EPA/ROD/R05-97/098
                                    1997
EPA Superfund
     Record of Decision:
     TOMAH MUNICIPAL SANITARY LANDFILL
     EPA ID: WID980610307
     OU01
     TOMAH, WI
     09/25/1997

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                              DECLARATION FOR THE RECORD OF DECISION

SITE NAME AND LOCATION

Tomah Municipal Sanitary Landfill, Tomah, Monroe County, Wisconsin

STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected remedial action for source control, operable unit 1, at the
Tomah Municipal Sanitary Landfill  (TMSL) site in Tomah, Monroe County, Wisconsin. The remedy was chosen in
accordance with the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERLA), as
amended by the Superfund Amendments and Reauthorization Act of 1986  (SARA) and is consistent with the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP) to the extent practicable.  This
decision is based upon the contents of the Administrative Record for the site.

It is anticipated that the State of Wisconsin will concur with this decision.  A written confirmation is
expected by September 30, 1997, and will be added to the administrative record upon receipt.

ASSESSMENT OF THE SELECTED REMEDY

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

DESCRIPTION OF THE SELECTED REMEDY

This operable unit is the first of two that are planned for the site.  The first operable unit addresses the
source of contamination by containing on-site wastes and contaminated soils. The function of this operable
unit is to seal off the TMSL site as a source of groundwater contamination and to reduce the risks associated
with the exposure to the contaminated materials. While the remedy does address one of the principal threats
at the site, the second operable unit will involve continued study and possible remediation of the
downgradient contaminant plume.

The major components of the selected remedy include:

•      Capping the approximately 18-acre landfill with a dual barrier cap that includes a
       geosynthetic clay liner, overlain by a low-permeability geomembrane, and covered with 3
       feet of soil and vegetated with plants that have a root system less than 3 feet.  This cap
       would meet the Wisconsin Administrative Code reguirements for closed landfills and
       would provide a landfill cap in conformance with Wis. Admin. Code ° NR 504.07
       (1996);

•      Expansion of an already existing active gas collection system; and
•
•      Conducting environmental monitoring to ensure the effectiveness of the remedial action.

Institutional controls are not included as part of the selected remedy because deed restrictions on the TMSL
property, enforceable by the State of Wisconsin, are already in place.  U.S. EPA has concluded that no
additional controls are necessary to prevent inappropriate use of the site.

DECLARATION STATEMENT

The selected is protective of human health and the environment; complies with Federal and state reguirements
that are legally applicable or relevant and appropriate to the remedial action except for groundwater cleanup

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standards, where a waiver is justified; and is cost-effective.  This remedy utilizes permanent solutions and
alternative treatment technologies to the maximum extent practicable for the site.  However,  because
treatment of the principal threats of the site was not found to be practicable,  this remedy does not satisfy
the statutory preference for treatment as aa principal element of the remedy.  The size of the landfill and
the fact that there are no on-site hot spots that represent the major sources of contamination preclude a
remedy in which contaminants could be excavated and treated effectively.

Because substances hazardous will remain at the site,  U.S. EPA will conduct a five-year review in accordance
with Section 121 of CERCLA to assess whether any other response is necessary.

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                             U.S. EPA Superfund
                             Record of Decision
                        Tomah Municipal Sanitary Landfill Site

                         Toma, Monroe County, Wisconsin
                                September, 1997
                                   TABLE OF CONTENTS

I.      Site Description	1

II.     Site History and Enforcement Activities	1

III.   Highlights of Community Participation	2

IV.     Scope and Role of Operable Unit	3

V.      Site Characteristics	3

VI.     Summary of Site Risks	7

VII.   Description of the Remedial Alternatives	10

VIII.   Evaluation of Alternatives	14

IX.     Statutory Determinations	19

X.      State Concurrence	19

FIGURES

Figure 1     Tomah Municipal Sanitary Landfill Site Location Map

Figure 2     Tomah Municipal Sanitary Landfill Site Base Map
             With Sampling Locations

Figure 3     Profile of Landfill Cap Design

Figure 4     Comparison of Alternatives

TABLES

Table 1      Summary of Contaminants Detected in Groundwater

APPENDICES

Appendix A -     Responsiveness Summary

Appendix B -     Administrative Record

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                                DECISION SUMMARY

I.      Site Description

The Tomah Municipal Sanitary Landfill  (TMSL) is located north of the City of Tomah, Monroe County, Wisconsin
(Figure 1).   The landfill occupies approximately 18 acres within the 40-acre site  (Figure 2).   The site is
bordered on the north by Deer Creek and its associated wetlands, on the east by 24th Avenue and agricultural
property, on the south by the Sunnyvale Subdivision, and on the west by agricultural fields and wetlands.

II.    Site History and Enforcement Activities

The City of Tomah  ("the City" or "Tomaah")  operated the TMSL as a disposal site from 1959 to 1979, disposing
of municipal and industrial wastes on 18 acres located on the southern portion of the site.  Wastes were
placed in shallow  (3 to 8 feet)  unlined trenches, which were excavated in the sandy subsoilss over the
southern half of the site and covered with native soils.

In August, 1975, the Wisconsin Department of Natural Resources  (WDNR)  ordered the City to close the site
because of potential degradation of local groundwater guality.  The City closed the site in 1979, covered it
with soil and topsoil, and planted grass and trees on the site.

In June, 1981, Union Camp Corporation submitted a Notification of Hazardous Waste Activity for a facility in
Tomah.  The company reported that from 1960 to 1977, it had disposed of 75,700 gallons of solvent waste from
plastics and printing operations at the TMSL.  These wastes contained volatile orgaanic compounds (VOCs) and
heavy metals.

In December, 1983, representatives of the WDNR conducted a Potential Hazardous Waste Site Prelimiary
Assessment for the TMSL.  The WDNR's assessment indicated that the landfill represented a potential hazard to
ground water and surface water,  and that there could be other migration pathways.

In June, 1984, the WDNR and the consulting firm Ecology and Environment, under authorization from U.S. EPA,
conducted a site inspection.  A groundwater sample from a downgradient monitoring well contained organic
contamination above levels of health concern. Based on these findings, WDNR nominated the site for inclusion
on U.S. EPA's National Priorities List (NPL) on April 3, 1985.  The site was subseguently added to the NPL on
March 31, 1989.

In February, 1992, U.S. EPA's Technical Assistance Team (TAT) sampled nine residential wells in the Sunnyvale
Subdivision adjacent to the TMSL.  One residential well contained elevated levels of vinyl chloride.

In 1993, the City provided municipal water to homes in the Sunnyvale Subdivision, south of the site, to
eliminate the potential hazard posed by the landfill for private drinking wells in the subdivision.   The
private wells were subseguently abandoned.

Research to identify parties responsible for conditions at the TMSL was completed early in 1993. U.S. EPA
identified 3 potentially responsible parties (PRPs):  the City of Tomaah as owner and operator of the
landfill; and Union Camp Corporation and the Veterans Hospital as generators of hazardous substances disposed
of aat the site.  U.S. EPA sent a special notice letter to the PRPs in July, 1993, to conduct a remedial
investigation/feasibility study  (RI/FS) with oversight by U.S. EPA.  On January 11, 1994, an Administrative
Order on Consent  (AOC) was entered into voluntarily by the PRPs to conduct the RI/FS at the TMSL site.

In April, 1994, U.S. EPA decided to take a presumptive remedy approach to the selection of a remedy for the
site.  After years of addressing contaminated landfills, U.S. EPA has found that the most practical way to
deal with the large variety and volume of waste found in municipal landfills is containment.  A containment
remedy may include one or more of the following components:  a landfill cap; a groundwater collection and
treatment system; a landfill gas collection and treatment system; a leachate collection and treatment system;
and future land use restrictions.  In the early stages of the presumptive remedy analysis for site,  U.S. EPA
concluded that containment at the TMSL would involve placing a cap over the landfill to reduce the amount of
water entering and migrating out of the landfill and installing and operating a landfill gas collection

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system.  Data collection efforts in the RI, risk assessment, and analysis of remedial alternatives in the FS
were streamlined based upon application of the OSWER Directive No. 9355.0-49FS entitled "Presumptive Remedy
for CERCLA Municipal Landfill Sites."  Use of the presumptive remedy approach allows a focused effort on data
collection to determine risk at the site, usually by examining groundwater conditions, and a subseguent
streamlined evaluation of alternatives to contaminated waste in the landfill.  Thus, the presumptive remedy
allows for selection of an on-site source control remedy before all off-site long-term groundwater
contamination issues are resolved.  This ROD addresses only the containment of contaminants from the source
area (i.e., the landfill).

In July, 1996, in response to indications that landfill gas was migrating off-site, the PRPs installed an
active gas extraction system along the southern boundary of the landfill.

III.    Highlights of Community Participation

In June, 1994, U.S. EPA hosted a "kick-off" public meeting at the Tomah City Hall Council Chambers.  The
purpose of the meeting was to inform local residents of the Superfund process, the presumptive remedy
approach and the work to be performed under the RI.   In addition, because there are two other Superfund sites
in Tomah, numerous other public meetings and availability sessions have been conducted.

