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