguirements and is licensed to accept only nonhazardous waste. The site does not
include a licensed demolition debris landfill directly west of the Land and Gas Reclamation landfill.

The Land and Gas Reclamation landfill site is located in a rural area in the Town of Williamstown,
approximately 2 miles south of the City of Mayville, and approximately 3.5 miles east of the City of Horicon,
Wisconsin (See Figure A). This 24.3 acre closed landfill is located in the east one-half of the southwest
guarter of Section 35, Township 12 North, Range 16 East, Town of Williamstown, Dodge County,
Wisconsin. This site is unfenced and access is not controlled.

The area surrounding the site is primarily agricultural land with low density residential development.
Horicon Wildlife Area, a major migratory bird habitat, is approximately 2.5 miles west of the site.

The dominant landform in the area is drumlins, long narrow glacially formed hills, with the water table at or
near the land surface between the hills.

II. SITE HISTORY AND ENFORCEMENT ACTIVITIES

The Land and Gas Reclamation Landfall was a licensed landfill, operated by the City of Mayville from 1959 to
1970 and then privately operated from 1970 to October 1986 when it ceased accepting waste. The Mayville
landfill was a small open dump that now is part of the northern end of the closed landfill (see Figure B). A
variety of waste disposal activities occurred at the Mayville site including open burning, battery recycling
operations and solvent disposal. It appears these past activities are a significant contributor to the
current groundwater problems as the highest groundwater contamination levels are directly down gradient and
adjacent to the old dump site.

Beginning in 1970 the site was operated by George Hechimovich and the site was then called the Hechimovich
Sanitary Landfill. The Mayville site was sold to and became part of the Hechimovich Sanitary Landfill in
1971. In March 1984 site ownership and operations were transferred to Land and Gas Reclamation, Inc. and the
site name was subseguently changed to LGRL in July 1985. The site was closed in October 1986.

During part of the 1970-1986 time period, the site was licensed to accept hazardous waste. Paint sludges and
cutting oils from local industries, possibly containing lead, chromium and solvents, were disposed of in
several lagoons on-site. It is estimated by USEPA that 53,000 gallons of liguid hazardous waste were
disposed of at this site. In addition, the site accepted approximately one million cubic yards of
nonhazardous household and commercial wastes. The landfill does not have a liner. An initial cover,
consisting of two to 4 feet of local till soils and 6 inches of topsoil, was placed in 1987. A system of
groundwater and surface water monitoring locations were included in a monitoring program reguired by the WDNR
at site closure.

In July 1987, the Land and Gas Reclamation Landfill Site was the subject of a WDNR state enforcement action,
resulting in a Stipulation and Order signed by the Dodge County Circuit Court, which directed George
Hechimovich, Hechimovich Sanitary Landfill, Inc., and Land and Gas Reclamation, Inc. to undertake certain
actions at the landfill, including the installation of a clay cap and a gas collection system. The court
ordered clay cap was installed, under WDNR supervision and approval, in 1991 and 1992. To date the cap has

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been satisfactorily installed and maintained.  In addition, since March 1992 the active gas extraction system
has been operating according to design specifications.  The installation and operation of these measures were
documented and approved as a source control interim action in a January 1994 Record
of Decision signed by WDNR and concurred with by USEPA.  The enhancement of this gas extraction system is the
main activity in the final remedy for the site.

The WDNR nominated the Land and Gas Reclamation site for listing on the NPL in 1988.  The site was listed on
the NPL, as the Hechimovich Sanitary Landfill, in March 1989.  Based on the information obtained from
landfill records in the possession of Daniel and George Hechimovich, the WDNR issued special notice letters
to fourteen potentially responsible parties  ("PRPs") on August 15, 1990 and special notice letters
to two additional PRPs on September 20, 1990.

The potentially responsible parties entered into an environmental repair contract with the WDNR, which became
effective on September 28, 1990, to perform a remedial investigation/feasibility study ("RI/FS") pursuant to
s.  144.442, Wisconsin Statutes. After the environmental repair contract was signed, the WDNR decided that,
due to the timing of the remedial actions, remediation at the site should be divided into two operable units;
a source control (landfill closure) operable unit and a groundwater operable unit.  The January 1994 Record
of Decision documented successful completion of the source control operable unit.  This Record of Decision
establishes the final remedy for the site and includes both source control and groundwater remedial measures.

III.  HIGHLIGHTS OF COMMUNITY PARTICIPATION

An Administrative Record has been established at the Mayville Public Library, 111 North Main Street,
Mayville, Wisconsin.

In September 1991,  a Superfund Fact Sheet on the Land and Gas Reclamation Landfill was issued by the WDNR.
On September 25, 1991, representatives of WDNR, USEPA, and the Wisconsin Department of Health and Social
Services held a public information meeting at 7:00 p.m.  at the Senior Center located at 330 N. Walnut Street
in Mayville, Wisconsin, and discussed the Land and Gas Reclamation Landfill and the landfill closure and
groundwater investigation work that was being conducted  at this site.  Approximately 50 residents of the
area attended the public meeting.

A proposed source control ROD which selected the source control for the Land and Gas Reclamation Landfill was
made available for public comment from December 3, 1992 through January 6, 1993.  Based on public comments a
new proposed ROD was made available for public comment, from October 15, 1993 to November 15, 1993. Comments
received during both public comment periods and WDNR's responses to those comments were included in a
Responsiveness Summary, which was part of the source control interim action ROD.  A notice announcing the
availability of the new proposed ROD and the start of the second public comment period was published in the
Mayville News on October 21, 1993.  The source control ROD was signed by the WDNR in January 1994.

The public participation reguirements of s. 144.442(6)(f),  Wisconsin Statutes, and the community relations
reguirements of Sections 117 and 113 (k) (2) (B) (I-v) of CERCLA were met in the source control interim remedy
selection process.

The Proposed Plan for the final remedy at this site was available for public comment from February 16, 1994,
to March 17, 1994.   A public meeting to present and discuss the plan was held at the Mayville Senior Center
on February 16, 1994.  Approximately 30 people attended.  During the public comment period one written
comment was received.  The state and federal public participation reguirements were also met in this final
remedy selection process.

IV.   SCOPE AND ROLE OF RESPONSE ACTION

The response action for this site, described in detail in Section VII, is an expansion or modification of the
current landfill gas extraction system.  The system will include operation and maintenance of the landfill
cap and gas control system, groundwater monitoring, deed restrictions as appropriate, continued natural
breakdown of groundwater contaminants and enhancement of the gas extraction system.  The enhancement will be
either through the addition of new extraction wells or an increase in the air flow through parts of the

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existing extraction system. Results of the Remedial Investigation show that the northern portion of the site
appears to be the most significant contributor of VOCs to the groundwater. This is the location of the old
Mayville Dump. If necessary, additional extraction wells, screened through the entire waste thickness, will
be placed in this area to accelerate the decrease in VOC concentration in the waste mass. It is possible
that a similar concentration reduction could be achieved by increasing the air flow through the current gas
system. With either approach the reduction in contaminant mass will reduce the VOC loading to groundwater
and will conseguently reduce down gradient groundwater contaminant concentrations. This will reduce
groundwater concentrations to acceptable limits
consistent with state and federal guidelines within an acceptable time frame.

Monitoring the groundwater at well nests one and three will be the prirmary means of evaluating the
performance of the remedial action. Improvements in groundwater guality should reasonably follow the
concentration decreases shown in Table 4. If the concentration changes do not follow the expected trend,
additional remedial measures may be necessary. It is most likely that some form of active remedial measures
would be installed on the north edge of the landfill.

V. SITE CHARACTERISTICS

A. Topography

The Land and Gas Reclamation Landfill site occupies the northern portion of a drumlin (a glacial landform
consisting of a long, narrow hill) in a drumlin field. There are two wetland areas adjacent to the Land and
Gas Reclamation Landfill site, one west and one north and east of the site.

B. Geology/Hydrogeology

The unconsolidated material in the area of the site consists of five distinct units. Some of these units were
glacially deposited while others are of more recent origin. The five units and their distribution are:

1) Peat - This organic material is of recent origin and exists southwest, east and north of the site.
The peat lies at the land surface and together with underlying silts and clay is up to 45 feet
thick. Where the peat is present the water table lies within it. The peat, because of its high
organic matter content, significantly retards groundwater contaminant migration through it.
Conseguently, the peat is not a significant migration pathway of concern and contamination in the
peat is restricted to an area close to the north edge of the waste fill.

2) Organic Silt and Clay - This material is almost only present where the peat is and underlies the
peat. It is of recent origin. Because of its low hydraulic conductivity it provides a limited
migration pathway potential for groundwater contaminants based on the groundwater results from the
site.

3) Brown Till - This material was identified in discontinuous layers to the north, west and south of
the waste fill. Its thickness varies from 10-20 feet and it is of medium density. Because of its
discontinuous nature the unit is not a groundwater contaminant migration pathway of concern.

4) Silty Gray Sand - Where present north of the site this unit is the primary groundwater contaminant
migration pathway. It directly underlies the refuse and varies from 2-27 feet in thickness.

5) Sandy Gray Till - This is the lowest glacially deposited unit and consists of a very dense till
that extends to the top of bedrock at most locations. It underlies much of the fill area. Because
of its dense nature, it offers limited contaminant migration potential.

The bedrock underlying the entire site is Maguoketa Shale. The shale is massive and very impermeable. It
provides a "bottom layer" through which contaminant migration is restricted.

