WARZYN INC - FEASIBILITY STUDY (FS) - SOURCE … · GEA/vlr/GEA [vlr-106-79] 13452.74 cc: Ms. Terry Evanson - WDNR (5 copies) ... The provisions for enacting the requirements of CERCLA

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Feasibility StudyReport Source Control Operable Unit13452.74 Remedial Investigation/Feasibility Study

Hagen Farm Site

Prepared for:Waste Management of Wisconsin, Inc.

Westchester, Illinois

Prepared by:Warzyn Engineering Inc.

Madison, Wisconsin

July 1990

WARZYN

July 5,1990

Mr.JaeLee-5HS-llU.S. Environmental Protection Agency230 South DearbornChicago, Illinois 60604

Re: Hagen Farm Source Control Operable UnitFeasibility Study (SCOU)

Dear Mr, Lee:

Enclosed please find five copies of the subject document. This reportincorporates your comments and is intended to be the document madeavailable for public review.

Should you have any questions, please do not hesitate to call us.

Respectfully submitted,

WARZYN ENGINEERING INC.

Gregory!:. AsburySenior Manager

GEA/vlr/GEA[vlr-106-79]13452.74

cc: Ms. Terry Evanson - WDNR (5 copies)Ms, Dee Brncich - WMI (5 copies)Mr. Tim Wright - The Jessup Group

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Feasibility StudySource Control Operable Unit

Remedial Investigation/Feasibility StudyHagen Farm Site

July 1990

TABLE OF CONTENTSPage No.

1. INTRODUCTION

Authorization, Purpose and Scope........................................................................... 1-1Report Organization ............................................................................................. 1-2Alternatives Array Document................................................................................... 1-2

2. BACKGROUND INFORMATION

Regional Location and General Site Physiography ............................................. 2-1History of Site Operations ........................................................................................ 2-2Previous Response Actions ....................................................................................... 2-2History of Site Investigations ................................................................................... 2-3

Source Characterization...................................................................................... 2-3Migration Pathway Assessment......................................................................... 2-6

Previous Reports........................................................................................................ 2-7

3. NATURE AND EXTENT OF THE PROBLEM

Source Conditions ...................................................................................................... 3-1Preliminary Assessment of Baseline Risks to Human Healthand the Environment ................................................................................................ 3-4

General Approach................................................................................................. 3-4Contaminants of Potential Concern.................................................................. 3-5Exposure Assessment........................................................................................... 3-6

Current Potential Exposure.......................................................................... 3-6Potential Future Exposure ........................................................................... 3-7

Toxicity Assessment.............................................................................................. 3-7Risk Characterization........................................................................................... 3-8

Current Site Conditions................................................................................. 3-8Future Site Conditions................................................................................... 3-8

Environmental Assessment................................................................................. 3-9

4. IDENTIFICATION AND SCREENING OF TECHNOLOGIES

Remedial Action Objectives..................................................................................... 4-1General Response Actions ....................................................................................... 4-2Identification and Screening of Remedial Technologies.................................... 4-3

Institutional Measures.......................................................................................... 4-3Containment .......................................................................................................... 4-4Direct Soil/Waste Treatment (On-Site)........................................................... 4-4

Biological.......................................................................................................... 4-4Chemical .......................................................................................................... 4-5Physical............................................................................................................. 4-5Thermal Destruction .................................................................................... 4-6

Direct Soil/Waste Treatment (Off-Site) .......................................................... 4-6In-Situ Soil/Waste Treatment ............................................................................ 4-7

Biological ......................................................................................................... 4-7Chemical .......................................................................................................... 4-7Physical............................................................................................................. 4-7Thermal............................................................................................................. 4-9

Disposal ................................................................................................................. 4-9Technologies Carried Through Initial Technology Screening .......................... 4-10


