EPA/ROD/R05-89/109
                                    1989
EPA Superfund
     Record of Decision:
     WAUSAU GROUND WATER CONTAMINATION
     EPA ID: WID980993521
     OU02
     WAUSAU, WI
     09/29/1989

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     * CITY OF WAUSAU                      * WAUSAU ENERGY COMPANY
     * MARATHON ELECTRIC  COMPANY          * AMOCO OIL CORPORATION
     * WAUSAU CHEMICAL  COMPANY

SEVERAL NEGOTIATION MEETINGS WERE  HELD TO DISCUSS TECHNICAL AND LEGAL ISSUES OF A  CONSENT  DECREE FOR THE
SITE.  HOWEVER, NEGOTIATIONS WERE  UNSUCCESSFUL,  AND THE PRPS DECLINED TO PARTICIPATE  IN  THE  RI/FS.  THE US EPA
THEN CONTRACTED WITH WARZYN ENGINEERING,  INC.  IN JULY 1987 TO CONDUCT THE RI/FS.

ALTHOUGH THE PRPS FAILED  TO REACH  AN AGREEMENT WITH US EPA, THEY HAVE MAINTAINED CONSIDERABLE INVOLVEMENT IN
US EPA'S STUDY.  TWO OF THE FIVE PRPS CONDUCTED AN INVESTIGATION OF THE WEST WELL  FIELD  AND  ALL HAVE
REQUESTED SPLIT SAMPLES AND/OR RESULTS OF DATA COLLECTED.  IN ADDITION, TWO OF THE PRPS, THE CITY OF WAUSAU
AND MARATHON ELECTRIC,  HAVE ENTERED INTO A CONSENT DECREE TO PERFORM THE OPERABLE  UNIT REMEDIAL
DESIGN/REMEDIAL ACTION  (RD/RA).

IN NOVEMBER, 1987,  (AS  AMENDED APRIL 1988)  US  EPA FILED SUIT  FOR RECOVERY OF PAST COSTS SPENT ON US EPA'S
EMERGENCY RESPONSE ACTIONS.  A SETTLEMENT WAS  REACHED BETWEEN THREE OF THE FOUR DEFENDANT  PRPS (MARATHON
ELECTRIC, THE CITY OF WAUSAU,  AND  WAUSAU CHEMICAL) FOR APPROXIMATELY 85% OF PAST COSTS.  A CONSENT DECREE WAS
ENTERED IN FEDERAL DISTRICT COURT  JULY 18,  1989.  A SECOND CONSENT DECREE WITH WAUSAU ENERGY IS EXPECTED TO
BE LODGED WITH THE COURT  IN THE NEAR FUTURE.

NEGOTIATIONS WITH THE PRPS  FOR THE FINAL RD/RA HAVE BEEN POSTPONED AT THE REQUEST  OF  THE PRP GROUP.   THIS IS
BASED ON THE FACT THAT  TWO  OF  THE  PRPS ARE CURRENTLY INVOLVED IN THE IMPLEMENTATION OF THE OPERABLE UNIT
RD/RA BASED ON AN AGREEMENT WITH US EPA TO PERFORM THE OPERABLE UNIT, AND TO ALLOW THE FINAL REMEDY PRP GROUP
TO ORGANIZE.  SPECIAL NOTICE LETTERS WILL BE SENT FOLLOWING ROD SIGNATURE TO THE FIVE PRPS LISTED ABOVE.
NEGOTIATIONS WILL PROCEED ACCORDING TO US EPA'S GENERAL GUIDANCE AND POLICIES.

#CR
III.  COMMUNITY RELATIONS

AN RI/FS "KICK-OFF" PUBLIC  MEETING WAS HELD IN SEPTEMBER 1987, TO INFORM THE LOCAL RESIDENTS OF THE SUPERFUND
PROCESS AND THE WORK TO BE  CONDUCTED.  ISSUES  RAISED DURING THE MEETING, ATTENDED  MOSTLY BY  PRP   AGENTS AND
CITY OFFICIALS, INCLUDED  THE COST  OF THE RI/FS,  THE ESTIMATED TIME TO COMPLETE THE STUDY,  AND THE NUMBER OF
PREVIOUS STUDIES PERFORMED  FOR THE SITE.

A SECOND PUBLIC MEETING WAS HELD IN OCTOBER 1988 TO DISCUSS THE FINDINGS OF THE PHASE I  RI AND PFS,  AND TO
PRESENT THE PROPOSED PLAN FOR  AN OPERABLE UNIT AT THE SITE.  TWO FORMAL PUBLIC COMMENTS  WERE RECEIVED DURING
THE PUBLIC MEETING AND  WRITTEN COMMENTS WERE ALSO RECEIVED DURING THE PUBLIC COMMENT  PERIOD.   ALL COMMENTS
RECEIVED DURING THE COMMENT PERIOD AND US EPA'S RESPONSES WERE INCLUDED IN THE RESPONSIVENESS SUMMARY FOR THE
INTERIM ROD.

INFORMATION REPOSITORIES  HAVE  BEEN ESTABLISHED AT WAUSAU CITY HALL, 407 GRANT STREET, AND  THE MARATHON COUNTY
PUBLIC LIBRARY, 400 FIRST STREET,  WAUSAU, WISCONSIN.  IN ACCORDANCE WITH SECTION 113(K)(1) OF CERCLA,  THE
ADMINISTRATIVE RECORD FOR THE  SITE IS AVAILABLE TO THE PUBLIC AT THESE LOCATIONS.   THE DRAFT FS AND THE
PROPOSED PLAN WERE AVAILABLE FOR PUBLIC REVIEW AND COMMENT FROM AUGUST 14, 1989 TO SEPTEMBER 12,  1989.

A PUBLIC MEETING TO DISCUSS THE FINDINGS OF THE RI/FS AND TO PRESENT US EPA'S PREFERRED  ALTERNATIVE FOR THE
FINAL REMEDY WAS HELD AUGUST 22, 1989 IN THE WAUSAU CITY HALL.  FOUR FORMAL PUBLIC COMMENTS  WERE   RECEIVED
DURING THE PUBLIC MEETING.  ALL OF THE COMMENTS WERE IN SUPPORT OF US EPA'S PREFERRED ALTERNATIVE.   ONE
ADDITIONAL COMMENT WAS  RECEIVED DURING THE REMAINDER OF THE PUBLIC COMMENT PERIOD.  ALL  COMMENTS WILL BE
ADDRESSED IN THE RESPONSIVENESS SUMMARY OF THIS DOCUMENT.  THE PROVISIONS OF SECTIONS 113(K)(2)(I-V)  AND 117
OF CERCLA RELATING TO COMMUNITY RELATIONS HAVE BEEN SATISFIED.

#SRR
IV.  SCOPE AND ROLE OF  RESPONSE ACTION

THE SCOPE OF THIS RESPONSE  ACTION  IS TO ADDRESS THE REMAINING CONCERNS  (PRINCIPAL  THREATS) AT THE SITE.  AS
DISCUSSED, A PREVIOUS OPERABLE UNIT ACTION AT  THE SITE ADDRESSES THE CONTAMINANT PLUME ORIGINATING FROM THE

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FORMER LANDFILL/MARATHON ELECTRIC  SOURCE AREA WHICH AFFECTS CW6.

DURING DEVELOPMENT OF THE  FINAL  FS,  IT  WAS  DETERMINED THAT THE DEEP PLUME WHICH ORIGINATES FROM THE  FORMER
CITY LANDFILL AREA AND MIGRATES  UNDER THE RIVER TO CW3 WOULD BEST BE ADDRESSED BY PURGING GROUNDWATER AT
THE SAME LOCATION AS THE INTERIM REMEDY EXTRACTION SYSTEM.  THEREFORE, IT WAS DETERMINED THAT AN  INCREASE  IN
THE MINIMUM PUMPING RATES  CALLED FOR IN THE EXTRACTION SYSTEM AND MODIFICATIONS TO THE MONITORING PLAN
WOULD PROVIDE THE MOST EFFECTIVE REMEDIATION FOR THIS CONTAMINANT PLUME. IT WAS ALSO ASSUMED THAT THE CITY
WOULD CONTINUE TO USE CW3  AS A SUPPLY WELL  AND THUS CONTINUE TO REMOVE CONTAMINANTS FROM THE MOST EASTERN
PORTION OF THE PLUME.

THE SELECTED ALTERNATIVE FOR THE FINAL  PHASE OF THE WAUSAU PROJECT, IN CONJUNCTION WITH THE OPERABLE UNIT,
WILL ADDRESS ALL CONCERNS  AT THE SITE.   REMAINING CONCERNS INCLUDE THREE SOURCE AREAS AND THE SHALLOW EAST
SIDE GROUNDWATER CONTAMINANT PLUME ORIGINATING FROM THE WAUSAU CHEMICAL SOURCE AREA.  THE IDENTIFIED SOURCE
AREAS INCLUDE; FORMER CITY LANDFILL/MARATHON ELECTRIC PROPERTY, WAUSAU CHEMICAL PROPERTY, AND   WAUSAU  ENERGY
PROPERTY.

THE FINAL REMEDY FOR THE SITE  IS INTENDED TO ADDRESS THE ENTIRE SITE WITH REGARDS TO THE PRINCIPAL THREATS TO
HUMAN HEALTH AND THE ENVIRONMENT POSED  BY THE SITE AS INDICATED IN THE RISK ASSESSMENT FOR THE SITE.  THE
FINDINGS OF THE RISK ASSESSMENT  ARE INCLUDED IN THE RI REPORT AND ARE SUMMARIZED IN A LATER SECTION  OF  THIS
DOCUMENT.

#css
V.  CURRENT SITE STATUS AND SITE CHARACTERISTICS

A.  CURRENT SITE STATUS

THE RI/FS WAS COMPLETED IN AUGUST  1989  FOR  US EPA BY ITS CONTRACTOR, WARZYN ENGINEERING, INC.  THE RI
ENTAILED TWO PHASES OF FIELD SAMPLING EVENTS.  PHASE I OF THE RI FIELD WORK WAS CONDUCTED FROM AUGUST THROUGH
JANUARY 1987, RESULTS OF WHICH ARE SUMMARIZED IN THE APRIL 1988 TECHNICAL MEMORANDUM.  PHASE II OF THE  RI
FIELD WORK WAS CONDUCTED FROM  JUNE TO SEPTEMBER 1988.  RESULTS OF BOTH PHASES OF WORK ARE INCLUDED IN THE  RI
REPORT FOR THE SITE.

THE FS DETAILS THE DEVELOPMENT AND EVALUATION OF AN ARRAY OF REMEDIAL ACTION ALTERNATIVES TO ADDRESS THE
ENTIRE WAUSAU GROUNDWATER  CONTAMINATION SITE AND SOURCES IMPACTING IT.

B.  SITE CHARACTERISTICS

      1. HYDROGEOLOGY

THE CITY PRODUCTION WELLS  ARE  LOCATED WITHIN GLACIAL OUTWASH AND ALLUVIAL SEDIMENTS UNDERLYING AND ADJACENT
TO THE WISCONSIN RIVER.  THE AQUIFER IS LOCATED WITHIN A BEDROCK VALLEY WHICH IS UNDERLAIN AND LATERALLY
BOUNDED BY RELATIVELY IMPERMEABLE  IGNEOUS BEDROCK. GROUNDWATER FLOW WITHIN THE UNCONFINED GLACIAL AQUIFER  HAS
BEEN DRASTICALLY CHANGED BY THE  INSTALLATION OF THE PRODUCTION WELLS.  UNDER NON-PUMPING CONDITIONS,
GROUNDWATER FLOWS TOWARD THE WISCONSIN  RIVER AND ITS TRIBUTARY (BOS CREEK).  GROUNDWATER NATURALLY DISCHARGES
AT THE SURFACE WATER BODIES.

HOWEVER, UNDER PUMPAGE CONDITIONS,  GROUNDWATER FLOWS TOWARD THE PRODUCTION WELLS.  THE NATURAL GROUNDWATER
FLOW DIRECTIONS ARE FREQUENTLY REVERSED DUE TO CITY WELL PUMPING WHICH INDUCES RECHARGE OF SURFACE WATER INTO
THE AQUIFER.  THE HORIZONTAL FLOW  IN THE VICINITY OF THE WELL FIELD IS INDICATED BY THE POTENTIOMETRIC
CONTOURS SHOWN IN FIGURE 4.

THE POTENTIOMETRIC SURFACE MAP ALSO INDICATES THAT THE CONE OF DEPRESSION FROM THE EAST WELL FIELD APPEARS TO
AFFECT GROUNDWATER FLOW BELOW  AND  TO THE WEST OF THE WISCONSIN RIVER.  MONITORING WELL NESTS LOCATED AT
MARATHON ELECTRIC INDICATE VERY  SLIGHT  DOWNWARD GRADIENTS ADJACENT TO THE WISCONSIN RIVER.  BELOW THE
WISCONSIN RIVER, THE EAST  WELL FIELD PRODUCTION WELL PUMPAGE HAS INDUCED SURFACE WATER RECHARGE OF THE
AQUIFER, CAUSING FLOW DOWNWARD THROUGH  THE  RIVER BED AND TOWARD CW3.

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AQUIFER HYDRAULIC CONDUCTIVITY  TESTS  PERFORMED DURING THE PHASE I RI INVESTIGATION  INDICATED  HYDRAULIC
CONDUCTIVITY VALUES RANGING FROM 1.7  X (10-4)  CM/SEC TO 8.1 X  (10-2) CM/SEC.  THE OVERALL AVERAGE  HYDRAULIC
CONDUCTIVITY OF THE OUTWASH AQUIFER IS APPROXIMATELY 2.2 X (10-2) CM/SEC, BASED ON  TEST  DATA  AT  MONITORING
WELLS.

      2. CHEMICAL CHARACTERISTICS

         A. GROUNDWATER  QUALITY

GROUNDWATER QUALITY SAMPLING CONDUCTED DURING BOTH PHASES OF THE FIELD INVESTIGATION HAS IDENTIFIED A
VERTICAL AND LATERAL DISTRIBUTION OF  TOTAL CHLORINATED ETHENES WHICH SUGGESTS THAT  A MINIMUM  OF  THREE SOURCES
ARE AFFECTING THE CITY WELL FIELD.   THE ESTIMATED AREAL DISTRIBUTION OF TOTAL CHLORINATED ETHENES  IS SHOWN IN
FIGURE 5.  THE DISTRIBUTION IS  BASED  ON A COMBINATION OF DATA OBTAINED FROM LABORATORY VOC ANALYSES OF ROUNDS
1, 2, AND 3 GROUNDWATER  SAMPLES (OCTOBER 1987 TO SEPTEMBER 1988), AND FIELD LABORATORY ANALYSES  OF
GROUNDWATER SAMPLES COLLECTED DURING DRILLING (OCTOBER AND NOVEMBER 1987).

WEST SIDE MONITORING WELLS  DELINEATE  A DEEP (GREATER THAN 100 FOOT) NORTH-SOUTH TRENDING TCE  PLUME.   BASED ON
THE VERTICAL DISTRIBUTION OF TCE THROUGHOUT THE AQUIFER IN THE VICINITY OF THE OLD  CITY  LANDFILL AND THE
PRESENCE OF TCE IN THE UNSATURATED ZONE IN THIS AREA, A SOURCE APPEARS TO BE LOCATED WITHIN THE  NORTHERN
PORTION OF THE FORMER CITY  LANDFILL/MARATHON ELECTRIC PROPERTY.  THE PLUME APPEARS  TO HAVE MIGRATED
NORTHWARD, UNDER INFLUENCE  OF PUMPAGE FROM CW6.   THE HIGHEST TCE CONCENTRATION  (4200 UG/L) IN THE  PLUME WAS
DETECTED APPROXIMATELY 550  FEET SOUTH OF CW6.

TCE WAS ALSO OBSERVED IN THE SHALLOW AQUIFER BETWEEN BOS CREEK AND CW6. THIS PLUME  IS SHOWN ON FIGURE 5 BY
THE LIGHTLY SHADED CONTOURS BETWEEN BOS CREEK AND CW6.  THE SHALLOW AQUIFER TCE CONTAMINATION APPEARS TO
RESULT FROM THE INDUCED  INFILTRATION  OF SURFACE WATER FROM BOS CREEK, WHICH HAS BEEN CONTAMINATED  BY THE
DISCHARGE FROM CW6.  THE INDUCED SURFACE WATER RECHARGE OF THE AQUIFER IS EVIDENT FROM THE DOWNWARD VERTICAL
GRADIENTS AT MONITORING  WELL NESTS IN THAT AREA.  BASED ON LABORATORY ANALYSES OF SAMPLES COLLECTED DURING
THE RI FIELD WORK, TCE CONCENTRATIONS ADJACENT TO THE CW6 DISCHARGE WERE ABOVE 100  UG/L.  TCE CONCENTRATIONS
IN THE PONDED AREA DOWNSTREAM WERE APPROXIMATELY 70 UG/L. TCE WAS NOT DETECTED IN SURFACE WATER  SAMPLES
COLLECTED UPSTREAM OF THE CW6 DISCHARGE,  NOR WAS IT DETECTED AT THE POINT OF DISCHARGE OF BOS CREEK TO THE
WISCONSIN RIVER.

THE DISTRIBUTION OF TCE  IN  MONITORING WELLS LOCATED BETWEEN THE WISCONSIN RIVER AND CW3  SUGGEST  EASTWARD
MIGRATION OF A DEEP TCE  PLUME BELOW THE WISCONSIN RIVER ALSO FROM THE VICINITY OF THE FORMER  CITY  LANDFILL
(REFER TO FIGURE 5).  TCE APPEARS TO  BE VERTICALLY DISTRIBUTED THROUGHOUT THE AQUIFER IN THE  VICINITY OF THE
OLD CITY LANDFILL.  SLIGHT  VERTICAL DOWNWARD GRADIENTS WERE OBSERVED IN MONITORING  WELLS IN THE  AREA.  THE
HIGHEST CONCENTRATIONS OF TCE WERE DETECTED AT A DEPTH OF APPROXIMATELY 115 FEET.   AFTER MOVING  INTO THE
DEEPER PORTION OF THE AQUIFER,  A PORTION OF THE PLUME APPEARS TO MIGRATE EASTWARD UNDER  THE INFLUENCE OF
PUMPAGE FROM CW3  (REFER  TO  FIGURE 4).

EAST SIDE MONITORING WELLS  INDICATE THREE PLUMES WITHIN THE EAST WELL FIELD AREA, ONE FROM THE WEST SIDE
ORIGINATING FROM THE FORMER CITY LANDFILL/MARATHON ELECTRIC PROPERTY (DISCUSSED ABOVE) AND TWO ORIGINATING
SOUTHWEST OF CW3.  THESE TWO PLUMES ARE RESTRICTED TO THE SHALLOW PORTION OF THE AQUIFER (UPPER  40 FEET),  AND
CONSIST OF PRIMARILY PCE, TCE,  AND DCE.  BOTH OF THESE PLUMES HAVE RESULTED FROM RELEASES OF  PCE FROM THE
WAUSAU CHEMICAL FACILITY.

A LARGE WIDELY DISPERSED VOC PLUME EXTENDING EASTWARD FROM THE WAUSAU CHEMICAL PROPERTY  WAS IDENTIFIED DURING
THE THREE SAMPLING ROUNDS.   THE HIGHEST CONCENTRATIONS OF VOCS IN THIS PLUME WERE DETECTED IN THE    VICINITY
OF THE WAUSAU CHEMICAL STORAGE  AREA BEHIND THE SOUTHERN PART OF THE BUILDING.

A SECOND PLUME WAS DETECTED NORTH OF  THE WAUSAU CHEMICAL FACILITY IN THE VICINITY OF THE NORTHERN  LOADING
DOCK.  THIS PLUME WAS DIFFERENTIATED  FROM THE OTHER PLUME BY THE RELATIVE ABSENCE OF PCE DEGRADATION PRODUCTS
(TCE, 1,2-DCE, ETC.).  ANALYSES CONDUCTED FOR ROUND 3 SAMPLES  (MAY 1988) INDICATE A PCE  CONCENTRATION OF
APPROXIMATELY 2000 UG/L.  BASED ON THE DIFFERENCES IN PLUME COMPOSITION AND AREAL DISTRIBUTION,  THE TWO
SHALLOW AQUIFER IMPACTS  APPEAR  TO BE  THE RESULT OF SEPARATE RELEASE EVENTS FROM ONE OR MORE SOURCES AT THE
WAUSAU CHEMICAL FACILITY.

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COMPARISON OF VOC CONCENTRATIONS AND PUMPAGE RATES AT CW3 AND CW4 SUGGESTS THAT BOTH WELLS HAVE  EXPERIENCED
MULTIPLE IMPACTS FROM THE  SAME  SOURCE AREA;  THE EXTENT OF IMPACT BEING DEPENDANT ON PUMPING  SCHEMES  OF THE
CITY'S SUPPLY WELLS, RIVER STAGE,  AND THE STRENGTH OF THE SOURCE. TOTAL VOCS AT BOTH CW3 AND CW4 HAVE  BEEN
DECREASING OVER TIME INDICATING A  POSSIBLE REDUCTION IN SOURCE INTENSITY.  HOWEVER, TCE CONCENTRATIONS AT CW3
HAVE REMAINED RELATIVELY CONSISTENT  WHICH IS ATTRIBUTED TO THE TCE PLUME MIGRATING UNDER THE RIVER FROM THE
WEST SIDE.

        B.  SOURCES OF CONTAMINATION

CONTAMINATION SOURCE AREAS WERE IDENTIFIED AND CHARACTERIZED BASED ON RESULTS OF FIELD SAMPLING  OF SOILS,
LANDFILL CONTENTS  (USING TEST PITS AND SOIL BORINGS), GROUNDWATER, SURFACE WATER, SEDIMENT AND SOIL  GAS
MEDIA.  BASED ON SAMPLING  ACTIVITIES CONDUCTED DURING THE RI,  FOUR SOURCE AREAS OF VOCS WERE IDENTIFIED.   TWO
OF THESE SOURCES ARE LOCATED ON THE  WEST SIDE OF THE WISCONSIN RIVER  (THE FORMER CITY LANDFILL AND  BOS
CREEK) AND TWO SOURCES ARE LOCATED ON THE EAST SIDE  (WAUSAU CHEMICAL AND WAUSAU ENERGY).

