PB97-964107
EPA/541/R-97/098
January 1998
EPA Superfund
Record of Decision:
Tomah Municipal Sanitary Landfill
Tomah, WI
9/25/1997
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Tomah Municipal Sanitary Landfill, Tomah, Monroe County. Wisconsin
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for source control, operable unit 1.
at the Tomah Municipal Sanitary Landfill (TMSL) site in Tomah, Monroe County, Wisconsin.
The remedy was chosen in accordance with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments
and Reauthorization Act of 1986 (SARA) and is consistent with the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP) to the extent practicable. This decision is based
upon the contents of the Administrative Record for the site.
It is anticipated that the State of Wisconsin will concur with this decision. A written
confirmation is expected by September 30, 1997, and will be added to the administrative record
upon receipt.
ASSESSMENT OF THE SELECTED REMEDY
Actual or threatened releases of hazardous substances from the site, if not addressed by
implementing the response action selected in this Record of Decision (ROD), may present an
imminent and substantial endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
This operable unit is the first of two that are planned for the site. The first operable unit
addresses the source of contamination by containing on-site wastes and contaminated soils. The
function of this operable unit is to seal off the TMSL site as a source of groundwater
contamination and to reduce the risks associated with exposure to the contaminated materials.
While the remedy does address one of the principal threats at the site, the second operable unit
will in\ olve continued study and possible remediation of the downgradient contaminant plume.
The major components of the selected remedy include:
Capping the approximately 18-acre landfill with a dual barrier cap that includes a
geosynthetic clay liner, overlain by a low-permeability geomembrane, and covered with 3
feet of soil and vegetated with plants that have a root system less than 3 feet. This cap
would meet the Wisconsin Administrative Code requirements for closed landfills and
would provide a landfill cap in conformance with Wis. Admin. Code § NR 504.07
(1996);
Expansion of an already existing active gas collection system; and
Conducting environmental monitoring to ensure the effectiveness of the remedial action.
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Institutional controls are not included as part of the selected remedy because deed restrictions on
the TMSL property, enforceable by the State of Wisconsin, are already in place. U.S. EPA has
concluded that no additional controls are necessary to prevent inappropriate use of the site.
DECLARATION STATEMENT
The selected remedy is protective of human health and the environment; complies with Federal
and State requirements that are legally applicable or relevant and appropriate to the remedial
action except for groundwater cleanup standards, where a waiver is justified; and is cost-
effective. This remedy utilizes permanent solutions and alternative treatment technologies to the
maximum extent practicable for the site. However, because treatment of the principal threats of
the site was not found to be practicable, this remedy does not satisfy the statutory preference for
treatment as a principal element of the remedy. The size of the landfill and the fact that there are
no on-site hot spots that represent the major sources of contamination preclude a remedy in
which contaminants could be excavated and treated effectively.
Because hazardous substances will remain at the site, U.S. EPA will conduct a five-year review-
in accordance with Section 121 of CERCLA to assess whether any other response is necessary.
William E. Muno
Superfund Division Director
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U.S. EPA Superfund
Record of Decision
Tomah Municipal Sanitary Landfill Site
Tomah, Monroe County, Wisconsin
September, 1997
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TABLE OF CONTENTS
I. Site Description 1
II. Site History and Enforcement Activities 1
III. Highlights of Community Participation 2
IV. Scope and Role of Operable Unit 3
V. Site Characteristics 3
VI. Summary of Site Risks 7
VII. Description of the Remedial Alternatives 10
VIII. Evaluation of Alternatives 14
IX. Statutory Determinations 19
X. State Concurrence 19
FIGURES
Figure 1 Tomah Municipal Sanitary Landfill Site Location Map
Figure 2 Tomah Municipal Sanitary Landfill Site Base Map
With Sampling Locations
Figure 3 Profile of Landfill Cap Design
Figure 4 Comparison of Alternatives
TABLES
Table 1 Summary of Contaminants Detected in Groundwater
APPENDICES
Appendix A - Responsiveness Summary
Appendix B - Administrative Record
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DECISION SUMMARY
JL Site Description
The Tomah Municipal Sanitary Landfill (TMSL) is located north of the City of Tomah. Monroe
County, Wisconsin (Figure 1). The landfill occupies approximately 18 acres within the 40-acre
site (Figure 2). The site is bordered on the north by Deer Creek and its associated wetlands, on
the east by 24th Avenue and agricultural property, on the south by the Sunnyvale Subdivision,
and on the west by agricultural fields and wetlands.
II. Site History and Enforcement Activities
The City of Tomah ("the City" or "Tomah") operated the TMSL as a disposal site from 1959 to
1979, disposing of municipal and industrial wastes on 18 acres located on the southern portion of
the site. Wastes were placed in shallow (3 to 8 feet) unlined trenches, which were excavated in
the sandy subsoils over the southern half of the site and covered with native soils.
In August, 1975, the Wisconsin Department of Natural Resources (WDNR) ordered the City to
close the site because of potential degradation of local groundwater quality. The City closed the
site in 1979, covered it with soil and topsoil, and planted grass and trees on the site.
In June, 1981, Union Camp Corporation submitted a Notification of Hazardous Waste Activity
for a facility in Tomah. The company reported that from 1960 to 1977, it had disposedof 75,700
gallons of solvent waste from plastics and printing operations at the TMSL. These wastes
contained volatile organic compounds (VOCs) and heavy metals.
In December, 1983, representatives of the WDNR conducted a Potential Hazardous Waste Site
Preliminary Assessment for the TMSL. The WDNR's assessment indicated that the landfill
represented a potential hazard to ground water and surface water, and that there could be other
migration pathways.
In June, 1984, the WDNR and the consulting firm Ecology and Environment, under
authorization from U.S. EPA, conducted a site inspection. A groundwater sample from a
downgradient monitoring well contained organic contamination above levels of health concern.
Based on these findings, WDNR nominated the site for inclusion on U.S. EPA's National
Priorities List (NPL) on April 3, 1985. The site was subsequently added to the NPL on March
31, 1989.
In February, 1992, U.S. EPA's Technical Assistance Team (TAT) sampled nine residential wells
in the Sunnyvale Subdivision adjacent to the TMSL. One residential well contained elevated
levels of vinyl chloride.
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In 1993, the City provided municipal water to homes in the Sunnyvale Subdivision, south of the
site, to eliminate the potential hazard posed by the landfill for private drinking wells in the
subdivision. The private wells were subsequently alandoned.
Research to identify parties responsible for conditions at the TMSL was completed early in 1993.
U.S. EPA identified 3 potentially responsible parties (PRPs): the City of Tomah as owner and
operator of the landfill; and Union Camp Corporation and the Veterans Hospital as generators of
hazardous substances disposed of at the site. U.S. EPA sent a special notice letter to the PRPs in
July, 1993, to conduct a remedial investigation/feasibility study (RI/FS) with oversight by U.S.
EPA. On January 11, 1994, an Administrative Order on Consent (AOC) was entered into
voluntarily by the PRPs to conduct the RI/FS at the TMSL site.
In April, 1994, U.S. EPA decided to take a presumptive remedy approach to the selection of a
remedy for the site. After years of addressing contaminated landfills, U.S. EPA has found that
the most practical way to deal with the large variety and volume of waste found in municipal
landfills is containment. A containment remedy may include one or more of the following
components: a landfill cap; a groundwater collection and treatment system; a landfill gas
collection and treatment system; a leachate collection and treatment system; and future land use
restrictions. In the early stages of the presumptive remedy analysis for this site, U.S. EPA
concluded that containment at the TMSL would involve placing a cap over the landfill to reduce
the amount of water entering and migrating out of the landfill and installing and operating a
landfill gas collection system. Data collection efforts in the RI, risk assessment, and analysis of
remedial alternatives in the FS were streamlined based upon application of the OSWER
Directive No. 9355.0-49FS entitled "Presumptive Remedy for CERCLA Municipal Landfill
Sites." Use of the presumptive remedy approach allows a focused effort on data collection to
determine risk at the site, usually by examining groundwater conditions, and a subsequent
streamlined evaluation of alternatives to contain contaminated waste in the landfill. Thus, the
presumptive remedy allows for selection of an on-site source control remedy before all off-site
long-term groundwater contamination issues are resolved. This ROD addresses only the
containment of contaminants from the source area (i.e., the landfill).
In July, 1996, in response to indications that landfill gas wa^ migrating off-site, the PRPs
installed an active gas extraction system along the southern boundary of the landfill.
III. Highlights of Community Participation
In June, 1994, U.S. EPA hosted a "kick-off' public meeting at the Tomah City Hall Council
Chambers. The purpose of the meeting was to inform local residents of the Superfund process,
the presumptive remedy approach and the work to be performed under the RI. In addition,
because there are two other Superfund sites in Tomah. numerous other public meetings and
availability sessions have been conducted.
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In 1993, U.S. EPA established an information repository at the Tomah Public Library, 716
Superior Avenue, Tomah, Wisconsin. U.S. EPA maintains a copy of the administrative record
for the site in the information repository. The RI and FS were released to the public in July,
1996, and April, 1997, respectively. A Proposed Plan was made available on August 7. 1997. A
public meeting was held on August 18. 1997, to discuss the RI/FS and Proposed Plan.
Advertisements were placed in local newspapers to announce the public meeting and comment
period. A public comment period for the Proposed Plan was established from August 7, 1997 to
September 5, 1997. The public generally supports the selected remedy. The responsiveness
summary is contained in Appendix A.