Groundwater flows radially away from the landfill. To both the east and west this flow discharges to either
adjacent wetlands and their drainage ditches or turns north and leaves the site as groundwater flow to the

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north-northeast. Groundwater flow leaving the site to the north, through the more permeable silty sands, is
of the greatest groundwater contaminant migration concern. The furthest migration distance and highest
pollutant concentrations are found along this flow direction.

Hydraulic conductivity values vary across the site depending on the type of material. The unit of most
concern, the silty sand, has values ranging from .0001 to .04 centimeters/second.

Vertical hydraulic gradients at the site are variable and are not strong influences on contaminant migration.
Horizontal gradients to the north of the site were measured at .03 foot/foot.

C. Contamination Extent

1. Groundwater

Groundwater contamination levels of concern exist to the north and west of the site. The northern plume is
the largest and contains the highest contamination concentrations. Vinyl chloride, trichloroethene and
1,2-dichloroethene are the predominant constituents of concern. They exist in the highest concentrations at
the northern edge of the fill (wells MW-1AR, MW-1RR) and decrease in concentration through wells W-3AR and
MW210 before reaching nondetectable levels approximately 900 feet north of the site (see Table 1 and Figure
D). The plume appears to be at steady state and is not expanding or contracting at this time. It is this
plume which is of the greatest concern and which drives the remedial action decision making at this site.

The western plume is summarized in Table 2 and exists only to limited extent to the west. Because of the
nature of groundwater flow at the site, contaminants leaving the west side of the site guickly turn north
following the groundwater flow. Conseguently, contaminants leaving the west of the site move north and
become part of the north plume leaving the site.

Groundwater contamination of concern was not found east or south of the site. No detectable levels were found
east of the site and to the south only well A-3A showed detectable concentrations. These results were not a
factor in evaluating the remedial options at the site.

The primary groundwater contaminants at the site are VOC's. (See Tables 1 and 2) Heavy metals and
semi-volatile compounds are not compounds of concern. Limited migration of these materials was found at the
Site and they were not considered when choosing a remedial action.

2. Surface Water, Sediment, Soil and Drinking Water

In addition to groundwater sampling; surface water, sediment, soil and nearby residential wells were tested
for the same contaminants as were tested for in groundwater. Surface waters, soils and sediment were not
found to be contaminated at levels of concern. However, the baseline risk assessment did indicate a
potential for environmental impacts to surface waters from groundwater discharge of vinyl chloride to the
wetlands. These impacts are addressed by the proposed remedial actions. The gas extraction system is
removing vinyl chloride and other VOCs from the waste mass. This reduction will decrease the rate vinyl
chloride enters groundwater and conseguently the surface water concentration will decrease.

As part of the Remedial Investigation, eleven nearby private water supply wells were tested. Only one well
contained detectable levels of contamination. A single water supply well approximately 1200 feet northeast
of the site did contain 1-2 parts per billion of 1,2-dichloroethene. These levels are below
health standards and are not believed to be related to the site. The affected well is believed to be
hydraulically side gradient of the site and has will casing into the Maguoketa Shale. As stated, the shale
retards contaminant migration downward and makes it very unlikely that contaminants could move from the site
to this well. The source of the private well contamination appears to be from a source other than the
landfill.

VI. SUMMARY OF SITE RISKS

As part of the site investigation, a baseline risk assessment was conducted to assess the current and

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potential risks posed by the site. The risk assessment determines whether contamination at the site could
pose an unacceptable health or environmental risk. Potential threats are estimated by making assumptions
about the manner, frequency and length of time a person or the parts of the environment could be exposed to
site related contaminants.

A baseline risk assessment conducted by a consultant under contract to the WDNR was completed in July 1993.
The assessment found that under the no action alternative, the human health risks from the site are not in
excess of acceptable levels set by the USEPA. The analysis of potential ecological effects suggests a
potential for limited environmental impacts. However, this potential was evaluated through a qualitative
screening analysis only. The following discussions summarize the chemicals of concern and the risk levels
they present.

A. Chemicals of Potential Concern

The primary chemicals of potential concern identified in the risk assessment based on frequency of occurrence
and concentration were vinyl chloride, trichloroethene, 1,2-dichloroethene, 1, 1-dichloroethene,
1,1-dichloroethane, and benzene. A complete listing of all potential chemicals of concern is shown in Table
3.

B. Human Health and Environmental Risk Characterization

The exposure assessment, developed as part of the human health and environmental risk assessment, developed a
conceptual model for the LGRL site based on general site characteristics. The conceptual model (Figure C)
describes ways by which chemicals from the LGRL site might contact potential receptors. This exposure
pathway analysis identified four potential mechanisms for exposure:

• direct contact with exposed waste;

• release of waste constituents to the ambient air via volatilization or wind-driven erosion,
followed by airborne migration to receptor locations;

• contaminant release to groundwater followed by migration through groundwater to water supply
wells;

• contaminant release to groundwater followed by migration through groundwater to surface water
or wetlands.
Based on these mechanisms, a list of potential exposure pathways were developed and evaluated for viability
(i.e., the potential to be complete) based on site-specific information (e.g., analysis of groundwater flow,
contaminant distribution, location of potential receptors).

Contaminant release to groundwater, followed by groundwater migration and discharge to the nearby wetlands
and ditches west and north of the site was determined to be the only viable migration pathway which might
lead to exposure. Terrestrial and aquatic wildlife could be exposed to site-related chemicals released to
the ditches and wetlands. Similarly, people walking through the wetlands and ditches could also be exposed
to site-related chemicals. Site monitoring data did identify surface water contamination from
constituents found in groundwater. Consequently, this was determined to be a completed exposure pathway.

The direct contact and the air pathways were not considered viable due to engineering controls from the
source control operable unit. Contaminant migration to existing water supply wells was also not considered
viable because analysis of groundwater flow indicates the site is not hydraulically connected to the aquifers
in which water supply wells are screened. The presence of the Maquoketa Shale, an aquitard restricts
groundwater contamination from migrating deeper to the depths that the water supply wells are drilled to.
Physical characteristics of the site (e.g., potential for landfill subsidence), the
nature of the adjacent land (wetlands not readily developable), limited population growth pressures, and
Wisconsin regulations (e.g., prohibition of development on former landfills) severely limit the potential for
site development, and thereby also preclude the exposure to contaminated groundwater from installation of

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water supply wells within the zone of contaminated groundwater.

The human health risk characterization evaluated exposure of "site visitors" to chemicals released to the
ditches and wetlands. Potential site visitors were assumed to include hunters, hikers, or children from
nearby homes trespassing onto the site and adjacent areas.

There are no reports of people routinely visiting the site or adjacent wetlands. Although there are no
physical barriers limiting access, the general remoteness of the site from large developments or major
roadways reduces the ready access of the site to people. There are approximately 14 homes within one-half of
the site. There are no apparent features about the site or adjacent areas that might draw hunters or hikers
to the area in preference to any other area in the vicinity. Hunting is not allowed on the site by the
landfill's owners. Similarly, there are no parks or wildlife areas adjacent to the site that could attract
hikers near the site.

The human health risk characterization guantitatively evaluated exposure through dermal absorption of surface
water while walking through the ditches and wetlands and incidental ingestion of sediment (other routes of
exposure while possible were determined to be less significant than those guantitatively addressed.) Surface
water exposures were evaluated for three cases; one based on measured surface water concentrations, and two
others based on chemical concentrations detected in groundwater and assumed to be discharging to the surface
water. Both carcinogenic and noncarcinogenic human health risks were evaluated.

The estimated human health risks were not in excess of levels identified by USEPA warranting remedial action.
All evaluations of noncarcinogenic risks were substantially below EPA's threshold of a hazard index of one.
EPA has stated that individual excess lifetime cancer risks less than 1 x 10-4 (one in ten
thousand) generally do not warfare remedial action at Superfund sites, although a risk of 1 x 10-6 (one in a
million) is the point of departure for developing remedial goals. All estimated individual excess lifetime
cancer risks were less than 1 x 10-4. Only one scenario, based on the highest concentrations detected in
groundwater, had estimated risks exceeding 1 x 10-6 (risks ranged from 2 x 10-6 to 3 x 10-6). The primary
chemical contributing to the risk was vinyl chloride.

The results of the human health risk assessment did not identify need for action. The need for the proposed
remedial actions is based on compliance with Applicable, Relevant and Appropriate Reguirements (ARARs) as
discussed later.

C. Ecological Risk Assessment

The screening level ecological risk assessment was conducted by comparing measured surface water and sediment
concentrations and potential future surface water concentrations to federal ambient water guality criteria,
Wisconsin water guality standards and criteria, and toxicity values. The results of the ecological risk
characterization indicate that potential fish and wildlife habitat adjacent to the LGRL may be potentially
exposed to contaminants migrating from the landfill. The fish and wildlife habitat consists primarily of a
wetland complex with associated ditches lying east and north of the landfill. The exposure pathways analysis
and results of the RI indicate that this wetland complex is the discharge point for contaminated groundwater
migrating from the landfill. These exposures were based on hypothetical future conditions. This potential
concern did not alter the selection of the preferred remedy.
An ecological survey of the area was conducted and no significant adverse ecological effects of landfill
contamination were observed. There was evidence to suggest that the wetlands have been disturbed as a result
of encroachment by landfill activities and the construction of ditches. Ditches within the wetlands were
shown to have a poor guality community of aguatic organisms and minnows. It does not appear that the ditches
are capable of supporting a sustainable population of aguatic organisms due to freguent drying out of the
ditches.

In summary, the baseline risk assessment indicates that there may be potential for ecological effects under
the no-action alternative. The ecological evaluation, however, was only a preliminary screening level
analysis. The baseline risk assessment further indicates that human health risks do not appear to be outside
USEPA's range of protectiveness.