Hagen Farm SiteJuly 5,1990

Page 2

Page No.5. DEVELOPMENT OF ALTERNATIVES

Alternative Development....................................................................................... 5-1Alternative 1: No Action .............................................................——..........—... 5-1Alternative 2: Capping.......,..................................................-................——............. 5-1Alternative 3: In-Situ Vapor Extraction and Capping........................................ 5-2Alternative 4: Waste Consolidation with Biological Treatment, VaporExtraction and Capping......................................................................—,................... 5-3Alternative 5: Waste Excavation With On-Site Incineration, VaporExtraction and Capping.............................................-....................--—................. 5-3

6. DETAILED ANALYSIS OF ALTERNATIVES

Analysis Criteria......——...........—.............-...-..............-—............................... 6-1Threshold Criteria..................................................-...............................-—..... 6-2

Overall Protection of Human Health and the Environment................. 6-2Compliance with Applicable or Relevant and AppropriateRequirements (ARARs).............................-......................--.................... 6-2

Primary Balancing Criteria..............................................................——............. 6-2Long-Term Effectiveness and Permanence............................................... 6-2Reduction of Toxiciry, Mobility or Volume Through Treatment......... 6-3Short-Term Effectiveness.............................................................................. 6-3Implementability............................................................................................. 6-3Cost.................................................................................................................... 6-4

Modifying Criteria ................................................................................................ 6-4State Acceptance ..................................................-..................——...—..... 6-4Community Acceptance ...........................-..................................,.........— 6-4

Alternative 1: No Action .......................................................................................... 6-4Description ............................................................................................................ 6-4Overall Protection of Human Health and the Environment........................ 6-5Compliance with ARARs ................................................................................... 6-5Long-Term Effectiveness and Permanence..................................................... 6-5Reduction in Toxicity, Mobility or Volume Through Treatment................ 6-5Short-Term Effectiveness ................................................................................... 6-6Implementability ................................................................................................ 6-6Cost ......................................................................................................................... 6-7State Acceptance .................................................................................................. 6-7Community Acceptance .................................................................................... 6-7

Alternative 2: Capping............................................................................................... 6-7Description ....................................................................................................... 6-7

Option 2a................................... ^ 6-8Option 2b......-....................--................-... ^ 6-9Option 2c...........................-..............-.................................. 6-11

Overall Protection of Human Health and the Environment........................ 6-14Compliance with ARARs ................................................................................. 6-14Long-Term Effectiveness and Permanence..................................................... 6-15Reduction in Toxiciry, Mobility or Volume Through Treatment................ 6-16Short-Term Effectiveness ............................................................................... 6-17Implementability ............................................................................................ 6-18Cost ................................................„............„................._ 6-19State Acceptance ................................................................................................ 6-19Community Acceptance ................................................................................... 6-19



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Page No.

Alternative 3: In-Situ Vapor Extraction and Capping........................................ 6-20Description ............................................................................................................ 6-20Overall Protection of Human Health and the Environment........................ 6-22Compliance with ARARs ................................................................................... 6-23Long-Term Effectiveness and Permanence..................................................... 6-24Reduction in Toxicity, Mobility or Volume Through Treatment................ 6-25Short-Tenn Effectiveness ................................................................................... 6-26Implementability ................................................................................................ 6-27Cost ..................................................................................................................... 6-28State Acceptance ............................................................................................. 6-29Community Acceptance .................................................................................. 6-29

Alternative 4: Waste Consolidation With Biological Treatment, VaporExtraction and Capping.............................................................................................. 6-29

Description............................................................................................................. 6-29Overall Protection of Human Health and the Environment........................ 6-32Compliance with ARARs ................................................................................... 6-32Long-Term Effectiveness and Permanence..................................................... 6-33Reduction in Toxicity, Mobility or Volume Through Treatment................ 6-34Short-Term Effectiveness .................................................................................. 6-35Implementability .................................................................................................. 6-36Cost ..................................................................................................................... 6-37State Acceptance .................................................................................................. 6-37Community Acceptance ...................................................................................... 6-37