The public participation requirements of sections 113(k)(2)(B) and 117 of CERCLA, 42 U.S.C.
§§ 9613(k)(2)(B) and 9617, have been met in the remedy selection process. This decision
document presents the selected remedy for the Tomah Municipal Sanitary Landfill Superfund
site, chosen in accordance with CERCLA, as amended by SARA, and to the extent practicable,
the NCP. The decision for this site is based on the Administrative Record.
IV. Scope and Role of Operable Unit
U.S. EPA has determined that installation of a low permeability geomembrane and a
geosynthetic clay liner (GCL) over the landfill and the operation of the active gas collection
system is necessary at the TMSL. This decision is based on an analysis of site risks, described in
detail below. The decision relies on the indications that the landfill is the source of
contamination to ground water which may be used by residents downgradient of the site and that
landfill gas is migrating off-site.
This ROD addresses on-site source control. The source control remedy will be implemented and
the site will be monitored to determine the effects of the source control on reducing the levels of
off-site groundwater contamination. After a period of sufficient monitoring a second risk
assessment and FS will be conducted for the off-site contamination, primarily in ground water.
An additional Proposed Plan and ROD will then be issued to select a remedial alternative for the
off-site contamination.
Because hazardous substances will remain at the site, U.S. EPA will conduct a five-year review
in accordance with Section 121 of CERCLA to assess whether any other source control response
is necessary.
V. Site Characteristics
The Phase I and II RI involved sampling and analysis of ground water, landfill gas, surface water
and sediment to determine site conditions. Groundwater samples were collected from residential
and monitoring wells around the site to determine the nature and extent of groundwater
contamination. Gas samples were collected from gas probes in and around the landfill and near
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residents south of the landfill to determine if landfill gases have migrated beyond the limits of
the waste and the site boundary. Surface water and sediment samples were collected in Deer
Creek and in the wetlands north of the landfill to evaluate if contaminants from the landfill were
impacting Deer Creek. Test pit excavations were also conducted to determine the approximate
boundaries of the landfilled area.
Based on the results of the RI, U.S. EPA examined the threats to human health and the
environment through exposure by ingestion and/or direct contact with contaminants in ground
water, and surface water and sediment. U.S. EPA did not quantify risks associated with
contaminants in surface soil and landfill gas because EPA presumed that a landfill cap and an
expanded gas collection system would be installed, thereby addressing the risks associated with
surface soil and gas, whatever they may be.
Site Conditions
Physical Features
1. Geology
Data from soil borings indicate that the TMSL is underlain predominantly by residual sand
materials, formed by the in-place weathering of sandstone bedrock, and alluvial unconsolidated
sands overlying the sandstone bedrock. The unconsolidated material consists of silty sands to
poorly graded fine- to medium-grained sand. The thickness of the unconsolidated deposits in the
immediate vicinity of the landfill ranges from 1 to 19 feet and generally increases toward Deer
Creek.
Underlying the unconsolidated sands is sandstone bedrock of Cambrian age. Two sandstone
mounds are located in the southwest and southeast corners of the site. The bedrock surface
slopes down from the sandstone mounds in all directions.
2. Hydrology
The TMSL site lies in the Deer Creek valley which is the primary drainage way near the site.
Deer Creek flows northeast across the northwestern corner of the property, within 230 feet of the
northwest corner of the landfilled area. The creek meanders through an extensive emergent
wetland located on the northwest portion of the property and joins Lemonweir Creek about one
mile east of the site. Deer Creek is classified as a cold water sport fishery (trout stream).
The moderately permeable site soils permit infiltration and restrict the volume of overland flow.
Surface runoff across the landfill is generally north toward Deer Creek, with the exception of the
low area along the southern property boundary where runoff drains to the south.
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3. Hydrogeology
Ground water beneath the site was encountered within the unconsolidated deposits, the landfill
waste, and the bedrock. The data collected indicates that the unconsolidated sand and the
sandstone bedrock generally function as a single aquifer. The water level data indicate that the
groundwater flow is northeast toward Deer Creek and the surrounding wetlands averaging
velocities between 0.02 and 0.38 ft/day. The groundwater contribution to Deer Creek appears to
be limited to the shallow portion of the aquifer. Deeper flow may occur beneath Deer Creek.
The majority of the landfill appears to be unsaturated. However, investigations showed up to 2
feet of saturated waste at the base of the landfill in some areas. The total thickness of the waste
is approximately 10-12 feet. Using the highest water levels measured at the site, U.S. EPA
estimates that 19,000 out of the 300,000 cubic yards in the landfill may be saturated. However,
seasonal fluctuations in the water table make it difficult to estimate the volume of saturated
wastes with any reliability.
The City and the majority of the private well owners obtain their water supply from the
Cambrian age sandstone aquifers. The City provides municipal water for all residential
properties within the City limits. Residents living outside of the city limits obtain their water
supply from private wells except for those persons living in the Sunnyvale Subdivision who are
serviced by municipal water. Ten of the eleven private wells currently used within one-half mile
of the site are located north and northeast of the site. Well logs from the current property owners
indicate that several of the wells are screened in the sandstone at depths of 50 to 80 feet. One
additional well is located approximately 500 feet east of the landfill. No well log could be
located for this well.
4. Ecology
The TMSL site is zoned as conservancy. The areas to the north, east, and west are classified as
vacant or agricultural. Deer Creek flows northeast across the northwestern corner of the site. The
WDNR. has designated Deer Creek as Class II trout waters, supporting primarily brook trout.
Adjacent woodlands, wetlands, and fields add to the diversity of wildlife habitat in the area.
Wildlife species found at the site would be typical of an urbanizing rural, agricultural area or
transients from adjacent habitats.
WDNR's Bureau of Endangered Resources reports no known occurrences of threatened,
endangered, or special concern species; natural communities; or State Natural Areas that would
be affected by remedial actions at the TMSL site. The U.S. Fish and Wildlife Service does report
that two federally listed species occur in Monroe County. However, the U.S. Fish and Wildlife
Service concluded that due to the nature and location of the proposed activities, the species
identified would not be adversely affected.
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5. Contamination
a) Surface Water and Sediment
Surface water and sediment samples were collected from four locations as part of the Phase 1
investigation (see Figure 2). Three of the four surface water/sediment samples were collected
from Deer Creek. The fourth sample was collected in the emergent wetland adjacent to the
Creek.
Volatile organic compounds (VOCs) and semivolatile organic compounds fSVOCs) were not
detected in the four surface water samples. 2-Butanone was detected in both the upstream and
downstream sediment samples. Low levels (56 to 60 (ig/kg) of three polynuclear aromatic
hydrocarbons (PAHs) were detected in the most downstream sediment sample location.
Comparable values for inorganic constituents were measured for surface water and sediment
samples collected at upstream and downstream sample locations, as well as in the wetland. The
data collected did not indicate that the surface water and sediment have been impacted by
landfill-related contaminants.
b) Ground water
The nature and extent of groundwater contamination was evaluated based on the results from 12
groundwater monitoring wells sampled during Phase I, and 7 additional wells installed and
sampled during the Phase II investigation. In addition, six private wells were sampled during
Phase II (see Figure 2). A summary of contaminants detected in the Phase I and II groundwater
sampling is presented in Table 1. Additional monitoring wells have been added and sampled
since the completion of the Phase II RI and the risk assessment. The groundwater operable unit
will include a complete evaluation of all data collected from the entire groundwater monitoring
well network.
Seven chlorinated VOCs were detected in the samples collected from the monitoring wells.
These VOCs include chloroethane, 1,1-dichloroethane, 1,2-dichloroethene (cis and trans), 1,2-
dichloropropane, 1,2-dichloroethane, and vinyl chloride. Five aromatic VOCs were also detected
including benzene, toluene, ethylbenzene, xylenes, and chlorobenzene. Vinyl chloride and
benzene were detected most frequently and exhibited the highest concentrations. The vinyl
chloride (0.7 to 1,200 (ig/L) and benzene (0.5 to 48 (ig/L) concentrations exceeded the WDNR's
Chapter NR 140 Preventative Action Limit (PAL), Enforcement Standard (ES), and Federal
Maximum Contaminant Level (MCL) in each sample in which they were detected. Vinyl
chloride appears to be the most persistent and widespread VOC. The vinyl chloride
concentrations decreased from 1,200 (ig/L adjacent to the landfill (in MW-7) to 36 |ig/L
approximately 800 feet downgradient from the site (in MW-9B). Analytical data from individual
well nests indicated that concentrations of both ben7ene and vinyl chloride were typically higher
in samples collected at depth compared with those collected at the water table. VOCs were not
detected in the upgradient or residential wells.
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Several SVOCs were also detected in the groundwater samples. The only SVOC to exceed Ch.
NR 140 ES and the MCL was bis(2-ethylhexyl) phthalate.
Various inorganic constituents were detected in groundwater samples. Twelve of the inorganic
parameters were detected in groundwater samples at concentrations exceeding federal primary or
secondary drinking-water standards. Inorganic constituents detected in downgradient ground
water may have migrated from the landfill. Downgradient concentrations of aluminum, iron, and
manganese were significantly higher than those concentrations found in upgradient wells.
Thallium, cadmium, and chromium concentrations measured downgradient of the landfill also
exceeded the federal drinking-water standards.