In 1993, U.S. EPA established an information repository at the Tomaah Public Library, 716 Superior Avenue,
Tomah,  Wisconsin.  U.S. EPA maintains a copy of the administrative record for the site in the information
repository.  The RI and FS were released to the public in July, 1996, and April, 1997, respectively.  A
Proposed Plan was made available on August 7, 1997.   A public meeting was held on August 18, 1997, to discuss
the RI/FS and Proposed Plan. Advertisements were placed in local newspapers to announce the public meeting
and comment period.  A public comment period for the Proposed Plan was established from August 7, 1997 to
September 5, 1997.  The public generally supports the selected remedy.  The responsiveness summary is
contained in Appendix A.

The public participation reguirement of sections 113 (k) (2) (B) and 117 of CERCLA, 42 U.S.C.00 9613(k) (2) (B)
and 9617, have been met in the remedy selection process.   This decision document presents the selected remedy
for the Tomah Municipal Sanitary Landfill Superfund site, chosen in accordance with CERCLA, as amended by
SARA, and to the extent practicable, the NCP.  The decision for this site is based on the Administrative
Record.

IV.    Scope and Role of Operable Unit

U.S. EPA has determined that installation of a low permeability geomembrane and a geosynthetic clay liner
(GCL) over the landfill and the operation of the active gas collection system is necessary at the TMSL.  This
decision is based on an analysis of site risks, described in detail below.  The decision relies on the
indications that the landfill is the source of contamination to ground water which may be used by residents
downgradient of the site and that landfill gas is migrating off-site.

This ROD addresses on-site source control.  The source control remedy will be implemented and the site will
be monitored to determine the effects of the source control on reducing the levels of off-site groundwater
contamination.  After a period of sufficient monitoring a second risk assessment and FS will be conducted for
the off-site contamination, primarily in ground water. An additional Proposed Plan and ROD will then be
issued to select a remedial alternative for the
off-site contamination.

Because hazardous substances will remain at the site,  U.S. EPA will conduct a five-year review in accordance
with Section 121 of CERCLA to assess whether any other source control response is necessary.

V.     Site Characteristics

The Phase I and II RI involved sampling and anlysis of ground water, landfill gas, surface water and sediment
to determine site conditions.  Groundwater samples were collected from residential and monitoring wells
around the site to determine the nature and extent of groundwater contamination.  Gas samples were collected

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from gas probes in and around the landfill and near residents south of the landfill to determine if landfill
gases have migrated beyond the limits of the waste and the site boundary.   Surface water and sediment samples
were collected in Deer Creek and in the wetlands north of the landfill to evaluate if contaminants from the
landfill were impacting Deer Creek.  Test pit excavations were also conducted to determine the approximate
boundaries of the landfilled area.

Based on the results of the RI,  U.S. EPA examined the threats to human health and the environment through
exposure by ingestion and/or direct contact with contaminants in ground water,  and surface water and
sediment.  U.S. EPA did not quantify risks associated with contaminants in surface soil and landfill gas
because EPA presumed that a landfill cap and an expanded gas collection system would be installed, thereby
addressing the risks associated with surface soil and gas, whatever they may be.

Site Conditions

Physical Features

1.    Geology

Data from soil borings indicate that the TMSL is underlain predominantly by residual sand materials, formed
by the in-place weathering of sandstone bedrock, and alluvial unconsolidated sands overlying the sandstone
bedrock.  The unconsolidated material consists of silty sands to poorly graded fine- to medium-grained sand.
The thickness of the unconsolidated deposits in the immediate vicinity of the landfill ranges from 1 to 19
feet and generally increases toward Deer Creek.

Underlying the unconsolidated sands is sandstone bedrock of Cambrian age.   Two sandstone mounds are located
in the southwest and southeast corners of the site. The bedrock surface slopes down from the sandstone mounds
in all directions.

2.     Hydrology

The TMSL site lies in the Deer Creek valley which is the primary drainage way near the site. Deer Creek flows
northeast across the northwestern corner of the property, within 230 feet of the northwest corner of the
landfilled area.  The creek meanders through an extensive emergent wetland located on the northwest portion
of the property and joins Lemonweir Creek about one mile east of the site.  Deer Creek is classified as a
cold water sport fishery (trout stream).

The moderately permeable site soils permit infiltration and restrict the volume of overland flow. Surface
runoff across the landfill is generally north toward Deer Creek, with the exception of the low area along the
southern property boundary where runoff drains to the south.

3.     Hydrogeology

Ground water beneath the site was encountered within the unconsolidated deposits,  the landfill waste, and the
bedrock.  The data collected indicates that the unconsolidated sand and the sandstone bedrock generally
function as a single aguifer.  The water level data indicate that the groundwater flow is northeast toward
Deer Creek and the surrounding wetlands averaging velocities between 0.02 and 0.38 ft/day.  The groundwater
contribution to Deer Creek appears to be limited to the shallow portion of the aguifer.  Deeper flow may
occur beneath Deer Creek.

The majority of the landfill appears to be unsaturated.  However, investigations showed up to 2 feet of
saturated waste at the base of the landfill in some areas.  The total thickness of the waste is approximately
10 - 12 feet.  Using the highest water levels measured at the site, U.S. EPA estimates that 19,000 out of the
300,000 cubic yards in the landfill may be saturated.  However, seasonal fluctuations in the water table make
it difficult to estimate the volume of saturated wastes with any reliability.

The City and the majority of the private well owners obtain their water supply from the Cambrian age
sandstone aguifers.  The City provides municipal water for all residential properties within the City limits.

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Residents living outside of the city limits obtain their water supply from private wells except for those
persons living in the Sunnyvale Subdivision who are serviced by municipal water.  Ten of the eleven private
wells currently used within one-half mile of the site are located north and northeast of the site.  Well logs
from the current property owners indicate that several of the wells are screened in the sandstone at depths
of 50 to 80 feet.  One additional well is located approximately 500 feet east of the landfill.  No well log
could be located for this well.

4.      Ecology

The TMSL site is zoned as conservancy. The areas to the north, east, and west are classified as vacant or
agricultural.  Deer Creek flows northeast across the northwestern corner of the site.  The WDNP has
designated Deer Creek as Class II trout waters, supporting primarily brook trout. Adjacent woodlands,
wetlands, and fields add to the diversity of wildlife habitat in the area. Wildlife species found at the site
would be typical of an urbanizing rural agricultural area or transients from adjacent habitats.

WDNR's Bureau of Endangered Resources reports no known occurrences of threatened, endangered, or special
concern species; natural communities; or State Natural Areas that would be affected by remedial actions at
the TMSL site.  The U.S. Fish and Wildlife Service does report that two federally listed species occur in
Monroe County.  However, the U.S. Fish and Wildlife Service concluded that due to the nature and location of
the proposed activities, the species identified would not be adversely affected.

5.      Contamination

a)      Surface Water and Sediment

Surface water and sediment samples were collected from four locations as part of the Phase I investigation
(see Figure 2).   Three of the four surface water/sediment samples were collected from Deer Creek.  The fourth
sample was collected in the emergent wetland adjacent to the Creek.

Volatile organic compounds (VOCs) and semivolatile organic compounds (SSVOCs) were not detected in the four
surface water samples.  2-Butanone was detected in both the upstream and downstream sediment samples.  Low
levels (56 to 60 Ig/kg)  of three polynuclear aromatichydrocarbons  (PAHs) were detected in most downstream
sediment sample location.

Comparable values for inorganic constituents were measured for surface water and sediment samples collected
at upstream and downstream sample locations, as well as in the wetland.  The data collected did not indicate
that the surface water and sediment have been impacted by landfill-related contaminants.

b)      Ground water

The nature and extent of groundwater contamination was evaluated based on the results from 12 groundwater
monitoring wells sampled during Phase I, and 7 additional wells installed and sampled during the Phase II
investigation.  In addition,  six private wells were sampled during Phase II  (see Figure 2).  A summary of
contaminants detected in the Phase I and II groundwater sampling is presented in Table 1.  Additional
monitoring wells have been added and sampled since the completion of the Phase II RI and the risk assessment.
The groundwater operable unit will include a complete evaluation of all data collected from the entire
groundwater monitoring well network.

Seven chlorinated VOCs were detected in the samples collected from the monitoring wells. These VOCs include
chloroethane, 1,1-dichloroethane, 1,2-dichloroethene (cis and trans), 1,2-dichloropropane,
1,2-dichloroethane, and vinyl chloride.  Five aromatic VOCs were also detected including benzene, toluene,
ethylbenzene, xylenes, and chlorobenzene.  Vinyl chloride and benzene were detected most frequently and
exhibited the highest concentrations.  The vinyl chloride (0.7 to 1,200 Ig/L) and benzene (0.5 to 48 Ig/L)
concentrations exceeded the WDNR's Chapter NR 140 Preventative Action Limit  (PAL), Enforcement Standard  (ES),
and Federal Maximum Contaminant Level  (MCL) in each sample in which they were detected. Vinyl chloride
appears to be the most persistent and widespread VOC.  The vinyl chloride concentrations decreased from 1,200
Ig/L adjacent to the landfill  (in MW-7) to 36 Ig/L approximately 800 feet downgradient from the site (in

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MW-9B).   Analytical data from individual well nests indicated that concentrationss of both benzene and vinyl
chloride were typically higher in samples collected at depth compared with those collected at the water
table.  VOCs were not detected in the upgradient or residential wells.