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VII. SCOPE OF REMEDIAL ACTION

The planned remedial action will be a continuation and expansion of the current source control measures. The
current clay cap will be maintained. The existing gas extraction system will continue to operate. The
expansion of the existing gas extraction system will involve accelerating the gas extraction rate. Either by
adding additional extraction wells or by increasing the air flow rate through the existing well system, the
system will remove the VOCs in the landfill waste guicker. This will reduce the potential VOC loadings to
the groundwater. Conseguently, there should be improvements in groundwater guality at an acceptable rate.

The expansion of the gas system will likely be targeted toward the northwest portion of the site. It
appears, based on the groundwater guality data and site history, that the area around gas well 14 is the most
significant VOC source in the waste fill. Increasing the VOC removal rate in this area should be the most
productive in terms of groundwater guality improvement. Currently the gas system is operating at an average
of 200 cfm and in 1993 removed approximately 7000 pounds of VOCs from the landfill. By placing additional
gas extraction wells, in a closely spaced grid, additional volatile contaminants will be removed from the
waste fill before they can migrate to groundwater. There are no specific estimates of what the increased
air flow or subseguent increased VOC removal rate will be. These specifics will be defined in the Remedial
Design phase. The extracted wastes will then be burned in the already operating flare system.

It is also possible that the current gas system could be used to accelerate the VOC removal from the waste.
By closing off the air flow through other portions of the landfill it may be possible to increase the vacuum
and air flow through the area around gas well 14. This would have the same effect of increasing the VOC
removal rate and decreasing the contaminant mass moving to groundwater.

Groundwater monitoring at the site will be continued to document improvements in water guality. The
groundwater guality improvements north of the site will be used to evaluate the success of the remedial
system. Monitoring well nests 1, 3, 210 and 214 will be the best indicators of environmental improvement.
Table 4 shows the improvements expected at well nest 1 over the next several years. If the expected
improvements are seen at this nest, then the remediation system will be working and improvement will be seen
in the nests further downgradient from the site. Because well nest 1 is right next to the site it should be
the first to show water guality improvement.

The values in Table 4 were developed taking existing water guality data from the site and then predicting
future concentrations using a simple statistical model. Since models are not very precise tools confidence
intervals were placed around each predicted concentration to account for some of the variability in
contaminant migration rates. Predicting contaminant migration is not a highly developed science so the
potential responsible parties were given some flexibility in meeting water guality improvement goals. Also,
it is expected that as additional water guality data are generated through long term monitoring at the site,
there will be refinements in the predicted water guality improvements.

Groundwater evaluations will be done annually for the first five years to closely monitor site conditions.
If water guality does not improve as predicted in Table 4, active remedial measures would likely be
necessary. The decision to implement an active groundwater remedial system could be done, at a minimum, any
time in the first five years of operation.

VIII. DESCRIPTION OF ALTERNATIVES

A. Remedial Action Objectives

Remedial action objectives were developed for this site to provide for long-term protection of human health
and the environment, and to meet ARARs. ARARs are any federal or state standard, reguirement, criteria or
limitation that are determined to be legally applicable or relevant and appropriate to the site cleanup. The
final remedial action objectives for this site are:

• Reduce groundwater contamination concentrations to levels below the Preventive Action Limits
established in NR 140 Wis. Adm. Code at the landfill waste edge.

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• Maintain human exposure levels to contaminants below state and federal guidelines. These are
primarily the state and federal groundwater and drinking water standards. The federal
standards are Maximum Contaminant Levels set in the Safe Drinking Water Act and the state
drinking water standards are set in NR 809 Wis. Adm. Code.

• Maintain ecological exposure levels to contaminants below potential levels of concern based on
state and federal criteria such as the federal surface water guality criteria.

B. Development of Alternatives

The remedial action objectives for this site involve eliminating or reducing human and ecological exposure
levels and reducing groundwater contaminant concentrations to acceptable levels.

The remedial alternatives were assembled from applicable remedial technology options. Some of the
alternatives incorporate the source control measures already installed at the site during the source control
work. These measures include primarily the landfill cap and gas extraction system. The alternatives
surviving the initial screening in the Feasibility Study document were evaluated and compared with respect to
the nine criteria set forth in the National Contingency Plan (NCP). In addition to the remedial action
alternatives, the NCP reguires that a no-action alternative also be considered for the site. The no-action
alternative serves primarily as a point of comparison for other alternatives.

C. Alternatives

1. Alternative 1 - No Further Action - Because some source control actions, installation of the clay
cap and gas extraction system, have already been completed, a no-action alternative cannot be
defined for this site. In this case, a no further action option has been defined as only the
physical installation of the clay cap and gas system. It does not include operation, maintenance
or monitoring of either component. Groundwater monitoring and institutional controls on land use
are also not included.

2. Alternative 2 - Natural Degradation/Institutional Controls - This option consists of the following
actions:

• Operating, maintaining and monitoring the source control measures (clay cap and gas
extraction).

• Implementing deed restrictions to prevent residential development in the area of groundwater
contamination.

• Conducting groundwater monitoring.

• Relying on natural attenuation processes to help achieve compliance with groundwater standards.

This alternative relies heavily on the natural breakdown of VOCs already in the groundwater to
achieve compliance with groundwater standards. The anaerobic groundwater environment down gradient
of the landfill allows microbiological dechlorination of the organic contaminants. Past research
has shown that under such conditions naturally occurring microbes can break down some chlorinated
compounds. This process is likely already occurring to some extent in the groundwater on site.
Based on experience at other sites, the existing condition at this site probably provides for some
biological breakdown. It is proposed, under this option, that the natural degradation rate (in
conjunction with source control) will bring groundwater concentrations down to acceptable levels in
a reasonable period of time generally defined as less than 30 years if no current nearby wells are
impacted. Groundwater monitoring, especially on the near down gradient edge of the fill, will be
reguired to track water guality improvements. Site reviews would be conducted annually to track
site progress. The rate of groundwater guality improvement should follow that shown in Table 4.
If improvement did not occur at a satisfactory rate, active groundwater treatment would be
reguired.

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3. Alternative 3 - Enhanced Source Control - This alternative includes additional source control
measures and also relies on the natural degradation process discussed previously. Increased gas
extraction would be accomplished either by increasing the number of extract on wells or the air
flow rate through the existing well system. This will be determined in the Remedial Design phase.
This is the selected remedy for the site and is discussed in more detail earlier in this document.

A contingency for farther action if remediation goals are not met as expected is included, and
would be some form of active remediation.

4. Alternative 4 - Groundwater Extraction, Treatment and Discharge - This alternative involves
pumping the most contaminated groundwater north of site, treating the water through an air
stripper and discharging it to one of the existing drainage ditches. Groundwater extraction would
be accomplished either using wells or trenches immediately down gradient of the landfill.
Treatment would be done with an air stripping tower to remove the VOC's. Discharge of
contaminants to the air and drainage ditches would be regulated under WDNR administrative rules.

IX. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

A. Introduction

USEPA 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 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

1. Overall Protection of Human Health and the Environment

A remedy must provide adeguate protection of human health and the environment and describe how risks are
eliminated, reduced or controlled through treatment, engineering controls or institutional controls.

2. Compliance with Applicable or Relevant and Appropriate Reguirements (ARARs).

The remedy must meet all applicable or relevant and appropriate reguirements of federal/state environmental
laws. If not, a waiver may apply.

PRIMARY BALANCING CRITERIA

3. Long-term Effectiveness and Permanence

Once cleanup goals have been met, this criterion 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.

5. Short-Term Effectiveness

This criterion 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 material and services are available.

7. Cost

Capital, operation and maintenance, and 30-year present worth costs are addressed through this criterion.

MODIFYING CRITERIA

8. State Acceptance

This criterion evaluates the state's acceptance of the proposed action.

9. Community Acceptance

This criterion summarizes the public's response to the alternative remedies after the public comment period.
The comments from the public will be addressed in the Responsiveness Summary attached to this ROD.

B. Remedial Alternatives for Final Remedial Action

The nine criteria evaluation is as follows:

1. 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.

a. Overall Protection of Human Health and the Environment

Alternative 1 (modified no action) does not provide adequate protection of the environment.
Under this scenario here would not be a long-term significant reduction in VOC loading to
the groundwater. By not maintaining the existing cap, eventual soil erosion will increase
the amount of water infiltrating through the waste. This will, in time, increase
contaminant movement to the groundwater. Also, by not operating the gas extraction system,
contaminants will not be removed from the waste. These contaminants, under this
alternative, would likely migrate to groundwater causing additional contamination.
Groundwater standards would not be met under this option.

Alternatives 2, 3 and 4 all meet this threshold criteria by reducing the mass of
contaminants in the landfill available for leaching to the groundwater. The difference
between each option the rate of reduction. These differences are evaluated under the
upcoming criteria.

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

Alternatives 3 and 4 meet the ARARs pertaining to this site. Both options satisfy the key
provisions of NR 140 Wis. Adm. Code of reducing groundwater contamination levels within
reasonable period of time. Only the rate at which the reduction would occur separates these
choices.

NR 140 Wis. Adm. Code requires active remediation measures when groundwater enforcement
standards are exceeded at a point of standards applications. Because this is an NPL site,
the point of standards application is the waste fill boundary. As discussed previously,
there are a number of health-based enforcement standards exceeded at the fill edge. The
active measures proposed for this site under Alternatives 3 and 4 should reduce groundwater

-------
concentrations at an acceptable rate. These measures meet the requirement to take an active
response.