Alternative 5: Waste Excavation with On-Site Incineration, VaporExtraction and Capping.............................................................................................. 6-37

Description............................................................................................................. 6-37Overall Protection of Human Health and the Environment........................ 6-40Compliance with ARARs ................................................................................ 6-40Long-Term Effectiveness and Permanence..................................................... 6-41Reduction in Toxicity, Mobility or Volume Through Treatment................ 6-42Short-Term Effectiveness ................................................................................. 6-43Implementability .................................................................................................. 6-44Cost.......................................................................................................................... 6-45State Acceptance ................................................................................................. 6-45Community Acceptance .................................................................................... 6-45

7. COMPARISON OF ALTERNATIVES

Overall Protection of Human Health and the Environment........................ 7-1Compliance with ARARs.................................................................................... 7-2Long-Term Effectiveness and Permanence..................................................... 7-2Reduction in Toxicity, Mobility or Volume Through Treatment................ 7-3Short-Term Effectiveness ................................................................................ 7-3Implementability.................................................................................................... 7-4Cost .............................. 7-5State Acceptance................................................................................................... 7-5Community Acceptance....................................................................................... 7-5

8. REFERENCES........................................................................................................... 8-1

Table of ContentsHagen Farm Site

July 3,1990Page 4

TABLES

Table 1 - EP Toxicity and Flammability Test ResultsTable 2 - Source Characterization SummaryTable 3 • Groundwater Quality SummaryTable 4 - Air Quality Sampling ResultsTable 5 - Summary of Probable ARARs

DRAWINGS13452-A2 - Regional Piezometric Surface Map13452-A3 - Structure of Cap Repair13452-A4 - Structure of Subtitle D Cap (NR 500)13452-A5 - Structure of Subtitle C Cap (NR 181)13452-F16 - Site Features Map

APPENDICES

Appendix A - CorrespondenceAppendix B - Cost SummaryAppendix C - Preliminary Development of Clean-Up Levels for Waste/Soil

MAL/vlr/GEA[skb-601-30]13452.74-MD

SECTION 1INTRODUCTION

AUTHORIZATION, PURPOSE AND SCOPEThis Remedial Investigation/Feasibility Study (RI/FS) is being conducted on behalf of WasteManagement of Wisconsin, Inc. (WMWI) and Uniroyal Plastics, Inc. (Uniroyal) for the HagenFarm Site (Site) in Stoughton, Wisconsin. The project is being performed pursuant to theComprehensive Environmental Response, Compensation and Liability Act of 1980(CERCLA). CERCLA requires the United States Environmental Protection Agency(U.S. EPA) to evaluate remedial activities, determine the appropriate extent of the activities,and ensure that remedial measures are cost-effective. Such remedial measures must, to theextent practicable, be in accordance with the National Oil and Hazardous Substances PollutionContingency Plan (NCP).

The U.S. EPA has authority and responsibility for carrying out these provisions underCERCLA as amended by the Superfund Amendments and Reauthorization Act of 1986(SARA). The provisions for enacting the requirements of CERCLA appear in the NCP(40 CFR 300).

CERCLA requires that after discovery of a possible uncontrolled site, a preliminarydetermination be made as to whether the site presents, or may present, a threat to the publichealth or the environment. If additional action is warranted, the U.S. EPA places the site onthe National Priorities List (NPL) of hazardous waste sites. For NPL sites, additional work isthen undertaken to better define potential problems, develop and evaluate possible solutions(remedies) and to select an action based on the study results. This process for selection ofremedial measures consists of the following three major sequential elements:

Remedial Investigation (RI) - During the RI, data are collected to define siteconditions, including the extent of releases from the site and the character of sourcematerials. Data on releases are evaluated to assess the potential effects of releases onpublic health and the environment.