Groundwater samples collected from the downgradient wells during the Phase I were also
analyzed for pesticides, PCBs, dioxins, and furans. The results of these analyses indicate trace
concentrations of octachloro-dibenzopara-dioxin (OCDD) in three of the samples. Three
pesticides were also detected: endrin, 2,4,5-TP, and chlordane. No PCBs or furans were detected.
c) Landfill Gas
Data collected from the investigation indicate that landfill gas is being generated at the site.
Methane concentrations, as measured in the gas probes and monitoring wells, ranged from 4 to
71 percent (by volume in air). Data collected from .-as probes installed beyond the boundary of
the landfill indicate that landfill gas is migrating offsite. The methane concentrations measured
from zero to 37 percent by volume. The lower explosive limit (LEL) for methane is 5 percent by
volume. Chapters NR 504 and NR 506 of the Wisconsin Administrative Code (WAC) require
that all waste disposal facilities have an effective means for controlling landfill gas migration
such that the concentration of explosive gases at or beyond the property boundary do not exceed
the LEL.
Gas samples were also analyzed using a portable gas chromatograph. VOCs detected include
vinyl chloride, 1,2-dichloroethene, 1,1,1-trichloroethane, trichloroethene, and toluene. In general,
the highest (338.7 to 773.10 ppm) and most consistent contaminant measured was 1,1,1-
trichloroethane.
VI. Summary of Site Risks
U.S. EPA used the data collected during the RI to assess human health and ecological risks. This
assessment compared contamination levels at the site with U.S. EPA standards. In addition,
further assessment of conditions at the site compared contamination levels at the site with Wis.
Admin. Code Ch. NR 140 (1996), Groundwater Standards. The assessment considered ways in
which people and wildlife could be exposed to site-related contaminants and whether such
exposure could increase the incidence of cancer and noncarcinogenic (noncancer related)
diseases above the levels that normally occur in the study area.
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The screening assumed that people could be exposed to site-related contaminants by a number of
different pathways (e.g., ingestion, inhalation, dermal contact). Exposure to surface water and
sediment and ground water were evaluated under current and future land use conditions. The
installation of a landfill cap and a gas collection system was presumed. As a result, risks from
direct contact wiih contaminants in soil on the landfill surface or landfill gases were not
evaluated.
Current land use and reasonably anticipated future use of the land at NPL sites are important
considerations in determining current risks, future potential risks, and the appropriate extent of
remediation. (See "Land Use in the CERCLA Remedy Selection Process," OSWER Directive
No. 9355.7-04, May 25, 1995). Land use assumptions affect the exposure pathways that are
evaluated in the risk assessment. The results of the risk assessment aid in determining the degree
of remediation necessary to ensure current and long-term protection at the site. The risk
assessment considers present use of the site to determine current risks. It may restrict its analysis
of future risks to the reasonably anticipated future land use.
In the case of the TMSL risk assessment. U.S. EPA assumed that the exposure to contaminants in
the surface water and sediment would continue to be the recreational use of Deer Creek. U.S.
EPA assumed the most conservative scenario for exposure to ground water in the future would
be residential use down^iadient of the site.
Potential risks to public health for cancer are expressed numerically, i.e., lxl04 or lxlO"6.
Carcinogenic risk expressed as lxl 04 means that of 10,000 people exposed to contamination
over a 70-year lifetime one individual could potentially develop cancer as a result of the
exposure. A carcinogenic risk of lxl 0"6 means that of 1,000,000 people exposed over a 70-year
lifetime one individual could potentially develop cancer as a result of the exposure. U.S. EPA
has established a carcinogenic risk range from lxl0"4 to lxlO"6 in an aftempt to set standards for
remediation and protectiveness. The measure of noncarcinogenic risk is termed a hazard index
(HI) and is also expressed numerically. When the HI exceeds 1, there is a potential for adverse
health effects.
In general, the majority of the predicted potential health impacts were associated with exposure
to contaminants detected in ground water. Dermal exposures to contaminants in the surface water
and sediment resulted in excess lifetime cancer risks below lxlO"6 and hazard indices below 1 for
recreational receptors. Contaminants in ground water were evaluated for residential ingestion,
inhalation, and dermal exposures. The total excess lifetime cancer risk for adult residents was
3x102, while that for child residents was 1x10"-. The adult resident's hazard index was 139 and
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the child's hazard index was estimated to be 325. Ingestion of groundwater contaminants (i.e..
vinyl chloride) resulted in the majority of the estimated risk and hazard.
The total overall risk for adult residents using the gioundwater and utilizing the wetlands for
fishing or other recreational activities is 3x10°, while that for the child is lxl0":. The risk is
primarily due to the presence of vinyl chloride in the ground water.
It should be noted that two exposure pathways were not evaluated quantitatively in the baseline
human health risk assessment. Because no soil samples were collected from the landfill itself and
a source control action has been proposed, no assessment of risk to persons having contact with
landfill soil and contents were estimated. However, hazardous substances are present in the
landfill that could pose some level of hazard should exposure occur.
Sampling from gas probes has confirmed the presence of landfill gases including VOCs. These
gases have been found to contain vinyl chloride, 1,2-dichloroethene, 1,1,1-trichloroethane,
toluene, and trichloroethene. However, the lack of quality assurance/quality control (QA/QC)
documentation preclude the use of gas samples taken to date in a quantitative risk assessment.
Thus, no quantitative risk was estimated for nearby residents who may be exposed to ambient
concentrations of these landfill gases. A review of the data indicates that the maximum vinyl
chloride concentration in the landfill gas was approximately 20 parts per million (ppm), while
that in ground water was 1,200 |ig/L or 1.2 ppm. Given that inhalation of vinyl chloride vapors
from ground water was estimated to result in a risk of approximately 2xl0"4 and the landfill gas
concentration is an order of magnitude higher than the groundwater concentration, the cancer risk
due to inhalation of vinyl chloride in the landfill gas could potentially result in risks of th<_ same
magnitude. Additional cancer risk could also be contributed by the other carcinogenic
compounds (such as trichloroethene) detected in the landfill gases.
The source control measures proposed in the FS call for the landfill gases to be collected with an
active gas collection system and treated prior to release. The gas collection system and treatment
will reduce explosion hazards and exposures to ambient concentrations inhaled by nearby
residents.
An ecological risk assessment was conducted to estimate the risks to terrestrial and aquatic
organisms at the site and qualitative measure impacts on areas surrounding the TMSL. Terrestrial
organisms associated with the TMSL were not considered at risk based on literature-derived
benchmark values. Exposure and risk to aquatic organisms was evaluated by directly comparing
surface water and sediment exposure dose to National Ambient Water Quality Criteria, state
standards, or other literature-based benchmark values. Based on this analysis, cobalt and
manganese in surface water were the only metals found that would potentially pose a risk to
aquatic organisms.
Actual damage to the aquatic and terrestrial ecosystem of Deer Creek and the adjacent wetlands
was not observed. Based on this analysis, ecological effects from TMSL contaminants are
considered insignificant at this time.
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Based on the information collected to date on the site contamination and associated risks to
human health and the environment, the installation of a low permeability cap to reduce the
amount of contaminants leaching from the landfill wastes to the underlying ground water and
continued collection of landfill gases is warranted. The need for remediation of the contaminated
ground water will be determined after implementation of the source control remedial actions and
after the investigation of the offsite ground water has been completed. The groundwater operable
unit will be addressed in a separate RI/FS, proposed plan and ROD.
VII. Description of the Remedial Alternatives
Remedial Action Objectives
The source control remedial action objectives were developed for this site to address the landfill
as a long-term source of contamination, to provide short- and long-term protection of human
health and the environment, and to meet the applicable or relevant and appropriate requirements
(ARARs).
Based on the analytical data collected to date and the associated risks, the media of concern
include the landfill gas and ground water. The site specific remedial action objectives for this
site include:
Landfill Gas Source Remedial Action Objectives
Prevent landfill gas migration such that at no time shall the standard concentration of
explosive gases in the soils outside the limits of waste, or air within 200 feet of or beyond
the landfill property boundary exceed the lower explosive limit (LEL) for such gases, in
accordance with Wis. Admin. Code Ch. NR 506 (1996), Landfill Operational Criteria.
Chapter NR 506 (1996) of the Wis. Admin Code requires that all waste disposal facilities
have an effective means for controlling landfill gas migration such that the concentration
of explosive gases at or beyond the property boundary does not exceed the LEL.
Prevent blower emission exceedances above standarus for the interim and permanent
landfill gas extraction system set forth in Wis. Admin. Code Ch. NR 445 (1996).
Groundwater Source Control Remedial Action Objectives
Provide an effective means to reduce infiltration through the landfill waste.
Eliminate contaminant migration pathways to the ground water, by providing a
mechanism to reduce VOC and metals contamination, thereby providing a potential
means to meet State groundwater standards within the aquifer affected by contaminants
associated with the landfill.
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Development of Alternatives
The remedial alternatives for the FS are typically assembled from applicable remedial technology
options. A wide range of technologies and remedial options are reduced by evaluating them with
respect to technical implementability, effectiveness, and cost. However, U.S. EPA has found that
the most practical way to deal with the large variety and volume of waste found in municipal
landfills is containment. U.S. EPA's guidance on presumptive remedies for CERCLA municipal
landfill sites indicates that components of the source containment may include:
landfill capping to reduce the amount of water entering and migrating out of the landfill;
extraction and treatment of contaminated ground water and leachate to control offsite
migration
construction of an active landfill gas collection and treatment system to prevent offsite
migration
Based on site-specific conditions, the selection of response actions need only consider those
components that are necessary. The lack of measurable leachate with the landfill indicates that a
leachate collection system is not necessary as a gen .-ral component of the presumptive remedy.