Several SVOCs were also detected in the groundwater samples.  The only SVOC to exceed Ch. NR 140 ES and the
MCL was bis(2-ethylhexyl) phthalate.

Various inorganic constituents were detected in groundwater samples. Twelve of the inorganic parameters were
detected in groundwater samples at concentrations exceeding federal primary or secondary drinking-water
standards.  Inorganic constituents detected in downgradient ground water may have migrated from the landfill.
Downgradient concentrations of aluminum, iron, and manganese were significantly higher than those
concentrations found in upgradient wells. Thallium, cadmimum, and chromium concentrations measured
downgradient of the landfill also exceeded the federal drinking-water standards.

Groundwater samples collected from the downgradient wells during the Phase I were also analyzed for
pesticides, PCBs, dioxins, and furans.  The results of these analyses indicate trace concentrations of
octachloro-dibenzopara-dioxin (OCDD) in three of the samples.  Three pesticides were also detected: endrin,
2,4,5-TP, and chlordane.  No PCBs or furans were detected.

c)     Landfill Gas

Data collected from the investigation indicate that landfill gas is being generated at the site. Methane
concentrations, as measured in the gas probes and monitoring wells, ranged from 4 to 71 percent (by volume in
air).   Data collected from gas probes installed beyond the boundary of the landfill indicate that landfill
gas is migrating offsite.  The methane concentrations measured from zero to 37 percent by volume.   The lower
explosive limit  (LEL)  for methane is 5 percent by volume.  Chapters NR 504 and NR 506 of the Wisconsin
Administrative Code (WAG) require that all waste disposal facilities have an effective means for controlling
landfill gas migration such that the concentration of explosive gases at or beyond the property boundary do
not exceed the LEL.

Gas samples were also analyzed using a portable gas chromatograph.  VOCs detected include vinyl chloride,
1,2-dichloroethene, 1,1,1-trichloroethane, trichloroethene, and toluene.  In general, the highest  (338.7 to
773.10 ppm) and most consistent contaminant measured was 1,1,1-trichloroethane.

VI.    Summary of Site Risks

U.S. EPA used the data collected during the RI to assess human health and ecological risks.  This assessment
compared contamination levels at the site with U.S. EPA standards.  In addition, further assessment of
conditions at the site compared contamination levels at the site with Wis. Admin. Code Ch. NR 140  (1996),
Groundwater Standards.  The assessment considered ways in which people and wildlife could be exposed to
site-related contaminants and whether such exposure could increase the incidence of cancer and
noncarcinogenic  (noncancer related)  diseases above the levels that normally occur in the study area.

The screening assumed that people could be exposed to site-related contaminants by a number of different
pathways  (e.g., ingestion, inhalation, dermal contact).  Exposure to surface water and sediment and ground
water were evaluated under current and future land use conditions.  The installation of a landfill cap and a
gas collection system was presumed.   As a result, risks from direct contact with contaminants in soil on the
landfill surface or landfill gases were not evaluated.

Current land use and reasonable anticipated future use of the land at NPL sites are important considerations
in determining current risks, future potential risks, and the appropriate extent of remediation.   (See "Land
Use in the CERCLA Remedy Selection Process," OSWER Directive No. 9355.7-04, May 25, 1995).  Land use
assumptions affect the exposure pathways that are evaluate in the risk assessment.  The results of the risk
assessment aid in determining the degree of remediation necessary to ensure current and long-term protection
at the site at the site.  The risk assessment considers present use of the site to determine current risks.
It may restrict its analysis of future risks to the reasonably anticipated future land use.

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In the case of the TMSL risk assessment.  U.S. EPA assumed that the exposure to contaminants in the surface
water and sediment would continue to be the recreational use of Deer Creek.  U.S. EPA assumed the most
conservative scenario for exposure to ground water in the future would be residential use downgradient of the
site.

Potential risks to public health for cancer are expressed numerically, i.e., 1x10 -4 or 1x10 -6. Carcinogenic
risk expressed as 1x10 -4 means that of 10,000 people exposed to contamination over a 70-year lifetime one
individual could potentially develop cancer as a result of the exposure.  A carcinogenic risk of 1x10 -6
means that of 1,000,000 people exposed over a 70-year lifetime one individual could potentially develop
cancer as a result of the exposure.  U.S. EPA has established a carcinogenic risk range from 1x10 -4 to 1x10
-6 in an attempt to set standards for remediation and protectiveness.   The measure of noncarcinogenic risk is
termed a hazard index (HI)  and is also expressed numerically.  When the HI exceeds 1, there is a potential
for adverse health effects.

In general, the majority of the predicted potential health impacts were associated with exposure to
contaminants detected in ground water.  Dermal exposures to contaminants in the surface water and sediment
resulted in excess lifetime cancer risks below 1x10 -6 and hazard indices below 1 for recreational receptors.
Contaminants in ground water were evaluated for residential ingestion, inhalation, and dermal exposures.  The
total excess lifetime cancer risk for adult residents was 3x10 -2, while that for child residents was 1x10
-2.  The adult resident's hazard index was 139 and the child's hazard index was estimated to be 325.
Ingestion of groundwater contaminants (i.e.,  vinyl chloride) resulted in the majority of the estimated risk
and hazard.

The total overall risk for adult residents using the groundwater and utilizing the wetlands for fishing or
other recreational activities is 3x10 -2 while that for the child is 1x10 -2.  The risk is primarily due to
the presence of vinyl chloride in the ground water.

It should be noted that two exposure pathways were not evaluated guantitatively in the baseline human helath
risk assessment.  Because no soil samples were collected from the landfill itself and a source control action
has been proposed, no assessment of risk to persons having contact with landfill soil and contents were
estimated.  However, hazardous substances are present in the landfill that could pose some level of hazard
should exposure occur.

Sampling from gas probes has confirmed the presence of landfill gases including VOCs.  These gases have been
found to contain vinyl chloride, 1,2-dichloroethene, 1,1,1-trichloroethane, toluene, and trichloroethene.
However, the lack of guality assurance/guality control (QA/QC) documentation preclude the use of gas samples
taken to date in a guantitative risk assessment. Thus, no guantitative risk was estimated for nearby
residents who may be exposed to ambient concentrations of these landfill gases.  A review of the data
indicates that the maximum vinyl chloride concentration in the landfill gas was approximately 20 parts per
million  (ppm) ,  while  that in ground water was 1,200 Ig/L or 1.22 ppm.  Given that inhalation of vinyl
chloride vapors  from ground water was estimated to result in a risk of approximately 2x10 -4 and the
landfill gas concentration is an order of magnitude higher than the groundwater concentration, the cancer
risk due to inhalation of vinyl chloride in the landfill gas could potentially result in risks of the same
magnitude.  Additional cancer risk could also be contributed by the other carcinogenic compounds (such as
trichloroethene) detected in the landfill gases.

The source control measures proposed in the FS call for the landfill gases to be collected with an active gas
collection system and treated prior to release.  The gas collection system and treatment will reduce
explosion hazards and exposures to ambient concentrations inhaled by nearby residents.

An ecological risk assessment was conducted to estimate the risks to terrestrial and aguatic organisms at the
site and gualitative measure impacts on areas surrounding the TMSL.  Terrestrial organisms associated with
the TMSL were not considered at risk based on literature-derived benchmark values.  Exposure and risk to
aguatic organisms was evaluated by directly comparing surface water and sediment exposure dose to National
Ambient Water Quality Criteria, state standards, or other literature-based benchmark values.  Based on this
analysis, cobalt and manganese in surface water were the only metals found that would potentially pose a risk
to aguatic organisms.

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Actual damage to the aquatic and terrestrial ecosystem of Deer Creek and the adjacent wetlands was not
observed.  Based on this analysis, ecological effects from TMSL contaminants are considered insignificant at
this time.

Based on the information collected to date on the site contamination and associated risks to human health and
the environment, the installation of a low permeability cap to reduce the amount of contaminants leaching
from the landfill wastes to the underlying ground water and continued collection of landfill gases is
warranted.  The need for remediation of the contaminated ground water will be determined after implementation
of the source control remedial actions and after the investigation of the offsite ground water has been
completed.  The groundwater operable unit will be addressed in a separate RI/FS, proposed plan and ROD.

VII.   Description of the Remedial Alternatives

Remedial Action Objectives

The source control remedial action objectives were developed for this site to address the landfill as a
long-term source of contamination, to provide short- and long-term protection of human health and the
environment, and to meet the applicable or relevant and appropriate requirements (ARARs).

Based on the analytical data collected to date and the associated risks, the media of concern include the
landfill gas and ground water.  The site specific remedial action objectives for this site include:

Landfill Gas Source Remedial Action Objectives

•      Prevent landfill gas migration such that at no time shall the standard concentration of
       explosive gas in the soils outside the limits of waste, or air within 200 feet of or beyond
       the landfill property boundary exceed the lower explosive limit  (LEL) for such gases, in
       accordance with Wis. Admin. Code Ch. NR 506 (1996), Landfill Operational Criteria.
       Chapter NR 506  (1996) of the Wis. Admin Code requires that all waste disposal facilities
       have an effective means for controlling landfill gas migration such that the concentration
       of explosive gases at or beyond the property boundary does not exceed the LEL.

•      Prevent blower emission exceedances above standards for the interim and permanent
       landfill gas extraction system set forth in Wis. Admin. Code Ch. NR 445  (1996).