THE FORMER CITY LANDFILL/MARATHON  ELECTRIC PROPERTY OCCUPIES A FORMER SAND AND GRAVEL PIT LOCATED ON THE  WEST
BANK OF THE WISCONSIN RIVER. THE LANDFILL,  WHICH CONSISTS OF APPROXIMATELY 4.5 ACRES, OPERATED BETWEEN 1948
AND 1955 AND ACCEPTED ALMOST ALL COMMERCIAL, INDUSTRIAL,  AND RESIDENTIAL WASTE GENERATED WITHIN  THE  CITY  OF
WAUSAU.  THE MAJORITY OF THE LANDFILL IS CURRENTLY COVERED BY A BITUMINOUS PAVEMENT PARKING  LOT,  HOWEVER  THE
SOUTHERN PORTION IS VEGETATED.

THE PREDOMINANT SOURCE OF  TCE CONTAMINATION TO CW6 AND CW3 APPEARS TO BE THE FORMER CITY LANDFILL/MARATHON
ELECTRIC PROPERTY.  ELEVATED CONCENTRATIONS OF TCE WERE DETECTED IN GROUNDWATER, SOIL, AND SOIL  GAS  SAMPLES
OBTAINED FROM THE NORTHERN PORTION OF THE LANDFILL. SOIL GAS CONCENTRATIONS WITHIN THE LANDFILL  RANGE  FROM
BELOW MINIMUM DETECTION LIMITS  (1.0  UG/L)  TO APPROXIMATELY 107 UG/L.  SOIL SAMPLES OBTAINED  FROM BORINGS  IN
THE VICINITY OF THE LANDFILL CONTAIN CONCENTRATIONS OF APPROXIMATELY 200 UG/KG.  GROUNDWATER SAMPLES OBTAINED
FROM THE WATER TABLE IN THE VICINITY OF THE LANDFILL INDICATE TCE CONCENTRATIONS RANGING FROM 16 UG/L  TO
APPROXIMATELY 1900 UG/L.   ALSO  DETECTED IN THE VICINITY OF THE LANDFILL WERE 1,1,1-TRICHLOROETHANE (TCA) ,
1,2-DICHLOROETHENE, CHLOROFORM, AND  CARBON TETRACHLORIDE AT   CONCENTRATIONS GENERALLY BELOW 100 UG/L.

IN ADDITION TO VOCS, CONTAMINANTS  IDENTIFIED IN LANDFILL SOIL/WASTE SAMPLES INCLUDE POLYCYCLIC AROMATIC
HYDROCARBONS  (PAHS) AND METALS. PAHS WERE FOUND THROUGHOUT THE FILL, WITH THE HIGHEST CONCENTRATIONS OBSERVED
IN THE CENTER OF THE FILL  AREA.  HEAVY METALS WERE DISTRIBUTED THROUGHOUT THE FILL.  CHROMIUM, ZINC, AND
NICKEL WERE ALSO DETECTED  IN GROUNDWATER SAMPLES FROM BENEATH THE FILL.  THESE METALS APPEAR TO  BE RESTRICTED
TO THE IMMEDIATE VICINITY  OF THE LANDFILL AND HAVE NOT BEEN DETECTED IN GROUNDWATER SAMPLES  OUTSIDE  OF THE
FILL AREA.

BASED ON CALCULATIONS PERFORMED FOR  THE RI,  THE TOTAL AMOUNT OF VOCS REMAINING IN THE UNSATURATED SOILS IN
THE NORTHERN PORTION OF THE LANDFILL IS ESTIMATED TO BE APPROXIMATELY 300 POUNDS.  THIS IS CONSIDERED  AN
ESTIMATE AND COULD VARY CONSIDERABLY IF CONTAMINATION EXISTS BENEATH THE FILL AND/OR IF AREAS OF UNDETECTED
HIGH CONCENTRATIONS OR NON-AQUEOUS PHASE OF CONTAMINANTS EXIST.

AS DISCUSSED PREVIOUSLY, LOW LEVELS  OF TCE WERE ALSO DETECTED IN SAMPLES FROM SHALLOW MONITORING WELLS ON THE
WEST SIDE IN THE VICINITY  OF BOS CREEK (SEE FIGURE 5).  THE SHALLOW CONTAMINATION APPEARS TO BE  A RESULT  OF
INFILTRATION OF TCE CONTAMINATED WATER TO THE AQUIFER FROM CW6 DISCHARGING TO THE CREEK.

THE WAUSAU CHEMICAL COMPANY IS  LOCATED BETWEEN CW3 AND CW4 ON THE EAST BANK OF THE WISCONSIN RIVER.  THE
FACILITY, ESTABLISHED IN 1964,  IS  A  BULK SOLVENT DISTRIBUTOR AND A TRANSFER STATION FOR SHIPMENT OF  WASTE
CHEMICALS AND SOLVENTS FROM AREA BUSINESSES.  THE FACILITY EXPERIENCED TWO DOCUMENTED PCE SPILLS IN  1983
TOTALING MORE THAN 1000 GALLONS, AND HAS BEEN CITED FOR GENERAL POOR  'HOUSEKEEPING' PRACTICES.   AS EARLY  AS
1975, WORKERS AT THE ADJACENT WATER  FILTRATION PLANT REPORTED "NOXIOUS ODORS" IN EXCAVATED SOILS DURING
EXPANSION OF THE PLANT.

SOLVENTS RELEASED FROM THE WAUSAU  CHEMICAL SOURCE AREAS ARE RESPONSIBLE FOR A LARGE PERCENTAGE OF THE  SHALLOW
GROUNDWATER CONTAMINATION  IN THE EAST WELL FIELD.  SOIL GAS AND SOIL BORING DATA REFLECTING  THE
DISTRIBUTION OF VOCS IN UNSATURATED  SOILS WERE COLLECTED AS PART OF THE SOIL GAS SURVEY AND  DURING SOIL
BORING FOR SOURCE CHARACTERIZATION.  RESULTS OF THIS DATA INDICATE HIGHER CONCENTRATIONS OF CONTAMINANTS ARE

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LOCATED IN THE SOUTHERN  PORTION OF THE SITE WITH DECREASING CONCENTRATIONS WITHIN AN ELONGATED  CONTAMINANT
ZONE TRENDING TOWARD THE EAST-NORTHEAST.   HOWEVER,  ELEVATED CONCENTRATIONS OF PCE WERE ALSO   FOUND IN
UNSATURATED SOILS NEAR THE  NORTH LOADING DOCK.   THE HIGHEST LEVELS OF PCE IN SOIL GAS WAS  REPORTED FROM THE
SOUTHERN END OF THE FACILITY AT A CONCENTRATION OF 4080 UG/L.  ANALYSES OF SOIL SAMPLES  INDICATE  3500 UG/KG
OF PCE IN THE VICINITY OF THE  NORTH LOADING DOCK,  AND 1000 UG/KG AT THE SOUTH END OF THE PROPERTY.

BASED ON CALCULATIONS PERFORMED FOR THE RI,  THE TOTAL AMOUNT OF VOCS REMAINING IN THE SOILS AT  WAUSAU
CHEMICAL IS APPROXIMATELY 300  POUNDS.  THIS IS CONSIDERED AN ESTIMATE AND COULD VARY CONSIDERABLY IF
CONTAMINATION EXISTS BENEATH EITHER THE FILTRATION PLANT OR THE WAUSAU CHEMICAL BUILDING.

THE WAUSAU ENERGY PROPERTY  LOCATED DIRECTLY SOUTH OF CW3 WAS ALSO IDENTIFIED AS A SOURCE FOR  GROUNDWATER
CONTAMINATION.  THE FACILITY OPERATED  AS A PETROLEUM BULK STORAGE AND DISTRIBUTION CENTER  FROM  THE LATE
1940'S UNTIL 1983.  PREVIOUS PROPERTY  OWNERS INCLUDE AMOCO OIL AND RUSH DISTRIBUTING.  HISTORICAL  DATA
INDICATE THAT AT LEAST SEVEN ABOVE GROUND STORAGE TANKS WERE LOCATED ON THE SOUTHERN HALF  OF  THE PROPERTY
AND CONTAINED VARIOUS PETROLEUM PRODUCTS.

SOIL GAS AND UNSATURATED SOIL  SAMPLES  HAVE BEEN CONDUCTED AT THE PROPERTY.  RESULTS INDICATE  VARIOUS
PETROLEUM BY-PRODUCTS, COMMONLY REFERRED TO AS  BETX (BENZENE, ETHYLBENZENE, TOLUENE, AND XYLENES)  IN
UNSATURATED SOILS AND GROUNDWATER BENEATH THE SITE.  PCE WAS DETECTED AT LOW LEVELS IN ISOLATED SOIL SAMPLES
AND SOIL GAS SAMPLES AT  DEPTH.   THE MAXIMUM BETX CONCENTRATION REPORTED IN ON SITE SOILS WAS  25,100 UG/KG.
THE MAXIMUM CONCENTRATION OF PCE FOUND IN SOILS WAS 8,600 UG/KG  (FROM A PREVIOUS STUDY-FOTH & VAN  DYKE)  AND
17.4 UG/KG FOUND IN SOIL GAS SAMPLES FROM THE PROPERTY.

#SSR
VI.  SUMMARY OF SITE RISKS

CERCLA REQUIRES THAT US  EPA PROTECT HUMAN HEALTH AND THE ENVIRONMENT FROM CURRENT AND POTENTIAL EXPOSURE TO
HAZARDOUS SUBSTANCES FOUND  AT  THE SITE.   AN ENDANGERMENT ASSESSMENT WAS CONDUCTED AS PART  OF  THE RI IN
ORDER TO ASSESS THE CURRENT AND POTENTIAL RISKS FROM THE SITE.  THIS SECTION SUMMARIZES THE AGENCY'S FINDINGS
CONCERNING THE RISKS FROM EXPOSURE TO  GROUNDWATER AND AIR EMISSIONS AT THIS SITE.

ASSESSMENT OF SITE RELATED  RISKS INVOLVED THE IDENTIFICATION OF CONTAMINANTS OF MOST CONCERN, ROUTES OF
CONTAMINANT MIGRATION AND POPULATIONS  POTENTIALLY EXPOSED TO THE CONTAMINANTS.  THIS INFORMATION WAS THEN
USED TO ESTIMATE EXPOSURE FROM CONTAMINANTS FOR THE POPULATION, WHICH WAS THEN COMPARED TO CHEMICAL TOXICITY
TO ARRIVE AT AN ESTIMATE OF HEALTH RISKS FOR THE SITE.

A.  IDENTIFICATION OF CONTAMINANTS OF  CONCERN

MORE THAN 50 COMPOUNDS WERE IDENTIFIED FROM THE RI DATA AS BEING PRESENT AT THE SITE  (TABLE 2).  A SUBSET OF
THE TOTAL NUMBER IDENTIFIED WAS SELECTED BASED  ON WHICH COMPOUNDS POSE THE GREATEST HEALTH RISKS,  THE
CONCENTRATIONS AND FREQUENCY OF DETECTION, AND  THE PHYSICAL PROPERTIES RELATING TO MOBILITY AND PERSISTENCE.

BASED ON THE ABOVE CRITERIA, THE FOLLOWING INDICATOR CHEMICALS WERE CONSIDERED TO BE REPRESENTATIVE OF SITE
CONTAMINATION AND TO POSE THE  GREATEST POTENTIAL HEALTH RISK.

       *    TETRACHLOROETHENE  (PCE)
       *    TRICHLOROETHENE (TCE)
       *    1,2-DICHLOROETHENE (DCE)

THESE COMPOUNDS HAVE BEEN USED TO EVALUATE TOXICITY, EXPOSURE PATHWAYS, AND POTENTIAL HEALTH  RISKS FOR THE
SITE.

B.  EXPOSURE ASSESSMENT

GROUNDWATER IN THE AREA  IS  THE CURRENT SOURCE OF DRINKING WATER FOR THE CITY OF WAUSAU WHICH  PROVIDES POTABLE
WATER TO APPROXIMATELY 33,000  PEOPLE.   THE AQUIFER OF CONCERN IS A CLASS I AQUIFER  (SOLE-SOURCE   AQUIFER
WITHOUT A VIABLE ALTERNATE  SOURCE OF SUPPLY)  AND IS HIGHLY VULNERABLE TO CONTAMINATION.  THE  CITY  OF WAUSAU

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TREATS WATER PRIOR TO DISTRIBUTION THROUGH THE USE OF TWO AIR STRIPPERS.  THE AIR STRIPPERS    EFFECTIVELY
REDUCE VOC CONCENTRATIONS  TO  BELOW THE  DETECTABLE LEVELS. HISTORICAL DATA INDICATE THAT DURING THE  PERIOD OF
1982 THROUGH MID-1984, LEVELS OF VOCS  IN THE CITY SUPPLY RANGED FROM 10 UG/L TO 100 UG/L.  HOWEVER,  IT  IS NOT
KNOWN HOW LONG, PRIOR TO 1982,  THE CITY'S WATER SUPPLY CONTAINED ELEVATED LEVELS OF VOCS. THEREFORE,  THE
EXPOSURE SCENARIO FOR DRINKING WATER DID NOT ADDRESS POSSIBLE EXPOSURES PRIOR TO 1982.

CURRENTLY THERE ARE NO KNOWN  PRIVATE WELLS USED FOR DRINKING WATER WITHIN THE STUDY AREA.  IN  ADDITION, THERE
IS A CITY OF WAUSAU ORDINANCE REQUIRING RESIDENTS TO UTILIZE THE MUNICIPAL SUPPLY FOR DOMESTIC PURPOSES.
HOWEVER, IN DEVELOPING HYPOTHETICAL EXPOSURE SCENARIOS FOR GROUNDWATER, INSTITUTIONAL CONTROLS WERE NOT
CONSIDERED ADEQUATE FOR PROTECTION FROM POTENTIAL FUTURE USE OF PRIVATE WELLS.

STRIPPING TOWER TREATMENT  OF  CONTAMINATED GROUNDWATER IS CURRENTLY OCCURRING AT THE CITY WATER TREATMENT
PLANT AND AT WAUSAU CHEMICAL.   IN  ADDITION,  THE EFFLUENT FROM THE EXTRACTION WELL PROPOSED FOR THE  INTERIM
REMEDY WILL ALSO INVOLVE DISPERSION OF  VOC EMISSIONS TO THE AIR. INDICATOR CONTAMINANTS DISPERSED INTO  THE
AIR FROM GROUNDWATER TREATMENT POSE A  POTENTIAL EXPOSURE PATHWAY TO EMPLOYEES OF COMPANIES AND RESIDENTS  NEAR
THE SOURCES OF AIR EMISSIONS.

THE POTENTIAL EXPOSURE PATHWAYS FOR THE SITE ARE LISTED BELOW AND SUMMARIZED IN TABLE 3.  POTENTIAL HEALTH
RISKS WERE EVALUATED FOR THE  FOLLOWING  EXPOSURE PATHWAYS AND POTENTIALLY EXPOSED POPULATION.

       *    RESIDENTS USING MUNICIPAL WATER ASSUMING THEY ARE EXPOSED TO
            CONTAMINANT CONCENTRATIONS  EQUAL TO THE LABORATORY DETECTION
            LIMITS OF 0.5  UG/L FOR PCE  AND TCE,  AND 1.0 UG/L FOR DCE.

       *    HYPOTHETICAL USERS OF  PRIVATE WELL WATER ASSUMING A PRIVATE
            WELL IS INSTALLED WITHIN THE CONTAMINATED AQUIFER IN THE
            FUTURE.  IT WAS ASSUMED THAT A USER WOULD BE EXPOSED TO THE
            HIGHEST CONCENTRATIONS FOUND IN GROUNDWATER, APPROXIMATELY
            4300 UG/L, TO  OBTAIN THE WORST CASE SCENARIO FOR THIS EXPOSURE PATHWAY.

       *    RESIDENTS AND  COMPANY  EMPLOYEES EXPOSED VIA AIR EMISSIONS IN
            THE VICINITY OF THE EMISSION SOURCES.  ESTIMATED CONTAMINANT
            EMISSIONS FROM THE SOURCE AREAS WERE CALCULATED ASSUMING
            CONTINUOUS OPERATION OF THE AIR STRIPPERS AND A CONSTANT RATE
            OF LOADING OF  VOCS.

THE CONTAMINANT INTAKE, AND THUS RISK THAT AN INDIVIDUAL WOULD LIKELY INCUR FROM EXPOSURE TO AN INDICATOR
CHEMICAL WAS ESTIMATED FOR THE EXPOSURE PATHWAY OF CONCERN BY INCORPORATING STANDARD EXPOSURE  ASSUMPTIONS OF
70-KG MAN, INGESTION OF TWO LITERS OF WATER PER DAY, INHALATION RATE OF 1.3 M3/HR AND A SKIN SURFACE AREA OF
18,200 CM2 FOR WATER, AND  AN  INHALATION RATE OF 20 M3/DAY FOR AIR EMISSIONS.

C.  TOXICITY ASSESSMENT

BASED ON TOXICOLOGICAL STUDIES PERFORMED ON LABORATORY ANIMALS, BOTH PCE AND TCE ARE CLASSIFIED AS  PROBABLE
HUMAN CARCINOGENS.  SCIENTIFIC DATA COLLECTED TO DATE ARE NOT SUFFICIENT TO CLASSIFY DCE AS TO ITS
CARCINOGENIC POTENTIAL.  THEREFORE,  NO  CANCER POTENCY FACTOR COULD BE DERIVED FOR DCE AND THUS,  DCE WAS NOT
INCLUDED IN THE CALCULATION OF SITE RISKS.  PCE IS ALSO ASSIGNED A REFERENCE DOSE VALUE.  THIS VALUE
REPRESENTS THE LEVELS TO WHICH HUMANS CAN BE EXPOSED ON A DAILY BASIS WITHOUT ADVERSE EFFECTS.   THE CRITICAL
TOXICITY VALUES  (I.E., CANCER POTENCY  FACTOR AND REFERENCE DOSE) FOR PCE AND TCE ARE LISTED IN TABLE 4.

THE Us EPA CONSIDERS INDIVIDUAL EXCESS  CANCER RISKS IN A RANGE OF (10-4) TO  (10-7) AS PROTECTIVE; HOWEVER,
THE (10-6) RISK LEVEL IS USED AS A POINT OF DEPARTURE FOR SETTING CLEANUP LEVELS AT SUPERFUND  SITES.  A  (10-6)
IS CONSIDERED APPROPRIATE  AS  A POINT OF DEPARTURE FOR SETTING CLEANUP LEVELS AT THIS SITE CONSIDERING THAT
GROUNDWATER IS CURRENTLY USED FOR  DRINKING WATER AND IS THE SOLE-SOURCE OF DRINKING WATER FOR  THE RESIDENTS
OF WAUSAU.

D.  SUMMARY OF RISK CHARACTERIZATION

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UNDER CURRENT WATER USE CONDITIONS,  A POTENTIAL CARCINOGENIC RISK OF APPROXIMATELY ONE IN ONE MILLION 1  X
(10-6) WAS CALCULATED FOR USERS  OF MUNICIPAL WATER FOR THE COMBINED EFFECTS OF PCE AND TCE.  THESE  RISK
LEVELS ARE BASED ON UNDETECTABLE LEVELS  OF VOCS PRESENT IN THE TREATED WATER WITHIN THE CITY WATER
DISTRIBUTION SYSTEM.  THE SHORT-TERM CARCINOGENIC RISKS TO HEALTH ASSOCIATED WITH PCE AND TCE CONTAMINATION
WOULD APPEAR TO BE MINIMAL UNDER CURRENT WATER USAGE PRACTICES.  THE LONG-TERM CANCER RISK ASSOCIATED WITH
CITY WATER USE WAS CALCULATED  TO BE  1.5  X (10-6)  BASED ON A LIFE TIME OF 70 YEARS  (SEE TABLE 5).

THE Us EPA HAS SET A MAXIMUM CONTAMINANT LEVEL (MCL)  OF 5 UG/L TCE FOR DRINKING WATER.  AN MCL  OF 5 UG/L FOR
PCE IS UNDER CONSIDERATION FOR PROPOSAL  IN THE NEAR FUTURE.  MCLS ARE ENFORCEABLE STANDARDS PROMULGATED  UNDER
THE SAFE DRINKING WATER ACT.   BECAUSE PCE AND TCE ARE CARCINOGENIC AND ARE NOT CONSIDERED TO BE WITHOUT
HAZARD BELOW A GIVEN THRESHOLD,  THE  US EPA HAS SET A NON-ENFORCEABLE MAXIMUM CONTAMINANT LEVEL  GOAL (MCLG)  OF
ZERO FOR TCE IN DRINKING WATER AND IS CONSIDERING THE SAME MCLG FOR   PCE.  BECAUSE IT IS NOT POSSIBLE TO
ACCURATELY MEASURE LEVELS OF THESE COMPOUNDS BELOW THE MINIMUM DETECTION LIMIT, A FUTURE HEALTH RISK MAY
EXIST TO INDIVIDUALS CONSUMING WATER OVER A PROLONGED PERIOD OF TIME DURING WHICH PCE AND TCE ARE PRESENT,
BUT BELOW DETECTABLE LIMITS.

IN ADDITION, PROTECTION OF RESIDENTS FROM EXPOSURE TO THE CONTAMINANTS OF CONCERN IS DEPENDENT  ON ADEQUATE
TREATMENT OF THE WATER.  THE POTENTIAL FOR EXPOSURE EXISTS IN THAT FAILURE OF THE TREATMENT SYSTEM  COULD
RESULT IN AN EXPOSURE PATHWAY  THROUGH THE CITY'S DRINKING WATER. BASED ON THE POSSIBILITY OF FAILURE OF  THE
AIR STRIPPERS, A POTENTIAL FUTURE RISK OF EXPOSURE TO PCE AND TCE VIA DRINKING WATER INGESTION  EXISTS AT THE
SITE.

THE CALCULATED POTENTIAL CARCINOGENIC RISKS FOR FUTURE USE OF PRIVATE WELL WATER WERE APPROXIMATELY 1000
TIMES HIGHER THAN THOSE CALCULATED FOR USERS OF MUNICIPAL WATER, ASSUMING USERS WOULD BE EXPOSED TO MAXIMUM
CONTAMINANT CONCENTRATIONS IDENTIFIED IN GROUNDWATER AT THE SITE (SEE TABLE 5).  BECAUSE INSTITUTIONAL
CONTROLS WERE NOT CONSIDERED ADEQUATE FOR PROTECTION FROM PRIVATE WELL USAGE, IT WAS DETERMINED THAT A
POTENTIAL FUTURE RISK OF EXPOSURE VIA GROUNDWATER EXISTS AT THE SITE.