Because Alternative 4 employs pump and treat, it would reduce groundwater contamination
levels the fastest. However, as is discussed later there are site specific concerns that
would likely limit the success of a pump and treat system.

Alternative 2, with its heavy reliance on natural attenuation, likely will not meet NR 140
requirements. It is not clear that natural attenuation with the existing source control
measures would reduce groundwater contamination at an acceptable rate. It is the WDNR's
opinion that Alternative 2 likely does not meet NR 140 and therefore fails this threshold
criteria test. However, since the field data are not conclusive in this matter, Alternative
2 is reviewed by the following balancing and modifying criteria to determine its value.

Alternatives 2, 3 and 4 do meet the solid waste closure requirements in NR 500-520 Wis. Adm.
Codes. Most importantly the provisions regulating the clay cap and gas extraction systems
are met. Also, the applicable air requirements in NR 445 are met.

2. Primary Balancing Criteria

Alternatives which satisfy the two threshold criteria are then evaluated according to the five primary
balancing criteria. Because Alternative 1 does not satisfy the threshold criteria, it will not be evaluated
any further.

a. Long-Term Effectiveness and Permanence

All three remaining choices fulfill this criteria. Alternative 4, pump and treat, likely
would decrease groundwater concentrations the fastest, while Alternative 2, natural
degradation, would be the slowest. Alternative 3 would fall somewhere in between.

All three possibilities are seen as permanent solutions because they ultimately reduce and
destroy the contaminant through treatment of some kind. The residual risk to human health
or the environment remaining after completion of any of the three approaches would be low.

With all three options it will take a period of years to reduce groundwater contamination to
acceptable levels. During this interim, public health will be additionally protected
through the use of deed restrictions and state solid waste regulations preventing private
well development in the area of groundwater contamination.

b. Reduction in Toxicity, Mobility and Volume Through Treatment

All three remaining alternatives provide waste treatment and consequently reduce contaminant
mobility. Alternative 2 uses the existing gas extraction system to draw VOC's from the
landfill waste and incinerate it. However, there are concerns that the existing system is
not reducing VOC contaminant levels in the waste fast enough. Based on site studies it
appears that the northwest corner of the landfill, the old Mayville dump area, is the
greatest contaminant source. It does not appear that the current gas system adequately
addresses this area. Consequently the waste treatment provided under this option is not
acceptable.

Alternative 3 provides for an enhanced gas extraction system in the area of the old Mayville
Dump. Consequently, this choice provides a more acceptable level of waste treatment and is
an improvement over Alternative 2. It reduces at a faster rate the mass of contamination
available to migrate to the groundwater.

Alternative 4 includes both the existing waste treatment features, while adding treatment of
groundwater contamination. This makes this option superior to either of the previous

-------
choices. However, there are limits to the effectiveness of this option. Because of the
fine nature of much of the unconsolidated materials northwest of the site groundwater
extraction rates may be limited. This limitation applies whether a trench or extraction
well system is used to pump groundwater. The resulting low pumping rate would make a pump
and treat system less effective. The area of influence and the volume of water treated
under this scenario appears be too limited to practically remediate the contaminated
groundwater. In addition, the pumping may reduce the water levels in the wetlands
north of the site adversely effecting their functions. Conseguently, even though
Alternative 4 provides the opportunity for accelerated remediation, the site geology appears
to severely limit the effectiveness of the groundwater extraction effort while causing
possible additional undesirable impacts on the surrounding wetlands.

c. Short-Term Effectiveness

All remaining options can be implemented relatively guickly. Alternative 2 is essentially
already in place. The enhanced gas extraction system of Alternative 3 can be implemented in
1-2 years time with no significant threats to public health, the environment or site workers
during construction. A similar time frame could be achieved with Alternative 4, again with
little or no threats to the environment, public health or site workers during construction.

There appears to be significant differences in the time reguired for each alternative to
achieve groundwater standards. Alternative 2 is the lowest because of its reliance on
natural degradation. Alternative 4 is the fastest because it entails groundwater pumping
and Alternative 3 is somewhere in between with its enhanced gas extraction system.

d. Implementability

All remaining alternatives use existing, well established, technologies. Conseguently there
are no foreseeable technical obstacles to implementation. Also, none of these choices face
any major administrative or agency approval problems. These types of remediation systems
are routinely reviewed and approved by both state and federal agencies.

e. Cost

Table 5 summarizes the estimated costs of each remedial action. For Alternatives 2 and 3,
costs are not a deciding factor. However, for Alternative 4, the costs associated with the
groundwater system are difficult to justify. As stated, the nature of the unconsolidated
material and the presence of on-site wetlands both work to reduce the rate at which
groundwater could be extracted. The low pumping rate would likely make a pump and treat
system ineffective at containing the existing plume. Conseguently, the additional costs do
not appear to be warranted.

3. Modifying Criteria

a. State Acceptance

The WDNR is the agency proposing this solution. USEPA concurrence is expected based on
comments received on the Proposed Plan.

b. Community Acceptance

There appears to be community support for this proposal. At the public meeting presenting
the Proposed Plan no opposition was voiced. Also, there were no written comments provided
opposing the plan. The strong community concerns are that the site cleanup move ahead
guickly and that surrounding water supplies remain free of contamination. The WDNR believes
the chosen remedial option will meet these concerns.

-------
4. Summary

Based on the comparisons made above, the WDNR believes Alternative 3, Enhanced Source Control, presents the
most balanced approach for achieving acceptable environmental cleanup at a reasonable cost. The
chosen remedial action achieves the remedial objectives for this site in an acceptable time frame and at a
reasonable cost.

Conclusions of Law

The implementation of an enhanced gas control system, in conjunction with the proposed deed restrictions and
environmental monitoring will protect human health and the environment from the exposure pathways identified
in the Baseline Risk Assessment for this site, complies with all legally applicable relevant and appropriate
reguirements, and is cost-effective. This action was designed to be final; it represents the best balance of
tradeoffs with respect to pertinent criteria, given the scope of the remedial actions. CERCLA's preference
for treatment is satisfied with the action.

Statutory Determinations

A. Protection of Human Health and the Environment

The selected remedy provides adeguate protection by reducing contaminant loadings from the
landfill. Current and future water supplies will be protected. The reduced contaminant loadings
will protect future groundwater and surface water guality and will over time remediate the already
contaminated groundwater near the site.

B. Attainment of ARARs

The selected remedy will be designed to meet all applicable, or relevant and appropriate
reguirements (ARARs) under federal and more stringent state environmental laws. All permits and
approvals reguired to implement the remedy will be obtained. The primary ARARs that will be
achieved by the selected alternatives are:

1. Action Specific ARARs

Wis. Adm. Codes NR 500-520 regulate the installation, operation and maintenance of the
landfill cap and gas extraction system. Some of the more important specific codes are:

NR 504 Landfill cap design and construction
NR 508 Landfill groundwater and gas monitoring

2. Chemical Specific ARARs

Wis. Adm. Code NR 140 regulates the responses taken to groundwater contamination, determines
when those responses should be taken and when those responses are completed. The selected
action will over time result in compliance with NR 140 Groundwater Quality Preventive Action
Limits at the waste boundary.

Wis. Adm. Code NR 445 regulates air emissions from the landfill gas extraction system. This
code establishes specific emission rates for VOCs from the landfill gas extraction system.

C. Cost Effectiveness

The selected remedy provides overall cost-effectiveness. The long-term human health and
environmental benefits of file selected alternative justify the cost.

D. Utilization of Permanent Solutions and Alternative Treatment Technologies

-------
The remedy is believed to be a permanent solution and satisfies the preference for treatment.

E. Preference for Treatment As a Principal Element

Treatment of the waste fill in the landfill through gas extraction to remove the VOC contaminant
mass is the principal part of the remedial action.

Decision - The Selected Remedy

Based on evaluation of the alternatives, the WDNP, believes that enhancement of the landfill gas extraction
system with contingencies for additional remedial measures if necessary will be protective of human health,
comply with ARARs, be cost-effective, and will utilize permanent solutions.

The components of the selected remedy are:

! Operation, maintenance and monitoring of landfill cap and gas system

! Groundwater monitoring using existing wells

! Deed restrictions, as appropriate

! Restriction on new water supply well construction

! Use of existing natural contaminant breakdown

! New gas extraction wells and enhanced extraction from areas of high contamination

! Connection of piping from new gas extraction well(s) to existing gas flare system

! Specific goals and deadlines set for contaminant breakdown, if not met,
additional work may be necessary

The WDNR has determined that the selected remedy will achieve the remedial action objectives for this site.

-------
                                                    REMEDIAL ACTION

                                                 ADMINISTRATIVE RECORD

                                                 (Index and Documents)

                                                        for the

                                                 HECHIMOVICH GROUNDWATER

                                                      OPERABLE UNIT

                                                   HORICON, WISCONSIN

                                                       MARCH 1992

                                      Wisconsin Department of Natural Resources
                                                   101 S. Webster Street
                                                  Madison, Wisconsin 53707
INTRODUCTION

These documents comprise the Administrative Record for the Hechimovich Groundwater Operable Unit.  An index
of the documents in the Administrative Record is located at the front of the first volume along with an
acronym index and an index of guidance documents used by EPA Agency Staff in selecting a response action at
the site.

The Administrative Record is also available for public review at Wisconsin Department of Natural Resources'
Office, 3911 Fish Hatchery Road, Fitchburg, WI 53711.  Questions concerning the Administrative Record should
be addressed to the EPA Administrative Record Coordinator.

The Administrative Record is reguired by the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) ,  as amended by the Superfund Amendments and Reauthorization Act (SARA) .