• Feasibility Study (FS) - In the FS, a number of potential remedial alternatives aredeveloped, evaluated against a range of factors and compared against one another.

Record of Decision (ROD) - The ROD documents the decision-making process of theU.S. EPA used in selecting remedial measures to reduce or eliminate releases from thesite.



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The FS for the Site is composed of two phases, the Source Control Operable Unit (SCOU)and the Groundwater Control Operable Unit (GCOU). This document represents the FS forthe SCOU phase and presents the development, screening and detailed analysis of alternativesto address risks posed by the contaminant source. The source is defined as the waste andcontaminated soil beneath the waste. Alternatives that address risks posed by contaminatedgroundwater that has migrated from the area beneath the waste will be evaluated in theGCOU FS document.

REPORT ORGANIZATIONSection 2 provides background information, including location, history of Site operations, andhydrogeology based on information developed in the RI. More detailed information will bepresented in the RI Report when it becomes finalized.

Section 3 summarizes the nature and extent of contamination.

Section 4 begins the FS element of the CERCLA process. This section presents a descriptionand summary of the technology screening process.

Section 5 presents a description of alternatives developed by assembling a number of promisingtechnologies, identified through the screening process, into remedial action alternatives.

Section 6 provides a detailed analysis of the developed alternatives addressing criteria set forthin 40 CFR 300.430.

Section 7 compares each alternative to the others.

Section 8 lists references used in the development of the FS.

ALTERNATIVES ARRAY DOCUMENTSections 2 through 5 of this report were previously submitted in the Alternatives ArrayDocument (Warzyn, October 1989) in accordance with the Administrative Consent Order.Comments from the U.S. EPA's and WDNR's review of the Alternatives Array Documenthave been incorporated in these sections. Sections 6 and 7 focus on the alternatives thatremained following the screening analysis contained in the Alternatives Array Document.

[skb-601-30a]13452.74

SECTION 2BACKGROUND INFORMATION

REGIONAL LOCATION AND GENERAL SITE PHYSIOGRAPHYThe Site is located at 2318 County Highway A, approximately one mile east of the City ofStoughton, Dane County, Wisconsin. The Site occupies the southwest quarter of Section 10,Township 5 North, Range 11 East, Town of Dunkirk; the boundaries are shown on Drawing13452-F16.

The Site's location in the Yahara River watershed is in an area of flat to gently rollingtopography (see Drawing 13452-A2). The Yahara River is located approximately 1.5 miles tothe west and flows in a southerly direction. The land surface generally slopes toward theYahara River from topographically high areas located to the northeast and east. Surface waterdrainage in the area is generally poorly developed, apparently due to permeable surface soils.The only substantial surface water bodies in the area are a pond located approximately 1/2 milesouth of the Site and the Yahara River.

Site topography is the result of sand and gravel mining and waste disposal activities. Prior tothese activities, the ground surface probably sloped from the existing topographically high arealocated west and northwest toward the southeast and east. The excavated area in thenorthwest corner of the property is flat. This flat area is separated by a ridge from the waterfilled depression located to the northeast. The Site is bounded on the north by the northernface of the gravel pit, and a private airplane landing strip associated with the topographicalhigh.

Three areas; A, B and C, have been identified as disposal areas (Drawing 13452-F16). Area Ahas been determined to be the area where co-disposal of liquid and solid wastes occurred;Areas B and C exhibit minor household waste and debris. The main waste disposal area (AreaA) is hummocky with the ground surface generally sloping east toward an intermittentdrainageway. The north portion contains numerous mounds of material, likely the result ofspoil piles from the gravel operation.