Even though the majority of the landfill appears to be unsaturated, reconsolidation was
considered in the alternatives. Investigations showed up to 2 feet of saturated waste at the base
of the landfill in some areas. As noted above, it is difficult to estimate the volume of saturated
waste with any reliability, but U.S. EPA believes that at most, 19,000 out of a total of 300.000
cubic yards of waste in the entire landfill are saturated.
In addition to source containment, the NCP requires that a no-action alternative be considered for
the site. The no-action alternative serves primarily as a point of comparison for other
alternatives.
The approach to develop the containment alternatives was to provide general source response
actions that address each medium of interest in order to satisfy the remedial action objectives:
Landfill Gas Response Actions
No action
Collection and treatment, if necessary, of landfill gas to prevent migration
Groundwater Source Response Actions
No action
Installation of a low permeability cap to reduce infiltration
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12
Removal of VOCs from the waste through landfill gas extraction
Excavation to remove saturated wastes
The landfill gas source and groundwater source response actions are closely related. The
installation of a low permeability cap will minimize the amount of water entering and migrating
out of the landfill. The cap will also enhance the performance of the gas collection system by
providing a seal over the landfill. The seal should increase the ability of the system to not only
remove methane but also VOCs before they enter the ground water. The remedial alternatives
developed combine the response actions for both the gas and groundwater source control.
Alternative Descriptions
A complete description of the various alternatives is provided in the Feasibility Study. A brief
narrative description of each alternative is provided below. Note that there is no discussion of
institutional controls as part of any alternative. This is because institutional controls in the form
of deed restrictions, enforceable by the State of Wisconsin, are already in place at the TMSL.
U.S. EPA has concluded that no additional controls are necessary to prevent inappropriate use of
the site.
Alternative 1: No action
The no action alternative is developed to act as a baseline to compare against all other
alternatives. This alternative would not include the current (interim) gas collection system or
monitoring of the gas probe or groundwater monitoring well network on and adjacent to the
landfill. This alternative will not meet the landfill gas or groundwater source control remedial
action objectives.
Alternative 2: Continued Operation and Monitoring of Existing Landfill Gas Extraction System.
and Continued Groundwater Monitoring
This alternative includes the operation of the existing landfill gas extraction system along the
southern perimeter of the landfill and continued landfill gas n.nd grouiiJwater monitoring.
Because gas extraction would be continued, there would be no change in risk to human health
and the environment. However, the existing gas collection system would not help to remove
VOCs or methane from within the landfill wastes. Thus, the landfill gas source remedial action
objective would not be fully addressed. Furthermore, since methane is still migrating beyond the
boundaries of the landfill with the existing extraction system, this alternative would not achieve
compliance with Wis. Admin. Code Chs. NR 504 and 506 (1996), Landfill Operational Criteria.
Additionally, no groundwater source containment would be implemented. No capital costs are
-------
13
involved in this alternative.
Alternative 3j. Installation of a Geomembrane Cap with Active Gas Extraction System
This alternative includes the installation of a multi-layered, single barrier cap consisting of a 6-
inch upper vegetative layer, a 30-inch rooting zone/drainage layer, and a 40-mil low density
polyethylene (LDPE) geomembrane layer. The basic benefit of the cap would be to reduce the
amount of infiltration entering the landfill and subsequent release of contaminants to the ground
water.
In addition, an active interior gas control system will be installed to extract gas over the entire
landfill. The gas extraction system would include the current gas migration control system and
additional perimeter and interior wells along the other boundaries of the landfill. Long-term
maintenance and monitoring of the groundwater and landfill gas would be implemented upon
completion of the actions and system startup.
This alternative would meet both the landfill gas and groundwater source control objectives.
However, this alternative does not include the clay component for the low permeability cap, and
would therefore not comply with Wis. Admin. Code Ch. NR 504 (1996), Landfill Location,
Performance, Design, and Construction Criteria. The minimum design and construction criteria
for final cover systems set forth in Wis. Admin. Code § 504.07 (1996) are relevant and
appropriate requirements for designing and constructing a cap for the Tomah Municipal Sanitary
Landfill. This is because the types of waste disposed of in the TMSL are similar to those found
in waste disposal facilities regulated under Wis. Admin. Code Ch NR 504 (1996). A dua!
barrier, low permeability cap consisting of a 2-foot clay layer underlying a geomembrane is
specified in Wis. Admin. Code § NR 504.07 (1996). The clay layer is required to provide a back-
up barrier system in the event the membrane fails, either during construction or at some time in
the future.
Alternative 4: Installation of a Geomembrane and a GCL Cap with Active Gas Extraction
System
This alternative provides the same benefits as Alternative 3, but will include the added back-up
barrier protection of a geosynthetic clay liner (GCL). The GCL would be placed directly beneath
the geomembrane. The GCL component provides a substitute material for the clay layer
component specified in Wis. Admin. Code § NR 504.07 (1996) for final cover design. By
incorporating the GCL material below the geomembrane cap, this cover system will provide an
equivalent performance to the cap design specified in the Wisconsin regulations. The alternative
would meet both the landfill gas and groundwater source control objectives.
Alternative 5: Installation of a Geomembrane Cap and 2 Feet of Clav with Active Gas
Extraction System
This alternative provides both the geomembrane layer and the 2-foot clay layer specified for final
landfill cover systems in Wis. Admin. Code § NR 504.07 (1996). The clay layer would meet the
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14
specifications set forth in Wis. Admin. Code § NR 504.06(2)(a) (1996). However, due to site
design restrictions, the clay would be discontinued along a line north of the existing gas
extraction system. A GCL material would be substituted for the clay south of the existing gas
system to reduce the encroachment on the adjacent residential properties, reduce drainage
problems, and eliminate the need to reconstruct the existing landfill gas collection system. The
alternative would meet both the landfill gas and groundwater source control objectives.
Alternative 6: Reconsolidation of Saturated Waste. Installation Geomembrane Cap with Active
Gas Extraction System
This alternative includes installation of a low permeability landfill cap and gas extraction system.
As described in Alternative 3, the landfill cap would be a multi-layered, single barrier cover,
consisting of a upper vegetative layer, a rooting zone/drainage layer and a geomembrane. The
final cap design would be modified by excavation of the maximum saturated area of waste found
along the northern portion of the landfill. Approximately 174,000 cubic yards of waste from the
north central portion of the landfill could be excavated and reconsolidated. Reconsolidation
options include moving excavated wastes to a more upland (south side) of the landfill or
backfilling the excavation with clean fill to water table and placing the wastes on top (i.e.,
effectively raising waste above high water levels). As with Alternative 3, this alternative would
meet both the landfill gas and groundwater source control objectives but would not comply with
Wis. Admin. Code Ch. NR 504 (1996), Landfill Location, Performance Design, and
Construction Criteria.
Alternative 7: Reconsolidation of Saturated Waste. Installation Geomembrane and GCL Cap
with Active Gas Extraction System
This alternative includes all the components of Alternative 6 with the addition of the GCL layer
below the geomembrane. This alternative would meet both the landfill gas and groundwater
source control objectives.
Alternative 8: Reconsolidation of Saturated Waste. Installation Geomembrane and Clay Cap
with Active Gas Extraction System
This alternative includes all the components of Alternative 6 with the additional of a 2-foot clay
layer. This alternative would meet both the landfill gas and groundwater source control
objectives.
VIII. Evaluation of Alternatives
Nine Evaluation Criteria
In the NCP, the U.S. EPA has established nine criteria that balance health, technical, and cost
considerations to determine the most appropriate remedial alternative. The criteria are designed
to select a remedy that will be protective of human health and the environment, attain Applicable
or Relevant and Appropriate Requirements (ARARs), utilize permanent solutions and treatment
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15
technologies to the maximum extent practicable, and be cost effective. The relative performance
of each of the remedial alternatives listed above has been evaluated using the nine criteria set
forth in the NCP as the basis of comparison. These nine criteria are summarized below:
Threshold Criteria
The selected remedy must meet the following threshold criteria:
1. Overall Protection of Human Health and the Environment addresses whether a remedy
provides adequate protection and describes how risks are eliminated, reduced or controlled
through treatment, engineering controls or institutional controls.
2. Compliance with Applicable or Relevant and Appropriate Requirements (ARARs^
addresses whether a remedy will attain applicable or relevant and appropriate requirements
under federal environmental laws and state environmental or facility siting laws or provide
grounds for issuing a waiver.
Primary Balancing Criteria
The balancing criteria are used to compare the effectiveness of the remedies.
3. Long-term Effectiveness and Permanence refers to the amount of risk to maintain reliable
protection of human health and the environment over time once cleanup goals have been met.
4. Reduction of Toxicity. Mobility or Volume Through Treatment is the anticipated
performance of treatment technologies that may be employed in a remedy to reduce the
harmful effects of principal contaminants, their ability to move in the environment, and the
amount of contamination present.
5. Short-term Effectiveness refers to the speed with which the remedy achieves protection, as
well as the remedy's potential to create adverse impacts on human health and the
environment during the construction and implementation period.
6. Implementability is the technical and administrative feasibility of a remedy, including the
availability of materials and services needed to implement the chosen solution.
7. Cost addresses the estimated capital and operation and maintenance (O&M) costs, evaluated
as the present worth cost. Present worth is the present value of the capital and future O&M
costs of an alternative based on the time value of money.