-------
                 HECHIMOVICH LANDFILL GROUNDWATER OPERABLE UNIT
                                 HORICON, WISCONSIN
                                  TABLE OF CONTENTS
VOLUME 1
      Corresp/Memo/Others
VOLUME 2
      Corresp/Memo/Others
VOLUME 3
      Enforcement Document
VOLUME 4
      Tech/Report/Studies
VOLUME 5
      Tech/Report/Studies
VOLUME 6
      Tech/Report/Studies
VOLUME 7
      Tech/Report/Studies
VOLUME 8
      Tech/Report/Studies
VOLUME 8(a)
      Tech/Report/Studies
VOLUME 8(b)
      Tech/Report/Studies
VOLUME 9
      Tech/Report/Studies
VOLUME 9(a)
      Tech/Report/Studies
VOLUME 9(b)
      Tech/Report/Studies
VOLUME 10
      Tech/Report/Studies
VOLUME 11
      Tech/Report/Studies
VOLUME 12
      Tech/Report/Studies
VOLUME 13
      Tech/Report/Studies
VOLUME 14
      Tech/Report/Studies
VOLUME 15
      Corresp/Memo/Others
VOLUME 16
      Corresp/Memo/Others
VOLUME 17
      Tech/Report/Studies
VOLUME 18
      Tech/Report/Studies
VOLUME 19
      Tech/Report/Studies
VOLUME 20
      Tech/Report/Studies
Docs.

Docs.

Docs.

Doc.

Docs.

Docs.

Docs.

Docs.

Doc.

Doc.

Docs.

Doc.

Doc.

Doc.

Docs.

Docs,

Doc.

Doc.

Docs.

Docs.

Doc.

Doc.

Doc.

Docs.
 1-15

 16-51

 52-56

57

 58-65

 66-70

 71-76

 72-77

77 cont.

77 cont.

 78-82

82 cont.

82 cont.

83

 84-87

88-89

90

91

 92-105

 106-125

126

127

128

 129-130

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                                                         ADMINISTRATIVE  RECORD INDEX
                                                                REMEDIAL ACTION
                                                 HECHIMOVICH LANDFILL  GROUNDWATER OPERABLE UNIT
                                                               HORICON,  WISCONSIN
                                                                                      RECIPIENT
                                                                                                                          DOCUMENT TYPE
                                                                                                                                                DOCNUMBER
Letter re:
Information regarding
hazardous and
toxic Meetes disposed
at Landfill site
Memorandum re:
District Review -
Hechimovich Landfill
Plans
Letter re:
Hechimovich Sanitary
Landfill, Inc.
                                           Wendell Woj ner
                                           Hechimovich Landfill
                                           File
Memorandum re:
Comments on the
Hechimovich Landfill
Site Inspection Report

Letter re:
Supplemental  Information
Proposed Hechimovich
Senitary Landfill
James Crawford,
WDNR
Dennis Iverson,
WARZYN
Hechimovich Landfill
File
James Birkett-Bauer,
WDNR
                                           Jim Birkett-Bauer
                                                                                      Land&Gas Reclamation
                                                                                      File
Letter re:
Modi fication to the
Plan Approval, Land
and Gas Reclamation
Landfill
Richard Schuff,
WDNR
                                                                                      George Hechimovich

-------
                                           Ken Braatz,
                                           Hechimovich Sanitary
                                           Landfill,  Inc.
                                                                                      Richard Schuff
Letter re:
Issues and allegations
raised in the WDNR's
February 26, 1987
memorandum to the
Land and Gas Reclamation
Landfill file
Dennis Iverson,
WARZYN
                                                                                      David Stewart
Letter re:
Response to Preliminary
In-field Conditions
Report

Letter re:
Draft Approval
Modi fication Letter
Richard Schuff,
WDNR
                                                                                      George  Hechimovich
                                           Lakshmi Sridharan,
                                           WDNR
                                                                                                                                                       10
                                                                                                            11
Letter re:
Review of Warzyn
Engineering Inc.'s
December 24, 1987
In-field Conditions
Report and Modi fication
to the Plan Approval,
Land and Gas Reclamation,
inc.   Landfill
Lakshmi Sridharan  &
Mark Giesfeldt,
WDNR
Land&Gas Reclamation
Inc.
Letter re:
Review of Warzyn
Engineering Inc.'s
December 24, 1987,
In-Field Conditions
Report and Modi fication
to the Plan Approval,
Land end Gas Reclamation,
Inc.   Landfill
Lakshmi Sridharan  &
Mark Giesfeldt,
WDNR
                                           David Hechimovich,
                                           Hechimovich Sanitary
                                                                                      Robert  Grefe,  WDNR
                                                                                                                                                       14
                                           WDNR

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                      Letter  re:
                      Air monitoring
                      requirements  as  stated
                      in the  4/24/89 Letter
                      from WDNR  to  Mr.
                      Hechimovich
                                                                                                            Julian Chazin,  WDNR
                      Letter  re:
                      Supplemental  Information
                      August  1989  Plan
                      Modi fication,  Land &
                      Gas  Reclamation,  Inc.
                      Landfill
Valeri Ranguette
Joel Schittone,
WARZYN
                                                                                                            Robert Grefe, WDNR
18
                      Letter  re:
                      Construction
                      Documentation and Plan
                      Modi fication  Approval;
                      Interim Cover and Final
                      Cover forthe  Land &
                      Gas  Reclamation Landfill
Lakshim Sridharan,
WDNR
                      Letter  re:
                      January 8,  1990
                      WDNR Approval  Letter
                      Phase II, Module
                      1 Construction
                      Hechimovich Sanitary
                      Landfill
Joel Schittone,
WARZYN
                                                                                                            Robert Grefe, WDNR
                                                                                                                                                                              19
                      Memorandum re:
                      Response  to
                      North  7,  1990
                      Preconstruction Meeting
                      Erosion Control and
                      Repair Methods  Land
                      & Gas  Reclamation,
                      Inc. Landfill
Joel Schittone,
WARZYN
                                                                                                            Robert Grefe, WDNR
                      Letter  re:
                      Continuation  of
                      cap  restoration work
                      being done  at the
                      Land &  Gas  Reclamation
                      Landfill
Hank Hechimovich,
Hechimovich Sanitary
Landfill, Inc.
                                                                                                            Robert Grefe, WDNR

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Memorandum re:
Field Observations
Robert Grefe,
WDNR
Hechimovich Landfill
File
Letter re:
Amendment to the
Wisconsin Enforcement
Agreement for the
Hechimovich Sanitary
Landfill Superfund
Site
Norman Niedergang,
USEPA
                                                                                      Paul Didier, WDNR
Letter re:
Plan Modification
Approval; Gas
Extraction System
Plans for the
Hechimovich Sanitary
Landfill
Lakshmi Sridharan,
WDNR
                                                                                      George Hechimovich
Letter re:
Plan Modification
Approval; Final Cover
and Cley Borrow
Source for the Land
and Gas Reclamation
Landfill
Lakshmi Sridharan,
WDNR
 Land&Reclamation
 Landfill
Letter re:
Continuation of
cap construction
work being done at
the Land & Gas
Reclamation, Inc.
Landfill
                                           Hechimovich Landfill
                                           File
Letter re:
Continuation of
cap construction
work being done at
the Land and Gas
Reclamation, Inc.
Landfill
George Hechimovich,
Land & Gas Reclamation,
Inc.
                                                                                      Robert Grefe, WDNR

-------
Letter re:
Hechimovich Sanitary
Landfill - Landfill
Gas Utili zation
Study
                                                                                      Robert Grefe, WDNR
Construction
Observation Report
Supplemental Information
Site Preparation,
Phase II, Module 1
Hechimovich Sanitary
Landfill
Valeri Ranguette,
Joel Schittone,
WDNR
                                                                                                                                                        30
Letter re:
Review of the Site
Evaluation Report
for the Land and
Gas Reclamation
Landfill dated
November 1990
                                                                                                                                                        31
Letter re:
Land and Gas
Reclamation Landfill
Eric Gredell,
RMT
Letter re:
Draft Plan Modification
Gas Collection System
Design Land & Gas
Reclamation, Inc.
Landfill
Brian McVean  &
Joel Schittone,
WARZYN
Letter re:
Land & Gas Reclamation,
Inc. Site a/k/a
Old Hechimovich
Sanitary Landfill

Letter re:
Land and Gas
Reclamation Landfill
Site
Michael Ohm,
Bell, Boyd  & Lloyd
Eric Gradell,
RMT
                                                                                      Mark Giesfeldt, WDNR
                                           Mike Schmoller, WDNR

-------
Letter re:
WDNR's granting of
extension to submit
draft RI/FS workplan
for the Land and  Gas
Reclamation, Inc.
Mi ke S chmo Her,
RMT
Eric Gredell, RMT,
Inc.
Letter re:
Acknowledgement of
Receipt

Letter re:
Draft Plan Modification;
Gas Collection System
Design; Land  & Gas
Reclamation Landfill
Dennis Mack,
WDNR
                                           George Hechimovich
Memorandum re:
Meeting notes to
discuss the relationship
between landfill
closure requirements
under the WDNR's  solid
waste and air quality
regulations, and  the
CERCLA remedial response
action
Meeting Notes re:
Discussion of
preliminary comments
on the RI/FS Workplan
Revision O for the
Land and Gas
Reclamation Landfill
Site
                                                                                      Various
Comment on the RI/FS
Workplan; Land &
Gas Reclamation
Landfill
                                                                                                                                                         41