Groundwater Source Control Remedial Action Objectives

•      Provide an effective means to reduce infiltration through the landfill waste.

•      Eliminate contaminant migration pathways to the ground water,  by providing a
       mechanism reduce VOC and metals contamination, thereby providing a potential
       means to meet State groundwater standards within the aquifer affected by contaminants
       associated with the landfill.

Development of Alternatives

The remedial alternatives for the FS are typically assembled from applicable remedial technology options.  A
wide range of technologies and remedial options are reduced by evaluating them with respect to technical
implementability, effectiveness, and cost.  However,  U.S. EPA has found that the most practical way to deal
with the large variety and volume of waste found in municipal landfills is containment.  U.S. EPA's guidance
on presumptive remedies for CERCLA municipal landfill sites indicates that components of the source
containment may include:

•      landfill capping to reduce the amount of water entering and migrating out of the landfill;

•      extraction and treatment of contaminated ground water and leachate to control offsite migration

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•      construction of an active landfill gas collection and treatment system to prevent offsite migration

Based on site-specific conditions, the selection of response actions need only consider those components that
are necessary.  The lack of measureable leachate with the landfill indicates that a leachate collection
system is not necessary as a general component of the presumptive remedy.

Even though the majority of the landfill appears to be unsaturated, reconsolidation was considered in the
alternatives.  Investigations showed up to 2 feet of saturated waste at the base of the landfill in some
areas.  As noted above, it is difficult to estimate the volume of saturated waste with any reliability, but
U.S. EPA believes that at most, 19,000 out of a total of 300,000 cubic yards of waste in the entire landfill
are saturated.

In addition to source containment, the NCP reguires that a no-action alternative be considered for the site.
The no-action alternative serves primarily as a point of comparison for other alternatives.

The approach to develop the containment alternatives was to provide general source response actions that
address each medium of interest in order to satisfy the remedial action objectives:

Landfill Gas Response Actions

•      No action
•      Collection and treatment, if necessary,  of landfill gas to prevent migration

Groundwater Source Response Actions

•      No action
•      Installation of a low permeability cap to reduce infiltration
•      Removal of VOCs from the waste through landfill gas extraction
•      Excavation to remove saturated wastes

The landfill gas source response actions are closely related.  The installation of a low permeability cap
will minimize the amount of water entering and migrating out of the landfill. The cap will also enhance the
performance of the gas collection system by providing a seal over the landfill.  The seal should increase the
ability of the system to not only remove methane but also VOCs before they enter the ground water.  The
remedial alternatives developed combine the response actions for both the gas and groundwater source control.

Alternative Descriptions

A complete description of the various alternatives is provided in the Feasibility Study.  A brief narrative
description of each alternative is provided below.  Note that there is no discussion of  institutional
controls as part of any alternative.  This because institutional controls in the form of deed restrictions,
enforceable by the State of Wisconsin, are already in place at the TMSL. U.S. EPA has concluded that no
additional controls are necessary to prevent inappropriate use of the site.

Alternative 1:  No action

The no action alternative is developed to act as a baseline to compare against all other alternatives.  This
alternative would not include the current (interim) gas collection system or monitoring of the gas probe or
groundwater monitoring well network on and adjacent to the landfill.  This alternative will not meet the
landfill gas or groundwater source control remedial action objectives.

Alternative 2:  Continued Operation and Monitoring of Existing Landfill Gas Extraction System and Continued
Groundwater Monitoring

This alternative includes the operation of the existing landfill gas extraction system along the southern
perimeter of the landfill and continued landfill gas and groundwater monitoring. Because gas extraction would
be continued, there would be no change in risk to human health and the environment.  However, the existing

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gas collection system would not help to remove VOCs or methane from within the landfill wastes.  Thus, the
landfill gas source remedial action objective would not be fully addressed.  Furthermore, since methane is
still migrating beyond the boundaries of the landfill with the existing extraction system, this alternative
would not achieve compliance with Wis. Admin. Code Chs.  NR 504 and 506 (1996), Landfill Operational Criteria.
Additionally, no groundwater source containment would be implemented.  No capital costs are involved in this
alternative.

Alternative 3:  Installation of a Geomembrane Cap with Active Gas Extraction System

This alternative includes the installation of a multi-layered, single barrier cap consisting of a 6-inch
upper vegetative layer, a 30-inch rooting zone/drainage layer, and a 40-mil low density polyethylene  (LDPE)
geomembrane layer.  The basic benefit of the cap would be to reduce the amount of infiltration entering the
landfill and subseguent release of contaminants to the ground water.

In addition, an active interior gas control system will be installed to extract gas over the entire landfill.
The gas extraction system would include the current gas migration control system and  additional perimeter
and interior wells along the other boundaries of the landfill.  Long-term maintenance and monitoring of the
groundwater and landfill gas would be implemented upon completion of the actions and system startup.

This alternative sould meet both the landfill gas and groundwater source control objectives. However, this
alternative does not include the clay component for the low permeability cap, and would therefore not comply
Wis. Admin. Code Ch. NR 504(1996), Landfill Location, Perfomance, Design, and Construction Criteria. The
minimum design and construction criteria for final cover systems set forth in Wis. Admin. Code ° 504.07(1996)
are relevant and appropriate reguirements for designing and constructing a cap for the Tomah Municipal
Sanitary Landfill.  This is because the types of waste disposed of in the TMSL are similar to those found in
waste disposal facilities regulated under Wis. Admin. Code Ch NR 504 (1996).   A dual
barrier, low permeability cap consisting of a 2-foot clay layer underlying a geomembrane is specified in Wis.
Admin. Code ° NR 504.07(1996).  The clay layer is reguired to provide a back-up barrier system in the event
the membrane fails, either during construction or at some time in the future.

Alternative 4:  Installation of a Geomembrane and a GCL Cap with Active Gas Extraction System

This alternative provides the same benefits as Alternative 3, but will include the added back-up barrier
protection of a geosynthetic clay liner (GCL).  The GCL would be placed directly beneath the geomembrane.
The GCL component provides a substitute material for the clay layer component specified in Wis. Admin. Code °
NR 504.07  (1996) for final cover design.  By incorporating the GCL material below the geomembrane cap, this
cover system will provide an eguivalent performance to the cap design specified in the Wisconsin regulations.
The alternative would meet both the landfill gas and groundwater source control objectives.

Alternative 5:  Installation of a Geomembrane Cap and 2 Feet of Clay with Active Gas Extraction System

This alternative provides both the geomembrane layer and the 2-foot clay layer specified for final landfill
cover systems in Wis. Admin. Code ° NR 504.07 (1996).  The clay layer would meet the specifications set forth
in Wis. Admin. ° NR 504.06(2)(1996).   However, due to site design restrictions, the clay would be
discontinued along a line north of the existing gas extraction system.   A GCL material would be substituted
for the clay south of the existing gas system to reduce the encroachment on the adjacent residential
properties, reduce drainage problems, and eliminate the need to reconstruct the existing landfill gas
collection system.  The alternative should meet both the landfill gas and groundwater source control
objectives.

Alternative 6:  Reconsolidation of Saturated Waste, Installation Geomembrane cap with Active Gas Extraction
System

This alternative includes installation of a low permeability landfill cap and gas extraction system. As
described in Alternative 3, the landfill cap would be a multi-layered,  single barrier cover, consisting of a
upper vegetative layer, a rooting zone/drainage layer and a geomembrane.   The final cap design would be
modified by excavation of the maximum saturated area of waste found along the northern portion of the

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landfill.  Approximately 174,000 cubic yards of waste from the north central portion of the landfill could be
excavated and reconsolidated.  Reconsolidation options include moving excavated wastes to a more upland
(south side) of the landfill or backfilling the excavation with clean fill to water table and placing the
wastes on top (i.e., effectively raising waste above high water levels).   As with Alternative 3, this
alternative would meet both the landfill gas and groundwater source control objectives but would not comply
with Wis. Admin. Code Ch. NR 504 (1996), Landfill Location, Performance Design, and Construction Criteria.

Alternative 7:  Reconsolidation of Saturated Waste, Installation Geomembrane and GCLL Cap with Active Gas
Extraction System

This alternative includes all the components of Alternative 6 with the addition of the GCL layer below the
geomembrane.  This alternative would meet both the landfill gas and groundwater source control objectives.

Alternative 8:  Reconsolidation of Saturated Waste, Installation Geomembrane and Clay Cap with Active Gas
Extraction System

This alternative includes all the components of Alternative 6 with the additional of a 2-foot clay layer.
This alternative would meet both the landfill gas and groundwater source control objectives.

VIII.  Evaluation of Alternatives

Nine Evaluation Criteria

In the NCP, the U.S. EPA has established 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 Applicable or Relevant and
Appropriate Reguirements (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 as the basis of comparison.
These nine criteria are summarized below:

Threshold Criteria

The selected remedy must meet the following threshold criteria:

1.  Overall Protection of Human Health and the Environment Addresses whether a remedy
    provides adeguate protection and describes how risks are eliminated,  reduced or controlled
    through treatment, engineering controls or institutional controls.

2.  Compliance with Appliable or Relevant and Appropriate Reguirements (ARARs)
    addresses whether a remedy will attain applicable or relevant and appropriate reguirements
    under federal environmental laws and state environmental or facility siting laws or provide
    grounds for issuing a waiver.