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HISTORY OF SITE OPERATIONSThe Site was operated as a sand and gravel pit prior to the late 1950's. Observations suggestgravel operations encompassed an area bounded by the current access road to the east, theformer Schroeter property boundary to the west and the current property boundary to thenorth (see Drawing 13452-F16). Mining operations reportedly terminated approximately 14 to18 ft below ground surface. Excavation may have ceased at this depth due to the presence ofgroundwater, more fine grained materials, or a change in sand and gravel quality (Warzyn,November 1987). At the time waste disposal was occurring, the property was owned by Henryand Nora Sundby, since deceased. The property was purchased from the Sundby's by OrrinHagen in approximately 1970, and by WMWI in 1987.

Based on available records, the gravel pit was used for disposal of waste material from the late1950's to the mid-1960's. Interviews indicate waste from Uniroyal was disposed during theperiod 1962-1966. Additional information suggests that waste from the City of Stoughton andother local sources was also disposed at the Site (Warzyn, November 1987). Based on the sizeof the potential disposal areas and existing topography, it appears most waste disposal activityoccurred in one main disposal area (i.e., Area A). These areas have been covered with soil andare now vegetated with grasses and 10 to 15 ft tall trees. Documentation of waste quantities isunavailable, but may have included solvents, other organic materials (acetone, butyl acetone,1,2-dichloroethene, vinyl chloride, and tetrahydrofuran) and scrap vinyl.

Uniroyal notified the U.S. EPA in June 1981 that F003 and F005 (listed in NR 181.16 WAC -^ Table II) solvents were disposed at the Site during the 1960s (see Appendix A). Therefore, the

Land Disposal Restrictions (LDRs) could potentially be an applicable or relevant andappropriate requirement (ARAR) for the Site as a result of the "mixture" and "derivedfrom" rules of NR 181 Wisconsin Administrative Code (WAC).

PREVIOUS RESPONSE ACTIONSIn response to complaints received from local residents, groundwater sampling at nearbyprivate water supply wells was conducted by the Wisconsin Department of Natural Resources(WDNR) beginning in November 1980. Sampling of private water supply wells was also laterconducted by Warzyn Engineering Inc. (Warzyn) on behalf of Uniroyal. Hydrogeologic studies


Hagen Farm SiteJuly 5, 1990

Page 2-3

were conducted by Warzyn (for Uniroyal) and by the United States Geological Survey(USGS). Sampling of on-Site monitoring wells during the period 1980-1986 indicated organiccompounds present in groundwater, including benzene, ethylbenzene, tetrahydrofuran, xylenesand toluene.

The Site was proposed for inclusion on the NPL on September 18, 1985. Subsequently, WMWIand Uniroyal entered into an Administrative Consent Agreement with the U.S. EPA toconduct an RI/FS (U.S. EPA Docket No. VW 87-C-016, dated September 14, 1987). Relevantcorrespondence for this project is contained in Appendix A

HISTORY OF Sn^ INVESTIGATIONSThis section summarizes the work performed to date to characterize the source ofcontamination and to evaluate the possible migration pathways of the contaminants. Moredetailed summaries can be found in Technical Memorandum Number 1 (TM-1), datedMarch 1989, and Technical Memorandum Number 2 (TM-2), dated February 1990.

Prior to RI activities, the Site was made secure from trespassers by installing a chain link fence,posted with signs, "Restricted Area: Unauthorized Persons Keep Out."

Source CharacterizationInvestigative activities performed as part of the source characterization include:

• Geophysical survey• Soil gas survey• Refuse borings/leachate head wells• Additional groundwater monitoring wells/source characterization wells• Groundwater/leachate sampling at source characterization wells and leachate wells• Test pits• Additional test pits and soil samples as part of Phase 2 Source Characterization



Page 2-4

Electromagnetic and magnetometer surveys of the main disposal area (Area A, approximately5.5 acres) and the two potential disposal areas (Areas B and C, approximately 1.5 acres each)were conducted. The objectives were to locate anomalies suggestive of potential boundariesbetween natural soils and waste materials, and to identify potential areas of buriedferromagnetic materials, in order to avoid buried metal in selecting boring locations.Electromagnetic and magnetic data are presented in Appendix A of TM-1 and summarized onDrawing 13452-F3 of TM-1. This data suggested that Area A is the main disposal area andAreas B and C contain only scattered areas of shallow waste.