THE POTENTIAL CANCER RISK TO INDIVIDUALS INHALING CONTAMINATED AIR EMANATING FROM THE STRIPPING TOWERS WAS
ESTIMATED BASED ON MODELING  OF THE COMBINED CONTAMINANT PLUMES FROM THE CITY'S AIR STRIPPERS AND THE WAUSAU
CHEMICAL AIR STRIPPER.  MODEL  RESULTS FOR A WORST CASE SCENARIO FOR EXPOSURE OF RECEPTORS TO AIR BORNE
CONTAMINANTS ESTIMATED A CANCER  RISK OF  1.7 X (10-6).   THE  ESTIMATED CURRENT RISK LEVEL IS NOT CONSIDERED TO
PRESENT AN APPRECIABLE HEALTH  RISK TO RESIDENTS.   HOWEVER, ALL ALTERNATIVES EVALUATED IN THE FS INCLUDE
TREATMENT OF OFF-GASES TO ELIMINATE  ANY  ADDITIONAL VOC EMISSIONS.  IN ADDITION, THE SELECTED    ALTERNATIVE
CALLS FOR ELIMINATION OF THE WAUSAU  CHEMICAL AIR STRIPPER, WHICH WILL REDUCE THE LEVEL OF CONTAMINANTS IN THE
CONTAMINANT PLUME.

#DA
VII.  DESCRIPTION OF ALTERNATIVES

A.  RESPONSE OBJECTIVES

THE FEASIBILITY STUDY WAS INITIATED  TO EVALUATE ALTERNATIVES FOR REMEDIATION OF THE GROUNDWATER CONTAMINATION
AND SOURCE AREAS AT THE SITE.  BASED ON  THE RISK ASSESSMENT, THREE PRIMARY SITE-SPECIFIC   RESPONSE
OBJECTIVES WERE IDENTIFIED;  1)  REDUCTION OF LONG-TERM EXPOSURE TO LOW LEVELS OF VOCS FROM INGESTION OF
DRINKING WATER; 2) PROTECTION  FROM POTENTIAL FUTURE USE OF PRIVATE WELLS IN CONTAMINATED GROUNDWATER;  AND,  3)
PROTECTION FROM EMISSIONS OF CONTAMINANTS FROM PROPOSED WATER TREATMENT SYSTEMS THAT RELEASE VOCS TO THE
ATMOSPHERE.

B. DEVELOPMENT OF ALTERNATIVES

IN DEVELOPING ALTERNATIVES FOR THIS  SITE SEVERAL INITIAL ASSUMPTIONS WERE MADE REGARDING BASE LINE  CONDITIONS
AT THE SITE.  IT WAS ASSUMED THAT THE WEST SIDE EXTRACTION SYSTEM WOULD BE INSTALLED AND OPERATED AS
DESCRIBED IN THE INTERIM ROD.  IT WAS ALSO DETERMINED, BASED ON COMPUTER MODELING OF THE SITE,  THAT THE  DEEP
TCE PLUME MOVING UNDER THE WISCONSIN RIVER TO CW3 WOULD BEST BE ADDRESSED AT THE SAME LOCATION  AS THE
PROPOSED EXTRACTION WELL AT  THE  FORMER LANDFILL SOURCE.  THEREFORE, IT WAS DETERMINED THAT AN INCREASE IN THE
PROPOSED MINIMUM PUMPING RATES CALLED FOR IN THE WEST SIDE EXTRACTION SYSTEM AND MODIFICATIONS  TO THE

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MONITORING PLAN WOULD PROVIDE  THE  MOST  EFFECTIVE REMEDIATION OF THIS CONTAMINANT PLUME.

AS DISCUSSED, THE REMAINING AREAS  OF CONCERN FOR THE SITE INCLUDE THE SOURCE AREAS AND THE SHALLOW EAST  SIDE
CONTAMINANT PLUME ORIGINATING  FROM THE  WAUSAU CHEMICAL SOURCE AREA.  THE THREE IDENTIFIED SOURCE AREAS
INCLUDE THE FORMER CITY LANDFILL,  THE WAUSAU CHEMICAL PROPERTY, AND THE WAUSAU ENERGY PROPERTY.

AT THE WAUSAU ENERGY SITE, PETROLEUM DERIVED COMPOUNDS HAVE BEEN FOUND IN GROUNDWATER SAMPLES DIRECTLY BELOW
THE SITE.  ALTHOUGH TOLUENE, ETHYLENE,  AND XYLENE WERE PREVIOUSLY DETECTED IN CW4, NO OFF-SITE MIGRATION OF
CONTAMINANTS WAS BEEN DETECTED DURING THE RI/FS,  ALTHOUGH TOLUENE,  ETHYLENE AND XYLENE WERE PREVIOUSLY
DETECTED IN CW4.  BECAUSE OFF-SITE MONITORING DOES NOT INDICATE  GROUNDWATER IMPACTS FROM THE   WAUSAU ENERGY
SOURCE AT PRESENT, GROUNDWATER REMEDIATION AT WAUSAU ENERGY IS NOT ADDRESSED AS PART OF THE FINAL  REMEDY.
HOWEVER, CONTAMINATED SOILS FOUND  AT WAUSAU ENERGY WILL BE ADDRESSED UNDER THE DISCUSSION OF SOURCE CONTROL.

A VARIETY OF TECHNOLOGIES TO ADDRESS RESPONSE OBJECTIVES WERE IDENTIFIED FOR FURTHER CONSIDERATION INCLUDING
SEVERAL FOR REMEDIATION OF SOURCE  AREAS.   HOWEVER, CONSIDERING THE NATURE OF THE SOURCE AREAS,   AND THE
CONTAMINANTS PRESENT, ONLY ONE SOURCE CONTROL TECHNOLOGY (SOIL VAPOR EXTRACTION) WAS RETAINED FROM THE
SCREENING OF TECHNOLOGIES.

FOLLOWING SCREENING OF TECHNOLOGIES,  ALTERNATIVES WERE DEVELOPED AND SCREENED FOR APPROPRIATENESS  BASED  ON
RESPONSE OBJECTIVES.  FIVE ALTERNATIVES REMAINED AFTER SCREENING AND WERE SUBJECTED TO DETAILED ANALYSIS
USING THE NINE EVALUATION CRITERIA DEVELOPED UNDER THE NATIONAL CONTINGENCY PLAN  (NCP).  TABLE 6 LIstS THE
FIVE ALTERNATIVES.

                                      TABIiE 6

                        REMEDIAL ACTION ALTERNATIVES
           ALTERNATIVE  1
                             NO ACTION
           ALTERNATIVE 2
                                           GROUNDWATER EXTRACTION AND
                                           TREATMENT WITH AIR STRIPPING AND
                                           DISCHARGE TO THE WISCONSIN RIVER
           ALTERNATIVE 3
                                           IN-SITU BIORECLAMATION WITH
                                           PARTIAL ABOVE GROUND TREATMENT
                                           AND DISCHARGE TO THE WISCONSIN
                                           RIVER
           ALTERNATIVE  4

           ALTERNATIVE  5
IN-SITU BIORECLAMATION

ACTIVE SOURCE CONTROL-SOIL VAPOR
EXTRACTION
C. ALTERNATIVES

ALTERNATIVE 1 - NO ACTION
THE NO ACTION ALTERNATIVE  IS  EVALUATED AS  REQUIRED BY THE NCP.
WOULD BE TAKEN BEYOND THE  INTERIM REMEDY.
                      UNDER THIS ALTERNATIVE,  NO RESPONSE ACTION
THE INTERIM REMEDY EXTRACTION WELL WILL PROVIDE A BARRIER TO CONTAMINANT MIGRATION FROM THE LANDFILL  SOURCE
TO CW6, ULTIMATELY RESULTING IN  THE  ELIMINATION OF CONTAMINANT IMPACT AT THIS WELL.  THE TIME TO ACHIEVE
PROTECTION OF CW6 UNDER THIS ALTERNATIVE DEPENDS ON THE RATE OF AQUIFER PURGING PROVIDED BY WELL CW6  PUMPING.
COMPUTER  SIMULATION OF THE NO ACTION ALTERNATIVE FOR THE LANDFILL SOURCE SHOWS THAT A GROUNDWATER  DIVIDE
WOULD BE PRESENT IN THE VICINITY OF  THE PONDED AREA IN BOS CREEK BETWEEN CW6 AND THE LANDFILL EXTRACTION
WELL. CONTAMINANTS ON EITHER SIDE OF THIS DIVIDE WOULD MIGRATE NORTH TO CW6 OR SOUTH TO THE EXTRACTION WELL.
GIVEN THE PUMPING RATES ASSUMED  FOR  THESE SIMULATIONS AND THE INITIAL MASS DISTRIBUTION, A TIME PERIOD OF

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APPROXIMATELY 10 YEARS  IS  ESTIMATED TO BE NECESSARY TO ACHIEVE CONTAMINANT CONCENTRATIONS BELOW THE  MCL  FOR
TCE  (5 UG/L) AT CW6.  THE  PERIOD  DURING WHICH CW6 DRAWS IN CONTAMINANTS FROM THE LANDFILL SOURCE IS  ESTIMATED
TO BE APPROXIMATELY 20  YEARS UNDER PROJECTED PUMPING CONDITIONS.

THE NO ACTION SIMULATION FOR THE  LANDFILL SOURCE SHOWS THAT THE EXTRACTION WELL AT THE LANDFILL WOULD ALSO
STOP ADDITIONAL MIGRATION  OF CONTAMINATION BENEATH THE WISCONSIN RIVER TO CW3.  A PERIOD OF APPROXIMATELY 6
YEARS IS ESTIMATED TO OBTAIN CONTAMINANT CONCENTRATIONS AT CW3 LESS THAN 5 UG/L.

THE SIMULATED GROUNDWATER  PIEZOMETRIC SURFACE CONTOURS FOR THE EAST WELL FIELD ARE SHOWN ON FIGURE  6.  THE
MAP INDICATES AN AREA OF HYDRAULIC INFLUENCE WHICH EXTENDS SOUTH OF THE WAUSAU CHEMICAL PROPERTY DUE
PRIMARILY TO PUMPING OF CW3.  WITH NO CW4 PUMPING,  THE SHALLOW EAST SIDE CONTAMINANT PLUMES LIE WITHIN THIS
AREA OF INFLUENCE.  THE SIMULATION SHOWS THE CONTAMINANT MASS REACHING CW3 FROM THE WAUSAU CHEMICAL  SOURCES
WOULD RESULT IN CONCENTRATIONS  CONSISTENTLY LESS THAN 5 UG/L AFTER APPROXIMATELY 6.3 YEARS.

THE TIME DURING WHICH CW3  WOULD DRAW IN CONTAMINANTS FROM EITHER EAST SIDE OR WEST SIDE SOURCES IS ESTIMATED
TO BE APPROXIMATELY 15  YEARS.   IT WAS ASSUMED THAT THE PHASE I REMEDY EXTRACTION WELL NORTH OF  THE LANDFILL
WOULD BE IN OPERATION,  AND THAT CONTAMINANTS IN UNSATURATED ZONE SOILS AT WAUSAU CHEMICAL WOULD REPRESENT A
GROUNDWATER CONTAMINANT SOURCE  THAT DECLINES IN STRENGTH OVER AN APPROXIMATELY 8-YEAR PERIOD.

PROBABLE ARARS FOR THE  NO  ACTION  ALTERNATIVE ARE SUMMARIZED IN TABLE 7. CHEMICAL-SPECIFIC ARARS IDENTIFIED
INCLUDE THOSE RELATED TO DRINKING WATER,  GROUNDWATER,  SURFACE WATER AND AIR QUALITY. DRINKING WATER  MCLS
FOR VOCS CAN BE MET BY  STRIPPING  TOWER TREATMENT, AS EVIDENCED BY ACTUAL PERFORMANCE DATA.  THE NO ACTION
ALTERNATIVE WOULD NOT COMPLY WITH CHAPTER NR 140 REQUIREMENTS FOR RESPONSES WHERE ENFORCEMENT STANDARDS    ARE
EXCEEDED.  AIR EMISSION LIMITS  ARE NOT ANTICIPATED TO BE EXCEEDED BY ANY OF THE IDENTIFIED SOURCES.

THE ONLY LOCATION-SPECIFIC ARAR IDENTIFIED INVOLVES POTENTIAL FUTURE REQUIREMENTS THAT MAY BE IMPLEMENTED
UNDER A WELLHEAD PROTECTION AREA  PROGRAM.  NO AREA HAS BEEN DESIGNATED TO DATE AND NO REQUIREMENTS HAVE  BEEN
IDENTIFIED.  ACTION-SPECIFIC ARARS IDENTIFIED RELATE TO PROPERTY USE AT THE LANDFILL AND UNCONTROLLED
EMISSION OF TOXIC ORGANICS FROM SOURCE AREAS.

THERE IS NO COST OR OPERATION AND MAINTENANCE (O&M)  ASSOCIATED WITH THE NO ACTION ALTERNATIVE.   ANNUAL COSTS
TO OPERATE THE PRESENT  AIR STRIPPER WERE NOT CONSIDERED AS O&M UNDER THIS ALTERNATIVE.

ALTERNATIVE 2 - GROUNDWATER EXTRACTION/ABOVE GROUND TREATMENT

ALTERNATIVE 2 INVOLVES  INSTALLATION OF A GROUNDWATER EXTRACTION SYSTEM TO ADDRESS THE SHALLOW GROUNDWATER
CONTAMINATION IN THE EAST  WELL  FIELD ORIGINATING FROM THE WAUSAU CHEMICAL FACILITY.  A GROUNDWATER EXTRACTION
AND TREATMENT SYSTEM WOULD BE INSTALLED ON THE WAUSAU CHEMICAL PROPERTY TO EXTRACT CONTAMINATED WATER IN
CLOSE PROXIMITY TO THE  AREA OF  GREATEST SOIL CONTAMINATION (SEE FIGURE 7).  THE SYSTEM WOULD INCLUDE A
CLUSTER OF WELLS DESIGNED  TO EXTEND THE ZONE OF INFLUENCE BENEATH THE CITY FILTRATION PLANT AND THE  WAUSAU
CHEMICAL BUILDING, AS WELL AS TO  THE EAST OF THE FACILITY WHERE CONTAMINANTS HAVE MIGRATED DUE  TO THE EFFECTS
OF AQUIFER RECHARGE FROM THE WISCONSIN RIVER.

EXTRACTED WATER WOULD BE PUMPED TO AN AIR STRIPPER FOR TREATMENT OF VOCS PRIOR TO DISCHARGE TO  THE WISCONSIN
RIVER.  OFF-GAS TREATMENT  WOULD BE INCLUDED IN THE TREATMENT PROCESS AND WOULD INVOLVE VAPOR PHASE ACTIVATED
CARBON UNITS TO TREAT GASES AND OFF SITE REGENERATION OF CARBON AND DESTRUCTION OF CONTAMINANTS.  IT IS
ESTIMATED THAT THE SYSTEM  FLOW  RATE WOULD BE APPROXIMATELY 300-500 GPM.

IMPLEMENTATION OF THIS  ALTERNATIVE IS EXPECTED TO LIMIT MIGRATION OF CONTAMINANTS FROM WAUSAU CHEMICAL TO
CW3.  CONTAMINANT TRANSPORT SIMULATIONS OF THIS ALTERNATIVE SHOWS THAT AT TOTAL SYSTEM PUMPING  RATES OF  200
AND 500 GPM, CONTAMINANT CONCENTRATIONS AT CW3 RESULTING FOR MIGRATION FORM THE WAUSAU CHEMICAL SOURCE WOULD
BE LESS THAN 5 UG/L IN  APPROXIMATELY 5.2 YEARS.   HOWEVER, COMPLETE RESTORATION OF THE AQUIFER ON THE EAST
SIDE OF THE RIVER WOULD REQUIRE 12 YEARS.

CONTAMINATION IN THE DEEP  GROUNDWATER PLUME ORIGINATING AT THE FORMER CITY LANDFILL/MARATHON ELECTRIC SOURCE
AREA IS NOT ANTICIPATED TO BE INFLUENCED BY PUMPING OF THE EAST SIDE EXTRACTION WELL SYSTEM. THUS,   THE  TIME
TO ACHIEVE PROTECTION OF CW3 UNDER THIS ALTERNATIVE IS NOT ANTICIPATED TO BE SUBSTANTIALLY DIFFERENT FROM

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THAT ESTIMATED UNDER THE NO ACTION ALTERNATIVE,  BECAUSE THE TIME TO ACHIEVE AQUIFER PURGING UNDER  BOTH
ALTERNATIVES IS DETERMINED BY  THE  TIME  REQUIRED TO REMEDIATE THE DEEP TCE PLUME.  HOWEVER, THE MAGNITUDE  OF
CONTAMINANT CONCENTRATIONS AFFECTING PRODUCTION WELL CW3 IS EXPECTED TO DECREASE, BECAUSE THE  CONTRIBUTION
OF CONTAMINANTS FROM THE EAST  SIDE SOURCE WILL BE REDUCED.

COSTS FOR ALTERNATIVE 2 ARE SUMMARIZED  IN TABLE 12.   MAJOR CAPITAL COST ITEMS INCLUDE GROUNDWATER  EXTRACTION
WELLS AND HEADER SYSTEM, PUMPS,  CONTROLS,  STRIPPING TOWER AND DISCHARGE LINE.  MAJOR OPERATION AND
MAINTENANCE ITEMS INCLUDE ENERGY COSTS,  SAMPLING AND MONITORING, ANALYTICAL LABORATORY, ROUTINE  SYSTEMS
INSPECTION AND MAINTENANCE, AND  REPORTING.   CAPITAL COSTS ARE ESTIMATED TO BE $480,000. ANNUAL   OPERATION
AND MAINTENANCE COSTS ARE ESTIMATED TO  BE APPROXIMATELY $120,000.  THE 10-YEAR PRESENT WORTH  (10%  DISCOUNT
RATE) ASSOCIATED WITH THE ABOVE  COSTS IS $1,330,000.

PROBABLE ARARS FOR ALTERNATIVE 2 ARE SUMMARIZED IN TABLE 8. CHEMICAL-SPECIFIC ARARS INCLUDE DRINKING WATER,
GROUNDWATER, SURFACE WATER AND AIR QUALITY STANDARDS, CRITERIA OR LIMITS. THESE INCLUDE DRINKING WATER MCLS
AND NR 140 STANDARDS.  DRINKING  WATER MCLS FOR VOCS CAN BE MET BY THE WATER UTILITY. THE PROPOSED  GROUNDWATER
RESPONSE ACTIONS WOULD SATISFY RESPONSE REQUIREMENTS OF NR 140.  MEETING WATER QUALITY-BASED EFFLUENT  LIMITS
ESTABLISHED TO MEET WATER QUALITY  CRITERIA SHOULD BE FEASIBLE USING PACKED TOWER STRIPPING.  MEETING
COMPOUND-SPECIFIC LIMITS FOR VOC EMISSIONS TO AIR WOULD BE FEASIBLE BASED ON ANTICIPATED CONCENTRATIONS AND
PUMPING RATES, REGARDLESS OF WHETHER OR NOT OFF-GAS CONTROLS ARE USED.

LOCATION-SPECIFIC ARARS INCLUDE  POSSIBLE WELLHEAD PROTECTION REQUIREMENTS, AND FLOODPLAIN ACTIVITY
REQUIREMENTS.  ACTION-SPECIFIC ARARS INCLUDE REQUIREMENTS FOR WELL CONSTRUCTION AND PLUMBING SYSTEM
STANDARDS, TREATMENT SYSTEM PLAN REVIEW,  OBTAINING A SURFACE WATER DISCHARGE PERMIT, VOC EMISSIONS LIMITS AND
CONSTRUCTION AND INDUSTRIAL SAFETY.   NO DIFFICULTIES IN ACHIEVING COMPLIANCE WITH ANY OF THESE HAVE   BEEN
IDENTIFIED.

IMPLEMENTATION OF THIS ALTERNATIVE IS NOT EXPECTED TO BE A PROBLEM.  THE TECHNOLOGY IS READILY AVAILABLE,
CONVENTIONAL, AND WELL DEMONSTRATED.  CONSTRUCTION IS STRAIGHT FORWARD AND NO UNUSUAL FEATURES ARE  ANTICIPATED
TO BE REQUIRED FOR THE SYSTEM.   COORDINATION BETWEEN Us EPA AND THE CITY OF WAUSAU WILL BE REQUIRED TO
ACCOMPLISH IMPLEMENTATION OF THE SYSTEM.

ALTERNATIVE 3 - IN-SITU BIORECLAMATION  WITH PARTIAL TREATMENT AND DISCHARGE

ALTERNATIVE 3 IS AN IN-SITU METHOD FOR  REMEDIATION OF THE SHALLOW EAST SIDE GROUNDWATER CONTAMINANT PLUME.
GROUNDWATER WOULD BE EXTRACTED,  A  PORTION WOULD BE TREATED AND DISCHARGED TO THE WISCONSIN RIVER AND THE
REMAINDER WOULD BE SUPPLEMENTED  WITH NUTRIENTS AND RECHARGED TO THE AQUIFER TO ENHANCE MICROBIALLY-MEDIATED
DEGRADATION OF CONTAMINANTS IN-SITU.

A LINE OF GROUNDWATER EXTRACTION WELLS  WOULD BE INSTALLED AROUND THE NORTH AND EAST PORTIONS OF  THE WAUSAU
CHEMICAL PROPERTY.  A CONCEPTUAL SYSTEM LAYOUT IS SHOWN ON FIGURE 8.  THE PLACEMENT OF BARRIER WELLS IS
INTENDED TO SURROUND THE SECTION (DOWNGRADIENT OF THE WAUSAU CHEMICAL SOURCES) OF THE PLUME WHERE  VOLATILE
CHLORINATED HYDROCARBON CONCENTRATIONS  GREATER THAN APPROXIMATELY 200 UG/L WERE OBSERVED. EXTRACTED
GROUNDWATER WOULD BE PUMPED TO A COMMON HEADER.   THE HEADER WOULD CONVEY WATER BACK TOWARD THE TREATMENT
SYSTEM.  THE FLOW WOULD BE SPLIT BETWEEN THE TREATMENT SYSTEM AND RECHARGE TO GROUNDWATER.