-------
Letter re:
Comments from review
of RI/FS Workplan
dated 1/25/91 for
the Land and Gas
Reclamation Landfill
Site
Charles Wilk,
USEPA
Memorandum re:
Comments on 14
Elements of the
Draft Quality Assurance
Project Plan  for
The RI/FS at
Land and Reclamation
Landfill
Kaushal Khanna,
USEPA
                                                                                                                                                         43
Letter re:
Land and Gas Reclamation,
Inc., Landfill
RI/FS Workplan
Review Comments
                                                                                      Eric Gredell, RMT
                                                                                                                                                         44
Letter re:
NR 506.08(6) Compliance
Hechimovich Sanitary
Landfill, Land and
Gas Reclamation,  Inc.
Landfill
                                                                                                                                                         45
Letter re:
Land and Gas Reclamation
Landfill
Eric Grendell,
RNT
Michael Schmoller,
WDNR
                                                                                                                                                         46
Memorandum re:
update on RMT
Laboratories approvel
process with USEPA
Region V

Letter re:
Plan Modification
Gas Collection  System
Design, Land and Gas
Reclamation Inc.
Landfill
                                                                                      E. Gredell, RMT
                                                                                                                                                         47

-------
Letter re:
Review of Revision  1
of Land and Gas
Reclamation Lanfill
RI/FS Study Workplan
April 30, 1991
 Michael Schmoller,
 WDNR
Letter re:
Record of Decision
for a Source Control
Operable Unit at the
Land and Gas Reclamation,
Inc.  Landfill
 Mi ke S chmo Her,
 WDNR
Letter re: Land and
Gas Reclamation
Landfill
 Eric Grendell,
 RMT
 Michael Schmoller,
 WDNR
                                                                                                                                                        51
State of Wisconsin
vs.  George Hechimovich
and Hechimovich Sanitary
Landfill, Inc. and
Land & Gas Reclamation
Inc.
 State of Wisconsin
 Circuit Court
State vs. George
Hechimovich, et al.
Law Offices
DeWitt, Porterr
Huggett, Schumacher,
Morgan, S.C.

 Ervin Doepke,
 Law office of
 Doepke, Hannan  & Elbert

 Steven Wickland,
 Wisconsin Department
 of Justice
Charles Laveque,
WDNR
                                                                                      Ervin Doepke
                                                                                                                          Enforcement
                                                                                                                          Document
                                     Enforcement
                                     Document
Letter re:
State of Wisconsin
vs.  Hechimovich
 Ervin Doepke,
 Law office Doepke,
 Hannan & Elbert
 Steven Wickland,
 WDOJ
Generator Profile
                                           Davis & Kuellhau
                                           Law

-------
                     Correspondence  re:
                     Hechimovich  Landfill
                     T own ship  of  Wi Hi ams t own
                     copies  of the report
                     of a  subsurface
                     investigation performed
                     at the  site
Ronald Palmquist,
Wisconsin Testing
Laboratories
                                                                                                           Hechimovich  Landfill
                     Letter  re:
                     Annual  quantity and
                     concentrations  of
                     waste disposed  of
                     through the  Hechimovich
                     Sanitary Landfill before
                     January 25,  1980
                                                                                                           Debbie Neuman,  WDNR
                                                                               Tech/Report/Studies
                                                                                                                                                                              59
                     Potential  Hazardous
                     Waste  Site -  Site
                     Inspection Report
                                                                                                           WDNR
                                                                US EPA
                                                                                                                                                                              61
                     Review  of  Region V
                     CLP  Data
                                                                                                           FIT
                     Review  of  Region V
                     CLP  Data
                                                                                                           WDNR
                     Hechimovich  Landfill
                     Survey  Summary
                                                                                                                                                                              64
18
                     Groundwater
                     Investigation Land
                     and  Gas  Reclamation,  Inc
                     with cover letter
                                                                                                           Richard  Schuff,  WDNR
                                                                               Tech/Report/Studies
                     Letter  re:
                     Information  relating
                     to the  testing of
                     the  growndwater
                     monitoring wells
Ken Braatz,
Hechimovich Sanitary
Landfill, Inc.
                                                                                                                                               Tech/Report/Studies

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Letter re:
Water Table Evaluation
Modules 1 and 2
Hechimovich Sanitary
Landfill
                                                                                      Richard Schuff, WDNR
Letter re:
Information related
to the testing of
groundwater monitoring
wells, Leachate head
monitoring well
measurements and Leachate
tank volumes at the
Landfill
Ken Braatz,
Hechimovich Sanitary
Landfill, Inc.
Technical Memorandum
Land and Gas Reclamation,
Inc.  Landfill Phase  I
Investigation

In-Field Conditions
Land Gas Reclamation
Landfill Inc.
Dennis Iverson  &
Larry Wehrheim,
WARZYN
James Birkett-Bauer,
WDNR
                                           WDNR
In-Field Conditions
Land and Gas Reclamation
Landfill
                                           Land & Gas Reclamation
                                           Inc.
                                                                                                                                                         71
Enforcement Agreement
Between the State
of Wisconsin and the
USEPA Region V  for  the
State Enforcement Lead
sites in Wisconsin
                                                                               Tech/Report/Studies
Response to
November 21, 1989,
WDNR Approval Letter
Modi fication of
Closure Plan -
Land & Gas Reclamation
Inc. Landfill
                                                                                      Robert Grefe, WDNR
                                                                               Tech/Report/Studies

-------
Statement of Work
for Organics Analysis
Statement of Work
for Inorganics
Analysis Multi-Media
Multi-Concentration
                                           US EPA
Conceptual Gas
Collection System
Design Report; and
Land & Gas Reclamation,
Inc.  Landfill
                                                                                      Robert Grefe, WDNR
                                                                               Tech/Report/Studies
Site Evaluation
Report for the
Land end Gas Reclamation
Landfill Site
Field Sampling  Plan

1990 Gas Extraction
Well Installation
Land & Gas Reclamation,
Inc. Landfill
Brian McVean  &
Joel Schittone,
WARZYN
Draft Model Quality
Assurance Proj ect
Plan Region V
Office of Superfund
Office of RCRA
                                           US EPA

-------
FICHE/FRAME PAGES
DATE
                     TITLE
                                                           AUTHOR
                                                                                          RECIPIENT
                                                                                                                        DOCUMENT
                                                                                                                          TYPE
                                                                                                                                                DOC#
               21
91/02/22
                                               Copy of State
                                               Environmental Repair
                                               Contract for the
                                               Land & Gas Reclamation
                                               Landfill
                                          Linda Meyer,
                                          WDNR
Chuck Wilk,
US EPA
Tech/Report/
Studies
                                                                                                                                                                              81
               433
91/04/30
RI/FS Workplan for the
Land & Gas Reclamation
Landfill Site
Revision 1
                                                                                         Dale Razabek,
                                                                                         Stephen
                                                                                         Johannsen &
                                                                                         Eric Gredell,
                                                                                         RMT
                                                                                                                        WDNR
                              Tech/Report/
                              Studies
                                                                                                                                                                              82
               149
               14
91/06/00
91/07/03
Modification of
Closure Plan
Gas Collection System
Design

Review of April 1991
RMT, Inc RI/FS
Workplan for the Land
& Gas Reclamation
Landfill Site with
cover letter
                                                                                         Warzyn
                                                                                         Jeffery
                                                                                         Sepesi,  Barr
                                                                                         Engineering
                                                                                         Co.
Land & Gas
Reclamation,
Inc.
Michael
Schmoller
Tech/Report/
Studies
Tech/Report/
Studies
                                                                                                                                                                              83
                                                                                                                                                                              84
               32
91/07/22
Land & Gas Reclamation
Landfill Superfund Site
Community Relations Plan
                                                                                         WDNR
                                                                                                                        Land & Gas
                                                                                                                        Reclamation
                                                                                                                        Inc.
                              Tech/Report/
                              Studies
                                                                                                                                                                              85-86
               77
91/07/24
                              92/3/13
                              91/8/28
                              91/4/30
WDNR Summary/
Exceedance Report

Revision 3 RI/FS
Workplan

Revision 2 RI/FS
Workplan

Revision 0 RI/FS
Workplan
                                                                                         WDNR
                                                           RMT
                                                           RMT
                                                           RMT
                                                                                          WDNR
                                                                                          WDNR
                                                                                          WDNR
                              Tech/Report/
                              Studies

                              Tech/Report/
                              Studies

                              Tech/Report/
                              Studies

                              Tech/Report/
                              Studies
                                                                                                                                                                              87
                                                                                                                                                                              89
                                                                                                                                                                              90

-------
92/4/15
Tech Memo 1
RI Phase I & II
                                          RMT
                                                                         WDNR
                                                             Tech/Report/
                                                             Studies
                                                                                                                                                91
92/4/8
USEPA Workplan
Concurrence
Mike
Schmoller, WDNR
                                                                         Michael Ohm
                              Corresp/Memo/
                              Other
                                                                                                                                                92
91/11/8
Workplan Approval
Mike
Schmoller, WDNR
                                                                         Michael Ohm
                              Corresp/Memo/
                              Other
                                                                                                                                                93
91/9/13
Workplan Changes
Michael
 Schmoller, WDNR
                                                                         File
                              Corresp/Memo/
                              Other
                                                                                                                                                94
91/8/28
Workplan Changes
Dale Rezabek
RMT
Mike Schmoller
WDNR
Corresp/Memo/
Other
                                                                                                                                                95
91/7/29
Revision I
Workplan
Concurrence
Mike
Schmoller,
WDNR
Michael Ohm
Corresp/Memo/
Other
                                                                                                                                                96
91/7/24
USEPA Workplan
Concurrence
Chuck Wilk
USEPA
Mike Schmoller
WDNR
Corresp/Memo/
Other
                                                                                                                                                97
91/5/20
91/2/15
Responses to
Workplan Comments