A soil gas survey was performed to screen areas for potential concentrated sources of volatileorganic compounds (VOCs) and examine the potential retention of VOCs in the unsaturatedzone. A target list of VOCs was analyzed and included:

• Acetone1,1-Dichloroethene

• Tetrahydrofuran (THF)1,1-Dichloroethane

• Trans-l,2-Dichloroethene• Trichlororethene• Benzene• 2-Hexanone• Toluene• Ethyl Benzene• M-Xylene• O + P-Xylene

Chlorobenzene

The analytical results of the soil gas survey are presented in Appendix B of TM-1.

VOCs detected include acetone, benzene, toluene, 2-hexanone, ethyl benzene, m-xylene ando + p-xylene. In Area A, about 50% of the samples resulted in detections. The distribution ofVOCs in Area A appears to be fairly scattered, although no detects occurred in the northwestsection of Area A. Only 20% of the samples from Area B and 30% of the samples from AreaC resulted in VOC detects. Soil gas survey results are discussed further in Section 3.



Page 6-9

A. A minimum of 2 ft of compacted clay, sloped adequately to allow surface waterrunoff. Slopes shall be no less than 2% and no steeper than 33%. The 2-ft claylayer shall meet the following specifications:

1) Have a saturated hydraulic conductivity of not more than 1 x 10-7 cm/sec;

2) Be compacted to 90% modified proctor density; and

3) Be constructed in lifts which do not exceed 8 in. after compaction.

3. Grading Layer

A. Clean fill and waste excavated from Areas B and C placed over the Site to obtaina minimum slope of 3%.

See Drawing 13452-A3 for a typical detail of a NR 181.44(12) cap structure.

Option 2b. Upgrading the existing cap to be consistent with NR 504.07 (Option 2b) wouldinclude:

1. Vegetated Top Layer

A. A minimum of 6 in, of topsoil over the cover layer to support vegetation.

B. Final slope of 2 to 33% (NR 506.08(3)(c)).

2. Cover Layer

A. A minimum 1.5- to 2.5-ft thick soil cover layer above the clay capping layer toprovide additional rooting depth for vegetation and to protect the clay cappinglayer from damage due to freeze-thaw and desiccation. The thickness of thislayer is based on:

1) The freeze-thaw susceptibility and moisture holding capacity of the material;

feasibility StudySource Control Operable Unit


Page 6-10

2) The geographic location of the facility; and

3) The type and thickness of the capping layer.

3. Clay Capping Layer

A. A minimum 2-ft thick clay cap to provide a low hydraulic conductivity barrier topercolation. Clay soil should be used for this layer and should meet the followingspecifications:

1) A minimum of 50% by weight which passes the 200 sieve;

2) A saturated hydraulic conductivity of 1 x 10'? cm/s or less;

3) Constructed in maximum 6-in. lift heights after compaction to at least 90%modified or 95% standard proctor density; and

4) Material may need to meet specifications for liquid limit and plasticity index.

4. Grading Layer

A Clean fill and waste excavated from Areas B and C placed over the Site to obtaina minimum slope of 3%.

In addition, the NR 504.07 cap requirements would be modified slightly to include a 12-in.thick sand layer between the cover layer and the clay capping layer. The purpose of the sandlayer is to provide an effective barrier to upward migration of moisture from the clay layerduring drying periods, thereby minimizing desiccation cracking. This modification is based onactual field data reported in The Omega Hills Final Cover Test Plot Study: Three Year DataSummary (Montgomery and Parsons, 1989). A brief discussion of the results of this study arepresented in the following three paragraphs.