Modifying Criteria
These criteria deal with support agency and community response to the alternatives.
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16
8. State Acceptance indicates whether, based on its review of the FS and the Proposed Plan,
the support agency (in this case, the WDNR) concurs with, opposes, or has no comment on
the recommended alternative.
9. Community Acceptance is assessed in the Record of Decision based upon a review of the
public comments received on the FS report and the Proposed Plan.
Evaluation of the Remedial Alternatives
As part of the FS all the remedial alternatives are evaluated against the nine criteria. Figure 4
contains a summary of this analysis.
Threshold Criteria
The threshold criteria are CERCLA statutory requirements that must be satisfied by any
alternative in order for it to be eligible for selection as a CERCLA remedy. Alternatives that do
not meet the threshold criteria are not carried through a comparison with the other alternatives.
1. Overall Protection of Human Health and the Environment
The no action alternative will not provide protection of human health and the environment.
Alternative 2 will provide only limited reduction of risk to human health arid the environment by
collecting landfill gas along the southern perimeter of the landfill. The remaining alternatives
that include a landfill cap and active gas extraction system provide the applicable components for
a CERCLA presumptive remedy for source control at the TMSL. Risks to human health and the
environment would be reduced due to the extraction and treatment of landfill gases and reduction
or elimination of source pathways for additional groundwater contamination.
2. Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
ARARs for the alternatives considered are contained in Table 1 of the Feasibility Study for
Source Control, dated April 14, 1997, as amended by U.S. EPA's letter of July 15, 1997. Note
that, at this time, EPA cannot say whether any of the alternatives considered will restore ground
water outside the landfill to federal and state drinking water standards. But under section
121(d)(4) of CERCLA, 42 U.S.C. §9621(d)(4), U.S. EPA may select a remedy that does not
attain cleanup standards when the remedial action selected is only part of a total remedial action
that will attain such level or standard of control when completed. That is the case here. Ground
water conditions will be addressed in a second operable unit.
The no action alternative and Alternative 2 will not comply with the ARARs because they do not
include the multi-layer cap required under Wis. Admin. Code § NR 504.06 (1996) for closed
landfills. In addition, for Alternative 2, the existing gas extraction system does not achieve
compliance with Wis. Admin. Code §§ NR 504 and 506 (1996) because some gas is continuing
to migrate off-site. The cap proposed as part of Alternatives 3 and 6 does not provide the back-
up component required by Wis. Admin. Code § NR 504.07 (1996). Alternatives 4, 5. 7, and 8
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17
would meet the Wisconsin Administrative Code requirements for closed landfills and would
provide a landfill cap in conformance with Wis. Admin. Code § NR 504.07 (1996). Alternatives
4 and 7 would meet the Wisconsin requirement for a clay capping layer by substituting a
geosynthetic clay liner that has an equivalent standard of performance, such that these
alternatives qualify for a variance under Wis. Admin. Code § NR 500.08(4) (1996).
Primary Balancing Criteria
3. Long-term Effectiveness and Permanence
Installation of a presumptive remedy cap and gas extraction system have been proven to be
reliable long-term containment technologies for municipal landfills. Alternatives 4, 5. 7 and 8
provide additional long-term effectiveness and permanence by including a back-up barrier to the
geomembrane layer in the multi-layer cap.
Alternatives 6, 7, and 8 include reconsolidation of saturated waste which may provide an
effective means to remedy groundwater within the waste. However, the majority of the landfill
appears to be unsaturated. U.S. EPA estimates that only 19,000 out of the 300,000 cubic yards
of waste estimated to be in the landfill are saturated. However, seasonal fluctuations in the water
table make it difficult to estimate the volume of saturated wastes with any reliability. In
addition, as has been shown at other landfill sites, water table elevations under the landfill may
drop after installation of the cap, reducing the volume of saturated wastes. The combination of
these factors makes it difficult to assess the contribution of saturated waste to groundwater
contamination and the benefits, if any, of reconsolidation.
4. Reduction of Toxicity, Mobility or Volume Through Treatment
The no action alternative will not reduce toxicity, mobility or volume of contamination. The rest
of the alternatives include a gas collection/extraction system that will treat VOCs if the levels are
such that treatment is necessary to meet Wisconsin air standards.
5. Short-term Effectiveness
Alternatives 3, 4, 5, 6, 7 and 8 would provide a remedy for ott-site landfill gas migration by
installation of an interior active gas extraction system, that would effectively reduce the health
and safety threat to landowners adjacent to the landfill. These alternatives would also result in
relatively little site disturbance. As a result, they will reduce public exposure to air emissions,
odor, noise and traffic. Because no waste will be exposed, the installation of the landfill cap will
not put workers or the public at risk from exposure.
6. Implementability
Required materials, services and equipment are available to implement each source control
alternative. Operation and maintenance of the existing landfill gas collection system have
already been implemented. Thus, Alternative 2 involves no construction and is the easiest to
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18
implement. All the Alternatives except 1 and 2 involve placement of the multi-layer cap and
would require care in construction to minimize potential damage to the existing gas collection
system.
7. Cost
The costs for the alternatives (including both capital expenditures and future operating costs that
have been discounted at a 2 percent rate) range from SI.4 million to S7.2 million. The cost for
each alternative is presented in Figure 4.
Costs associated with Alternatives 6, 7, and 8 are high due to a number of factors, including: the
amount of unsaturated wastes that would need to be moved to get to the saturated wastes at the
base of the fill, the small area available for excavation activities, a phased excavation approach,
waste handling activities, uncertainty concerning the treatment of groundwater produced during
excavation, and potential characterization of any portion of reconsolidated waste, contaminated
soils, or contaminated ground water. Costs of these alternatives are almost double that of their
counterpart with no reconsolidation.
Modifying Criteria
8. Support Agency Acceptance
U.S. EPA is the lead agency for this site and the author of this ROD. WDNR has been the
support agency for the RI/FS and has reviewed this ROD. The State of Wisconsin has indicated
a willingness to concur with this decision. A written confirmation is expected by September 30,
1997, and will be added to the administrative record upon receipt.
9. Community Acceptance
A Proposed Plan was prepared and released to the public on August 5. 1997. A 30-day public
comment period was conducted between August 7, 1997, and September 5, 1997. A public
meeting on the proposal was held on August 18, 1997. The public generally supports the
proposed remedy. The comments U.S. EPA received, together with U.S. EPA's responses, are
described in the Responsiveness Summary attached to this ROD.
Selected Alternative
U.S. EPA has determined that Alternative 4: Installation of a low permeability geomembrane
and a geosvnthetic clay liner (GCL) over the landfill and the operation of the active gas
collection system is the best remedy for source control at the TMSL. Alternatives 4, 5, 7, and 8
fully meet all the NCP criteria. The only criterion that clearly revealed differences between the
four acceptable alternatives was cost. All things being equal, U.S. EPA prefers to select the most
cost-effective remedial alternative. Alternative 4 while meeting all threshold, balancing, and
modifying criteria was also the least costly of the four acceptable alternatives.
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19
The Remedial Action Objectives that the selected remedy must meet are described above in
Section VII. The ARARs for the selected remedy are listed in Table 1 of the Feasibility Study
for Source Control, dated April 14, 1997, as amended by U.S. EPA's letter of July 15, 1997.
They include Wisconsin regulations concerning landfill performance and design set forth in Wis.
Admin. Code Chs. NR 504 and 506, and air standards set forth in the Clean Air Act, 42 U.S.C. v>
7401 et seq.. and Wis. Admin. Code Ch. NR 439 (1996).
It should be mentioned that Alternative 4 only addresses on-site source control at the landfill and
that a subsequent risk assessment, FS, proposed plan, and ROD will address off-site groundwater
contamination.
IX. Statutory Determinations
U.S. EPA and the State of Wisconsin believe the selected remedy will protect human health and
the environment; complies with ARARs, except for groundwater cleanup standards where a
waiver is justified; is cost-effective; and utilizes permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent practicable. The selected
remedy will not satisfy the preference for treatment as a principal element. The size of the
landfill and the fact that there are no on-site hot spots that represent the major sources of
contamination preclude a remedy in which contaminants could be excavated and treated
effectively.
X. State Concurrence
The State of Wisconsin has indicated a willingness to concur with this decision. A written
confirmation is expected by September 30, 1997 and will be added to the administrative record
upon receipt.
-------
FIGURES
-------
! North Tomah
Boyonton
C«m
IXQ Z> NORTH WESTERN
'TOMAF
sucxLsy
LANe
Sandpit.-.
^Sandpit
Trailer
S«ndp*U *'
t
3
1
r
rground
SCALE IN FEET
b-«
NSlN^
V.
quaorangle
location FIGURE 1
Site Location Map
Tomah Municipal Sanitary Landfill
E'04'95 ES MS i»#Lx Mao 9-3-S7 'ikrrvnj ' CH2IV1I I ILL.
-------
S3/E1K
S3/E1K
T5/S3K
S3/E1K
S3/E1K
T5/S3K
FIGURE 2
SAMPLE LOCATION MAP
-------
1000
995 : -
990
985
980
9;o
965
WIDTH VARIES
6 i TOPSOIL
geomembranl
EIXlSTlNd GRADE
I
OSYNTHETC CLAY LINE^
1 50
250
cto»cHe»w< -
ilOOO
, 995
990
985
ccocnffHrnc clay limcr
ANCHOR TRENCH DETAIL
M(JI TO SCALE
980
j
I
970
965
TOMAH MUNICIPAL SANITARY LANDFILL
TOMAH.