Closure Policy
Letter
                                          RMT
Mike
Schmoller, WDNR
Mike Schmoller
WDNR

Michael Ohm
Corresp/Memo/
Other

Corresp/Memo/
Other
                                                                                                                                                98
                                                                                                                                                99
90/3/26
90/3/19
ATSDR Preliminary
Health Assessment
(Draft)

Enforcement
Agreement
Amendment
Chester
Tate, DHHS
David
Ullrich,
USEPA
Norm
Neidergang,
USEPA

Paul Didier,
WDNR
Corresp/Memo/
Other
Corresp/Memo/
Other
                                                                                                                                                100
                                                                                                                                                101
89/6/13
88/4/3
June 7,1989
Meeting Notes, WDNR

Preliminary
Health Assessment
Christine
Diebels

Wisconsin
Division Health
                                                                         File
                              Corresp/Memo
                              Other

                              Corresp/Memo
                              Other
                                                                                                                                                102
                                                                                                                                                103

-------
92/5/1
Tech Memo RI
Phases I & II Review
Chuck Wilk
US EPA
Mike Schmoller
WDNR
Corresp/Memo/
Other
                                                                                                                                                104
92/5/11
Tech Memo RI
Phase I & II
Mike
Schmoller, WDNR
                                                                         Michael Ohm
                              Corresp/Memo/
                              Other
                                                                                                                                                105
92/5/22
92/6/2
92/6/11
May 18, 1992
Meeting Notes

Env. Monitoring
Water Supply
Warzyn
Engineering

Warzyn
Engineering

Sandy Heimke
WDNR
Hank
Hechimovich

Robert Grefe
WDNR

Jerome
Oechsner
Corresp/Memo/
Other

Corresp/Memo/
Other

Corresp/Memo/
Other
                                                                                                                                                106
                                                                                                                                                107
                                                                                                                                                108
92/11/19


93/2/2
Plan Modification
Risk Assessment
Robert Grefe
WDNR

Randall Duncan
Barr
George
Hechimovich

Mike Schmoller,
WDNR
Corresp/Memo/
Other

Corresp/Memo/
Other
                                                                                                                               109
                                                                                                                                                110
93/2/10
Risk Assessment
                                          Randall Duncan
                                          Barr
                               File
                              Corresp/Memo/
                              Other
                                                                                                                                                111
93/5/3
93/5/7
Draft RI

Review

Draft RI
Review
Tom Poy,

US EPA

Mike Schmoller,
WDNR
Mike Schmoller,

WDNR

Mike Ohm
Corresp/Memo/

Other

Corresp/Memo/
Other
                                                                                                                                                112
                                                                                                                                                113
93/5/27


93/6/2
Risk Assessment
Review

Risk Assessment
Review
RMT, Inc.
Tom Poy,
US EPA
Mike Schmoller,
WDNR

Mike Schmoller,
WDNR
Corresp/Memo/
Other

Corresp/Memo/
Other
                                                                                     114
                                                                                                                                                115
93/6/-
Private Well
Results
                                                           WDNR
                                                             Corresp/Memo/
                                                             Other
                                                                                                                                                116
93/7/1
Risk Assessment
Response
Jeff Sepesi,
Barr
Mike Schmoller,
WDNR
Corresp/Memo/
Other
                                                                                                                                                117

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93/8/27


93/9/20


93/9/28


93/10/1


93/10/18


93/11/10


94/1/13


94/1/24


92/8


93/4


93/4



93/9


93/11
Timeline
Letter

Alternative Array
Review

RI Comment
Responses

RI Approval
Alternative Array
Review

Focused FS
Approval

FS Review
FS Review


Construction Report


Baseline Risk
Assessment

Remedial

Investigation Report

Alternative
Array

Feasibility
Study
Mike Schmoller,
WDNR

Mike Schmoller,
WDNR

Mike Schmoldt,
RMT

Mike Schmoller,
WDNR

Tom Poy,
US EPA

Mike Schmoller,
WDNR

Tom Poy,
 USEPA

Mike Schmoller,
WDNR

Warzyn
Engineering

Barr
RMT
RMT
RMT
Mike Ohm
Mike Schmoldt,
RMT

Mike Schmoller,
WDNR

Mike Schmoldt,
RMT

Mike Schmoller,
WDNR

Mike Ohm
Mike Schmoller,
WDNR

Mike Ohm
WDNR
                               WDNR
                               WDNR
                               WDNR
                               WDNR
Corresp/Memo/
Other

Corresp/Memo/
Other

Corresp/Memo/
Other

Corresp/Memo/
Other

Corresp/Memo/
Other

Corresp/Memo/
Other

Corresp/Memo/
Other

Corresp/Memo/
Other

Tech/Reports/
Studies

Tech/Reports/
Studies

Tech/Reports/

Studies

Tech/Reports/
Studies

Tech/Reports/
Studies
                                                      118
119
120
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122
                                                      123
                                                                                                                               124
                                                      125
                                                      126
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                                   State of Wisconsin \ DEPARTMENT OF NATURAL RESOURCES

                                                                           Southern District Headquarters
                                                                               Fitchburg, Wisconsin 53711
                                                                                   TELEPHONE 608-275-3266
                                                                                     TELEFAX 608-275-3338
George E. Meyer
Secretary

September 13, 1995                            IN REPLY REFER TO: Land and Gas Reclamation Landfill

Tom Poy 5HS-11
United States Environmental Protection Agency
Hazardous Waste Enforcement Branch
77 W. Jackson Blvd
Chicago, IL 60604


SUBJECT:  Record of Decision Concurrence


Dear Mr. Poy:


Attached is the signed Record of Decision for the Land and Gas Reclamation Landfill site.  This is being
submitted for USEPA's concurrence.  As we have discussed the key component of the final remedy for the site
is a continuation and possible expansion of the existing gas extraction system.  It appears this
remedy will reduce groundwater contaminant concentrations to acceptable levels within a reasonable period of
time.

If you have additional guestions about this site please contact me directly.

        Sincerely,


        Michael Schmoller
        Hydrogeologist
        608-275-3303
                                                     
                                                          Printed on
                                                          Recycled
                                                           Paper

-------
                                                                  TAKLE 1

                                             GROUNDWATER CONTAMINANT IiEVELS NORTH OF THE SITE
      PARAMETER
Vinyl Chloride
Trichloroethene
1, 2-Dichloroethene
                                     MW-1A
2,800
 100
7,000
                                                           MW-1RR
 4,300
 2,800
19,000
                                                                                 MW-3AR
1,000
  78
1,700
                                                                                                   MW-210A
200
180
 ND
                                                                                                                    MW-214A
ND
ND
ND
  NR 140
ENFORCEMENT
    STD

     .2
     5
    100
All concentrations in parts per billion,  all  readings  from May,  1992.

Source:  RMT Draft-Final Remedial Investigation,  September,  1993.
                                                                 TABIiE 2

                                             GROUNDWATER CONTAMINANT IiEVELS WEST OF THE SITE

                                                                       WELLS
        PARAMETERS
                                                    MW-5R
                                                                            MW-5AR
                                                                                                      P-4RR
                                                                                                                        M-205A
                                                                                                                                                NR 140
                                                                                                                                             ENFORCEMENT
                                                                                                                                                STD
      Vinyl Chloride
      Trichloroethene
      1,2 - Dichloroethene
                19
                29
                72
All concentration in parts per billion, all readings  from May,  1992.

Source:  RMT Draft-Final Remedial Investigation,  September,  1993.
                    6
                   10
                      14
                      59
                      53
                                             .2
                                             5
                                             100

-------
                                                        TABIiE 3

                                             CHEMICALS OF POTENTIAL CONCERN
                                        LAND AND GAS RECLAMATION LANDFILL SITE
VOLATILE ORGANICS
                                     SEMI-VOLATILE ORGANICS
                                                                            METALS
                                                                                                       INORGANICS
Benzene
Carbon disulfide
Chlorobenzene
Chloroethane
Chioromethane
1,4-Dichlorobenzene b
1,1-Dichloroethane
1,2-Dichloroethane
1,1-Dichloroethene
1,2-Dichloroethene
Dichlorofluoromethane a
1,2-Dichloropropane
Ethylbenzene
Ethyl ether a
4-Methyl-2-pentanone b
Syrene b
Tetrachloroethene
Toluene
Trichloroethene
Vinyl chloride
Xylene

a Tentatively identified compound.
b Detected only in leachate wells.
Bis(2-chloroethyl)ether
Diethylphthalate b
2,4-Dimethylphenol b
Di-n-butylphthalate
Naphthalene b
Phenol b
Aluminum
Arsenic
Barium
Calcium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Selenium
Sodium
Vanadium
Zinc
Alkalinity
Ammonia as N
Chloride
Nitrate + Nitrite
Sulfate
source:  Barr Engineering Baseline Risk Assessment, 1993

-------
TABIiE 4






ESTIMATED  VOC CONCENTRATIONS AND 95 I>ERCENT  CONFIDENCE LIMITS
1995
1996
1997
1998
1999
Well
Upper 95%
Upper 95%
Upper 95%
Upper 95%
Upper 95%

Estimated
Estimated
Estimated
Estimated
Estimated

Concentration
Concentration
Concentration
Concentration
Concentration
MW-1RR
245
70
19
5.5
1.7