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Nine refuse borings (RB1 to RB9) and three additional soil borings (ESB1 to ESB3) wereperformed in and near Disposal Area A. The objectives were to physically characterize thetype and thickness of the fill cover, profile materials, and physically characterize basal soils inthe fill area, including laboratory (vertical) permeability and grain size. The locations of theborings were based on the results of the geophysical investigation and the soil gas survey. Theadditional soil borings were located near the edge of each fill area, as determined by thegeophysical investigation, in order to substantiate the geophysical boundaries. Refuse boringlogs are contained in Appendix C and the boring locations are shown on Drawing 13452-F5 ofTM-1.

Throughout the drilling operations, boreholes were monitored with a Photoionization meter(HNu), an explosive gas meter, and a Monitox hydrogen cyanide meter. A composite cuttingsample did not exhibit EP toxicity and flammability as defined by NR 181 WAC. Results of theEP toxicity and flammability tests are shown in Table 1. Liquid was only encountered at onelocation during drilling (ESB3, approximately 7 ft below ground surface). Leachate HeadwellLHl was installed at this location.

Headspace vapor sampling was performed at Leachate Headwell LHl to characterize organicvapors associated with the liquid waste. Table 5 of TM-1 summarizes sampling information.Samples were then sent to Radian Corporation for U.S. EPA target compound list (TCL) ofVOCs and THF analysis.

Leachate was encountered in only one out of nine of the refuse borings; this was likely perchedwater. Approximately 10 to 15 ft of unsaturated soil separate the waste and the water table.As a result, three groundwater monitoring wells were installed adjacent to the fill area, and fivesource characterization wells (water table wells) were installed near Disposal Area ALocations are shown in Drawing 13452-F2 and boring logs are included in Appendix C of TM-1.

Liquid samples were collected from each of the five source characterization wells and theleachate well. Five casing volumes were removed from each water table well before the samplewas taken. The leachate well was not purged due to the small volume of liquid present(approximately 0.8 gal), so that enough sample could be obtained. Specific conductance andpH were analyzed in the field.



Page 2-7

Eighteen soil borings were drilled at eleven locations (Drawing 13452-F2 of TM-1), tocharacterize and identify soil properties potentially controlling contaminant migration.Groundwater observation wells were installed at selected locations.

The groundwater investigation included the installation and use of water level observationwells to supplement existing water level and piezometric head data. Objectives included thedelineation of geological strata which may serve as potential contaminant migration pathways,and the determination of groundwater flow direction hydraulic gradient and hydraulicconductivity within the unconsolidated materials and bedrock.

Groundwater levels were measured on September 14-15, October 21, and December 8, 1988,for use in determining groundwater flow direction and hydraulic gradients.

Single well in-situ hydraulic conductivity tests were performed on 13 newly installedgroundwater observation wells. In addition, measurements on 6 previously tested wells wereduplicated in order to check the reproducibility of the results. The objectives of these testswere to determine hydraulic parameters (hydraulic conductivity, transmissivity) and assessgroundwater flow rates for the water-bearing strata.

PREVIOUS REPORTSIn addition to TM-1, an Alternatives Array Document was submitted for review and commentsto the U.S. EPA and the WDNR which documented the development and screening of sourcecontrol alternatives. A preliminary identification of Applicable or Relevant and AppropriateRequirements (ARARs) was made at the time of the submittal of the Alternatives ArrayDocument.

[skb-601-30b]13452.74-MD

SECTIONSNATURE AND EXTENT OF THE PROBLEM

This section summarizes the nature, magnitude and migration potential of contaminantsidentified at the Site, along with an assessment of the potential health risks.

SOURCE CONDITIONSThe three separate disposal areas (A, B and C) were established based on prior knowledge ofdisposal practices (Drawing 13452-F16). Area A is suspected to be the main disposal area andencompasses approximately 5.5 acres. Areas B and C are suspected to contain isolated areas ofprior disposal and encompass approximately 1.5 acres each.