WISCONSIN
FIGURE 9
REMEDIAL
ALTERNATIVE 4
CMAHN BY- JUM
"WJCCT NO. 27SO4-O02
CXCKCD VY: UK
SC*£ AS SMOVN
GrOKMESA MOORE
Wt- APRH. 1. 1997
FIGURF :i
Cap Design for
Alternative 4
Tomah Municipal Sanitary L.i'ujfin
CH2MHILL
-------
Evaluation Criteria
1.
Ovciall Protection of Human
Health anil Environment
o
~
2.
Compliance wilh ARARs *
o
O
O
O
V
long-term P.llcclivcncss and Permanence
o
*
~
*
4
Reduction of Toxicity, Mt»bility,
or Volume through Treatment
o.
ShorMcrm liffcctiveness
o
t-
ft.
Impleineniabilily
7,
Cost ($ millions)
$0
$1.4
$2.8
$3.2
$Cl>
$6,1
$6.5
$7.2
H.
Support Agency Acceptance
The Slate
of Wisconsin fully supports and accepts Alternative #4
().
Community Acceptance 0
imtimmily o
.plain e of the recoMuneruJed alternative will he <
oaliiated
iit the puhhe
comment period
9 Fully mco/s criteria Ijl Parltally mcels criteria (Pops not meet criteria
* Except For Groundwater ARARs
«i MS r iit)| aik q ~ m; ..
FIGURE 4
Comparison of Alternatives
Tomah Municipal Sanitary Landfill
¦ CH2MHILL
-------
TABLES
-------
Table 1
Summary cf Contaminants
Detected in Groundwater
Minimum
Maximum
Total
Positive
Detection
Detected
Detected
Parameter
Analyses
Detections
Frequency
Value
Value
Units
Volatile Organic Compounds
1,1-Dichloroethane
8
4
50.0%
1
27
pg/L
1,2-Dichloroethane
8
2
25.0%
3
4
pg/L
1,2-Dichloropropane
8
2
25.0%
5
16
pg/L
2-Hexanone
8
1
12.5%
86
86
pg/L
Acetone
8
2
25.0%
2
320
pg/L
Benzene
8
5
62.5%
5
48
mq/l
Carbon Disulfide
8
3
37.5%
0
1
M9/L
Chlorobenzene
8
5
62.5%
1
8
M9/L
Chloroethane
8
5
62.5%
1
13
M9/L
cis-1,2-dichloroethene
8
4
50.0%
1
210
M9/L
Ethylbenzene
8
4
50.0%
1
48
M9/L
2-Butanone (MEK)
8
1
12.5%
280
280
M9/L
4-Methyl-2-pentanone (MIBK)
8
1
12.5%
32
32
M9/L
Styrene
8
1
12.5%
3
3
Pg/L
Toluene
8
5
62.5%
1
550
M9/L
1,2-Dichloroethene (total)
8
5
62.5%
1
200
Mg/L
trans-1,2-dichloroethene
8
1
12.5%
1
1
M9/L
Vinyl Chloride
8
8
100.0%
3
1,200
M9/L
Xylenes (total)
8
3
37.5%
59
180
mq/l
Semivolatile Organic Compounds
1,2-Dichlorobenzene
8
2
25.0%
1
1
MQ/L
1,4-Dichlorobenzene
8
5
62.5%
2
22
pg/L
2.4-Dimethylphenol
8
2
25.0%
5
16
pg/L
2-Methylnaphthalene
8
3
37.5%
2
5
pg/L
2-Methylphenol (o-cresol)
8
1
12.5%
18
18
M9/L
4-Chloro-3-methylphenol
8
2
25.0%
8
11
M9/L
4-Methylphenol (p-cresol)
8
1
12.5%
1,100
1,100
pg/L
bis(2-chloroethyl) ether
8
1
12.5%
7
7
pg/L
bis(2-ethylhexyl) phthalate
8
1
12.5%
27
27
pg/L
Di-n-butyl phthalate
8
1
12.5%
1
1
pg/L
Diethylphthalate
8
4
50.0%
4
110
pg/L
N-Nitrosodiphenylamine
8
1
1 ?.5%
2
2
pg/L
Naphthalene
8
3
37.5%
5
16
pg/L
Phenol
8
1
12.5%
54
54
pg/L
Pesticides/TCDDs
Endrin
3
1
33.3%
0
0
pg/L
Gamma-Chlordane
3
1
33.3%
0
0
pg/L
Octachlorodibenzo-p-dioxin
3
2
66.7%
63
380
pg/L
2,4,5-TP (Silvex)
3
1
33.3%
1
1
pg/L
Page 1 of 2
-------
Table 1
Summary of Contaminants
Detectec
in Groundwater
Minimum
Maximum
Total
Positive
Detection
Detected
Detected
Parameter
Analyses
Detections
Frequency
Value
Value
Units
Inorganics
Aluminum
8
8
100.0%
515
186,000
pg/L
Antimony
8
4
50.0%
2
53
Pg/L
Arsenic
8
7
87.5%
4
112
pg/L
Barium
8
8
100.0%
117
1,730
pg/L
Beryllium
8
4
50.0%
2
11
Pg/L
Cadmium
8
2
25.0%
8
12
pg/L
Calcium
8
8
100.0%
4,960
150,000
pg/L
Chromium, Total
8
7
87.5%
2
320
pg/L
Cobalt
8
8
100.0%
6
103
pg/L
Copper
8
6
75.0%
14
232
pg/L
Iron
8
8
100.0%
825
353,000
pg/L
Lead
8
8
100.0%
3
158
pg/L
Magnesium
8
8
100.0%
1,020
114,000
pg/L
Manganese
8
8
100.0%
811
19,000
pg/L
Mercury
8
6
75.0%
0
3
pg/L
Nickel
8
8
100.0%
8
143
pg/L
Potassium
8
8
100.0%
1,360
114,000
pg/L
Selenium
8
ti
100.0%
3
24
pg/L
Silver
8
3
37.5%
11
22
pg/L
Sodium
8
8
100.0%
6,390
251,000
pg/L
Thallium
8
5
62.5%
3
21
pg/L
Vanadium
8
8
100.0%
1
233
pg/L
Zinc
8
7
87.5%
52
439
pg/L
Page 2 of 2
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APPENDIX A
Responsiveness Summary
-------
RESPONSIVENESS SUMMARY
TOMAH MUNICIPAL SANITARY LANDFILL
TOMAH, MONROE COUNTY, WISCONSIN
PURPOSE
This responsiveness summary has been prepared to meet the requirements of Sections
113(k)(2)(B)(iv) and 117(b) of the Comprehensive Environmental Response, Compensation, and
Liability Act of 1986 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), which requires the United States Environmental
Protection Agency (U.S. EPA) to respond to each of the significant comments, criticisms, and
new data submitted in written and oral presentations on a proposed plan for remedial action. The
responsiveness summary provides a summary of citizen's comments and concerns identified and
received during the public comment period, and U.S. EPA's responses to those comments and
concerns. All comments received by U.S. EPA during the public comment period were
considered in the selection of the remedial alternative for the TMSL. The responsiveness
summary serves two purposes: it summarizes community preferences and concerns regarding the
remedial alternatives, and it shows members of the community how their comments were
incorporated into the decision-making process.
This document summarizes written anu oral comments received during the public comment
period of August 7, 1997 to September 5, 1997. The comments have been paraphrased to
efficiently summarize them in this document. The public meeting was held at 6:00 p.m. on
August 18, 1997 at the Tomah City Hall Council Chambers, Tomah, Wisconsin. A full
transcript of the public meeting, as well as all site related documents, are available for review at
the Information Repository, located at the Tomah Public Library, 716 Superior Avenue, Tomah,
Wisconsin. Comments and questions were received during the public meeting from several
residents and/or city officials. Additionally, comments were mailed to U.S. EPA.
OVERVIEW
The proposed remedial alternative for the Tomah Municipal Sanitary Landfill was announced to
the public just prior to the beginning of the public comment period. U.S. EPA proposed the
installation of a low permeability geomembrane and a GCL over the landfill to reduce infiltration
of water, with an active gas collection system.
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Community Comments
1. Comment: One commenter was concerned about the efficacy of the landfill cap to
alleviate groundwater contamination.
Response: Groundwater conditions at the site will be monitored for approximately a year
after implementation of the cap. At that time, or when the Agencies determine that
sufficient time has passed to assess the impact of the cap, an evaluation will be made as to
the ability of the cap as well as the gas extraction system to reduce levels of
contamination in ground water. After this evaluation a risk assessment will be conducted
to determine the risk posed by the levels of contamination in the ground water. If needed,
a second feasibility study will be conducted to look at remedial alternatives for the
ground water. A proposed plan and record of decision will be issued by the U.S. EPA
proposing a groundwater clean-up alternative for the site.
2. Comment: This same commenter indicated that he had lived by the landfill property for
almost fifty years and had seen landfill'ng in the northeastern portion of the property.
This portion had not previously been identified as an area that accepted wastes.
Response: Based upon this comment and the lack of sufficient remedial investigation
data from the area, U.S. EPA has determined that additional characterization is needed to
determine if the landfill area extends into the northeastern portion of the property. The
U.S. EPA recommends that additional characterization be conducted in this area during
the remedial design. The design sampling will help determine if the recommended dual-
barrier cap needs to be extended to cover the suspected area. The extent of design
sampling will be determined during review of the remedial design project planning
documents.