Primary Balancing Criteria

The balancing criteria are used to compare the effectiveness of the remedies.

3.  Long-term Effectiveness and Permanence refers to the amount of risk to maintain reliable
    protection of human health and the environment over time once cleanup goals have been met.

4.  Reduction of Toxicity,  Mobility or Volume Through Treatment is the anticipated
    performance of treatment technologies that may be employed in a remedy to reduce the
    harmful effects of principal contaminants, their ability to move in the environment, and the
    amount of contamination present.

5.  Short-term Effectiveness refers to the speed with which the remedy achieves protection, as

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    well as the remedy's potential to create adverse impacts on human health and the
    environment during the construction and implementation period.

6.  Implementability is the technical and administrative feasibility of a remedy, including the
    availability of materials and services needed to implement the chosen solution.

7.  Cost addresses the estimated capital and operation and maintenance  (O&M) costs, evaluated
    as the present worth cost.  Present worth is the present value of the capital and future O&M
    costs of an alternative based on the time value of money.

Modifying Criteria

These criteria deal with support agency and community response to the alternatives.

8.  State Acceptance indicates whether, based on its review of the FS and the Proposed Plan,
    the support agency (in this case, the WDNR)  concurs with, opposes, or has no comment on
    the recommended alternative.

9.  Community Acceptance is assesed in the Record of Decision based upon a review of the
    public comments received on the FS report and the Proposed Plan.

Evaluation of the Remedial Alternatives

As part of the FS all the remedial alternatives are evaluated against the nine criteria.  Figure 4 contains a
summary of this analysis.

Threshold Criteria

The threshold criteria are CERCLA statutory reguirements that must be satisfied by any alternative in order
for it to be eligible for selection as a CERCLA remedy.  Alternatives that do not meet the threshold criteria
are not carried through a comparison with the other alternatives.

1.  Overall Protection of Human Health and the Environment

The no action alternative will not provide protection of human health and the environment. Alternative 2 will
provide only limited reduction of risk to human health and the environment by collecting landfill gas along
the southern perimeter of the landfill.  The remaining alternatives that include a landfill cap and active
gas extraction system provide the applicable components for a CERCLA presumptive remedy for source control at
the TMSL.  Risks to human health and the environment would be reduced due to the extraction and treatment of
landfill gases and reduction or elimination of source pathways for additional groundwater contamination.

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

ARARs for the alternatives considered are contained in Table 1 of the Feasibility Study for Source Control,
dated April 14, 1997, as amended by U.S. EPA's letter of July 15, 1997.  Note that, at this time, EPA cannot
say whether any of the alternatives considered will restore ground water outside the landfill to federal and
state drinking water standards.  But under section 121(d)(4) of CERCLA, 42 U.S.C. °9621(d)(4), U.S. EPA may
select a remedy that does not attain cleanup standards when the remedial action selected is only part of a
total remedial action that will attain such level or standard of control when completed.  That is the case
here.  Ground water conditions will be addressed in a second operable unit.

The no action alternative and Alternative 2 will not comply with the ARARs because they do not include the
multi-layer cap reguired under Wis. Admin. Code ° NR 504.06  (1996) for closed landfills.  In addition, for
Alternative 2, the existing gas extraction system does not achieve compliance with Wis. Admin. Code °° NR 504
and 506  (1996) because some gas is continuing to migrate off-site.  The cap proposed as part of Alternatives
3 and 6 does not provide the back-up component reguired by Wis. Admin. Code ° NR 504.07 (1996).   Alternatives
4, 5, 7, and 8 would meet the Wisconsin Administrative Code reguirements for closed landfills and would

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provide a landfill cap in conformance with Wis. Admin. Code ° NR 504.07  (1996).   Alternatives 4 and 7 would
meet the Wisconsin requirement for a clay capping layer by substituting a geosynthetic clay liner that has an
equivalent standard of performance, such that these alternatives qualify for a variance under Wis. Admin.
Code ° NR 500.08 (4) (1996) .

Primary Balancing Criteria

3.  Long-term Effectiveness and Permanence

Installation of a presumptive remedy cap and gas extraction system have been proven to be reliable long-term
containment technologies for municipal landfills.  Alternatives 4, 5, 7 and 8 provide additional long-term
effectiveness and permanence by including a back-up barrier to the geomembrane layer in the multi-layer cap.

Alternatives 6, 7, and 8 include reconsolidation of saturated waste which may provide an effective means to
remedy groundwater within the waste.  However, the majority of the landfill appears to be unsaturated.  U.S.
EPA estimates that only 19,000 out of the 300,000 cubic yards of waste estimated to be in the landfill are
saturated.  However,  seasonal fluctuations in the water table make it difficult to estimate the volume of
saturated wastes with any reliability.  In addition, as has been shown at other landfill sites, water table
elevations under the landfill may drop after installation of the cap, reducing the volume of saturated
wastes.  The combination of these factors makes it difficult to assess the contribution of saturated waste to
groundwater contamination and the benefits, if any, of reconsolidation.

4.  Reduction of Toxicity,  Mobility or Volume Through Treatment

The no action alternative will not reduce toxicity, mobility or volume of contamination.  The rest of the
alternatives include a gas collection/extraction system that will treat VOCs if the levels are such that
treatment is necessary to meet Wisconsin air standards.

5.  Short-term Effectiveness

Alternatives 3, 4, 5, 6, 7 and 8 would provide a remedy for off-site landfill gas migration by installation
of an interior active gas extraction system that would effectively reduce the health and saafety threat to
landowners adjacent to the landfill.  These alternatives would also result in relaatively little site
disturbance.  As a result,  they will reduce public exposure to air emissions, odor, noise and traffic.
Because no waste will be exposed, the installation of the landfill cap will not put workers or the public at
risk from exposure.

6.  Implementability

Required materials, services and equipment are available to implement each source control alternative.
Operation and maintenance of the existing landfill gas collection system have already been implemented.
Thus, Alternative 2 involves no construction and is the easiest to implement.  All the Alternatives except 1
and 2 involve placement of the multi-layer cap and would require care in construction to minimize potential
damage to the existing gas collection system.

7.  Cost

The costs for the alternatives (including both capital expenditures and future operating costs that have been
discounted at a 2 percent rate)  range from $1.4 million to $7.2 million.  The cost for each alternative is
presented in Figure 4.

Costs associated with Alternatives 6, 7, and 8 are high due to a number of factors, including: the amount of
unsaturated wastes that would need to be moved to get to the saturated wastes at the base of the fill, the
small area available for excavation activities, a phased excavation approach, waste handling activities,
uncertainty concerning the treatment of groundwater produced during excavation,  and potential
characterization of any portion of reconsolidated waste, contaminated soils, or contaminated ground water.
Costs of these alternatives are almost double that of their counterpart with no reconsolidation.

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Modifying Criteria

8.   Support Agency Acceptance

U.S. EPA is the lead agency for this site and the author of this ROD.  WDNR has been the support agency for
the RI/FS and has reviewed this ROD.  The State of Wisconsin has indicated a willingness to concur with this
decision.  A written confirmation is expected by September 30, 1997,  and will be added to the administrative
record upon receipt.

9.   Community Acceptance

A Proposed Plan was prepared and released to the public on August 5,  1997.  A 30-day public comment period
was conducted between August 7, 1997, and September 5, 1997.  A public meeting on the proposal was held on
August 18, 1997.  The public generally supports the proposed remedy.   The comments U.S. EPA received,
together with U.S. EPA's responses, are described in the Responsiveness Summary attached to this ROD.

Selected Alternative

U.S. EPA has determined that Alternative 4:  Installation of a low permeability geomembrane and a
geosynthetic clay liner (GCL) over the landfill and the operation of the active gas collection system is the
best remedy for source control at the TMSL.  Alternatives 4, 5, 7 and 8 fully meet all the NCP criteria.  The
only criterion that clearly revealed differences between the four acceptable alternatives was cost.  All
things being egual, U.S. EPA prefers to select the most cost-effective remedial alternative.  Alternative 4
while meeting all threshold, balancing, and modifying criteria was also the least costly of the four
acceptable alternatives.

The Remedial Action Objectives that the selected remedy must meet are described above in Section VII.  The
ARARs for the selected remedy are listed in Table 1 of the Feasibility Study for Source Control, dated April
14, 1997, as amended by U.S. EPA's letter of July 15, 1997. They include Wisconsin regulations concerning
landfill performance and design set forth in Wis. Admin. Code Chs. NR 504 and 506, and air standards set
forth in the Clean Air Act, 42 U.S.C.0 7401 et seg.,  and Wis. Admin.  Code Ch. NR 439 (1996).

It should be mentioned that Alternative 4 only addresses on-site source control at the landfill and that a
subseguent risk assessment, FS, proposed plan, and ROD will address off-site groundwater contamination.

IX.  Statutory Determinations

U.S. EPA and the State of Wisconsin believe the selected remedy will protect human health and the
environment; complies with ARARs, except for groundwater cleanup standards where a waiver is justified; is
cost-effective; and utilizes permanent solutions and alternative treatment technologies or resource recover
technologies to the maximum extent practicable.  The selected remedy will not satisfy the preference for
treatment as a principal element.  The size of the landfill and the fact that there are no on-site hot spots
that represent the major sources of  contamination preclude a remedy in which contaminants could be excavated
and treated effectively.