FOR A GROUNDWATER EXTRACTION RATE  OF 500 GPM,  APPROXIMATELY 300 GPM WOULD BE TREATED USING VOC STRIPPING  AND
DISCHARGED TO THE WISCONSIN RIVER.   A VOC STRIPPING TOWER WITH OFF-GAS CONTROLS WOULD BE USED FOR
TREATMENT.  CARBON ADSORPTION  WOULD BE  PROVIDED FOR OFF-GAS TREATMENT.

THE 200 GPM NOT TREATED ABOVE  GROUND AND DISCHARGED WOULD BE SUPPLEMENTED WITH NUTRIENTS AND RECHARGED OVER
THE SOUTHERN END OF THE WAUSAU CHEMICAL PROPERTY.  INFILTRATION TRENCHES FILLED WITH GRAVEL WOULD  EFFECTIVELY
DISTRIBUTE WATER OVER THE AREA.  NUTRIENTS SUCH AS NITROGEN OR PHOSPHORUS WOULD BE ADDED.  WHERE AEROBIC
CONDITIONS ARE DESIRED, HYDROGEN PEROXIDE WOULD BE FED.  A CARBON AND ENERGY SOURCE SUCH AS A METHANOL MAY BE
REQUIRED TO SUPPORT HETEROTROPHIC  GROWTH.

LABORATORY AND FIELD STUDY WOULD BE REQUIRED TO CONFIRM FEASIBILITY AT THE SITE AND DETERMINE THE  REQUIRED
OPERATING ENVIRONMENT AND CONDITIONS.   IT IS ANTICIPATED THAT PLANNING, EXECUTION AND ANALYSIS OF  LABORATORY

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STUDIES COULD BE ACCOMPLISHED WITHIN A 6-MONTH PERIOD,  AND THAT PLANNING, EXECUTION AND ANALYSIS OF  FIELD
PILOT TESTING PROGRAM COULD  BE ACCOMPLISHED WITHIN A 1.5-YEAR PERIOD, DEPENDING ON THE SCOPE AND COMPLEXITY
OF STUDIES AND ON THE OUTCOME OF  EARLY TEST PHASE ACTIVITIES.  OVERALL, A TWO-YEAR PERIOD COULD BE REQUIRED
FOR TESTING AND DEMONSTRATION.

TECHNOLOGIES DESCRIBED  IN  THIS ALTERNATIVE ARE EXPECTED TO PROVIDE PROTECTION OF CW3 BY CREATING A BARRIER TO
THE MIGRATION OF MOST OF THE CONTAMINANTS  IN THE SHALLOW EAST SIDE PLUME, IN ADDITION TO AQUIFER RESTORATION.
THIS ALTERNATIVE IS NOT EXPECTED  TO  AFFECT THE DEEP CONTAMINANT PLUME ORIGINATING ON THE WEST SIDE.

COMPUTER SIMULATION OF  THE ALTERNATIVE SHOWS THAT THE PROPOSED LINE OF EXTRACTION WELLS CAN CREATE AN
EFFECTIVE HYDRAULIC BARRIER  TO CONTAMINANT MIGRATION TO CW3 IF PUMPING RATES ARE HIGH ENOUGH.  THE SIMULATED
HEAD CONTOUR MAP SHOWN  ON  FIGURE  6 SHOWS THIS OCCURS AT A TOTAL SYSTEM PUMPING RATE OF 500 GPM AND AN
INFILTRATION RATE OF 200 GPM AT THE  SOURCE.   CONTAMINANT TRANSPORT SIMULATION SHOWS THAT PCE CONCENTRATIONS
AT CW3 WOULD DECREASE BELOW  5 UG/L AFTER APPROXIMATELY 2.5 YEARS.  COMPLETE AQUIFER PURGE TIME FOR THE  EAST
SIDE GROUNDWATER UNDER  THIS  ALTERNATIVE COULD NOT BE ESTIMATED USING THE CONTAMINANT  TRANSPORT MODEL.   THE
SIMULATION SHOWS THAT THE  GROUNDWATER  MOUND RESULTING FROM THE RECHARGE MAY FORCE A SMALL AMOUNT  (Less  Than 1
percent) OF CONTAMINATION  TO MIGRATE AROUND THE EAST SIDE OF THE EXTRACTION SYSTEM.  HOWEVER, THE MASS  NOT
CAPTURED IS NOT LIKELY  TO  RESULT  IN  DETECTABLE CONCENTRATIONS AT CW3.  PUMPING AT LOWER RATES OR WITH WIDELY
SPACED WELLS MAY NOT PROVIDE THE  DESIRED HYDRAULIC CONTROL.

COSTS FOR ALTERNATIVE 3 ARE  SUMMARIZED IN  TABLE 13.  MAJOR CAPITAL COST ITEMS INCLUDE LABORATORY AND FIELD
TESTING PROGRAMS, SYSTEM REVIEW AND  APPROVAL,  EXTRACTION WELL AND HEADER SYSTEM, STRIPPING TOWER, CARBON
ADSORBER, FOUNDATIONS,  NUTRIENT FEEDING SYSTEM,  RECHARGE TRENCH AND PIPING, CONTROLS AND UTILITIES AND
DISCHARGE PIPING.  MAJOR OPERATION AND MAINTENANCE COST ITEMS INCLUDE ENERGY COSTS, SAMPLING AND MONITORING,
ANALYTICAL LABORATORY,  ROUTINE SYSTEMS INSPECTION AND MAINTENANCE, AND REPORTING.  FOR COSTING PURPOSES, IT
IS ASSUMED A TIME PERIOD OF  SIX YEARS  WOULD BE REQUIRED.  CAPITAL COSTS ARE ESTIMATED TO BE $990,000.   THE
ANNUAL OPERATION AND MAINTENANCE  COSTS ARE ESTIMATED TO BE APPROXIMATELY $160,000.  THE 6-YEAR PRESENT  WORTH
(10 percent DISCOUNT RATE) ASSOCIATED  WITH THE ABOVE COSTS IS $1,710,000.

PROBABLE ARARS FOR ALTERNATIVE 3  ARE SUMMARIZED IN TABLE 9. CHEMICAL-SPECIFIC ARARS FOR DRINKING WATER,
GROUNDWATER, SURFACE WATER AND AIR WERE IDENTIFIED FOR THIS ALTERNATIVE.  THESE INCLUDE DRINKING WATER  MCLS
AND NR 140 GROUNDWATER  STANDARDS.  DRINKING WATER MCLS CAN BE MET BY STRIPPING TOWER TREATMENT AT THE WATER
UTILITY.  THE AQUIFER RESTORATION EFFORT WOULD BE CONSISTENT WITH NR 140 REQUIREMENTS FOR REMEDIAL RESPONSES
TO GROUNDWATER CONTAMINATION.  SURFACE WATER CRITERIA COMPLIANCE WOULD BE FEASIBLE USING STRIPPING TOWER
TREATMENT TO MEET WATER QUALITY-BASED  EFFLUENT LIMITS FOR WATER DISCHARGED TO THE WISCONSIN RIVER.   VOC
EMISSION RATE LIMITS FOR SPECIFIC COMPOUNDS WOULD BE ATTAINABLE FOR THE STRIPPING TOWER EMISSIONS.

LOCATION-SPECIFIC ARARS INCLUDE FLOODPLAIN AND POSSIBLE WELLHEAD PROTECTION AREA REQUIREMENTS.
ACTION-SPECIFIG ARARS FOR  THE GROUNDWATER  EXTRACTION, TREATMENT AND DISCHARGE SYSTEMS ARE THE SAME AS FOR
ALTERNATIVE 2.  NO PARTICULAR COMPLIANCE DIFFICULTIES ARE ANTICIPATED.  TO ACHIEVE COMPLIANCE WITH STATE
REQUIREMENTS REGARDING  INTRODUCTION  OF MATERIALS INTO GROUNDWATER OR ON LAND  (INCLUDING INJECTION WELL  AND
INFILTRATION SYSTEM RESTRICTIONS), A DEMONSTRATION THAT SIGNIFICANT ADVERSE EFFECTS WILL NOT RESULT  WOULD  BE
REQUIRED.

IMPLEMENTATION OF THE EXTRACTION  WELLS AND ABOVE GROUND TREATMENT PORTION OF THIS ALTERNATIVE IS NOT EXPECTED
TO BE A PROBLEM.  THE MAJOR  UNCERTAINTY WITH THIS TECHNOLOGY IS RELATED TO THE ABILITY TO STIMULATE  BACTERIA
TO DEGRADE THE COMPOUNDS OF  CONCERN.   THE  TECHNOLOGY IS NOT WELL DEMONSTRATED FOR THE CONTAMINANTS FOUND AT
THE SITE.

ALTERNATIVE 4 - IN-SITU BIORECLAMATION

ALTERNATIVE 4 IS AN IN-SITU  METHOD FOR REMEDIATION OF THE SHALLOW EAST SIDE GROUNDWATER UTILIZING
BIODEGRADATION OF CONTAMINANTS IN THE  GROUNDWATER.  ALTERNATIVE 4 IS SIMILAR TO ALTERNATIVE 3, EXCEPT ALL
EXTRACTED GROUNDWATER WOULD  BE RECHARGED BACK TO THE AQUIFER.  THIS ALTERNATIVE PROVIDES FOR RAPID
RESTORATION OF THE AQUIFER AND ELIMINATES  THE COSTS ASSOCIATED WITH ABOVE GROUND TREATMENT AS WITH
ALTERNATIVE 3.

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UNDER ALTERNATIVE 4, GROUNDWATER WOULD BE EXTRACTED,  SUPPLEMENTED WITH NUTRIENTS AND RECHARGED TO  THE AQUIFER
TO ENHANCE MICROBIALLY-MEDIATED CONTAMINANT DEGRADATION IN-SITU.  A LINE OF GROUNDWATER EXTRACTION WELLS
WOULD BE INSTALLED AROUND  THE NORTHERN AND EASTERN PORTIONS OF THE WAUSAU CHEMICAL PROPERTY.  THE  CONCEPTUAL
EXTRACTION AND RECHARGE  SYSTEM LAYOUT IS  THE SAME AS  THAT DEVELOPED FOR ALTERNATIVE 3  (FIGURE 8).  THE
GROUNDWATER EXTRACTION AND RECHARGE  RATES AND CONSIDERATIONS REGARDING THE ADDITION OF NUTRIENTS AND OTHER
ENHANCEMENTS TO RECHARGE WATER ARE THE SAME AS THOSE  DISCUSSED FOR ALTERNATIVE 3.

COMPUTER SIMULATION OF THE ALTERNATIVE SHOWS THAT THE PROPOSED LINE OF EXTRACTION WELLS CAN NOT  PROVIDE
COMPLETE HYDRAULIC CONTROL OF THE EXTRACTION/RECHARGE SYSTEM AT ANY PUMPING RATE.  CONTAMINANT TRANSPORT
SIMULATION SHOWS THAT PCE  CONCENTRATIONS  AT CW3 WOULD DECREASE BELOW 5 UG/L AFTER APPROXIMATELY  2.5 YEARS.
AS WITH ALTERNATIVE 3, COMPLETE AQUIFER PURGE TIME FOR THE EAST SIDE GROUNDWATER UNDER THIS ALTERNATIVE
COULD NOT BE ESTIMATED USING THE CONTAMINANT TRANSPORT MODEL.

THE SIMULATION ALSO SHOWS  THAT THE GROUNDWATER MOUND  RESULTING FROM THE RECHARGE CAUSES APPROXIMATELY 5%  OF
THE CONTAMINANT MASS TO  MIGRATE AROUND THE EAST SIDE  OF THE EXTRACTION SYSTEM TO CW3  (SEE FIGURE 6). THE
ACTUAL RECAPTURE EFFICIENCY WILL DEPEND ON SUCH FACTORS AS THE SPECIFIC SYSTEM CONFIGURATION, LOCALIZED
VARIATIONS IN AQUIFER PROPERTIES, EXTRACTION/RECHARGE RATES AND OPERATING CONDITIONS, AND LOCAL  HYDROLOGIC
FACTORS, SUCH AS PRECIPITATION, RUNOFF AND INFILTRATION RATES.  ACHIEVING A 100 PERCENT RECAPTURE  EFFICIENCY
IS NOT CONSIDERED FEASIBLE.

COSTS FOR ALTERNATIVE 4  ARE SUMMARIZED IN TABLE 14.   MAJOR CAPITAL COST ITEMS INCLUDE LABORATORY AND FIELD
TESTING PROGRAMS, SYSTEM REVIEW AND  APPROVAL,  EXTRACTION WELL AND HEADER SYSTEM, NUTRIENT FEEING SYSTEM,
RECHARGE TRENCH AND PIPING,  CONTROLS AND  UTILITIES.   MAJOR OPERATION AND MAINTENANCE COST ITEMS  INCLUDE
ENERGY COSTS, SAMPLING AND MONITORING,  ANALYTICAL LABORATORY, ROUTINE SYSTEMS INSPECTION AND MAINTENANCE,  AND
REPORTING.  AS WITH ALTERNATIVE 3, REMEDIATION PERIOD ESTIMATES WERE NOT OBTAINED USING THE CONTAMINANT
TRANSPORT MODEL.  IT WAS ASSUMED THAT ALTERNATIVE 4 WOULD REQUIRE MORE TIME THAN ALTERNATIVE 3, AND LESS  TIME
THAN ALTERNATIVE 2  (DUE  TO IN-PLACE  CONTAMINANT DEGRADATION) TO ACHIEVE REMEDIAL OBJECTIVES.  A  PERIOD OF 9
YEARS WAS ASSUMED FOR COSTING PURPOSES.   CAPITAL COSTS ARE ESTIMATED TO BE $710,000.  THE ANNUAL OPERATION
AND MAINTENANCE COSTS ARE  ESTIMATED  TO BE APPROXIMATELY $112,000.  THE 9-YEAR PRESENT WORTH  (10% DISCOUNT
RATE) ASSOCIATED WITH THE  ABOVE COSTS IS  $1,380,000.

PROBABLE ARARS FOR ALTERNATIVE 4 ARE SUMMARIZED IN TABLE 10. CHEMICAL-SPECIFIC ARARS FOR DRINKING  WATER,
GROUNDWATER, SURFACE WATER AND AIR WERE IDENTIFIED FOR THIS ALTERNATIVE.  THESE INCLUDE DRINKING WATER MCLS
AND NR 140 GROUNDWATER STANDARDS.  THE AQUIFER RESTORATION EFFORT WOULD BE CONSISTENT WITH REQUIREMENTS FOR
RESPONSES TO GROUNDWATER CONTAMINATION UNDER NR 140.

LOCATION-SPECIFIC ARARS  INCLUDE FLOODPLAIN AND POSSIBLE WELLHEAD PROTECTION AREA REQUIREMENTS.
ACTION-SPECIFIG ARARS FOR  THE GROUNDWATER EXTRACTION, TREATMENT AND DISCHARGE SYSTEMS ARE THE SAME AS FOR
ALTERNATIVE 3.

IMPLEMENTATION OF THE EXTRACTION WELLS,  TRENCHING, AND DISCHARGE PORTION OF THIS ALTERNATIVE IS  NOT EXPECTED
TO BE A PROBLEM.  THE MAJOR UNCERTAINTY WITH THIS TECHNOLOGY IS RELATED TO THE ABILITY TO STIMULATE EXISTING
BACTERIA TO DEGRADE THE  COMPOUNDS OF CONCERN IN THE  GROUNDWATER.  THIS TECHNOLOGY IS NOT WELL DEMONSTRATED
FOR THE CONTAMINANTS FOUND AT THE SITE.

ALTERNATIVE 5 - ACTIVE SOURCE CONTROL-SOIL VAPOR EXTRACTION

ALTERNATIVE 5 IS A SOURCE  CONTROL ALTERNATIVE UTILIZING IN-SITU SOIL VAPOR EXTRACTION  (SVE) TO REMOVE
CONTAMINANTS FROM UNSATURATED SOILS  THEREBY REDUCING THE POTENTIAL FOR FUTURE CONTAMINANT RELEASES TO
GROUNDWATER.  CONTAMINANTS VACUUMED  FROM THE SOIL, IN THE VAPOR PHASE, WOULD BE TREATED USING VAPOR PHASE
CARBON UNITS, PRIOR TO RELEASE TO THE ATMOSPHERE.  THE SCOPE OF ALTERNATIVE 5 INCLUDES REMEDIATION OF
UNSATURATED SOILS AT THE FORMER CITY LANDFILL/MARATHON ELECTRIC PROPERTY, WAUSAU CHEMICAL AND WAUSAU ENERGY.

FOR THE FORMER LANDFILL  AREA, SOIL GAS EXTRACTION WELLS WOULD BE INSTALLED WITHIN THE LIMITS OF  THE FILL  IN
THE NORTHERN PORTION OF  THE LANDFILL WHERE THE HIGHEST VOC CONCENTRATIONS HAVE BEEN OBSERVED.  A CONCEPTUAL
SYSTEM LAYOUT IS SHOWN ON  FIGURE 9.   A HEADER PIPE WOULD BE INSTALLED TO CONNECT THE WELLS TO AN INDUCTION
FAN BLOWER.  THE BLOWER  AND CONTROL  PANEL WOULD BE HOUSED IN A SMALL SHED. IT IS ANTICIPATED   THAT AIR

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RECHARGE WELLS WOULD BE REQUIRED AND ARE  INCLUDED IN THE DESIGN & COST OF THE ALTERNATIVE.

A SIMILAR TYPE OF SOIL GAS  EXTRACTION  SYSTEM WOULD BE INSTALLED ON THE WAUSAU CHEMICAL PROPERTY.   SOIL  GAS
WOULD BE EXTRACTED NEAR THE FORMER TANK STORAGE AREA.  THIS AREA IS NEAR THE CENTER OF HIGH SOIL GAS VOC
CONCENTRATIONS OBSERVED AT  THE  SITE.   A SECOND EXTRACTION AREA WOULD BE LOCATED NEAR THE NORTH END OF THE
BUILDING.  A HEADER WOULD CONNECT  THE  EXTRACTION WELLS TO A COMMON BLOWER.  AIR RECHARGE WELLS WOULD ALSO BE
ANTICIPATED FOR THIS SYSTEM.  CONCEPTUAL  LAYOUT IS SHOWN ON FIGURE 10. PILOT STUDY RESULTS INDICATE A RADIUS
OF INFLUENCE OF APPROXIMATELY 85 FEET  WAS OBTAINED AT A GAS EXTRACTION RATE OF 72 SCFM.  A SOIL GAS
EXTRACTION SYSTEM WOULD ALSO BE INSTALLED AT THE WAUSAU ENERGY PROPERTY ON THE SOUTH SIDE OF THE BUILDING.
SOIL TYPES ENCOUNTERED IN ON-SITE  BORINGS WERE SIMILAR TO THOSE ENCOUNTERED AT SEVERAL WAUSAU CHEMICAL   SITE
BORINGS AND IT IS THEREFORE, ASSUMED THAT THE RADIUS OF INFLUENCE WOULD BE SUFFICIENT TO COVER THE ENTIRE
FACILITY.

TECHNOLOGIES DESCRIBED IN THIS  ALTERNATIVE WOULD REDUCE THE TIME REQUIRED TO MEET RESPONSE OBJECTIVES FOR
GROUNDWATER CLEAN-UP, BECAUSE THERE WILL  BE A REDUCTION IN CONTAMINANT LOADING TO THE AQUIFER, BY  REDUCING
CONTAMINANT LEVELS IN THE UNSATURATED  ZONE SOILS.  HOWEVER, SUBSTANTIAL REDUCTIONS IN EXISTING CONTAMINANT
CONCENTRATIONS IN GROUNDWATER WOULD NOT BE EXPECTED TO OCCUR AS A RESULT OF VAPOR EXTRACTION AT THE SOURCE.

BASED ON COMPUTER SIMULATIONS DURING DEVELOPMENT OF THE FS, IT WAS SHOWN THAT EXTRACTION OF GROUNDWATER ON
THE EAST SIDE IN THE VICINITY OF THE WAUSAU CHEMICAL SOURCE AREA WOULD CREATE A GROUNDWATER DIVIDE WHERE
CONTAMINANTS WOULD GET "HUNG UP" DUE TO COMPETITION FOR WATER BETWEEN CW3 AND THE EXTRACTION SYSTEM (SEE
DISCUSSION UNDER ALTERNATIVE 2). BECAUSE  OF THIS PHENOMENON, EXTRACTING GROUNDWATER AT THE SOURCE  RESULTS
IN A LONGER PERIOD TO PURGE THE AQUIFER THAN ALLOWING CONTAMINANTS TO FLOW TO THE CURRENTLY OPERATING CITY
SUPPLY WELLS.  IT WAS, THEREFORE,  DETERMINED THAT CITY SUPPLY WELLS CW6 AND CW3 WOULD BE INCORPORATED INTO
THE SOURCE CONTROL ALTERNATIVE  AS  THE  MEANS FOR ADDRESSING GROUNDWATER CONTAMINATION REMEDIATION.

COMPUTER MODELING OF THIS ALTERNATIVE  WAS PERFORMED BY DECREASING THE CONTAMINANT LOADING RATES FROM SOILS  TO
ZERO AFTER 1.5 YEARS TO SIMULATE REMOVAL  OF THE SOURCES.  TWO DIFFERENT COMPUTER SIMULATIONS WERE  PERFORMED
TO DETERMINE THE OPTIMUM PUMPAGE RATES FOR THE CITY'S SUPPLY WELLS CW3 AND CW6.  IT WAS DETERMINED THAT
INCREASED PUMPAGE OF THE SUPPLY WELLS  RESULT IN A REDUCED TIME PERIOD FOR REMEDIATION UNDER THIS ALTERNATIVE.