3. Comment: This same commenter, as well as other ciuzens who attended the public
meeting, had concerns about surface water runoff from the new cap affecting their
properties.
Response: As part of the design and implementation of the new landfill cap, engineering
controls will be put in place to collect surface run-off and prevent it from impacting
properties adjacent to the landfill. U.S. EPA will require operation and maintenance of
the cap so as to ensure the integrity of the cap and associated engineering controls.
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4. Comment: Another commenter had questions about the extent of sampling that occurred
in the Sunnyvale subdivision. In particular, why was more sampling not performed?
Response: Groundwater and landfill gas monitoring were conducted south of the landfill
in the Sunnyvale subdivision. Groundwater monitoring involved private well sampling
as well as the installation and sampling of a monitoring well. Data collected from ground
water indicated that the potential effects of the landfill on ground water to the south of the
site was unlikely. This coupled with the facts that ground water appeared to moving to
the east/northeast away from the subdivision and that the City of Tomah had extended
municipal water services to the area provided reasonable assurances that the impact of the
landfill on ground water to the south of the landfill was minimal. U.S. EPA then made
the determination that an extended investigation of ground water south of the landfill was
not warranted. Migration of landfill gas south of the landfill into the subdivision was also
monitored. Sampling efforts concentrated on homes and yards adjacent to the landfill,
since these homes appeared to be those that would affected first, until the responsible
parties installed an active gas extraction system to remove the gas from the landfill. The
in-home gas sampling was eventually discontinued after the gas extraction system
effectively reduced the amount of gas migrating beyond the southern border of the
landfill to safe levels. This system will be expanded and monitoring will continue as part
oi'the remedy for the landfill. Capping will also increase the effectiveness of the
extraction system. As part of the presumptive remedy, soil sampling was not conducted
since it is assumed that the site will be capped. Some sediment and surface water
sampling was conducted in Deer Creek, and the landfill was found not to have impacted
the creek.
5. Comment: One commenter was concerned about the affects of the Superfund clean-up on
property values near the landfill.
Response: U.S. EPA believes that, in general, a Superfund clean-up will increase property
values not only on the Superfund site itself, but in areas adjacent to the site.
6. Comment: One commenter wondered how long is there going to be a guarantee that the
cap is going to stay effective without changes from the EPA?
Response: After construction of the landfill cap, an operation and maintenance plan will
go into effect, the purpose of which will be to ensure that the remedy continues to be
effective in preventing infiltration into the landfill and removing gas. Part of the
operation and maintenance will be monitoring. Should conditions arise resulting in
questions about the integrity of the remedy, U.S. EPA and the WDNR reserve the right to
propose changes to address the new conditions and secure the integrity of the remedy.
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1. Comment: The City requested that remedial Alternative 3, installation of a low
permeability geomembrane cap over the laadfill to minimize infiltration, and an active
gas extraction system, as described in the Tomah Municipal Sanitary Landfill (TMSL)
Feasibility Study (FS) for Source Control be selected in the Record of Decision.
Response: The U.S. EPA and the WDNR have reviewed and analyzed all the remedial
alternatives presented in the TMSL FS for Source Control and have selected remedial
Alternative 4 as the most appropriate remedy based upon an analysis of U.S. EPA's nine
health, technical, and cost criteria as described in the Proposed Plan issued on August 7,
1997 and the attached Record of Decision. Alternative 4 included installation of a low
permeability geomembrane and a geosynthetic clay liner over the landfill to minimize
infiltration of water, and an active gas extraction system. Alternative 3 failed to meet the
threshold criteria for compliance with applicable or relevant and appropriate requirements
because it did not include a dual-barrier system and thus did not meet state requirements.
The dual-barrier landfill cap provides a sufficient back-up system should one of the
barrier layers fail.
Comments of Union Camp Corporation
Union Camp Corporation, one the Potentially Responsible Parties at the Tomah Municipal
Sanitary Landfill, submitted comments on the remedy, on the risk analysis, and on the allocation
of responsibility for paying for the cleanup. Union Camp included in its submission the detailed
comments of one of its contractors, TRC Environmental Solutions Inc., on the choice of the
landfill cover and on the risk assessment. Union Camp also included copies of comments it
submitted to EPA Headquarters concerning the Agency's Municipal Solid Waste Settlement
Proposal.
With respect to Union Camp's comments on allocation of costs for the cleanup and on the
Municipal Solid Waste Settlement Proposal, EPA declines to respond at this time. The purpose
of the public comment period on the Proposed Plan for the Tomah Municipal Sanitary Landfill
was to solicit comments on the remedy the Agency had tentatively chosen for the site. EPA will
respond to Union Camp in due course concerning allocation and liability issues. But EPA
believes it is important to keep technical questions concerning the adequacy of the selected
remedy and legal/policy questions concerning allocation of responsibility separate.
Union Camp, by contrast, seems to want to blend the analysis of the proposed remedy with
arguments about allocation of responsibility. There is an implication in Union Camp's
comments that remedial decisions could differ depending on the number of viable PRPs at a site.
Where a great many viable PRPs are present, one kind of remedy might be chosen; for an
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identical site with only a few viable PRPs, a different, presumably cheaper, remedy should be
selected. EPA rejects this way of proceeding as fundamentally inconsistent with the National
Contingency Plan.
1. Comment: Union Camp and TRC advance various arguments why selection of a dual
barrier cap is unwarranted at the TMSL. One argument is that the improvement in
performance of a dual barrier cap over a single geomembrane is minimal, and not worth
the additional $469,000 it would cost. A second argument is that the choice of a dual
barrier cap is a "policy" decision, not a technical/engineering decision. Finally, Union
Camp asserts that single membrane liners have been selected at other sites in Wisconsin,
implying that the selection of dual membrane for the TMSL is an arbitrary decision
Response: In 1996, the State of Wisconsin changed its regulations concerning the design
of final cover systems for landfills to require two impermeable layers - a geomembrane
and a clay layer - rather than one. The new requirement purposely built in a certain
amount of redundancy in order to provide protection if the geomembrane layer failed.
Hence, arguments about the minimal incremental reduction provided by a second layer
are beside the point. Union Camp's technical arguments assume that the main
geomembrane layer would never fail. But what if it does? The Wisconsin regulation was
not intended to reduce infiltration by another fraction of a percent, but rather, to provide
basic impermeability if the geomembrane is breached. Union Camp does not explain
how the system it favors offers any similar safeguard feature. It nowhere cites any
figures regarding the reliability of single membrane covers. Rather, it terms a potential
breach a "speculative" event and it implies that it should not have to subsidize safeguards
designed to address such things. Suffice it to say that if a breach of the geomembrane
were a sure thing, U.S. EPA and WDNR wuuld not select a remedy that included a
geomembrane as a component.
As for Union Camp's argument that requiring dual barrier systems is a policy decision,
U.S. EPA agrees, but questions why Union Camp finds fault with thai. Most, if not all,
environmental requirements - state and federal - are imposed as a result of policy
decisions. We should be clear that by a "policy decision," we mean here that, in order to
guard against the failure of landfill cover systems, Wisconsin chose to impose by
regulation a requirement for a dual barrier system. This was not a policy decision in the
sense of a guidance document or policy paper that might or might not be followed. Since
1996, dual barriers have been legally required in Wisconsin.
U.S. EPA is not aware of any instances since the 1996 regulations were adopted of
WDNR's approving a single barrier cover for a landfill in Wisconsin. There may be
instances prior to 1996, but the adoption of new standards makes those cases irrelevant.
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2. Comment: Union Camp is concerned that because of the prospect "that the extreme
nature of the risk assessment may precipitate unwarranted public concern," the current
risk assessment should not be published as a final administrative record document.
Response: U.S. EPA used the current risk assessment in selecting the source control
remedy. It was therefore both proper and necessary for U.S. EPA to include the risk
assessment in the administrative record. EPA made it available for public review
together with the rest of the administrative record at the Tomah Public Library. To date,
EPA has received no comments expressing unwarranted public concern about the risk
assessment.
EPA disagrees with Union Camp that the risk assessment was extreme in nature. U.S.
EPA's contractor used standard U.S. EPA guidance documents and standard policy in
developing reasonably conservative assumptions. U.S. EPA and the WDNR reviewed
and approved it. Of course, the risk assessment may be superseded by further analysis.
But that is no reason to suppress the current risk assessment.
3. Comment: TRC states that in the risk assessment "the exposure scenario is not an
appropriate representation of potential current risks, as the concentrations of constituents
of concern (COCs) are from a well located immediately downgradient and adjacent to the
landfill boundary and are not representative of current exposure point concentrations'".
Response: Since the monitoring well network used to characterize impact to local
groundwater conditions in the vicinity of the landfill contains only eight wells, a
reasonable but conservative approach to assessing potential impacts to human health must
take into account the possibility that parent chemicals and their products of degradation
may exist at concentrations that are higher than what were observed. Ideally, the best
way to provide a conservative estimate of a potential exposure is to provide the 95%
upper confidence limit (UCL) of the mean concentration; however, this approach is a
viable option only with a sample size large enough to provide a good estimate of the
mean. This is suggested to be 10 samples at a minimum, preferably twenty or more (EPA
1992). In cases where the sample populations are small or where the data exhibits
considerable variability, guidance suggests that the highest measured or modeled
concentrations be used as the exposure concentrations. Since only eight monitoring wells
were available to characterize groundwater conditions, the highest values detected were
used in the risk assessment, in accordance with guidance.