6
1
0.2
0.03
0.01

0.37
0.03
x 10'3
1 x 10 '4
x 10'8






Parameter
Lower 95%
Lower 95%
Lower 95%
Lower 95%


Confidence
Confidence
Confidence
Confidence
Confidence

Limit
Limit
Limit
Limit
Limit
DCE
3,361
953
262
75
24
TCE
545
95
18
3
0.58
Vinyl
3,752
308
17
1.3
0.08
chloride





Lower 95%





Confidence
Confidence
Confidence
Confidence
Confidence

Limit
Limit
Limit
Limit
Limit

18
5
1.4
04
0.1

0.07
0.01
2 x 10'3
4 x 10'4
7 x 10'5

4 x 10'5
3 x 10' 6
2 x 10'7
1 x 10'8
8 x lO'lO

-------
      MW-1AR       DCE             1,901
5,432             15,522           1,720
4,915             14,045           1,556
4,447             12,708           1,408
4.024             11.499            1.274
3,641             10,405
12
6.7
3.5
1.9
1
992
735
545
392
293
TCE
30
16.6
8.7
4.8
2
Vinyl
1,790
1,326
982
706
528
chloride
4.9
2.7
1.4
0.8
0.4

550
407
302
217
162


        NOTE:

              All concentrations are in parts per billion  (ppb)

-------
                                     TABLE 5 - Clean-up Alternatives Components and Costs
                                          Land & Gas Reclamation Landfill Superfund Site
Alternative Description
Alternative 1
No Additional Action

Alternative 2
Natural
Breakdown of
Contamination
Alternative 3
Enhanced
Source Control
with Natural
Breakdown of
Contamination
Alternative 4
Groundwater
Extraction,
Treatment and
Discharge
!  No Action
!  Operation,  maintenance and monitoring of landfill cap
  and  gas  system
  Groundwater monitoring using existing wells
  Deed restrictions,  as appropriate
  Restriction on new water supply well construction
  Use  of existing natural contaminant breakdown
Capital
Cost*

 $0
 $0
Annual
 O&M*

 $0
 $0
  Operation,  maintenance and monitoring of landfill cap and
  gas  system
  Groundwater monitoring using existing wells
  Deed restrictions,  as appropriate
  Restriction on new water supply well construction
  Use  of existing natural contaminant breakdown
  New  gas extraction wells and enhanced extraction from areas
  of high contamination
!  Connection  of piping from new gas extraction well(s)  to
  existing gas  flare  system
!  Specific goals and deadlines set for contaminant breakdown,
  if not  met,  additional  work necessary
 $107,000
 $11,000
  Operation,  maintenance and monitoring of landfill cap and
  gas  system
  Groundwater monitoring using existing wells
  Deed restrictions,  as appropriate
  Restriction on new water supply well construction
  Use  of existing natural contaminant breakdown
 $706,000
 $104,000
                        ! Interceptor/collection trench and sumps at north end of
                         landfill
                        ! Air stripping treatment system with exhaust air discharge to
                         atmosphere
                        ! Discharge of treated groundwater to existing drainage
                         ditches
                        ! Monitoring of treatment system

-------
* The capital cost of $2,140.000 has already been spent to construct the final landfill  cap and gas  extraction and
  flare system.   These costs are not shown in this table.

* An annual operation and maintenance cost of $79,000 is necessary to operate the existing system.   This  cost is  also
  not shown in the table.

Source:  WDNR Proposed Plan, 1994

-------
                                      RESPONSIVENESS SUMMARY

This Responsiveness Summary has been prepared to meet the requirements of Sections 113  (k)  (2)  (B)  (iv) and
117(b) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended by
the Superfund Amendments and Reauthorization Act of 1986, which requires the United States Environmental
Protection Aqency or the state on state lead sites to respond" ... to each of the siqnificant comments,
criticisms, and new data submitted in written or oral presentations" on a proposed plan or draft Record of
Decision  (ROD) for remedial action.  The Responsiveness Summary addresses concerns
expressed by the public and potentially responsible parties in the written and oral comments received by the
State reqardinq the final remedy for the Land and Gas Reclamation Landfill.

A.      OVERVIEW

I.      PUBLIC COMMENT PERIOD

An Administrative Record has been established at the Mayville Public Library, 111 North Main Street,
Mayville, Wisconsin.

The Proposed Plan for the final remedy was available for public comment from February 16, 1994, to March 17,
1994.  A public meetinq to present and discuss the plan was held at the Mayville Senior Center on February
16, 1994.  Approximately 30 people attended.  Durinq the public comment period one written comment was
received.

B.      COMMUNITY INVOLVEMENT

Public interest reqardinq the site has been low.  The community qenerally seems to favor the remedial actions
chosen in the ROD.

C.      SUMMARY OF SIGNIFICANT COMMUNITY COMMENTS

Comment 1

At the February public meetinq concern was raised by several individuals about the rate of qroundwater
cleanup.  There were concerns why the WDNR was not proposinq a pump and treat option.

Response

It was explained why the DNR believes that pump and treat was of limited value at the site and why it was
believed the proposed actions would clean up the qroundwater at an acceptable rate.  It was also stated that
qroundwater monitorinq would be conducted to track the rate of improvement in water quality.  If improvements
do not occur, additional remedial actions would be required.

Comment 2

The WDNR received a sinqle written comment concerninq the need to keep the local residents informed on clean
up proqress at the site.

Response

The WDNR aqrees and efforts will be made to keep all residents informed on actions at the site.

-------
                                                             REMEDIAL  RESPONSE BRANCH

                                                          CORRESPONDENCE  SIGN-OFF SHEET
SITE:         HECHIMOVICH LANDFILL

ITEM:       Notice  Letter
            Administrative Order
            Control  Correspondence

MUST BE MAILED BY:

SIGN-OFF:  (Names not  required are scratched)
RRB
                                  Date
Special Notice Letter
Information Request
Other ROD Concurrence
PM
                Division  Director
                        W.   Muno
Deputy Regional Administrator
                 D. Ullrich

Regional Administrator
                 V. Adamkus
                                                                                          Section Chief
                                                                                          C. Puchalski

                                                                                          Branch Chief
                                                                                           L. Kyte
                                         ,  for mailing

                                    Date Returned for mailing

-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION V

DATE:

SUBJECT: Request for Concurrence on the Record of Decision for
the Hechimovich Landfill Cite in Williamstown Township, Wisconsin
Gail Ginsberg
Regional Counsel
FROM: William Muno
Associate Director for Superfund

TO: Valdas V. Adamkus
Regional Administrator

We are recommending that you concur with the remedy selected for the Hechimovich Landfill Site, as presented
in the Record of Decision (ROD) prepared by the Wisconsin Department of Natural Resources (WDNR), by signing
the enclosed letter of concurrence.

WDNR is the lead Agency for this site in accordance with the Superfund Memorandum of Agreement (SMOA) between
U.S. EPA and WDNR. Hechimovich Landfill is a non-Fund financed State-lead enforcement site. Under 40 CFR
300.515 (e) (2) (i) and (ii) of the National Oil and Hazardous Substances Pollution Contingency Plan, U.S. EPA
may concur with the remedy selected by WDNR.

Because the risk assessment indicates no unacceptable human health risks and limited potential ecological
risk, WDNR has selected a final remedy for the Hechimovich Landfill site which utilizes natural attenuation
of the groundwater contamination with monitoring. Contaminant target levels have been established for the
groundwater over the next 5 years. If these target levels are not met, a decision will be made on the
implementation of a more active pump and treat remedy. To aid the natural attenuation process and to address
the potential impact to the wetlands, the existing gas extraction system will be enhanced in areas of high
contamination (i.e., the northern part of the landfill). This will reduce the VOC loading to the groundwater
and will help prevent further migration of the plume. In addition, institutional controls will be
implemented as appropriate. WDNR has also stated for clarity that the cap and gas extraction system
installed in the earlier interim action will continue to be maintained and operated as part of the final
remedy for the site.

As such, we believe that concurrence with the remedy is a proper exercise of your delegated authority.
Please feel free to contact either of us if you have any guestions.
cc: D. Ullrich
M. Jordan

Enclosures
bcc w/o enclosures: T. Poy
W. Carney
L. Kyte
C. Puchalski
M. Berman

-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 5

R-19J
Mr. George E. Meyer
Secretary
Wisconsin Department of Natural Resources
101 South Webster Street
Madison, Wisconsin 53707

Dear Mr. Meyer:

The United States Environmental Protection Agency (U.S. EPA) hereby concurs with the selected remedy as
identified in the enclosed Record of Decision (ROD) completed by the Wisconsin Department of Natural
Resources (WDNR) for the Hechimovich Landfill Site. Our concurrence is in accordance with 40 CFR
5300.515 (e) (2) (i) and (ii) and is based on the administrative record.

Because there is no unacceptable risk to human health, we agree that the best course of action is to allow
the contaminated groundwater at the site to naturally attenuate while reducing the volatile organic compound
loading by enhancing gas extraction. If the groundwater contaminant targets, as established in the ROD, are
not met, we agree that the remedy will need to be reevaluated and that a more active groundwater remedy may
be needed.

As the final remedy for the site, we also agree with WDNR that the exiting landfill cap and gas collection
system need to be operated, maintained, and where appropriate, institutional controls should be implemented
to restrict exposure to site contaminants.

We look forward to our continuing involvement on the Hechimovich Landfill Site as it moves through the
Remedial Design/Remedial Action.

Sincerely yours,

Valdas V. Adamkus
Regional Administrator

Enclosure
bcc w/o enclssure: W. Muno
T. Poy
W. Carney
L. Kyte
C. Puchalski
M. Herman

-------