X.   State Concurrence

The State of Wisconsin has indicated a willingness to concur with this decision.  A written confirmation is
expected by September 30,  1997 and will be added to the administrative record upon receipt.
                          FIGURES

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                                  Table 1
                            Summary of Contaminants
                            Detected in Groundwater
Parameter
Volatile Organic Compounds
1,1-Dichloroethane
1,2-Dichloroethane
1,2-Dichloropropane
2-Hexanone
Acetone
Benzene
Carbon Disulfide
Chlorobenzene
Chloroethane
cis-1,2-dichloroethene
Ethylbenzene
2-Butanone  (MEK)
4-Methyl-2-pentanone  (MIBK)
Styrene
Toluene
1,2-Dichloroethene  (total)
trans-1,2-dichloroethene
Vinyl Chloride
Xylenes(total)
Semivolatile Organic Compounds
1,2-Dichlorobenzene
1,4-Dichlorobenzene
2,4-Dimethylphenol
2-Methylnaphthalene
2-Methylphenol  (o-cresol)
4-Chloro-3-methylphenol
4-Methylphenol  (p-cresol)
bis(2-chloroethyl)ether
bis(2-ethylhexyl)phthalate
Di-n-butyl phthalate
Diethyllphthalate
N-Ni tros odiphenylamine
Naphthalene
Phenol
Pesticides/TCDDs
Endrin
Gamma-Chlordane
Octachlorodibenzo-p-dioxin
2,4,5-TP  (Silvex)
Total
Analyses
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
Is
8
8
8
8
8
8
8
8
8
8
8
8
8
8
3
3
3
3
Positive
Detection
Detections Freguency
4
2
2
1
2
5
3
5
5
4
4
1
1
1
5
5
1
8
3

2
5
2
3
1
2
1
1
1
1
4
1
3
1
1
1
2
1
50,
25,
25,
12,
25,
62,
37,
62,
62,
50,
50,
12,
12,
12,
62,
62,
12,
100,
37,

25,
62,
25,
37,
12,
25,
12,
12,
12,
12,
50,
12,
37,
12,
33,
33,
66,
33,
. 0%
. 0%
. 0%
.5%
. 0%
.5%
.5%
.5%
.5%
. 0%
. 0%
.5%
.5%
.5%
.5%
.5%
.5%
. 0%
.5%

. 0%
.5%
. 0%
.5%
.5%
. 0%
.5%
.5%
.5%
.5%
. 0%
.5%
.5%
.5%
.3%
.3%
.7%
.3%
Minimum Maximum
Detected Detected
Value
1
3
5
86
2
5
0
1
1
1
1
280
32
3
1
1
1
3
59

1
2
5
2
18
8
1,100
7
27
1
4
2
5
54
0
0
63
1
Value
27
4
16
86
320
48
1
8
13
210
48
280
32
3
550
200
1
1,200
180

1
22
16
5
18
11
1,100
7
27
1
110
2
16
54
0
0
380
1
Units
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L

Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
pg/L
Ig/L

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                                    Table 1
                            Summary of Contaminants
                            Detected in Groundwater
Parameter
Inorganics
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium, Total
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
                                 Minimum   Maximum
  Total    Positive   Detection  Detected  Detected
Analyses  Detections  Freguency    Value     Value
                                                                                  Units
8
4
7
8
4
2
8
7
8
6
8
8
8
8
6
8
8
8
3
8
5
8
7
100.
50.
87.
100.
50.
25.
100.
87.
100.
75.
100.
100.
100.
100.
75.
100.
100.
100.
37.
100.
62.
100.
87.
, 0%
, 0%
,5%
, 0%
, 0%
, 0%
, 0%
,5%
, 0%
, 0%
, 0%
, 0%
, 0%
, 0%
, 0%
, 0%
, 0%
, 0%
,5%
, 0%
,5%
, 0%
,5%
515
2
4
117
2
8
4,960
2
6
14
825
3
1,020
811
0
8
1,360
3
11
6,390
3
1
52
186,000
53
112
1,730
11
12
150,000
320
103
232
353,000
158
114,000
19,000
3
143
114,000
24
22
251,000
21
233
439
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L
Ig/L

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                            APPENDIX A

                        RESPONSIVENESS SUMMARY

                      TOMAH MUNICIPAL SANITARY LANDFILL

                       TOMAH, MONROE COUNTY, WISCONSIN

PURPOSE

This responsiveness summary hass been prepared to meet the requirements of Sections 113(k)(2)(B)(iv) and
117(b)  of Comprehensive Environmental Response, Compensation, and Liability Act of 1986  (CERCLA), as amended
by the Superfund Amendments and Reauthorization Act of 1986  (SARA),  which requires the United States
Environmental Protection Aqency (U.S. EPA) to respond to each of the siqnificant comments, criticisms, and
new data submitted in written and oral presentations on a proposed plan for remedial action.  The
responsiveness summary provides a summary of citizen's comments and concerns identified and
received durinq the public comment period, and U.S. EPA's responses to those comments and concerns.  All
comments received by U.S. EPA durinq the public comment period were considered in the selection  of the
remedial alternative for the TMSL.  The responsiveness summary serves two purposes: it summarizes community
preferences and concerns reqardinq the remedial alternatives, and it shows members of the community how their
comments were incorporated into the decision-makinq process.

This document summarizes written and oral comments received durinq the public comment period of Auqust 7,
1997 to September 5, 1997.  The comments have been paraphrased to efficiently summarize them in  this
document.  The public meetinq was held at 6:00 p.m. on Auqust 18, 1997 at the Tomah City Hall Council
Chambers, Tomah, Wisconsin.  A full transcript of the public meetinq, as well as all site related documents,
are available for review at the Information Repository, located at the Tomah Public Library, 716 Superior
Avenue, Tomah, Wisconsin.  Comments and question were received durinq the public meetinq from several
residents and/or city officials.  Additionally, comments were mailed to U.S. EPA.

OVERVIEW

The proposed remedial alternative for the Tomah Municipal Sanitary Landfill was announced to the public just
prior to the beqinninq of the public comment period.  U.S. EPA proposed the installation of a low
permeability qeomembrane and a GCL over the landfill to reduce infiltration of water, with an active qas
collection system.

Community Comments

1.     Comment:   One commenter was concerned about the efficacy of the landfill cap to alleviate
       qroundwater contamination.

       Response:  Groundwater conditions at the site will be monitored for approximately a year
       after implementation of the cap.  At that time, or when the Aqencies determine that
       sufficient time has passed to assess the impact of the cap, an evaluation will be made as to
       the ability of the cap as well as the qas extraction system to reduce levels of
       contamination in qround water.  After this evaluation a risk assessment will be conducted
       to determine the risk posed by the levels of contamination in the qround water.  If needed,
       a second feasibility study will be conducted to look at remedial alternatives for the
       qround water.  A proposed plan and record of decision will be issued by the U.S. EPA
       proposinq a qroundwater clean-up alternative for the site.

2.     Comment:  This same commenter indicated that he had lived by the landfill property for
       almost fifty years and had seen landfillinq in the northeastern portion of the property.
       This portion had not previously been identified as an area that accepted wastes.

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       Response:  Based upon this comment and the lack of sufficient remedial investigation
       data from the area,  U.S.  EPA has determined that additional characterization is needed to
       determine if the landfill area extends into the northeastern portion of the property.   The
       U.S. EPA recommends  that  additional characterization be conducted in this area during
       the remedial design.  The design sampling will help determine if the recommended dual-
       barrier cap needs to be extended to cover the suspected area.  The extent of design
       sampling will be determined during review of the remedial design project planning documents.

3.      Comment:  This same  commenter, as well as other citizens who attended the public
       meeting, had concerns about surface water runoff from the new cap affecting their properties.

       Response:  As part of the  design and implementation of the new landfill cap, engineering
       controls will be put in place to collect surface run-off and prevent it from impacting
       properties adjacent  to the landfill.  U.S. EPA will reguire operation and maintenance of
       the cap so as to ensure the integrity of the cap and associated engineering controls.

4.      Comment:  Another commenter had guestions about the extent of sampling that occurred
       in the Sunnyvale subdivision.  In particular, why was more sampling not performed?

       Response:   Groundwater and landfill gas monitoring were conducted south of the landfill
       in the Sunnvale subdivision.  Groundwater monitoring involved private well sampling
       as well as the installation and sampling of a monitoring well.  Data collected from ground
       water indicated that the  potential effects of the landfill on ground water to the south of the
       site was unlikely.   This  coupled with the facts that ground water appeared to moving to
       the east/northeast away from the subdivision and that the City of Tomah had extended
       municipal water services  to the area provided reasonable assurances that the impact of the
       landfill on ground water  to the south of the landfill was minimal.  U.S. EPA then made
       the determination that an extended investigation of ground water south of the landfill was
       not warranted.  Migration of landfill gas south of the landfill into the subdivision was also
       monitored.  Sampling efforts concentrated on homes and yards adjacent to the landfill,
       since these homes appeared to be those that would affected first,  until the responsible
       parties installed an active gas extraction system to remove the gas from the landfill.  The
       in-home gas sampling was  eventually discontinued after the gas extraction system
       effectively reduced  the amount of gas migrating beyond the southern border of the
       landfill to safe levels.   This system will be expanded and monitoring will continue as part
       of the remedy for the landfill.  Capping will also increase the effectiveness of the
       extraction system.   As part of the presumptive remedy, soil sampling was not conducted
       since it is assumed  that  the site will be capped.  Some sediment and surface water
       sampling was conducted in Deer Creek, and the landfill was found not to have impacted the creek.