BASED ON THE SIMULATION, A  TCE  CONCENTRATION OF LESS THAN 5 UG/L COULD BE ACHIEVED AT CW6 AFTER APPROXIMATELY
4.5 YEARS.  TCE CONCENTRATIONS  AT  CW3  RESULTING FROM MIGRATION FROM THE LANDFILL WOULD BE LESS THAN 5 UG/L
AFTER APPROXIMATELY 4 YEARS.  WELLS CW3 AND CW6 WOULD CONTINUE TO DRAW IN CONTAMINANTS FROM THE LANDFILL FOR
6 AND 14 YEARS, RESPECTIVELY.   PCE CONCENTRATIONS AT PRODUCTION WELL CW3 WOULD BE REDUCED TO LESS  THAN  5 UG/L
AFTER APPROXIMATELY 3.3 YEARS AND  WELL CW3 WOULD NO LONGER DRAW IN CONTAMINANTS FROM THE WAUSAU CHEMICAL
SOURCES AFTER APPROXIMATELY 5 YEARS.

IT IS NOT ANTICIPATED THAT  VOC  EMISSIONS  FROM THE WATER UTILITY STRIPPING TOWERS WOULD BE HIGHER THAN THOSE
ASSUMED FOR MODELING OF AIR EMISSIONS.  NO OFF-GAS CONTROLS ARE PROPOSED FOR THE WATER UTILITY   STRIPPING
TOWERS CONSIDERING THAT THEIR OPERATION WOULD PRODUCE EMISSIONS WITHIN THE ACCEPTABLE RISK LEVEL OF (10-6)
AND THEREFORE ARE CONSIDERED REPRESENTATIVE OF BASELINE CONDITIONS.  THE SOIL VAPOR EXTRACTION SYSTEMS  WOULD
REPRESENT NEW SOURCES.  BASED ON PRELIMINARY RISK CALCULATIONS, RISKS ASSOCIATED WITH NEW VOC EMISSIONS IN
THE AREA WOULD NEED TO BE ADDRESSED.   VAPOR PHASE CARBON IS THEREFORE INCLUDED FOR OFF-GAS TREATMENT FOR
THESE SYSTEMS.

COSTS FOR ALTERNATIVE 5 ARE SUMMARIZED IN TABLE 15.  MAJOR CAPITAL COST ITEMS INCLUDE SOIL GAS EXTRACTION AND
AIR RECHARGE WELLS, HEADER  PIPE LINE,  BLOWER,  MOTOR, CONTROLS AND A SHELTER TO PROTECT EQUIPMENT.   MAJOR
OPERATION AND MAINTENANCE COST  ITEMS INCLUDE CARBON, ELECTRICITY, MONITORING AND ANALYTICAL LABORATORY  COSTS,
ROUTINE SYSTEMS INSPECTION  AND  MAINTENANCE,  AND REPORTING.  CAPITAL COSTS ARE ESTIMATED TO BE $252,000.
OPERATION COSTS ARE ESTIMATED TO BE $222,000.   PRESENT WORTH COSTS ARE ESTIMATED TO BE $474,000.   AN 18-MONTH
OPERATING PERIOD WAS ASSUMED AND COSTS WERE NOT DISCOUNTED.

USE OF THE CITY PRODUCTION  WELLS AS PART  OF THE REMEDY REQUIRES THAT THE COST OF OPERATING AND MAINTAINING
THE WELLS AND STRIPPING TOWERS  BE  CONSIDERED PART OF THE COST OF THE REMEDY.  COSTS WERE DEVELOPED BASED    ON
OPERATING THE 8-FT DIAMETER TOWER  AT THE  WAUSAU WATER UTILITY.  MAJOR ITEMS INCLUDE ENERGY COSTS FOR PUMPING
WELLS AND STRIPPING TOWERS,  AND OPERATION AND MAINTENANCE OF STRIPPING TOWERS.  IT WAS ASSUMED THAT FOR EACH

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CITY PRODUCTION WELL, THE  TIME  UNTIL NO MORE CONTAMINANTS ARE DRAWN IN TO A WELL REPRESENTS THE TIME  OF
OPERATION.  THE ESTIMATED  PRESENT WORTH OF THE CITY OPERATING THE TWO CITY WELLS AND TREATING THE WATER  IS
$260,000.  OPERATING CW6 AND  TREATING ITS  WATER FOR VOC REMOVAL FOR 14 YEARS ACCOUNTS FOR $180,000.   THE
CORRESPONDING COST FOR CW3 FOR  A 6-YEAR OPERATING PERIOD IS $80,000.  THE ESTIMATED TOTAL PRESENT WORTH  COST
OF ALTERNATIVE 5 IS $734,000.

PROBABLE ARARS FOR ALTERNATIVE  5 ARE SUMMARIZED IN TABLE 11. CHEMICAL-SPECIFIC ARARS ADDRESSING DRINKING
WATER, GROUNDWATER AND AIR QUALITY  STANDARDS WERE IDENTIFIED FOR ALTERNATIVE 5.  THESE INCLUDE DRINKING  WATER
MCLS AND NR 140 GROUNDWATER STANDARDS.   DRINKING WATER STANDARDS FOR VOCS CAN BE MET AT THE WATER UTILITY
USING VOC STRIPPING TOWER  TREATMENT.   THIS ALTERNATIVE WOULD MEET THE REQUIREMENTS FOR RESPONSE UNDER CHAPTER
NR 140.  MEETING STATE EMISSION LIMITS  CAN BE ACHIEVED WITHOUT CONTROLS FOR SPECIFIC ORGANIC COMPOUNDS.

LOCATION-SPECIFIC ARARS INCLUDE REQUIREMENTS RELATED TO ACTIVITIES WITHIN FLOODPLAINS AND WELLHEAD  PROTECTION
AREAS.  ACTION-SPECIFIG ARARS INCLUDE LANDFILL PROPERTY USE RESTRICTIONS.  COMPLIANCE WITH   POSSIBLE FUTURE
REQUIREMENTS SHOULD NOT BE A  PROBLEM.

IMPLEMENTATION OF THIS ALTERNATIVE  IS NOT  EXPECTED TO BE A PROBLEM.  THE TECHNOLOGY IS READILY AVAILABLE AND
WELL DEMONSTRATED.  NO UNUSUAL  FEATURES ARE ANTICIPATED WITH IMPLEMENTATION AND OPERATION OF THE    SYSTEM.

VIII.  SUMMARY OF COMPARATIVE ANALYSIS  OF  ALTERNATIVES

IN ORDER TO DETERMINE THE  MOST  APPROPRIATE ALTERNATIVE THAT IS PROTECTIVE OF HUMAN HEALTH AND THE
ENVIRONMENT, ATTAINS ARARS, IS  COST-EFFECTIVE,  AND UTILIZES PERMANENT SOLUTIONS AND TREATMENT TECHNOLOGIES  TO
THE MAXIMUM EXTENT PRACTICABLE,  ALTERNATIVES WERE EVALUATED AGAINST EACH OTHER.  COMPARISONS WERE BASED  ON
THE NINE EVALUATION CRITERIA  OUTLINED IN SARA.   A SUMMARY OF THE COMPARISON IS PROVIDED IN TABLE 16.
FOLLOWING IS A DISCUSSION  OF  EACH OF THE CRITERIA AND A SUMMARY OF THE ALTERNATIVES' PERFORMANCE AGAINST EACH
OF THESE.

1.  OVERALL PROTECTION OF  HUMAN HEALTH AND THE ENVIRONMENT:

EACH OF THE ALTERNATIVES  (EXCEPT NO ACTION)  WILL ACHIEVE REDUCTION OF RISKS FROM CONTAMINANTS AND PATHWAYS  OF
CONCERN IDENTIFIED FOR THE SITE. HOWEVER,  THE ALTERNATIVES DIFFER IN THE TIME NEEDED TO PURGE THE AQUIFER OF
CONTAMINANTS, AND THUS TIME TO  REDUCE RISKS FROM DRINKING WATER, GROUNDWATER, AND AIR EMISSIONS.  ALTERNATIVE
1 REQUIRES THE LONGEST TIME TO  ACHIEVE  CLEAN-UP.   ALTERNATIVE 2 REQUIRES THE NEXT LONGEST PERIOD.
ALTERNATIVES 3 AND 4 REQUIRE  SIMILAR PERIODS FOR REMEDIATION OF THE EAST SIDE CONTAMINANT PLUME WHICH IS
EXPECTED TO BE SHORTER THAN PUMP AND TREAT UNDER ALTERNATIVE 2.  HOWEVER, AS WITH ALTERNATIVE 2, ALTERNATIVES
3 AND 4 DO NOT PROVIDE ANY REDUCTION IN TIME FOR PURGING OF THE DEEP PLUME MIGRATING UNDER THE RIVER  TO  CW3.
THIS RESULTS IN A SIGNIFICANTLY LONG TIME  PERIOD FOR CONTAMINANTS TO REMAIN IN THE AQUIFER.  IN ADDITION,
THERE IS SOME UNCERTAINTY  AS  TO WHETHER IN-SITU BIORECLAMATION WOULD PERFORM AS PREDICTED FOR THE
CONTAMINANTS PRESENT AT THE SITE. ALTERNATIVE 5 ACHIEVES SOURCE REDUCTION WHICH RESULTS IN A SUBSTANTIAL
REDUCTION IN TIME FOR REMEDIATION OF CONTAMINATION IN THE AQUIFER. INCREASED PUMPAGE OF CITY SUPPLY WELLS AS
CALLED FOR UNDER THIS ALTERNATIVE,  FURTHER REDUCES THE TIME FOR REMEDIATION OF THE SITE.

2.  COMPLIANCE WITH ARARS:

ALL APPLICABLE OR RELEVANT AND  APPROPRIATE REQUIREMENTS UNDER FEDERAL AND STATE ENVIRONMENTAL REGULATIONS ARE
MET BY ALTERNATIVES 2, 3,  4 AND 5.   ALTERNATIVE 1 (NO ACTION)  WOULD NOT COMPLY WITH WISCONSIN NR 140
REQUIREMENTS FOR RESPONSE  WHEN  GROUNDWATER QUALITY STANDARDS ARE EXCEEDED.  THEREFORE, THE NO ACTION
ALTERNATIVE WILL NOT BE INCLUDED IN THE DISCUSSIONS THAT FOLLOW PERTAINING TO EVALUATION OF ALTERNATIVES
AGAINST THE REMAINING CRITERIA.

SUPERFUND MONIES MAY NOT BE ABLE TO BE  USED AT THE WAUSAU ENERGY SOURCE AREA IF IT IS DETERMINED THAT
CONTAMINANTS FROM THIS SOURCE ARE STRICTLY DERIVED FROM A PETROLEUM SOURCE.  HOWEVER, THE WISCONSIN HAZARDOUS
SUBSTANCES SPILL LAW DOES  INCLUDE A PROVISION TO ADDRESS SUCH SPILLS AND WOULD BE PURSUED.

3.  LONG-TERM EFFECTIVENESS:

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THE ALTERNATIVES DIFFER  IN THE  TIME  REQUIRED TO ACHIEVE VARIOUS OBJECTIVES, BUT IN THE LONG-TERM, EACH OF THE
ACTION ALTERNATIVES IS EXPECTED TO ACHIEVE  COMPLIANCE WITH MCLS AND STATE GROUNDWATER STANDARDS  (NR  140) IN
THE AQUIFER.  TABLE 16 LISTS THE TIME  PERIOD REQUIREMENT FOR EACH OF THE ALTERNATIVES.

4.  REDUCTION OF TOXICITY, MOBILITY  OR VOLUME:

ALTERNATIVES 3 AND 4 PROVIDE TOXICITY  REDUCTION AS A RESULT OF CONTAMINANT DEGRADATION.  VOLUME AND  TOXICITY
REDUCTIONS ARE PROVIDED  BY ALTERNATIVES  2,  3 AND 5 AS A RESULT OF CONTAMINANT ADSORPTION ON VAPOR  PHASE
CARBON AND SUBSEQUENT DESTRUCTION DURING THERMAL REGENERATION OF THE CARBON.

5. SHORT-TERM EFFECTIVENESS:

THE SHORT-TERM RISKS ASSOCIATED WITH IMPLEMENTATION ARE NOT EXPECTED TO BE A PROBLEM FOR ANY OF THE
ALTERNATIVES.  ALL OF THE ALTERNATIVES (INCLUDING THE PHASE I REMEDY)  WILL RESULT IN CONTAMINATED MATERIAL
BEING BROUGHT TO THE SURFACE, HOWEVER  NO APPRECIABLE RISKS TO RESIDENTS ARE EXPECTED, AND WORKERS CAN USE
CONVENTIONAL PERSONNEL PROTECTIVE GEAR.

SHORT-TERM RISKS ASSOCIATED WITH OPERATION  OF THE ALTERNATIVES VARY. CARBON TREATMENT OF OFF-GASES GENERATED
BY STRIPPING OF VOCS IS  PLANNED FOR  ALTERNATIVES 2,5, AND THE PUMP AND TREAT PORTION OF ALTERNATIVE  3.
ALTERNATIVE 4 AND THE BIORECLAMATION PORTION OF ALTERNATIVE 3 DO HAVE POTENTIAL RISKS ASSOCIATED WITH THE
ADDITIVES NECESSARY FOR  CONTAMINANT  BREAKDOWN AND THE TRANSFORMATION PRODUCTS FROM THE PROCESS.  RISKS FROM
THESE ALTERNATIVES WOULD RESULT IF THE CONTAMINANTS WERE NOT BROKEN DOWN COMPLETELY BEFORE REACHING  CW3, OR
IF ADDITIVES FROM THE PROCESS WERE TO  REACH CW3.

THE ALTERNATIVES DIFFER  IN THE  TIME  NEEDED  TO PURGE THE AQUIFER OF CONTAMINANTS.  ALTERNATIVE 2 REQUIRES THE
LONGEST TIME TO ACHIEVE  AQUIFER PURGING.  THIS IS BECAUSE PUMPING OF EXTRACTION WELLS AT WAUSAU CHEMICAL IN
CONJUNCTION WITH CW3 WOULD CREATE A  GROUNDWATER DIVIDE THAT WOULD ACTUALLY CAUSE CONTAMINANTS TO BE  HELD UP
LONGER IN THE AQUIFER. IN ADDITION,  THIS ALTERNATIVE WOULD NOT REDUCE THE TIME FRAME DURING   WHICH
CONTAMINANTS WOULD CONTINUE TO  IMPACT  CW6 ON THE WEST SIDE OF THE RIVER.  ALTERNATIVES 3 AND 4 REQUIRE
SIMILAR PERIODS FOR REMEDIATION OF THE EAST SIDE CONTAMINANT PLUME WHICH IS EXPECTED TO BE SHORTER THAN PUMP
AND TREAT UNDER ALTERNATIVE 2.   HOWEVER,  AS WITH ALTERNATIVE 2, THESE ALTERNATIVES DO NOT PROVIDE ANY
REDUCTION IN TIME FOR PURGING OF THE DEEP TCE PLUME MIGRATING UNDER THE RIVER TO CW3.  ALTERNATIVE 5 RESULTS
IN A SUBSTANTIAL REDUCTION IN TIME FOR REMEDIATION OF CONTAMINATION IN THE AQUIFER BECAUSE IT ADDRESSES THE
SOURCE AREAS ON BOTH SIDES OF THE RIVER.  ADDED CONTROLS ON PUMPING RATES OF CITY SUPPLY WELLS FURTHER
REDUCES THE TIME FOR REMEDIATION UNDER THIS ALTERNATIVE.

6.  IMPLEMENTABILITY:

TECHNOLOGIES USED FOR ALTERNATIVES 2 AND 5,  AND PART OF 3, ARE CONVENTIONAL AND WELL DEMONSTRATED.
BIORECLAMATION AS PROPOSED FOR  ALTERNATIVE  4 AND PART OF ALTERNATIVE 3 IS NOT CONVENTIONAL OR WELL
DEMONSTRATED FOR THE TYPES OF CHEMICALS  FOUND AT THE SITE.  IN ADDITION, Us EPA'S OFFICE OF RESEARCH AND
DEVELOPMENT  (ORD) HAS REVIEWED  THE POTENTIAL FOR IN-SITU BIORECLAMATION AND HAS EXPRESSEDCONCERN OVER THE
UNCERTAINTIES REGARDING  WHETHER THIS TECHNOLOGY WOULD WORK FOR THE CONTAMINANTS FOUND AT THE SITE.
IMPLEMENTATION WOULD REQUIRE FAIRLY  EXTENSIVE LABORATORY AND FIELD TESTING PRIOR TO START-UP. IT IS  ESTIMATED
THAT APPROXIMATELY TWO YEARS WOULD BE  REQUIRED PRIOR TO FULL SCALE OPERATION OF A BIORECLAMATION SYSTEM AT
THE SITE.

ADMINISTRATIVELY, ALTERNATIVE 5 WOULD  REQUIRE THE LEAST AMOUNT OF COORDINATION.  ALTERNATIVES 2, AND THE
ABOVE GROUND PORTION OF  3 REQUIRE ADDITIONAL COORDINATION BECAUSE OF TREATMENT AND DISCHARGE SYSTEM.
ALTERNATIVE 4 AND THE IN-SITU PORTION  OF 3  WOULD BE ADMINISTRATIVELY DIFFICULT BECAUSE THE TECHNOLOGY IS
RELATIVELY UNKNOWN, AND  REQUIRES REINJECTION OF WATER BACK INTO THE GROUND.

THERE ARE NO DIFFICULTIES ANTICIPATED  IN OBTAINING MATERIALS FOR ANY OF THE ALTERNATIVES. MATERIALS  ARE
AVAILABLE AND CONSIDERED CONVENTIONAL  AND READILY AVAILABLE.

7.  COST:

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COMPARISON OF PRESENT WORTH  COSTS  FOR THE  ALTERNATIVES INDICATES THAT ALTERNATIVE 5 IS THE LEAST COSTLY AT
$738,000.  THIS IS DUE TO THE  SHORTER OPERATION TIME OF THE SOURCE CONTROL ACTION AND THE REDUCED O&M  COSTS
ASSOCIATED WITH THE CITY AIR STRIPPERS DUE TO THE REDUCED TIME REQUIRED FOR THEIR USE.  ALTERNATIVE 2 HAS THE
NEXT LOWEST PRESENT WORTH COST AT  $1,330,000.   ALTERNATIVE 4 IS SOMEWHAT HIGHER AT $1,380,000 AND THE PRESENT
WORTH COST FOR ALTERNATIVE 3 IS HIGHEST AT $1,710,000 DUE TO THE COMBINATION OF SYSTEMS USED.  ALTERNATIVE  1
HAS NO ASSOCIATED COSTS.

8.   STATE ACCEPTANCE:

THE STATE HAD EXPRESSED INTEREST IN A BIORECLAMATION ALTERNATIVE IF ONE SHOWED PROMISE FOR THE SITE.
HOWEVER, BECAUSE OF THE NEED FOR EXTENSIVE LABORATORY AND FIELD PILOT STUDIES, THE STATE HAS AGREED THAT A
BIORECLAMATION ALTERNATIVE SHOULD  NOT BE PURSUED FOR THE SITE.  THE STATE SUPPORTS ALTERNATIVE 5 DUE TO ITS
ABILITY TO REDUCE AQUIFER PURGE TIMES AT A LOW COST.

9.   COMMUNITY ACCEPTANCE:

THE CITY OF WAUSAU, MARATHON ELECTRIC,  AND WAUSAU CHEMICAL, ALL OF WHICH ARE PRPS, HAVE EXPRESSED A
PREFERENCE FOR ALTERNATIVE FIVE.   THE COMMUNITY IN WAUSAU HAS NOT EXPRESSED A PREFERENCE FOR ANY ALTERNATIVE.
SPECIFIC COMMENTS RECEIVED DURING  THE PUBLIC COMMENT PERIOD AND AT THE PUBLIC MEETING FOR THE PROPOSED PLAN
ARE ADDRESSED IN THE RESPONSIVENESS SUMMARY INCLUDED WITH THIS DOCUMENT.

SUMMARY OF COMPARISON

UNDER ALTERNATIVE 1 (NO ACTION), CONTAMINANTS WOULD BE PURGED ONLY THROUGH PUMPING OF THE SUPPLY WELLS AND
THE WEST SIDE EXTRACTION WELL. NOTHING WOULD BE DONE TO REDUCE CONTAMINANT LOADING TO THE AQUIFER FROM SOURCE
AREAS NOR TO EXPEDITE REMOVAL  OF CONTAMINANTS IN THE EAST WELL FIELD.  GIVEN THE NATURE AND LOCATION OF THE
SITE, THIS ALTERNATIVE IS NOT  CONSISTENT WITH THE OBJECTIVES FOR REMEDIAL ACTION AT THE SITE AND IS THEREFORE
NOT CONSIDERED A VIABLE OPTION FOR THE SITE.   IN ADDITION, WISCONSIN GROUNDWATER STANDARDS UNDER NR 140 WOULD
NOT BE MET UNDER THIS ALTERNATIVE.  NR 140 HAS BEEN DETERMINED TO BE AN ARAR FOR THE SITE.

ALTHOUGH ALL OF THE OTHER ALTERNATIVES WILL ACHIEVE AQUIFER PURGING IN THE LONG-TERM, THERE ARE SIGNIFICANT
DIFFERENCES IN THE TIME TO PURGE THE  GROUNDWATER.  ALTERNATIVES 2, 3, AND 4 ARE GROUNDWATER REMEDIATION
ALTERNATIVES THAT DO NOT ADDRESS REMEDIATION OF SOURCE AREAS.  IN ADDITION, THEY DO NOT PROVIDE ANY REDUCTION
IN THE TIME TO REMEDIATE THE DEEP  PLUME ORIGINATING FROM THE LANDFILL.  THIS RESULTS IN A SIGNIFICANT TIME
PERIOD TO ACHIEVE THE RESPONSE OBJECTIVES.   IN ADDITION,  THE ACTUAL TIME FRAME FOR AQUIFER PURGING UNDER THE
BIOREMEDIATION ALTERNATIVES  CANNOT BE DETERMINED, SO AN ESTIMATE IS BASED ON GROUNDWATER FLOW. ALTERNATIVE  5,
SOURCE CONTROL, REQUIRES THE SHORTEST TIME PERIOD FOR REMEDIATION OF THE SITE BECAUSE IT ELIMINATES THE
CONTINUED ADDITION OF CONTAMINANTS TO THE  GROUNDWATER AND PROVIDES FOR THE REMOVAL OF REMAINING CONTAMINANTS
IN GROUNDWATER THROUGH PUMPING OF  CW3 AND  CW6.  ALTERNATIVE 5 ALSO PROVIDES FOR A REDUCTION IN TIME TO PURGE
THE DEEP WEST SIDE PLUME BY  REMOVING  THE SOURCE AND SPECIFYING PUMPING RATES FOR THE CITY'S SUPPLY WELLS CW3
AND CW6.