4.
Comment: TRC states that in the risk assessment "the future risk scenario cannot be
completed until there is a determination regarding institutional controls, which could or
will be imposed, regarding future well drilling in the area."
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Response: At the time the risk assessment was issued, institutional controls were not in
place, and since the option still existed for not implementing this action, a reasonably
conservative position of continuity with current conditions was taken. Due to the
uncertainties associated with assessing future scenarios under these conditions, this
position is still believed to be the most realistic and protective of human health since it
covers what could occur in the event that no action is implemented and other conditions
are allowed to remain the unchanged. In summary, a re-issue of the risk assessment
based on alternative "future" scenarios is not warranted.
5. Comment: TRC states that in the risk assessment "the arithmetic mean is reported as 279
mg/L on page 2-18, when it should read 279 ug/L".
Response: Page 2-18 of the text does state that the mean concentration for vinyl chloride
is reported in mgfL, when in reality, the units should have been reported as ugfL. Mean
values were discussed in the uncertainty section and were not used for assessing potential
risks, therefore this text error has no bearing on the calculations. As shown in the risk
assessment tables, the highest downgradient concentration for vinyl chloride is 1200
ug/L.
6. Comment: TRC states that in the risk assessment "it is unclear how the 'volatilization
factor' was used and how the dimensions of the risk calculation balance."
Response: The volatilization factor is a unitless number set at a default value of "0.0005
x 1000 L/m3" (or "0.5" as presented in the assumptions). This default value is an integral
part of equations 1 and 2 presented in RAGS Part B (EPA 1991) and is based on the
relationship between the concentration of a contaminant in household water and the
average concentration of the volatilized contaminant in air. In the derivation of this
number, all uses of household water were considered and a default air exchange rate and
dwelling size was assumed. For more information on the volatilization factor used in
these equations, RAGS directs the reader to the paper by J.B. Andelman (1990).
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APPENDIX B
Administrative Record
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U.S. EPA ADMINISTRATIVE RECORD
REMEDIAL ACTION
TOMAH SANITARY LANDFILL
TOMAH, WISCONSIN
ORIGINAL-
08/30/95
DOCI DATE
AUTHOR
RECIPIENT
TITLE/DESCRIPTION
r *3:::ssc:sxi:s:e
PAGES
1 12/16/83 Eigenbrodt, V., MDNR U.S. EPA
2 06/27/84 Nolan, C., Ecology U.S. EPA
and Environment,
Inc.
Preliainary Assessient
Site Inspection Report
5
14
3 12/05/84 Nolan, C., Ecology File
and Environaent,
Inc.
Heaorandua re: June 19, 1984 Site Inspection
4 03/24/92 Ecology and
Environment, Inc.
7 03/10/94 Daws I Noore
U.S. EPA
5 09/00/93 U.S. EPA/OSMER U.S. EPA
& 09/00/93 U.S. EPA/OSHER U.S. EPA
U.S. EPA
Litter Report 113
Quick Reference Fact Sheet: 'Presumptive 8
Reiedies: Policy and Procedures' (OSHER
Directive 9355.0-47FS; EPA 540-F-93
047; P8 93-963345)
Quick Reference Fact Sheet: 'Presumptive 14
Reaedy for CERCIA Nunicipal Landfill Sites'
(OSHER Directive 9355.0-49FS; EPA
540-F-93-035; PB 93-963J39)
rtork Plan (DRAFT): Volume 1 of 2 (Text and 265
Attachaents A-B)
8 03/10/94 Daaes I Noore
9 06/18/94 Daaes I Noore
U.S. EPA
U.S. EPA
10 07/13/94 Trainor, D. and Nankoaski, N., U.S.
Steiner, J., Daaes I EPA
Noore
Work Plan (DRAFT): Volume 2 of 2 (Attachments 342
C-E)
Hark Plan: Addendum I 154
Letter re: DIN's Responses to U.S. EPA's 9
Quality Assurance Section Coaaents to
Addendua I of the Nork Plan
11 02/21/95 Daaes I Noore
U.S. EPA
R?aedial Investigation Report (DRAFT): Voluae 146
1 of 2 (Text)
12 02/21/95 Daaes i Noore U.S. EPA
Remedial Investigation Report (DRAFT): Voluae
2 of 2 (Appendices A-F)
770
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AR
U.S. ENVIRONMENTAL PROTECTION AGENCY
REMEDIAL ACTION
ADMINISTRATIVE RECORD
FOR
TOMAH SANITARY LANDFILL SITE
TOMAH, MONROE COUNTY, WISCONSIN
UPDATE #1
JULY 25, 1997
NO. DATE
1 06/13/95
AUTHOR
RECIPIENT
06/14/95
07/13/95
12/20/95
04/00/96
04/03/96
04/24/96
06/12/96
Dames & Moore U.S. EPA
Trainor, D.,
Dames & Moore
Mankowski, M.,
U.S. EPA
Trainor, D.,
Dames & Moore
Kuhlman, W.;
Boardman, Suhr,
Curry & Field
Zippay, N. and
M. Mankowski,
U.S. EPA
Ch2M Hill
Mankowski, M.,
U.S. EPA
Patterson, K.,
City of Tomah
Mankowski, M.,
U.S. EPA
Dames & Moore U.S. EPA
Mankowski, M.
and N. Zippay,
U.S. EPA
Kuhlman, W.;
Boardman, Suhr,
Curry & Field
U.S. EPA
TITLE/DESCRIPTION PAGES
Work Plan for Phase II 242
of the Remedial Investi-
gation/Feasibility Study
(RI/FS) at the Tomah
Municipal Sanitary
Landfill Site
Letter: D&M's Responses 79
to U.S. EPA Comments on
Phase I Draft RI Report
and the Phase II Work Plan
Letter re: U.S. EPA/WDNR 9
Conditional Approval of
the Phase II RI Work Plan
for the Tomah Municipal
Landfill Site w/Comments
Letter: D&M's Responses 24
to Conditional Approval
of the RI Phase II Work
Plan
LFG Migration Control 110
Project Report for the
Tomah Landfill Site
Letter re: Outline of 5
Measures Concerning the
Methane Issue
Letter re: U.S. EPA 2
Approval of Proposed
Short Term Measures as
Outlined in the Design
Specifications
Final Risk Assessment 177
for the Tomah Municipal
Sanitary Landfill Site
06/13/96
Mankowski, M.,
U.S. EPA
Patterson, K.,
City of Tomah
Letter re: U.S. EPA/WDNR 10
Conditional Approval of
the Draft Final RI Report
and the Responses to U.S.
EPA Comments on the Draft
Final RI Report
1
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Tomah Sanitary Landfill AR
Update # 1
Page 2
NO. DATE AUTHOR RECIPIENT
10 07/15/96 Dames & Moore U.S. EPA
11 07/15/96 Dames & Moore U.S. EPA
12 09/27/96 Dames & Moore U.S. EPA
13 10/28/96 Mankowski, M., Patterson, K.,
U.S. EPA City of Tomah
14 04/14/97 Dames & Moore U.S. EPA
15 07/15/97 Mankowski, M., Patterson, K.,
U.S. EPA City of Tomah;
et al.
TITLE/DESCRIPTION PAGES
Remedial Investigation 2 84
Report for Source
Control: Volume I (Text,
Tables and Figures)
[FINAL]
Remedial Investigation 1433
Report for Source
Control: Volume II
(Appendices A-H) [FINAL]
Response to U.S. EPA 36
and WDNR Comments and
Revised Future Activities
Plan for the RI/FS of
Groundwater and Source
Control at the Tomah
Municipal Sanitary
Landfill Site
Letter re: U.S. EPA/ 6
WDNR Discussion and
Comments Concerning the
Remaining Issues on the
Response to U.S. EPA/WDNR
Comments and Revised
Future Activities Plan
Feasibility Study for 12 0
Source Control: Final
(Revised) Draft Report
Letter re: U.S. EPA/WDNR 16
Approval w/Modifications
of the Feasibility Study
for Source Control, Final
(Revised) Draft Report
w/Attachments
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U.S. ENVIRONMENTAL PROTECTION AGENCY
REMEDIAL ACTION
ADMINISTRATIVE RECORD
FOR
TOMAH MUNICIPAL SANITARY LANDFILL SITE
TOMAH, WISCONSIN
UPDATE #2
SEPTEMBER 12, 1997
NO. DATE
AUTHOR
RECIPIENT
TITLE/DESCRIPTION
PAGES
1 08/18/97
Southwest
Reporters,
Inc.
U.S. EPA
Transcript of Procee-
dings: August 18, 1997
U.S. EPA Public Meeting
re: the Tomah Armory
Landfill and Tomah
Municipal Sanitary
Landfill Sites
102
2 09/04/97
Johnson, W.,
City of
Tomah
Bill, B.,
U.S. EPA
Letter re: City of
Tomah's Comments on the
Proposed Plan for the
Tomah Municipal Sanitary
Landfill Site
3 09/04/97
"^rshall, D.,
Union Camp
Corporation
Bill, B.,
U.S. EPA
Letter re: Union Camp's
Comments on the Proposed
Plan for the Tomah Muni-
cipal Sanitary Landfill
Site
31
4 09/05/97
Tomah
Residents
U.S. EPA
Three Public Comment
Sheets re: Citizens'
Comments on the Proposed
Plan for the Tomah Muni-
cipal Sanitary Landfill
Site (PORTIONS OF THIS
DOCUMENT HAVE BEEN
REDACTED)
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