5.      Comment:  One commenter was concerned about the affects of the Superfund clean-up on
       property values near the  landfill.

       Response:  U.S. EPA believes that, in general, a Superfund clean-up will increase property
       values not only on the Superfund site itself, but in areas adjacent to the site.


6.      Comment:  One commenter wondered how long is there going to be a guarantee that the
       cap is going to stay effective without changes from the EPA?

       Response:  After construction of the landfill cap, an operation and maintenance plan will
       go into effect, the  purpose of which will be to ensure that the remedy continues to be
       effective in preventing infiltration into the landfill and removing gas.  Part of the
       operation and maintenance will be monitoring.  Should conditions arise resulting in
       guestions aabout the integrity of the remedy, U.S. EPA and the WDNR reserve the right to
       propose changes to address the new conditions and secure the integrity of the remedy.

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Comment of the City of Tomali

I.     Comment:  The City requested that remedial Alternative 3, installation of a low
       permeability geomembrane cap over the landfill to minimize infiltration, and an active
       gas extraction system, as described in the Tomah Municipal Sanitary Landfill (TMSL)
       Feasibility Study  (FS) for Source Control be selected in the Record of Decision.

       Response: The U.S. EPA and the WDNR have reviewed and analyzed all the remedial
       alternatives presented in the TMSL FS for Source Control and have selected remedial
       Alternative 4 as the most appropriate remedy based upon an analysis of U.S. EPA's nine
       health, technical, and cost criteria as described in the Proposed Plan issued on August 7,
       1997 and the attached Record of Decision.  Alternative 4 included installation of a low
       permeability geomembrane and a geosynthetic clay line over the landfill to minimize
       infiltration of water, and an active gas extraction system.  Alternative 3 failed to meet the
       threshold criteria for compliance with applicable or relevant and appropriate requirements
       because it did not include a dual-barrier system and thus did not meet state requirements.
       The dual-barrier landfill cap provides a sufficient back-up system should one of the
       barrier layers fail.

Comments of Union Camp Corporation

Union Camp Corporation, one the Potentially Responsible Parties at the Tomah Municipal Sanitary Landfill,
submitted comments on the remedy, on the risk analysis, and on the allocation of responsibility for paying
for the cleanup.  Union Camp included in its submission the detailed comments of one of its contractors, TRC
Environmental Solutions Inc., on the choice of the landfill cover and on the risk assessment.  Union Camp
also included copies of comments it submitted to EPA Headquarters concerning the Agency's Municipal Solid
Waste Settlement Proposal.

With respect to Union Camp's comments on allocation of costs for the cleanup and on the Municipal Solid Waste
Settlement Proposal, EPA declines to respond at this time.  The purpose of the public comment period on the
Proposed Plan for the Tomah Municipal Sanitary Landfill was to solicit comments on the remedy the Agency had
tentatively chosen for the site.  EPA will respond to Union Camp in due course concerning allocation and
liability issues.  But EPA believes it is important to keep technical questions concerning the adequacy of
the selected remedy and legal/policy questions concerning allocation of responsibility separate.

Union Camp, by contrast, seems to want to blend the analysis of the proposed remedy with arguments about
allocation of responsibility.  There is an implication in Union Camp's comments that remedial decisions could
differ depending on the number of viable PRPs at a site. Where a great many viable PRPs are present, one kind
of remedy might be chosen; for an identical site with only a few viable PRPs, a different, presumably
cheaper, remedy should be selected.  EPA rejects this way of proceeding as fundamentally inconsistent with
the National Contingency Plan.

1.     Comment:  Union Camp and TRC advance various arguments why selection of a dual
       barrier is unwarranted at the TMSL.  One argument is that the improvement in
       performance of a dual barrier cap over a single geomembrane is minimal, and not worth
       the additional $469,000 it would cost.  A second argument is that the choice of a dual
       barrier cap is a "policy" decision, not a technical/engineering decision.  Finally, Union
       Camp asserts that single membrane liners have been selected at other sites in Wisconsin,
       implying that the selection of dual membrane for the TMSL is an arbitrary decison

       Response: In 1996, the State of Wisconsin changed its regulations concerning the design
       of final cover systems for landfills to require two impermeable layers - a geomembrane
       and a clay layer - rather than one.  The new requirement purposely built in a certain
       amount of redundancy in order to provide protection if the geomembrane layer failed.
       Hence, arguments about the minimal incremental reduction provided by a second layer
       are beside the point.  Union Camp's technical arguments assume that the main
       geomembrane layer would never fail.  But what if it does?  The Wisconsin regulation was

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       not intended to reduce infiltration by another fraction of a percent,  but rather,  to provide
       basic impermeability if the geomembrane is breached.   Union Camp does  not explain
       how the system it favors offers any similar safeguard feature.   It nowhere cites any
       figures regarding the reliability of single membrane  covers.  Rather,  it terms a potential
       breach a "speculative" event and it implies that it should have to subsidize safeguards
       designed to address such things.  Suffice it to say that if a breach of the geomembrane
       were a sure thing,  U.S. EPA and WDNR would not select a remedy that included a
       geomembrane as a component.

       As for Union Camp's argument that reguiring dual barrier systems is a  policy decision,
       U.S. EPA agrees, but guestions why Union Camp finds fault with that.  Most, if not all,
       environmental reguirements - state and federal - are  imposed as a result of policy
       decisions.   We should be clear that by a "policy decision," we mean here that, in order to
       guard against the failure of landfill cover systems,  Wisonsin chose to impose by
       regulation a reguirement for a dual barrier system.  This was not a policy decision in the
       sense of a guidance document or policy paper that might or might not be followed.   Since
       1996, dual barriers have been legally reguired in Wisconsin.

       U.S. EPA is not aware of any instances since the 1996 regulations were adopted of
       WDNR's approving a single barrier cover for a landfill in Wisconsin.  There may be
       instances prior to 1996, but the adoption of new standards makes those cases irrelevant.

2.      Comment:  Union Camp is concerned that because of the prospect "that the extreme
       nature of the risk assessment may precipitate unwarranted public concern, " the current
       risk assessment should not be published as a final administrative record document.

       Response: U.S. EPA used the current risk assessment in selecting the source control
       remedy.  It was therefore both proper and necessary for U.S. EPA to include the risk
       assessment in the administrative record.  EPA made it available for public review
       together with the rest of the administrative record at the Tomah Public Library.  To date,
       EPA has received no comments expressing unwarranted public concern about the risk assessment.

       EPA disagrees with Union Camp that the risk assesment was extreme in nature.  U.S.
       EPA's contractor used standard U.S. EPA guidance documents and standard policy in
       developing rasonably conservative assumptions.  U.S.  EPA and the WDNR  reviewed
       and approved it.  Of course, the risk assessment may be superseded by  further analysis.
       But that is no reason to suppress the current risk assessment.

3.      Comment:  TRC states that in the risk assessment "the exposure scenario is not an
       appropriate representation of potential current risks, as the concentrations of constituents
       of concern (COCs)  are from a well located immediately downgradient and adjacent to the
       landfill boundary and are not representative of current exposure point concentrations".

       Response: Since the monitoring well network used to characterize impact to local
       groundwater conditions in the vicinity of the landfill contains only eight wells,  a
       reasonable but conservative approach to assessing potential impacts to human health must
       take into account the possibility that parent chemicals and their products of degradation
       may exist at concentrations that are higher than what were observed.  Ideally, the best
       way to provide a conservative estimate of a potential exposure is to provide the 95%
       upper confidence limit  (UCL) of the mean concentration; however, this  approach is a
       viable option only with a sample size large enough to provide a good estimate of the
       mean.  This is suggested to be 10 samples at a miniumum, preferably twenty or more (EPA
       1992).  In cases where the sample populations are small or where the data exhibits
       considerable variability, guidance suggests that the  highest measured  or modeled
       concentrations be used as the exposure concentrations.  Since only eight monitoring wells
       were available to characterize groundwater conditions, the highest values detected were
       used in the risk assessment, in accordance with guidance.

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4.      Comment:   TRC states that in the risk assessment "the future risk scenario cannot be
       completed until there is a determination regarding institutional controls, which could or
       will be imposed,  regarding future well drilling in the area."

       Response: At the time the risk assessment was issued, institutional controls were not in
       place,  and since the option still existed for not implementing this action, a reasonably
       conservative position of continuity with current conditions was taken.   Due to the
       uncertainties associated with assessing future scenarios under these conditions,  this
       position is still believed to be the most realistic and protective of human health since it
       covers what could occur in the event that no action is implemented and other conditions
       are allowed to remain the unchanged.  In summary, a re-issue of the risk assessment
       based on alternative "future" scenarios is not warranted.

5.      Comment:   TRC states that in the risk assessment "the arithmetic mean is reported as 279
       mg/L on page 2-18,  when it should read 279 ug/L".