ALL OF THE ALTERNATIVES  (OTHER THAN NO ACTION)  PROVIDE A REDUCTION IN TOXICITY OF CONTAMINANTS.  ALTERNATIVES
2,  5 AND THE PUMP AND TREAT  PORTION OF 3 PROVIDE A REDUCTION IN VOLUME AS WELL.  ALTERNATIVES 2 AND 5 USE
PROVEN TECHNOLOGIES THAT CAN EASILY BE IMPLEMENTED AND HAVE A LOW POTENTIAL FOR FAILURE, AND THE PROPOSED
ACTIONS WILL HAVE NO PROBLEM COMPLYING WITH FEDERAL AND STATE ARARS.   ALTERNATIVES 3 AND 4 USE A TECHNOLOGY
THAT MAY  NOT BE COMPLETELY  EFFECTIVE ON THE CONTAMINANTS PRESENT AT THE SITE.  IN ADDITION, SOME OF THE
REQUIRED ADDITIVES NEEDED TO ENHANCE  BIODEGRADATION, COULD EXCEED THE STATE'S NR 140 GROUNDWATER STANDARDS
FOR THOSE SUBSTANCES.

COSTS AND IMPLEMENTATION TIMES FOR ALTERNATIVES VARY AS WELL. ALTERNATIVE 5, SOURCE CONTROL, IS THE LEAST
COSTLY AND REQUIRES THE SHORTEST TIME PERIOD TO IMPLEMENT AND COMPLETE THE REMEDIAL ACTION. ALTERNATIVE 2 HAS
THE NEXT LOWEST COST AND REQUIRES  A SIMILAR IMPLEMENTATION PERIOD.  ALTERNATIVES 3 AND 4 HAVE THE HIGHEST
COSTS ASSOCIATED WITH THEM DUE TO  THE BIORECLAMATION TECHNOLOGY PROPOSED. THESE ALTERNATIVES ALSO REQUIRE THE
LONGEST IMPLEMENTATION TIME. A PERIOD OF 2 YEARS TO BEGIN THE PROCESS WILL BE REQUIRED DUE TO THE NEED FOR
EXTENSIVE TESTING PRIOR TO START UP.

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#SR
IX.  SEIiECTED REMEDY AND  STATUTORY DETERMINATIONS

SECTION 121 OF SARA REQUIRED  THAT  ALL REMEDIES FOR SUPERFUND SITES BE PROTECTIVE OF HUMAN HEALTH AND  THE
ENVIRONMENT, COMPLY WITH  ARARS,  BE COST-EFFECTIVE,  AND UTILIZE PERMANENT SOLUTIONS AND ALTERNATE TREATMENT
TECHNOLOGIES TO THE MAXIMUM EXTENT PRACTICABLE.   ALTERNATIVE 5 IS BELIEVED TO PROVIDE THE BEST BALANCE  OF
TRADE-OFFS AMONG ALTERNATIVES WITH RESPECT TO THE CRITERIA USED TO EVALUATE REMEDIES.  BASED ON THE
EVALUATION OF THE ALTERNATIVES,  Us EPA AND THE STATE OF WISCONSIN BELIEVE THAT ALTERNATIVE 5 WOULD BE
PROTECTIVE, ATTAIN ARARS,  BE  COST-EFFECTIVE,  AND WILL UTILIZE PERMANENT SOLUTIONS AND ALTERNATE TREATMENT
TECHNOLOGIES OR RESOURCE  RECOVERY  TECHNOLOGIES TO THE MAXIMUM EXTENT PRACTICABLE.

THE SELECTED REMEDY ENTAILS:

       *    INSTALLATION  OF SOIL VAPOR EXTRACTION (SVE)  SYSTEMS TO REMOVE
            VOCS IN SOILS AT  EACH  OF THE THREE IDENTIFIED SOURCE AREAS;

       *    TREATMENT OF  OFF-GASES FROM THE SVE OPERATION USING VAPOR
            PHASE CARBON  UNITS WHICH WILL BE REGENERATED AT AN OFF-SITE
            RCRA APPROVED FACILITY;  AND

       *    GROUNDWATER REMEDIATION UTILIZING SPECIFIED PUMPAGE RATES OF
            THE MUNICIPAL SUPPLY WELLS IN ORDER TO EXPEDITE REMOVAL OF THE
            GROUNDWATER CONTAMINANT PLUMES AFFECTING THESE WELLS.

       *    TREATMENT OF  GROUNDWATER UTILIZING EXISTING CITY AIR STRIPPERS

THE RESPONSE OBJECTIVES FOR THE  FINAL REMEDY ARE TO ELIMINATE RISKS TO GROUNDWATER BY REDUCING THE SOURCE OF
CONTAMINANTS IN SOURCE AREAS' SOILS,  AND TO MINIMIZE VOC EMISSIONS TO AIR FROM THE EXISTING AND PROPOSED
TREATMENT PROCESSES.  THE PERFORMANCE STANDARDS FOR THE SVE IN SOURCE SOILS WILL BE DETERMINED USING  A
MASS-FLUX GROUNDWATER MODEL TO DETERMINE WHAT CLEANUP LEVELS ARE NEEDED IN SOILS TO ACHIEVE CLEANUP OF  THE
AQUIFER.  THESE CLEANUP LEVELS WILL BE BASED ON THE REQUIREMENT TO ATTAIN WISCONSIN NR 140 GROUNDWATER
STANDARDS FOR PCE, 1.0 UG/L,  AND TCE,  1.8 UG/L AT THE SOURCE BOUNDARY.  ATTAINMENT OF CLEANUP LEVELS  WILL BE
CONFIRMED THROUGH SAMPLE  ANALYSIS  OF GROUNDWATER AT THE BOUNDARY OF THE SOURCE AREAS.

THE FINAL REMEDY INCORPORATES THE  INTERIM REMEDY SUCH THAT THE WEST SIDE EXTRACTION SYSTEM IS CONSIDERED PART
OF THE OVERALL SITE REMEDIATION. IT IS EXPECTED TO ADDRESS THE TCE CONTAMINATION ORIGINATING FROM THE  FORMER
CITY LANDFILL/MARATHON ELECTRIC  SOURCE AREA WHICH MIGRATES TO BOTH CW6 AND CW3.  IT ALSO INCLUDES A PROVISION
FOR AN ADDITIONAL EXTRACTION  WELL  IF REQUIRED TO OBTAIN THE DESIRED PERFORMANCE OBJECTIVES.  THE INTERIM ROD
DID NOT SPECIFY A TIME PERIOD FOR  OPERATION OF THE WEST SIDE EXTRACTION SYSTEM BECAUSE CONTAMINANT TRANSPORT
MODELING HAD NOT BEEN COMPLETED  AT THE TIME.   IT IS NOW ANTICIPATED THAT THIS SYSTEM WILL BE REQUIRED TO
OPERATE FOR APPROXIMATELY 14  YEARS;  UNTIL LEVELS OF TCE ARE NOT DETECTED ABOVE THE WISCONSIN NR 140 STANDARD
OF 1.8 UG/L AT SPECIFIED  POINTS  OF COMPLIANCE.

HE COSTS ESTIMATED FOR ALTERNATIVE 5 DO NOT INCLUDE COSTS FOR OPERATING THE INTERIM REMEDY EXTRACTION WELL.
FIVE YEARS OF OPERATION AND MAINTENANCE COSTS FOR THE INTERIM REMEDY WERE ESTIMATED IN THE INTERIM ROD.  IT
IS NOW ESTIMATED THAT THE SYSTEM WILL BE REQUIRED TO OPERATE FOR APPROXIMATELY 14 YEARS.  THIS WILL REQUIRE
AN ADDITIONAL 9 YEARS OF  O&M  AND WILL RESULT IN ADDITIONAL COSTS FOR THAT SYSTEM. ESTIMATED COSTS FOR O&M OF
THE INTERIM SYSTEM WERE ESTIMATED  TO BE $140,000 PER YEAR.  HOWEVER IT IS EXPECTED THAT ACTUAL O&M COSTS FOR
THE SYSTEM WILL BE SOMEWHAT LESS DUE TO OVERLAP OF MONITORING REQUIREMENTS FOR THE REMAINING PORTIONS OF THE
SITE.

THE FINAL REMEDY ALSO WILL REQUIRE THAT EXISTING GROUNDWATER EXTRACTION SYSTEMS CURRENTLY OPERATING IN  THE
EAST WELL FIELD, OTHER THAN CITY SUPPLY WELL CW3,  CEASE OPERATION ONCE THE SVE SYSTEM IS INSTALLED. THIS  IS
NECESSARY IN ORDER TO OBTAIN  THE DESIRED RESULT OF PURGING CONTAMINANTS FROM THE AQUIFER UTILIZING CW3.
GROUNDWATER MODELING PERFORMED DURING THE FS INDICATED THAT COMPETING EXTRACTION SYSTEMS COULD CAUSE
CONTAMINANTS TO GET TRAPPED AT THE GROUNDWATER DIVIDE CREATED BY MULTIPLE PUMPING SYSTEMS, AND REQUIRE  LONGER
PURGE TIME TO REMEDIATE THE AQUIFER.

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AS STATED ABOVE, THE REMEDY  IS  CONSIDERED THE MOST COST-EFFECTIVE REMEDIAL ACTION.   IT COMPLIES WITH FEDERAL
AND STATE ARARS.   IT IS  PROTECTIVE  OF HUMAN HEALTH AND THE ENVIRONMENT BY REDUCING THE TIME  PERIOD  DURING
WHICH WATER CONSUMERS ARE  EXPOSED TO TRACE LEVELS OF CONTAMINANTS IN DRINKING WATER, BY ELIMINATING FUTURE
POTENTIAL RISK TO  PRIVATE  WELL  USERS,  AND BY PREVENTING INCREASED VOC EMISSIONS TO BE RELEASED TO THE
ATMOSPHERE.  REQUIREMENTS  OF SECTION 121(B)(1)(A-G)  WHICH HAVE BEEN DETERMINED TO BE APPLICABLE TO  THIS
OPERATION ARE DISCUSSED  BELOW.

1. PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT

BASED ON THE RISK  ASSESSMENT DEVELOPED FOR THE SITE, LONG-TERM EXPOSURE TO LOW LEVELS OF VOCS IN DRINKING
WATER, POTENTIAL EXPOSURE  THROUGH THE USE OF PRIVATE WELLS, AND EXPOSURE TO AIR EMISSIONS  FROM EXISTING  VOC
TREATMENT SYSTEMS  ARE THE  IDENTIFIED RISKS ASSOCIATED WITH THE SITE. IMPLEMENTATION  OF SVE SYSTEMS  AT THE
SOURCE AREAS AND TREATMENT OF OFF-GASES,  AS CALLED FOR UNDER ALTERNATIVE 5, PROVIDES PROTECTION TO  HUMAN
HEALTH AND THE ENVIRONMENT THROUGH  VOLATILIZATION OF VOCS FROM CONTAMINATED SOILS, AND EXPEDITED REMOVAL OF
CONTAMINANTS FROM  GROUNDWATER BY INCREASED PUMPAGE OF MUNICIPAL WELLS.

VOLATILIZATION OF  VOC-CONTAMINATED  SOILS WILL ELIMINATE THE SOURCE OF CONTINUED LOADING OF VOCS TO  THE
AQUIFER; THUS REDUCING THE TIME DURING WHICH RESIDENTS ARE EXPOSED TO TRACE LEVELS OF VOCS.  IMPLEMENTATION
OF ALTERNATIVE 5 WILL NOT  POSE  ANY  UNACCEPTABLE SHORT-TERM RISKS OR CROSS-MEDIA IMPACTS TO THE SITE,  THE
WORKERS, OR THE COMMUNITY.   NO  ENVIRONMENTAL IMPACTS HAVE BEEN IDENTIFIED FOR THE SITE.  THIS IS LARGELY DUE
TO THE FACT THAT IMPACTS FROM THE SITE HAVE BEEN TO GROUNDWATER, AND SOILS IN INDUSTRIAL AREAS.

2.  ATTAINMENT OF  APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS OF ENVIRONMENTAL LAWS

ALTERNATIVE 5 WILL BE DESIGNED  TO MEET ALL APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS  (ARARS) OF
FEDERAL AND MORE STRINGENT STATE ENVIRONMENTAL LAWS.  TABLES 7-11 LIST THE ARARS THAT APPLY  TO EACH OF THE
ACTION ALTERNATIVES AND  THE  FOLLOWING DISCUSSION PROVIDES THE DETAILS OF THE ARARS THAT WILL BE MET BY
ALTERNATIVE 5.  THE LAND BAN REQUIREMENTS OF RCRA DO NOT APPLY TO THIS REMEDIAL ACTION.

       A.   FEDERAL:  SAFE DRINKING WATER ACT (SDWA) / STATE CHAPTER NR
            109 WISCONSIN  ADMINISTRATIVE CODE (WAG)

THE SDWA AND CORRESPONDING STATE STANDARDS SPECIFIES MAXIMUM CONTAMINANT LEVELS  (MCLS) FOR DRINKING WATER AT
PUBLIC WATER SUPPLIES.   SINCE TCE IS REGULATED UNDER THE SDWA MCLS, REQUIREMENTS FOR ACHIEVING MCLS ARE
RELEVANT AND APPROPRIATE FOR THIS REMEDIAL ACTION.  PCE IS UNDER CONSIDERATION FOR A PROPOSED MCL OF 5 UG/L
IN THE NEAR FUTURE. THEREFORE,  THE  LIKELY PROPOSED MCL FOR PCE IS A TBC  (TO BE CONSIDERED) FOR THIS REMEDIAL
ACTION.

        B.  STATE:  CHAPTER  NR  140  WAG

WISCONSIN GROUNDWATER PROTECTION ADMINISTRATIVE RULE, CHAPTER NR 140 WAG, REGULATES  PUBLIC HEALTH GROUNDWATER
QUALITY STANDARDS  FOR THE  STATE OF  WISCONSIN.  THE ENFORCEABLE GROUNDWATER QUALITY STANDARD  FOR TCE IS 1.8
UG/L.  GROUNDWATER QUALITY STANDARDS AS FOUND IN NR 140 WAG ARE ARARS FOR THIS REMEDIAL ACTION.

        C.  FEDERAL: CLEAN AIR  ACT  (CAA)

THE CAA IDENTIFIES AND REGULATES THE RELEASE OF POLLUTANTS TO AIR. SECTION 109 OF THE CAA  IDENTIFIES THOSE
POLLUTANTS FOR WHICH AMBIENT AIR QUALITY STANDARDS  (AAQS) HAVE BEEN ESTABLISHED.  SECTION  112 OUTLINES
CRITERIA FOR POLLUTANTS  FOR  WHICH THERE ARE NO APPLICABLE AAQS. EMISSIONS FROM EXISTING AND  PROPOSED
TREATMENT SYSTEMS  ARE NOT  EXPECTED  TO EXCEED THE AAQSS FOR ANY OF THE COMPOUNDS PRESENT IN GROUNDWATER.

        D.  STATE: CHAPTER NR 445 WAG

WISCONSIN CHAPTER  NR 445 ESTABLISHES HOURLY OR ANNUAL EMISSION RATE LIMITS FOR SPECIFIC CONTAMINANTS.
EMISSIONS RATES ON THE ORDER OF 1 LB/DAY FOR INDIVIDUAL SYSTEMS ARE ESTIMATED AND WOULD BE EXPECTED TO  MEET
THE LIMITS.

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3. COST-EFFECTIVENESS

ALTERNATIVE 5 AFFORDS A HIGH  DEGREE  OF  EFFECTIVENESS BY PROVIDING PROTECTION FROM CHRONIC LOW LEVEL  EXPOSURE
OF TCE FOR PRODUCTION WELLS CW3 AND  CW6,  PROVIDING PROTECTION FROM POTENTIAL EXPOSURE TO FUTURE    PRIVATE
WELL USERS, AND PREVENTING FURTHER DISCHARGE OF VOC EMISSIONS.  ALTERNATIVE 5 IS THE LEAST COSTLY ALTERNATIVE
THAT IS PROTECTIVE OF HUMAN HEALTH AND  THE ENVIRONMENT.  THEREFORE,  ALTERNATIVE 5 IS   CONSIDERED  TO BE  THE
MOST COST-EFFECTIVE ALTERNATIVE THAT IS PROTECTIVE.

4.  UTILIZATION OF PERMANENT  SOLUTIONS  AND ALTERNATIVE TREATMENT TECHNOLOGIES OR RESOURCE RECOVERY
    TECHNOLOGIES TO THE MAXIMUM EXTENT  PRACTICABLE

US EPA AND THE STATE OF WISCONSIN  BELIEVE THE SELECTED REMEDY REPRESENTS THE MAXIMUM EXTENT TO WHICH
PERMANENT SOLUTIONS AND TREATMENT  TECHNOLOGIES CAN BE UTILIZED IN A COST-EFFECTIVE MANNER FOR THE  FINAL
REMEDY AT THE WAUSAU SITE.  OF THE ALTERNATIVES THAT ARE PROTECTIVE OF HUMAN HEALTH AND THE ENVIRONMENT  AND
COMPLY WITH ARARS, Us EPA AND THE  STATE HAVE DETERMINED THAT THE SELECTED REMEDY PROVIDES THE BEST BALANCE
OF TRADEOFFS IN TERMS OF LONG-TERM EFFECTIVENESS AND PERMANENCE, REDUCTION IN TOXICITY, MOBILITY OR  VOLUME
ACHIEVED THROUGH TREATMENT, SHORT-TERM  EFFECTIVENESS, IMPLEMENTABILITY, COST, ALSO CONSIDERING THE STATUTORY
PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT AND CONSIDERING STATE AND COMMUNITY ACCEPTANCE.

ALTHOUGH ALL OF THE ALTERNATIVES THAT ARE PROTECTIVE AND COMPLY WITH ARARS WILL ACHIEVE REDUCTION  OF RISKS,
THERE ARE SIGNIFICANT DIFFERENCES  IN THE TIME REQUIRED TO ACHIEVE THIS GOAL.  ALTERNATIVES 2, 3, AND 4 ARE
GROUNDWATER REMEDIATION ALTERNATIVES THAT DO NOT ADDRESS SOURCE AREAS.  THIS RESULTS IN CONTAMINATION FROM
SOURCE AREA SOILS LOADING TO  THE AQUIFER FOR SEVERAL ADDITIONAL YEARS.  IN ADDITION, NONE OF THESE
ALTERNATIVES PROVIDE ANY REDUCTION IN TIME TO REMEDIATE THE DEEP TCE PLUMES ORIGINATING FROM THE FORMER
LANDFILL SOURCE AREA.  THIS ALSO RESULTS IN A SIGNIFICANT TIME PERIOD TO ACHIEVE REDUCTION OF   RISKS.
ALTERNATIVE 5 REQUIRES THE SHORTEST  TIME PERIOD FOR REMEDIATION OF THE SITE BECAUSE IT ELIMINATES  THE
CONTINUED LOADING OF CONTAMINANTS  TO THE GROUNDWATER, AND IT PROVIDES FOR REDUCTION IN TIME TO PURGE THE DEEP
TCE PLUMES BY REMOVING THE SOURCE  AND INCREASING REMOVAL RATES OF CONTAMINANTS AT THE MUNICIPAL SUPPLY WELLS.

THE SELECTION OF A TREATMENT  TECHNOLOGY FOR REMEDIATION OF CONTAMINATED SOILS IS CONSISTENT WITH THE
SUPERFUND PROGRAM POLICY THAT THE  HIGHLY TOXIC AND MOBILE WASTES ARE A PRIORITY FOR TREATMENT AND  TO ENSURE
PERMANENCE AND LONG-TERM EFFECTIVENESS  OF THE REMEDY.  UNDER THE SELECTED REMEDY, TREATMENT OF GROUNDWATER
WILL NOT PROVIDE A REDUCTION  OF TOXICITY,  MOBILITY, OR VOLUME (TMV).   HOWEVER, IT WILL REDUCE   CONTAMINANT
LEVELS IN GROUNDWATER AND THUS REDUCE THE RISKS ASSOCIATED WITH INGESTION OF GROUNDWATER, WHICH HAS  BEEN
DETERMINED TO BE A GREATER RISK THAN INHALATION OF AIR EMISSIONS. WHILE OTHER ALTERNATIVES EVALUATED PROVIDED
TREATMENT TO ACHIEVE TMV REDUCTIONS  IN  GROUNDWATER, THESE ALTERNATIVES HAD OTHER DIFFICULTIES.  ALTERNATIVE 2
REQUIRED ALMOST TWICE AS LONG TO PURGE  CONTAMINANTS.  ALTERNATIVES 3 AND 4   PROPOSE A TECHNOLOGY  THAT HAS
NOT BEEN SHOWN TO WORK ON CONTAMINANTS  PRESENT IN GROUNDWATER AT THE SITE AND THUS WOULD REQUIRE EXTENSIVE
TESTING THAT WOULD DELAY FULL SCALE  OPERATION OF THE SYSTEM FOR AN ESTIMATED TWO YEARS.  BASED ON  THESE
FACTORS, IT WAS DETERMINED THAT ALTERNATIVE 5 WOULD PROVIDE THE SHORTEST TIME PERIOD DURING WHICH  RECEPTORS
WOULD BE EXPOSED TO CONTAMINANTS IN  DRINKING WATER.  IN ADDITION, BASED ON AIR MODELING, RELEASE OF  EMISSIONS
FROM THE MUNICIPAL AIR STRIPPERS DO  NOT CONTRIBUTE A GREATER THAN 1 X  (10-6) RISK LEVEL TO RECEPTORS.

SINCE TREATMENT OF GROUNDWATER WILL  NOT ACHIEVE A REDUCTION IN TOXICITY, MOBILITY OR VOLUME, THE MAJOR
TRADE-OFFS THAT PROVIDE THE BASIS  FOR THIS SELECTION DECISION ARE LONG-TERM EFFECTIVENESS, SHORT-TERM
EFFECTIVENESS, IMPLEMENTABILITY, AND COST.  THE SELECTED REMEDY CAN BE IMPLEMENTED AND COMPLETED MORE QUICKLY
WITH LESS DIFFICULTY AND AT LESS COST THAN GROUNDWATER TREATMENT ALTERNATIVES, THUS REDUCING THE EXPOSURE
TIME FOR PATHWAYS OF CONCERN.  ALTERNATIVE 5 IS THEREFORE CONSIDERED TO BE THE MOST APPROPRIATE SOLUTION TO
CONTAMINATION AT THE SITE BECAUSE  IT PROVIDES THE BEST TRADE-OFFS WITH RESPECT TO THE NINE CRITERIA  AND
REPRESENTS THE MAXIMUM EXTENT TO WHICH  PERMANENT SOLUTIONS AND TREATMENT ARE PRACTICABLE.

5. PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT

BY TREATING THE VOC-CONTAMINATED SOILS  USING SVE WITH CARBON ABSORPTION OF OFF-GASES WITH REGENERATION OF THE
CARBON, THE SELECTED REMEDY SATISFIES THE STATUTORY PREFERENCE FOR REMEDIES THAT EMPLOY TREATMENT  OF  THE
PRINCIPAL THREAT WHICH PERMANENTLY AND  SIGNIFICANTLY REDUCES TOXICITY, MOBILITY, OR VOLUME OF HAZARDOUS
SUBSTANCES AS A PRINCIPAL ELEMENT.   TREATMENT OF GROUNDWATER TO REDUCE TOXICITY, MOBILITY, OR   VOLUME WOULD

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ALSO SEEM TO BE DESIRABLE TO  SATISFY THE  STATUTORY PREFERENCE.   HOWEVER, TREATMENT OF GROUNDWATER TO
PERMANENTLY AND SIGNIFICANTLY REDUCE TOXICITY,  MOBILITY,  OR VOLUME OF CONTAMINANTS WAS   NOT FOUND TO BE
PRACTICABLE OR COST-EFFECTIVE FOR  REMEDIATION OF THE SITE.

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#RS
RESPONSIVENESS SUMMARY:  WAUSAU GROUNDWATER CONTAMINATION SITE
                            WAUSAU, WISCONSIN

PURPOSE

THIS RESPONSIVENESS SUMMARY IS  DEVELOPED TO DOCUMENT COMMUNITY INVOLVEMENT AND CONCERNS DURING THE
DEVELOPMENT OF THE  FEASIBILITY STUDY (FS)  FOR THE WAUSAU GROUNDWATER CONTAMINATION SITE, WAUSAU, WISCONSIN.
COMMENTS RECEIVED DURING THE  PUBLIC COMMENT PERIOD WERE CONSIDERED IN THE SELECTION OF THE REMEDIAL ACTION
FOR THE SITE.  THE RESPONSIVENESS  SUMMARY SERVES TWO PURPOSES: IT PROVIDES Us EPA WITH INFORMATION ABOUT
COMMUNITY PREFERENCES AND  CONCERNS REGARDING THE REMEDIAL ALTERNATIVES, AND IT SHOWS MEMBERS OF  THE COMMUNITY
HOW THEIR COMMENTS WERE INCORPORATED  INTO THE DECISION-MAKING PROCESS.

THIS DOCUMENT SUMMARIES THE ORAL COMMENTS RECEIVED AT THE PUBLIC MEETING HELD AUGUST 22,  1989, AND ONE
WRITTEN COMMENT RECEIVED DURING THE PUBLIC COMMENT PERIOD OF AUGUST 14 TO SEPTEMBER 12, 1989.

OVERVIEW

THE PREFERRED ALTERNATIVE  FOR THE  WAUSAU GROUNDWATER CONTAMINATION (WAUSAU) SITE WAS ANNOUNCED TO THE PUBLIC
JUST PRIOR TO THE BEGINNING OF  THE PUBLIC COMMENT PERIOD.  THE PREFERRED ALTERNATIVE INCLUDES:

       *    INSTALLATION OF SOIL VAPOR EXTRACTION (SVE)  SYSTEMS TO REMOVE
            VOCS IN SOILS  AT  EACH  OF  THE THREE IDENTIFIED SOURCE AREAS;

       *    TREATMENT OF OFF-GASES FROM THE SVE OPERATION USING VAPOR
            PHASE CARBON UNITS  WHICH  WILL BE REGENERATED AT AN OFF-SITE
            RCRA APPROVED  FACILITY; AND

       *    GROUNDWATER REMEDIATION UTILIZING SPECIFIED PUMPAGE RATES OF
            THE MUNICIPAL  SUPPLY WELLS IN ORDER TO EXPEDITE REMOVAL OF THE
            GROUNDWATER CONTAMINANT PLUMES AFFECTING THESE WELLS.

       *    TREATMENT OF GROUNDWATER  UTILIZING EXISTING CITY AIR STRIPPERS

JUDGING FROM THE COMMENTS  RECEIVED DURING THE PUBLIC COMMENT PERIOD,  ALL PARTIES SUPPORT  THE SELECTED REMEDY.
HOWEVER, CONCERN HAS BEEN  EXPRESSED OVER THE AMOUNT OF MONEY SPENT TO DATE AT THE SITE BY ALL    PARTIES
INVOLVED.

SUMMARY OF PUBLIC COMMENTS AND  AGENCY RESPONSES

THE PUBLIC COMMENT PERIOD  WAS HELD FROM AUGUST 14 TO SEPTEMBER 12, 1989 TO RECEIVE COMMENTS CONCERNING THE
DRAFT FEASIBILITY STUDY  (FS). BECAUSE OF THE SIMILARITIES, INDIVIDUAL COMMENTS HAVE BEEN  SUMMARIZED  AND
GROUPED WHERE APPROPRIATE.

A. COMMENT: THE MAYOR OF WAUSAU, THE  WAUSAU CITY COUNCIL PRESIDENT, WAUSAU CHEMICAL CORPORATION, AND MARATHON
ELECTRIC CORPORATION ALL EXPRESSED SUPPORT FOR THE AGENCY'S SELECTED ALTERNATIVE.  HOWEVER, ALL   PARTIES
ALSO EXPRESSED CONCERN OVER THE AMOUNT OF MONEY THAT HAS BEEN SPENT ON THE SITE TO DATE.  SPECIFICALLY, FOR
THE REMEDIAL INVESTIGATION/FEASIBILITY STUDY (RI/FS)  CONDUCTED BY Us EPA'S CONTRACTOR, AND THE EXPENSES
INCURRED BY EACH OF THE INVOLVED PARTIES FOR ACTIONS RELATING TO THE CONTAMINATION PROBLEM.

A. RESPONSE: Us EPA WISHES TO EXTEND  THANKS TO ALL PARTIES FOR THEIR SUPPORT OF ITS SELECTED REMEDIAL
ALTERNATIVE FOR THE SITE.  IT IS HOPED THAT AN EXPEDITED AGREEMENT CAN BE REACHED AND THE REMEDIAL ACTION
IMPLEMENTED IN A TIMELY MANNER.  WHILE Us EPA UNDERSTANDS THE CONCERN OVER COSTS THAT HAVE BEEN  SPENT TO
DATE, IT ALSO RECOGNIZES THAT THE  INCURRED COSTS COULD NOT HAVE BEEN AVOIDED.  STUDIES OF THE NATURE REQUIRED
TO FULLY IDENTIFY THE EXTENT  OF CONTAMINATION AT THE SITE TEND TO BE QUITE EXPENSIVE.  THE COST  OF THE RI/FS
FOR THIS SITE IS WITHIN THE AVERAGE RANGE FOR AN RI/FS.   THE COSTS INCURRED BY INDIVIDUAL PARTIES RELATED  TO
THE CONTAMINATION HAVE, FOR THE MOST  PART,  BEEN NECESSARY TO ADDRESS THE MORE IMMEDIATE PROBLEMS POSED BY  THE

-------
CONTAMINATION OF THE CITY'S WELL  FIELD.

B. COMMENT: WAUSAU CHEMICAL CORPORATION  HAS  REQUESTED SPECIFIC DIRECTION FROM Us EPA AND WDNR BE  INCLUDED  IN
THE ROD AS TO THE FUTURE OPERATION  OF ITS  GROUNDWATER EXTRACTION SYSTEM IN LIGHT OF THE FACT THAT THE
SELECTED ALTERNATIVE DOES NOT  INCLUDE THE  CONTINUED PUMPAGE OF GROUNDWATER IN THE VICINITY OF THE WAUSAU
CHEMICAL PROPERTY.

B. RESPONSE: THE SELECTED REMEDY  CALLS FOR THE REMOVAL OF ALL GROUNDWATER EXTRACTION SYSTEMS, OTHER THAN CITY
WELL 3, FROM THE EAST WELL FIELD.   THIS  WILL INCLUDE THE WAUSAU CHEMICAL EXTRACTION SYSTEM. THIS  SUBJECT IS
ALSO ADDRESSED IN SECTION IX-THE  SELECTED  REMEDY,  OF THE ROD AND IS QUOTED BELOW:


THE FINAL REMEDY ALSO WILL REQUIRE  THAT  EXISTING GROUNDWATER EXTRACTION SYSTEMS CURRENTLY OPERATING IN THE
EAST WELL FIELD, OTHER THAN CITY  SUPPLY  WELL CW3,  CEASE OPERATION ONCE THE SVE SYSTEM IS INSTALLED.  THIS  IS
NECESSARY IN ORDER TO OBTAIN THE  DESIRED RESULT OF PURGING CONTAMINANTS FROM THE AQUIFER UTILIZING CW3.
GROUNDWATER MODELING PERFORMED DURING THE  FS INDICATED THAT COMPETING EXTRACTION SYSTEMS COULD CAUSE
CONTAMINANTS TO GET TRAPPED AT THE  GROUNDWATER DIVIDE CREATED BY MULTIPLE PUMPING SYSTEMS, AND REQUIRE LONGER
PURGE  TIME TO REMEDIATE THE AQUIFER.

-------
#TABLES AND ATTACHMENTS
                                    TABIiE 1

          EXISTING REPORTS ON TCAUSAU GROUNDTCATER CONTAMINATION SITE

   1. GROUNDWATER INVESTIGATION,  (FOR CITY OF WAUSAU),  BECHLER HOPPE ENGINEERS,  INC.,  1983.

   2. SUBSURFACE EXPLORATION  AND  TESTING PROGRAM TO EVALUATE GROUND WATER QUALITY AT  THE WAUSAU CHEMICAL
      FACILITIES IN WAUSAU CHEMICAL FACILITIES IN WAUSAU, WISCONSIN,  (FOR WAUSAU CHEMICAL COMPANY),  STS
      CONSULTANTS, LTD.,  1984.

   3. HYDROGEOLOGICAL  INVESTIGATION OF VOLATILE ORGANIC CONTAMINATION IN WAUSAU,  WISCONSIN MUNICIPAL
      WELLS,  (FOR Us EPA), ROY  F. WESTON,  INC., SEPTEMBER, 1985.

   4. INVESTIGATION OF AN ABANDONED CITY OF WAUSAU LANDFILL, FEBRUARY, 1986.

   5. EXISTING CONDITIONS REPORT  AND EXPLORATION PROGRAM, EAST MUNICIPAL WELL  FIELD,  WAUSAU,  WISCONSIN,
      (FOR WDNR), TWIN CITY TESTING CORPORATION,  AUGUST, 1986.

   6. VOC GROUNDWATER  INVESTIGATION AT THE FORMER WAUSAU ENERGY FACILITY IN WAUSAU, WISCONSIN,  (FOR WAUSAU
      ENERGY CORPORATION), FOTH & VAN DYKE AND ASSOCIATES, INC., JULY, 1986.

   7. HYDROGEOLOGICAL  INVESTIGATION OF THE ALLUVIAL AQUIFER BENEATH CITY  WELL SIX, WAUSAU,  WISCONSIN,
      (FOR CITY OF WAUSAU  AND  MARATHON  ELECTRIC), RMT,  INC., AND GERAGHTY & MILLER, INC.,  JULY,  1987.

-------
MEDIUM
GROUNDWATER
                                 TABLE 2

               TARGET COMPOUNDS LIST CHEMICALS DETECTED
                            FEASIBILITY STUDY
                     WAUSAU WATER SUPPLY NPL SITE
                            WAUSAU, WISCONSIN
                         CHEMICAL CONCENTRATION
CHEMICAL
ALL LOCATIONS
VOLATILE

CHLOROMETHANE
VINYL CHLORIDE
METHYLENE CHLORIDE
ACETONE
1,1-DICHLOROETHENE
1,1-DICHLOROETHANE
1,2-DICHLOROETHENE  (TOTAL)
CHLOROFORM
2-BUTANONE
1,1,1-TRICHLOROETHANE
CARBON TETRACHLORIDE
TRICHLORETHENE
1,1,2-TRICHLOROETHANE
BENZENE
4-METHYL-2-PENTANONE
TETRACHLOROETHENE
TOLUENE
CHLOROBENZENE
ETHYL BENZENE
XYLENES  (TOTAL)
MINIMUM   MAXIMUM

 (UG/L)     (UG/L)
GEOMETRIC
MEAN
(UG/L)
4
3
1
2
—
—
1
2
—
1
2
1
2
18
—
1
2
2
3
16
7
6
190
3070
2
3
1300
44
5
53
69
4200
4
310
2
2440
890
54
440
2000
5
4
8
11
—
—
20
11
—
3
19
29
2
125
—
45
46
7
53
428

-------
                             TABIiE 2 (CONT)
                 NUMBER LOCATION SAMPLED FOR ANALYSIS
CHEMICAL
                                        TOTAL
                                                  POSITIVE DETECTION
                                        134
VOLATILE
CHLOROMETHANE
VINYL CHLORIDE
METHYLENE CHLORIDE
ACETONE
1,1-DICHLOROETHENE
1,1-DICHLOROETHANE
1,2-DICHLOROETHENE  (TOTAL)
CHLOROFORM
2-BUTANONE
1,1,1-TRICHLOROETHANE
CARBON TETRACHLORIDE
TRICHLORETHENE
1,1,2-TRICHLOROETHANE
BENZENE
4-METHYL-2-PENTANONE
TETRACHLOROETHENE
TOLUENE
CHLOROBENZENE
ETHYL BENZENE
XYLENES  (TOTAL)
                                                            2
                                                            4
                                                            8
                                                            11
                                                            1
                                                            1
                                                            48
                                                            6
                                                            1
                                                            16
                                                            3
                                                            68
                                                            5
                                                            5
                                                            1
                                                            53
                                                            5
                                                            6
                                                            4
                                                            6
                         CHEMICAL CONCENTRATION
SEMIVOLATILE

PHENOL
NAPTHALENE
2-METHYLNAPTHALENE
FLUORENE
PENTACHLOROPHENOL
PHENANTHRENE
BIS  (2-ETHYLHEXYL) PHTHALATE
(UG/L)
                                                   (UG/L)

                                                   2
                                                   22
                                                   23
                                                   4
                                                   6
                                                   4
                                                   19
                                                             (UG/L)

-------
                 NUMBER  LOCATION SAMPLED FOR ANALYSIS
CHEMICAL

SEMIVOLATILE

PHENOL
NAPTHALENE
2-METHYLNAPTHALENE
FLUORENE
PENTACHLOROPHENOL
PHENANTHRENE
BIS  (2-ETHYLHEXYL) PHTHALATE
PESTICIDE/PCB

NONE DETECTED
                      TOTAL
                      31
                                                  POSITIVE DETECTION
                   TOTAL
                    31
CHEMICAL
METAL/CN  (B)

BARIUM
CHROMIUM
IRON
MANGANESE
ZINC
CHEMICAL
METAL/CN  (B)

BARIUM
CHROMIUM
IRON
MANGANESE
ZINC
       CHEMICAL CONCENTRATION
                      MINIMUM   MAXIMUM

                       (UG/L)     (UG/L)
                                                            GEOMETRIC
                                                             MEAN
                                                             (UG/L)
206
28
169
69
2750
325
594
18100
6100
2860
259
77
1800
937
2800
NUMBER LOCATION SAMPLED  FOR ANALYSIS

                      TOTAL      POSITIVE DETECTION
                      32
                                           3
                                           3
                                           17
                                           25
                                           2

-------
                             TABIiE 2 (CONT)
                             PRODUCTION WEIiS
                              CW3, CW4, CW6
VOLATILE

ACETONE
1,2-DICHLOROETHENE  (TOTAL)
TRICHLOROETHENE
TETRACHLOROETHENE
CHLOROBENZENE
                              MINIMUM
(UG/L)
1
53
7
MAXIMUM

 (UG/L)

16
20
150
14
15
GEOMETRIC
MEAN
(UG/L)
9
100
13
                 NUMBER LOCATION SAMPLED FOR ANALYSIS
CHEMICAL

VOLATILE

ACETONE
1,2-DICHLOROETHENE  (TOTAL)
TRICHLOROETHENE
TETRACHLOROETHENE
CHLOROBENZENE
          TOTAL
          3
                                                  POSITIVE DETECTION
SEMIVOLATILE
NON DETECTED

PESTICIDE/PCB

NONE DETECTED

-------
                             TABIiE 2 (CONT)
                         CHEMICAL CONCENTRATION
CHEMICAL
METAL/CN

IRON
MANGANESE
CHEMICAL
IRON
MANGANESE
CHEMICAL
GEOMETRIC
SURFACE SOILS

VOLATILE

METHYLENE CHLORIDE
1,1,1-TRICHLOROETHANE
TETRACHLOROETHENE
XYLENES  (TOTAL)
                                        MINIMUM   MAXIMUM  GEOMETRIC
                                                            MEAN
                                        (UG/L)     (UG/L)     (UG/L)
                       957
                       1610
5300
2920
2110
2110
NUMBER LOCATION SAMPLED  FOR ANALYSIS

                       TOTAL     POSITIVE DETECTION

                       3
       CHEMICAL CONCENTRATION

                      MINIMUM   MAXIMUM


              (UG/L)    (UG/L)
                                                            MEAN
                                                             (UG/L)
            64
                       190
                       3
                       3
                       4
                                           110
CHEMICAL

VOLATILE
                 NUMBER LOCATION SAMPLED FOR ANALYSIS

                              TOTAL     POSITIVE DETECTION
METHYLENE CHLORIDE
1,1,1-TRICHLOROETHANE
TETRACHLOROETHENE
XYLENES  (TOTAL)

-------
MEDIUM
SURFACE SOILS

CHEMICAL
CHEMICAL CONCENTRATION



     MINIMUM   MAXIMUM

       (UG/KG)   (UG/KG)
SEMIVOLATILE

PHENOL
4-METHYLPHENOL
BENZOIC ACID
NAPHTHALENE
2-METHYLNAPHTHALENE
ACENAPHTHYLENE
ACENAPHTHENE
DIBENZOFURAN
FLUORENE
PHENANTHRENE
ANTHRACENE
FLOURANTHENE
PYRENE
BUTYLBENZYLPHTHALATE
BENZO  (A) ANTHRACENE
BIS  (2-ETHYLHEXYL) PHTHALATE
CHRYSENE
DI-N-OCTYLPHTHALATE
BENZO  (B) FLUORANTHENE
BENZO  (K) FLUORANTHENE
BENZO  (A) PYRENE
INDENO  (1,2,3-CD)  PYRENE
DIBENZ  (A,H) ANTHRACENE
BENZO  (G,H,I) PERYLENE

PESTICIDE/PCB

NOT ANALYZED

METAL/CN

NOT ANALYZED
89
—
—
37
32
2
51
38
100
200
32
200
150
59
110
150
390
—
250
—
100
210
—
230
93
200
160
720
770
110
69
180
120
2500
480
6600
2900
390
2400
1600
3200
380
5400
1600
2700
1200
390
1400
                                                       GEOMETRIC
                                                       MEAN
                                                        (UG/KG)
                                    90
                                    192
                                    264
                                    22
                                    59
                                    82
                                    109
                                    651
                                    155
                                    1300
                                    910
                                    150
                                    749
                                    489
                                    861

                                    1380

                                    604
                                    614

                                    655

-------
SURFACE WATER  (BOS  CREEK)

                              MINIMUM   MAXIMUM        GEOMETRIC
                                                       MEAN
VOLATILE                      (UG/L)     (UG/L)          (UG/L)

1,2-DICHLOROETHENE  (TOTAL)    11                1
TRICHLOROETHENE               1          110              41
TETRACHLOROETHENE             13                2

               NUMBER  LOCATION  SAMPLED FOR ANALYSIS

CHEMICAL                      TOTAL     POSITIVE DETECTION
                              12

1,2-DICHLOROETHENE  (TOTAL)                        2
TRICHLOROETHENE                                   10
TETRACHLOROETHENE                                 2

SEMIVOLATILE

NOT ANALYZED

PESTICIDE/PCB

NOT ANALYZED

METAL/CN

NOT ANALYZED

-------
                           TABLE 2 (CONTINUED)
MEDIUM

WISCONSIN RIVER


CHEMICAL
       CHEMICAL CONCENTRATION

            MINIMUM   MAXIMUM

              (UG/L)    (UG/L)
                                                       GEOMETRIC
                                                       MEAN
                                                        (UG/L)
1,2-DICHLOROETHENE  (TOTAL)
TRICHLOROETHENE
TETRACHLOROETHENE
CHEMICAL
NUMBER LOCATION SAMPLED  FOR ANALYSIS

            TOTAL      POSITIVE  DETECTION
            4
1,2-DICHLOROETHENE  (TOTAL)
TRICHLOROETHENE
TETRACHLOROETHENE
SEMIVOLATILE

NOT ANALYZED

PESTICIDE/PCB

NOT ANALYZED

METAL/CN

NOT ANALYZED

MEDIUM

SEDIMENT - BOS CREEK



VOLATILE

ACETONE
1,2-DICHLOROETHENE  (TOTAL)
TRICHLOROETHENE
tOLUENE
            MINIMUM

             (UG/KG)

            18
            6
            6
MAXIMUM

 (UG/KG)

190
200
17
7
GEOMETRIC
MEAN
(UG/KG)

     58
     51
     59

-------
CHEMICAL
NUMBER LOCATION SAMPLED  FOR ANALYSIS

            TOTAL     POSITIVE  DETECTION
            11
ACETONE
1,2-DICHLOROETHENE  (TOTAL)
TRICHLOROETHENE
TOLUENE

SEMIVOLATILE

NONE DETECTED

PESTICIDE/PCB

NONE DETECTED

METALS

NOT ANALYZED

SUBSURFACE SOILS
VOLATILE

CHEMICAL

METHYLENE CHLORIDE
TRICHLOROETHENE
TETRACHLOROETHENE
TOLUENE
ETHYLBENZENE
XYLENES  (TOTAL)
            TOTAL
             3
            TOTAL
             3
            TOTAL
              29

            MINIMUM   MAXIMUM

             (UG/KG)    (UG/KG)
GEOMETRIC
MEAN
(UG/KG)
1
4
1
1
4
2
2000
10
3500
46
2900
21000
43
6
77
5
37
22

-------
CHEMICAL
NUMBER LOCATION SAMPLED  FOR ANALYSIS

            TOTAL      POSITIVE  DETECTION
            29
VOLATILE

CHEMICAL

METHYLENE CHLORIDE
TRICHLOROETHENE
TETRACHLOROETHENE
TOLUENE
ETHYLBENZENE
XYLENES  (TOTAL)
SEMIVOLATILE

PHENOL
NAPTHALENE
2-METHYLNAPHTALENE
            MINIMUM   MAXIMUM

             (UG/KG)    (UG/KG)

                         320
                         4900
                         16000
                                 5
                                 3
                                 12
                                 9
                                 3
                                 7
GEOMETRIC
MEAN
  (UG/KG)
                 NUMBER  LOCATION SAMPLED FOR ANALYSIS
CHEMICAL
PHENOL
NAPTHALENE
2-METHYLNAPHTALENE
CHEMICAL
DIMETHYLPHTHALATE
FLUORENE
PHENANTHRENE
ANTHRACENE
DI-N-BUTYLPHTHALATE
FLOURANTHENE
PYRENE
BENZO  (A) ANTHRACENE
CHRYSENE
BIS(METHYLHEXYL) PHTHALATE
                              TOTAL
                              29
                                        POSITIVE DETECTION
                         CHEMICAL CONCENTRATION
                              MINIMUM
                                        MAXIMUM
                               (UG/L)    (UG/L)
110
63
63
48
58
30
31
98
130
45
140
1600
2600
120
76
1400
1300
660
750
84
                                      GEOMETRIC
                                      MEAN
                                      (UG/L)

                                           120
                                           320
                                           260
                                           85
                                           66
                                           220
                                           210
                                           250
                                           290
                                           60

-------
                 NUMBER LOCATION SAMPLED FOR ANALYSIS
CHEMICAL
                              TOTAL
                              29
                                        POSITIVE DETECTION
DIMETHYLPHTHALATE
FLUORENE
PHENANTHRENE
ANTHRACENE
DI-N-BUTYLPHTHALATE
FLOURANTHENE
PYRENE
BENZO  (A) ANTHRACENE
CHRYSENE
BIS(METHYLHEXYL) PHTHALATE
2
2
11
6
2
15
12
6
6
5
                           TABLE 2 (CONTINUED)
                         CHEMICAL CONCENTRATION
CHEMICAL
                              MINIMUM
                                        MAXIMUM
                               (UG/L)    (UG/L)
     GEOMETRIC
     MEAN
     (UG/L)
BENZO  (B) FLUORANTHENE        110       680
BENZO  (K) FLUORANTHENE        100       760
BENZO  (A) PYRENE              120       750
INDENO  (1,2,3-CD)  PYRENE      130       680
DIBENZ  (A,H) ANTHRACENE       —        74
BENZO  (G,H,I) PERYLENE        130       800
          220
          210
          250
          220

          270

-------
                 NUMBER  LOCATION SAMPLED FOR ANALYSIS
CHEMICAL
                              TOTAL
                                        POSITIVE DETECTION
BENZO  (B) FLUORANTHENE
BENZO  (K) FLUORANTHENE
BENZO  (A) PYRENE
INDENO  (1,2,3-CD) PYRENE
DIBENZ  (A,H) ANTHRACENE
BENZO  (G,H,I) PERYLENE

PESTICIDE/PCB
                     10
                     9
                     8
                     6
                     1
                     5
NOT ANALYZED

METAL/CN

COPPER
MG/KG     MG/KG     MG/KG

           107
MEDIUM
LANDFILL REFUSE
                              MINIMUM   MAXIMUM
                                                       GEOMETRIC
                                                       MEAN
METHYLENE CHLORIDE
ACETONE
1,2-DICHLOROETHENE
TRICHLOROETHENE
TOLUENE
ETHYL BENZENE
XYLENES  (TOTAL)
9
71
21
36
3
2
4
1900
160
220
160000
750
4
24
70
100
67
680
60
3
13
                 NUMBER  LOCATION SAMPLED FOR ANALYSIS
CHEMICAL
                              TOTAL
                              15
                                        POSITIVE DETECTION
METHYLENE CHLORIDE
ACETONE
1,2-DICHLOROETHENE
TRICHLOROETHENE
TOLUENE
ETHYL BENZENE
XYLENES  (TOTAL)

-------
SEMIVOLATILE

PHENOL
2-CHLOROPHENOL
1,2-DICHLOROBENZENE
2-METHYLPHENOL
4-METHYLPHENOL
ISOPHORONE
1,2,4-TRICHLOROBENZENE
NAPTHALENE
4-CHLORO-3-METHYLPHENOL
2-METHYLNAPTHALENE
2-CHLORONAPTHALENE
ACENAPTHYLENE
ACENAPHTHENE
DIBENZOFURAN
FLUORENE
PENTACHLOROPHENOL
PHENANTHRENE
ANTHRACENE
FLUORANTHENE
PYRENE
BUTYLBENZYLPHTHALATE
BENZO  (A) ANTHRACENE
BIS (2-ETHYLHEXYL) PHTHALATE
CHRYSENE
BENZO  (B) FLUORANTHENE
BENZO  (K) FLUORANTHENE
BENZO  (A) PYRENE
MINIMUM
(UG/KG)
—
—
—
—
—
—
—
49
—
65
—
—
45
19
82
820
170
19
60
63
130
420
110
54
410
430
480
MAXIMUM
(UG/KG)
2200
2200
210
75
830
130
1200
1300
2300
890
170
130
730
330
500
32000
15000
2200
45000
49000
2300
24000
54000
25000
25000
25000
25000
GEOMETRIC
MEAN
(UG/KG)
     150

     150
     180
     63
     186
     2900
     1100
     250
     1600
     1700
     500
     1400
     860
     970
     1700
     1400
     1200

-------
                 NUMBER  LOCATION SAMPLED FOR ANALYSIS
CHEMICAL
                              TOTAL
                              15
                                        POSITIVE DETECTION
PHENOL
2-CHLOROPHENOL
1,2-DICHLOROBENZENE
2-METHYLPHENOL
4-METHYLPHENOL
ISOPHORONE
1,2,4-TRICHLOROBENZENE
NAPTHALENE
4-CHLORO-3-METHYLPHENOL
2-METHYLNAPTHALENE
2-CHLORONAPTHALENE
ACENAPTHYLENE
ACENAPHTHENE
DIBENZOFURAN
FLUORENE
PENTACHLOROPHENOL
PHENANTHRENE
ANTHRACENE
FLUORANTHENE
PYRENE
BUTYLBENZYLPHTHALATE
BENZO  (A) ANTHRACENE
BIS  (2-ETHYLHEXYL) PHTHALATE
CHRYSENE
BENZO  (B) FLUORANTHENE
BENZO  (K) FLUORANTHENE
BENZO  (A) PYRENE

PESTICIDE/PCB
                    1
                    1
                    1
                    1
                    1
                    1
                    1
                    7
                    1
                    7
                    1
                    1
                    3
                    7
                    5
                    5
                    11
                    10
                    12
                    12
                    3
                    10
                    10
                    12
                    10
                    10
                    9
TOTAL
6
 (UG/L)
                                        (UG/L)
(UG/L)
AROCHLOR 1260
                                  850    2300
                                                            1400
AROCHLOR 1260
                     TOTAL      POSITIVE DETECTION
                                        2

-------
                             TABLE 2  (CONT)
                         CHEMICAL CONCENTRATION
CHEMICAL
                              MINIMUM   MAXIMUM

                               (UG/L)    (UG/L)
                       GEOMETRIC
                       MEAN
                        (UG/L)
ARSENIC
CHROMIUM
COPPER
MERCURY
ZINC
107
0.5
323
76
1130
1410
1.9
3260
383
1.2
2160
                 NUMBER  LOCATION SAMPLED FOR ANALYSIS
CHEMICAL
                              TOTAL     POSITIVE DETECTION
                              14
ARSENIC
ChROMIUM
COPPER
MERCURY
ZINC

-------
                                 TABLE 4
        CRITICAL TOXICITY VALUES FOR INDICATOR CONTAMINANTS  (A)
                     WAUSAU WATER SUPPLY NPL SITE
                            WAUSAU, WISCONSIN

                       REFERENCE DOSE (MG/KG/DAY)
                              ORAL
                              SUBCHRONIC
                                                  CHRONIC
INDICATOR CONTAMINANT
TETRACHLOROETHENE
  (PCE)
TRICHLOROETHENE
  (TCE)
1,2-DICHLOROETHENE  (TOTAL)
  (DCE)
                                                   l.OE-02
                                   INHALATION
                              SUBCHRONIC
                                                  CHRONIC
TETRACHLOROETHENE
  (PCE)
TRICHLOROETHENE
  (TCE)
1,2-DICHLOROETHENE  (TOTAL)
  (DCE)
                              CHRONIC
                                                  EPA WEIGHT OF EVIDENCE
                                                  CLASSIFICATION  (B)
INDICATOR CONTAMINANT
TETRACHLOROETHENE
  (PCE)
TRICHLOROETHENE
  (TCE)
1,2-DICHLOROETHENE  (TOTAL)
  (DCE)
B2

B2

D

-------
                      CARCINOGENIC POTENCY FACTOR
                             (MG/KG/DAY)  - 1

                                        ORAL                INHALATION

INDICATOR CONTAMINANT

TETRACHLOROETHENE                       5.10E-02            3.30E-03
  (PCE)
TRICHLOROETHENE                         1.10E-02            1.3E-02
  (TCE)
1,2-DICHLOROETHENE  (TOTAL)
  (DCE)

(A)  - VALUES OBTAINED FROM  INTEGRATED RISK INFORMATION SYSTEM  (IRIS)  (4/89).

(B)  -  (HUMAN CARCINOGEN)  SUFFICIENT EVIDENCE FROM EPIDEMIOLOGIC STUDIES
TO SUPPORT A CASUAL ASSOCIATION BETWEEN EXPOSURE CANCER.

GROUP Bl -  (PROBABLE HUMAN  CARCINOGEN)  LIMITED EVIDENCE OF CARCINOGENICITY  IN  HUMANS  FROM
EPIDEMIOLOGICAL STUDIES.

GROUP B2 (PROBABLE HUMAN  CARCINOGEN)  SUFFICIENT EVIDENCE OF CARCINOGENICITY IN HUMANS.

GROUP C  (PROBABLE HUMAN CARCINOGEN)  LIMITED EVIDENCE OF CARCINOGENICITY  IN  ANIMALS.

GROUP D  (NOT CLASSIFIED)  INADEQUATE EVIDENCE OF CARCINOGENICITY IN ANIMALS.

GROUP E  (NO EVIDENCE OF CARCINOGENICITY IN HUMANS)  NO EVIDENCE FOR
CARCINOGENICITY IN AT LEAST TWO ADEQUATE ANIMAL TESTS OR IN BOTH
EPIDEMIOLOGIC AND ANIMAL  STUDIES.

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                                 TABLE 5
      MAXIMUM CONCENTRATIONS AND RESULTING POTENTIAL CANCER RISKS
               FOR CONTAMINANTS AND PATHWAYS OF CONCERN
             AT THE TCAUSAU GROUNDWATER CONTAMINATION SITE
EXPOSURE PATHWAY/             MAXIMUM             POTENTIAL
CONTAMINANT OF CONCERN        CONCENTRATION       CANCER RISK
PCE                           .5 UG/L             8.9 X  (10-7)
TCE                           .5 UG/L             6.3 X  (10-7)

EXPOSURE PATHWAY/RISK TOTAL:                      1.5 X  (10-6)

2) GROUNDWATER  (PRIVATE  WELLS)  (B)

PCE                           2440 UG/L           4.5 X  (10-3)
TCE                           4200 UG/L           5.2 X  (10-3)

EXPOSURE PATHWAY/RISK TOTAL:

3) AIR EMISSIONS  FROM STRIPPERS

PCE                           1.3 UG/M (3)         4.8 X  (10-7)
TCE                           .37/M (3)            1.2 X  (10-6)

EXPOSURE PATHWAY/RISK TOTAL:                      1.7 X  (10-6)

A: CONCENTRATIONS OF  INDICATOR CONTAMINANTS IN THE MUNICIPAL SYSTEM WERE
ASSUMED TO BE EQUAL TO LABORATORY ANALYTICAL METHOD DETECTION LIMITS.

B: CONCENTRATIONS OF  INDICATOR CONTAMINANTS USED IN THE PRIVATE WELL
SCENARIO WERE THE MAXIMUM CONCENTRATIONS DETECTED IN GROUNDWATER AT THE SITE.

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                                 TABLE 6
                     REMEDIAL ACTION ALTERNATIVES

ALTERNATIVE 1  NO ACTION

ALTERNATIVE 2  GROUNDWATER EXTRACTION AND TREATMENT WITH AIR STRIPPING
               AND DISCHARGE TO  THE  WISCONSIN RIVER.

ALTERNATIVE 3  IN-SITU BIORECLAMATION WITH PARTIAL ABOVE GROUND
               TREATMENT AND DISCHARGE TO THE WISCONSIN RIVER.

ALTERNATIVE 4  IN-SITU BIORECLAMATION.

ALTERNATIVE 5  ACTIVE SOURCE CONTROL-SOIL VAPOR EXTRACTION.

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                                TABIiE 12
               SUMMARY OF PROBABLE COSTS:  ALTERNATIVE 2
                           FEASIBILITY STUDY
                     WAUSAU WATER SUPPLY NPL SITE
                           WAUSAU, WISCONSIN

   ITEM                                 COST

GROUNDWATER EXTRACTION SYSTEM          $ 70,000
STRIPPING TOWER AND APPURTENANCES      $ 110,000
VAPOR PHASE CARBON UNIT AND
APPURTENANCES                           $ 50,000
DISCHARGE SYSTEM                        $ 40,000
UTILITIES EXCAVATION SPOILS MANAGEMENT $ 15,000

           CAPITAL FACILITIES SUBTOTAL $ 285,000
ENGINEERING DESIGN  (15%)                $  45,000
CONTRACT AND PROJECT
ADMINISTRATION  (25%)                    $  70,000
               CAPITAL  SUBTOTAL         $  400,000

               CONTINGENCIES  (20%)      $  80,000
               CAPITAL TOTAL            $  480,000


                ANNUAL OPERATION AND MAINTENANCE COSTS

                              FIRST YEAR          SUBSEQUENT YEARS

WATER LEVELS                    $ 5,000              $ 5,000
WATER QUALITY                   $ 26,000            $ 8,000
FLOW MONITORING                 $ 3,000              $ 3,000
ENERGY                          $ 6,000              $ 6,000
GENERAL 0 & M LABOR             $ 20,000            $ 20,000
REPORTING AND ADMINISTRATION    $ 30,000            $ 30,000
CARBON PURCHASE AND
REGENERATION                    $ 30,000            $ 30,000

      0 & M SUBTOTAL            $ 120,000            $ 102,000

      CONTINGENCIES  (20%)       $ 24,000            $ 20,000

      0 & M TOTAL               $ 144,000            $ 122,000

                          12-YEAR PRESENT  WORTH

PRESENT WORTH OF CAPITAL  (NOT DISCOUNTED)           $ 480,000
PRESENT WORTH OF 0 & M  (10% DISCOUNT RATE)          $ 850,000

                  PRESENT WORTH TOTAL              $1,330,000

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                                TABIiE 13
               SUMMARY OF PROBABLE COSTS:  ALTERNATIVE 3
                            FEASIBILITY STUDY
                     WAUSAU WATER SUPPLY NPL SITE
                            WAUSAU, WISCONSIN

   ITEM                                 COST

GROUNDWATER EXTRACTION SYSTEM          $ 95,000
STRIPPING TOWER AND APPURTENANCES      $ 110,000
VAPOR PHASE CARBON UNIT AND
APPURTENANCES                           $ 50,000
DISCHARGE SYSTEM                        $ 40,000
INFILTRATION/NUTRIENT SYSTEM            $ 90,000
UTILITIES AND EXCAVATION SPOILS
MANAGEMENT                              $ 10,000
LAB AND PILOT TESTING                   $ 200,000

           CAPITAL FACILITIES SUBTOTAL $ 595,000

ENGINEERING DESIGN  (15%)                $ 90,000
CONTRACT AND PROJECT
ADMINISTRATION  (25%)                    $ 150,000

               CAPITAL SUBTOTAL        $ 825,000

               CONTINGENCIES  (20%)      $ 165,000
               CAPITAL  TOTAL            $ 990,000


                ANNUAL  OPERATION AND MAINTENANCE COSTS

                              FIRST YEAR          SUBSEQUENT YEARS

WATER LEVELS                    $ 5,000             $ 5,000
WATER QUALITY                   $ 26,000            $ 8,000
FLOW MONITORING                 $ 5,000             $ 5,000
ENERGY                          $ 6,000             $ 6,000
GENERAL 0 & M LABOR             $ 40,000            $ 40,000
REPORTING AND ADMINISTRATION    $ 30,000            $ 30,000
CARBON PURCHASE AND
REGENERATION                    $ 40,000            $ 40,000

      0 & M SUBTOTAL            $ 152,000           $ 134,000

      CONTINGENCIES  (20%)       $ 30,000            $ 27,000

      0 & M TOTAL               $ 182,000           $ 161,000

                          6-YEAR PRESENT WORTH

PRESENT WORTH OF CAPITAL  (NOT DISCOUNTED)           $ 990,000
PRESENT WORTH OF 0 & M  (10% DISCOUNT RATE)          $ 720,000

                  PRESENT WORTH TOTAL              $1,710,000

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               SUMMARY OF PROBABLE COSTS:  ALTERNATIVE 4
                           FEASIBILITY STUDY
                     WAUSAU WATER SUPPLY NPL SITE
                           WAUSAU, WISCONSIN

   ITEM                                 COST

GROUNDWATER EXTRACTION SYSTEM          $ 120,000
UTILITIES AND EXCAVATION SPOILS
MANAGEMENT                              $ 10,000
INFILTRATION/NUTRIENT SYSTEM            $ 90,000
UTILITIES AND EXCAVATION SPOILS
MANAGEMENT                              $ 10,000
LAB AND PILOT TESTING                   $ 200,000

           CAPITAL FACILITIES SUBTOTAL $ 420,000
ENGINEERING DESIGN  (15%)                $  65,000
CONTRACT AND PROJECT
ADMINISTRATION  (25%)                    $  105,000

               CAPITAL  SUBTOTAL         $  590,000

               CONTINGENCIES  (20%)      $  120,000


               CAPITAL  TOTAL            $  710,000


                ANNUAL  OPERATION AND MAINTENANCE COSTS

                              FIRST  YEAR          SUBSEQUENT YEARS

WATER LEVELS                   $ 5,000              $ 5,000
WATER QUALITY                  $ 26,000            $ 8,000
FLOW MONITORING                $ 5,000              $ 5,000
ENERGY                         $ 5,000              $ 5,000
GENERAL 0 & M LABOR            $ 30,000            $ 30,000
REPORTING AND ADMINISTRATION   $ 30,000            $ 30,000


      0 & M SUBTOTAL           $ 111,000            $ 93,000

      CONTINGENCIES  (20%)      $ 22,000            $ 19,000

      0 & M TOTAL              $ 133,000            $ 112,000

                          9-YEAR  PRESENT WORTH

PRESENT WORTH OF CAPITAL  (NOT DISCOUNTED)           $ 710,000
PRESENT WORTH OF 0 & M  (10% DISCOUNT RATE)          $ 670,000

                  PRESENT WORTH  TOTAL              $1,380,000

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               SUMMARY OF PROBABLE  COSTS:  ALTERNATIVE 5
                           FEASIBILITY STUDY
                     WAUSAU WATER SUPPLY NPL SITE
                           WAUSAU,  WISCONSIN

                                 CAPITAL COSTS
            ITEM                                   COST
WELLS, HEADER AND APPURTENANCES                   $ 90,000
BLOWER HOUSE, CONTROLS, UTILITIES                 $ 60,000
OFF-GAS TREATMENT  (CARBON)                        $ 25,000

           CAPITAL FACILITIES  SUBTOTAL           $ 175,000

ENGINEERING DESIGN  (20%)                          $ 29,000
CONTRACT AND PROJECT ADMINISTRATION (25%)         $ 36,000

                             CAPITAL  SUBTOTAL    $ 210,000

CONTINGENCIES  (20%)                               $ 42,000

                             CAPITAL  TOTAL       $ 252,000

                    OPERATION  AND MAINTENANCE COSTS


MONITORING                                        $ 15,000
ENERGY                                            $ 5,000
GENERAL 0 & M LABOR                               $ 30,000
REPORTING AND ADMINISTRATION                      $ 45,000
CARBON PURCHASE AND TREATMENT                     $ 90,000

           VAPOR SYSTEM 18 MONTH 0  &  M SUBTOTAL  $ 185,000

CONTINGENCIES  (20%)                               $ 37,000

           VAPOR SYSTEM 18 MONTH 0  &  M TOTAL     $ 222,000

WELL CW3 AND STRIPPER  - ENERGY                   $ 15,000
                       - 0 & M                     $ 3,000
WELL CW6 AND STRIPPER  - ENERGY                   $ 21,000
                       - 0 & M                     $ 3,500

    CITY WELL AND STRIPPER ANNUAL 0 & M TOTAL    $ 42,500

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                             PRESENT WORTH

PRESENT WORTH OF VAPOR SYSTEM CAPITAL
(NOT DISCOUNTED)                                  $ 252,000
PRESENT WORTH OF VAPOR SYSTEM 0  & M
(NOT DISCOUNTED)                                  $ 222,000

           VAPOR SYSTEM PRESENT  WORTH  TOTAL       $ 474,000

PRESENT WORTH OF CW3 COST  (6 YEARS)               $ 80,000
PRESENT WORTH OF CW6 COST  (14 YEARS)              $ 180,000

           CITY WELL AND STRIPPER PRESENT
           WORTH TOTAL                            $ 260,000

           ALTERNATIVE 5 PRESENT WORTH TOTAL     $ 734,000

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