       Response: Page 2-18 of the text does state that the mean concentration for vinyl chloride
       is reported in mg/L, when in reality, the units should have been reported as ug/L.  Mean
       values were discussed in the uncertainty section and were not used for assessing potential
       risks,  therefore this text error has no bearing on the calculations.  As shown in the risk
       assessment tables,  the highest downgradient concentration for vinyl chloride is 1200 ug/L.


6.      Comment:   TRC states that in the risk assessment "it is unclear how the 'volatilization
       factor' was used and how the dimensions of the risk calculation balance."

       Response: The volatilization factor is a unitless number set at a default value of "0.0005
       x 1000 L/m3" ("0.5" as presented in the assumptions).  This default value is an integral
       part of eguations 1 and 2 presented in RAGS Part B (EPA 1991) and is based on the
       relationship between the concetration of a contaminant in househould water and the
       average concetration of the volatilized contaminant in air.  In the derivation of this
       number, all uses of household water were considered and a default air exchange rate and
       dwelling size was assumed.  For more information on the volatilization factor used in
       these eguations,  RAGS direct the reader to the paper by J.B. Andelman (1990).

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                          U.S. EPA ADMINISTRATIVE RECORD
                                 REMEDIAL ACTION
                             TOMAH SANITARY LANDFILL
                                 TOMAH, WISCONSIN
                                     ORIGINAL
                                     08/30/95
                                                                                             AR
DOC#  DATE

   1  12/16/83

   2  06/27/84



   3  12/05/84



   4  03/26/92
AUTHOR

Eigenbrodt, V. MDNR

Nolan, C., Ecology
and Environment,
Inc.

Nolan, C., Ecology
and Environment,
Inc.

Ecology and
Environment, Inc.
   5  09/00/93  U.S. EPA/OSWER
   6  09/00/93  U.S. EPA
   7  03/10/94  Dames & Moore
   8  03/10/94  Dames & Moore
   9  06/18/94

  10  07/13/94
RECIPIENT

U.S. EPA

U.S. EPA



File



U.S. EPA


U.S. EPA
                      U.S. EPA
Dames & Moore

Trainer, D. and
Steiner, J., Dames &
Moore
                      U.S. EPA
                      U.S. EPA
                      U.S. EPA
TITLE/DESCRIPTION

Preliminary Assessment

Site Inspection Report
PAGES

     5

    14
Memorandum re: June 19, 1984 Site Inspection   3
Letter Report                                113
Quick Reference Fact Sheet: "Presumptive       8
Remedies: Policy and Procedures"  (OSWER
Directive 9355.0-47FS; EPA 540-F-93
047; PB 93-963345)

Quick Reference Fact Sheet:  "Presumptive     14
Remedy for CERCLA Municipal Landfill Sites"
(OSWER Directive 9355.0-49FS; EPA
540-F-93-035; PB 93-963339)

Work Plan (DRAFT): Volume 1 of 2  (Text and   265
Attachments A-B)

Work Plan (DRAFT): Volume 2 of 2  (Attachments342
C-E)
                                          Work Plan: Addendum I
                                                                                        154
Mankowski, M.,  U.S  Letter re: D&M's Responses to U.S. EPA's       9
EPA                 Quality Assurance Section Comments to
                    Addendum I of the Work Plan
  11  02/21/95  Dames & Moore
  12  02/21/95  Dames & Moore
                      U.S. EPA
                      U.S. EPA
                    Remedial Investigation Report  (DRAFT): Volumel46
                    1 of 2  (Text)

                    Remedial Investigation Report  (DRAFT): Volume770
                    2 of 2  (Appendices A-F)

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                                 U.S. ENVIRONMENTAL PROTECTION AGENCY
                                            REMEDIAL ACTION
No.    DATE      AUTHOR

 1    06/13/95  Dames & Moore
     06/14/95   Trainer, D.,
                Dames & Moore
     07/13/95   Mankowski, M.,
                U.S. EPA
4   12/20/95
5   04/00/96
Trainer, D. ,
Dames & Moore
Dames & Moore
                                         ADMINISTRATIVE RECORD
                                                  FOR
                                     TOMAH SANITARY LANDFILL SITE
                                    TOMAH, MONROE COUNTY, WISCONSIN

                                                UPDATE #1
                                              JULY 25, 1997
                                      RECIPIENT
                      U.S. EPA
                      Mankowski, M.,
                      U.S. EPA
                      Patterson, K.,
                      City of Tomah
Mankowski, M.,
U.S. EPA
                      U.S. EPA
TITLE/DESCRIPTION

Work Plan for Phase II
of the Remedial Investi-
gation/Feasibility Study
(RI/FS) at the Tomah
Municipal Sanitary
Landfill Site

Letter:  D&M's Responses
to U.S. EPA Comments on
Phase I Draft RI Report
and the Phase II Work Plan

Letter re: U.S. EPA/WDNR
Conditional Approval of
the Phase II RI Work Plan
for the Tomah Municipal
Landfill Site w/Comments

Letter: D&M's Responses
to Conditional Approval
of the RI Phase II Work
Plan

LFG Migration Control
Project Report for the
Tomah Landfill Site
                                                                                            PAGES

                                                                                              242
                                                                         79
24
                                                                                               110

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    04/03/96
7   04/24/96
8  06/12/96
9  06/13/96
          Kuhlman,  W.;
          Boardman, Suhr,
          Curry & Field

          Zippay, N.  and
          M.  Mankowski,
          U.S.  EPA
          Ch2M Hill
          Mankowski,  M.
          U.S.  EPA
10
07/15/96  Dames & Moore
11
07/15/96  Dames & Moore
Mankowski, M.
and N. Zippay,
U.S. EPA

Kuhlman,  W.;
Boardman, Suhr,
Curry & Field
                                U.S. EPA
Patterson, K.,
City of Tomah
                                      U.S. EPA
                                      U.S. EPA
Letter re:  Outline of
Measures Concerning the
Methane Issue

Letter re:  U.S. EPA
Approval of Proposed
Short Term Measures as
Outlined in the Design
Specifications

Final Risk Assessment
for the Tomah Municipal
Sanitary Landfill Site

Letter re: U.S. EPA/WDNR
Conditional Approval of
the Draft Final RI Report
and the Responses to U.S.
EPA Comments on the Draft
Final RI Report

Remedial Investigation
Report for Source
Control: Volume I (Text,
Tables and Figures)
[FINAL]

Remedial Investigation
Report for Source
Control: Volume II
(Appendices A-H)  [FINAL]
                                                                                                         177
                                                                          10
                                                                                                              284
                                                                                                             1433

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12   09/27/96  Dames & Moore
 U.S. EPA
                      Response to U.S. EPA
                      and WDNR Comments and
                      Revised Future Activities
                      Plan for the RI/FS of
                      Groundwater and Source
                      Control at the Tomah
                      Municipal Sanitary
                      Landfill Site
                                                                          36
13  10/28/96  Mankowski,  M.,
              U.S.  EPA
Patterson, K.,
City of Tomah
Letter re: U.S. EPA/
WDNR Discussion and
Comments Concerning the
Remaining Issues on the
Response to U.S. EPA/WDNR
Comments and Revised
Future Activities Plan
14 04/14/97  Dames & Moore
15 07/15/97  Mankowski,  M.,
             U.S.  EPA
U.S. EPA
Patterson, K.,
City of Tomah;
et al.
Feasibility Study for
Source Control: Final
(Revised) Draft Report

Letter re: U.S. EPA/WSNR
Approval w/Modifications
of the Feasibility Study
for Source Control, Final
(Revised) Draft Report
 w/Attachments
                                                                         120
                                                                          16

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                              U.S. ENVIRONMENTAL PROTECTION AGENCY
                                        REMEDIAL ACTION

                                      ADMINISTRATIVE RECORD
                                               FOR
                             TOMAH MUNICIPAL SANITARY LANDFILL SITE
                                        TOMAH, WISCONSIN

                                            UPDATE #2
                                        SEPTEMBER 12, 1997
NO.    DATE      AUTHOR

 1    08/18/97  Southwest

                Reporters,
                Inc.
                                      RECIPIENT
                       U.S. EPA
                     TITLE/DESCRIPTION

                      Transcript of Procee-

                      dings: August 18, 1997
                      U.S. EPA Public Meeting
                      re:  the Tomah Armory
                      Landfill and Tomah
                      Municipal Sanitary
                      Landfill Sites
                                                                        PAGES

                                                                          102
2   09/04/97   Johnson, W.,
               City of
               Tomah
                       Bill, B.,
                       U.S. EPA
                      Letter re: City of
                      Tomah's Comments on the
                      Proposed Plan for the
                      Tomah Municipal Sanitary
                      Landfill Site
3  09/04/97
Marshall, D.,
Union Camp
Corporation
Bill, B.,
U.S. EPA
Letter re: Union Camp's
Comments on the Proposed
Plan for the Tomah Muni-
cipal Sanitary Landfill
Site
                                                                          31
4  09/05/97
Tomah
Residents
                       U.S. EPA
                      Three Public Comment
                      Sheets re: Citizens'
                      Comments on the Proposed
                      Plan for the Tomah Muni-
                      cipal Sanitary Landfill
                      Site (PORTIONS OF THIS
                      DOCUMENT HAVE BEEN
                      REDACTED)

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