In Area A, zones indicative of buried metal, based on the geophysical data, generallycorrespond to the extent of waste derived from direct observation in borings and test pits. Soil

\^/ gas detects also correspond to the presence of waste, based on the borings and test pits.However, VOCs were not detected at all soil gas locations within the waste area (as defined bythe test pits and borings). Based on waste thicknesses observed at test pit and boring locations,a waste isopach map for Area A was constructed (Drawing 13452-F16). The waste volume forArea A is estimated at 67,650 cu yd, at an average depth of 8 ft. Based upon refuse borings,test pits and water table measurements, the bottom of the waste material is estimated to be 10to 15 ft above the seasonal high water table in Areas A, B and C. The volume of unsaturatedsubwaste soils is approximately 112,000 cu yd. No methane was detected with the explosive gasmeter during test pits and soil borings.

Compounds present in the groundwater beneath Area A were dominated by VOCs, includingTHF, xylenes and 2-butanone. The highest concentrations of these compounds were observedin well SCW4, near the southern end of Area A These concentrations are as follows:

THF 630 ppmxylenes 35 ppm2-butanone 4,400 ppm



Page 3-2

Two other VOCs were also detected, ethyl benzene and toluene. Semivolatiles detected in thegroundwater include:

benzole acid bis (2-chloroisopropyl)ether2,4-dimethylphenol naphthalene4-methylphenol 4-chloro-3-methylphenolphenol diethylphthalate1,4-dichlorobenzene bis(2-ethylhexyl)phthalatebenzyl alcohol di-n-octyl phthalate

Table 3 summarizes the VOC and semi-VOC groundwater concentration data.

THF and xylenes were also present in many of the soil gas samples; however, 2-butanone wasnot a target compound for the soil gas screening. Weak organic acids and phenols suggestiveof municipal waste decomposition, and iron and manganese suggestive of oxygen deficientconditions, were present at some locations.

Area B seems to possess only scattered waste, and the correlation between the results ofvarious characterization tasks is not particularly strong. Test pits near the largest geophysicalanomaly showed a small quantity of municipal waste, and soil gas detections did not alwayscoincide with geophysical anomalies. Area C also appears to contain only isolated areas ofwaste. Soil gas detects do not coincide with geophysical anomalies. Test Pit TP5 did notexhibit waste, although it was located in the vicinity of a soil gas detect. Areas B and C do notappear to have accepted industrial waste. For these reasons, Area A will be considered the

S^ region of maximum contamination, and Areas B and C will be considered collectively as thearea of minimum contamination.

To address the potential for volatilization of contaminants, four ambient air samples werecollected and analyzed for VOCs. Samples were collected from sampling stations located onthe north, south, east and west boundaries.

The results of the air analyses indicated low concentrations of a number of VOCs, generallybelow 10 ug/m^, in each of the samples collected (Table 2). Two compounds, methylenechloride and trichlorofluoromethane, were detected at higher concentrations in the samples(approximately 100 ug/m^). However, these compounds were also identified in associated tripblanks. Additionally, the laboratory hold times were exceeded for the air samples. These



Page 3-3

results must, therefore, be interpreted as qualitative; the development of quantitative datawould require further sampling testing and evaluation. In general, the chemical contaminantsidentified, and the magnitude of contaminant concentrations, were similar among the foursamples. Based on meteorological data collected continually during the sampling period, theaverage wind direction originated from the south toward the north. Air VOC concentrationsmeasured from sample PA-01-01, located north of the disposal area (downwind), were notsubstantially different from those measured at the other locations. These data do not identifyan atmospheric gradient of VOCs across the waste area, because the type and magnitude ofVOCs identified from upwind samples were similar to downwind samples. However, due todata qualifiers this conclusion is based on qualitative results.

Surficial soils are absent over most of the waste areas. The waste is unsaturated and dissolvedcontaminants can infiltrate through unsaturated soils to the water table. Thus, soils are anapparent contaminant migration pathway. Soil erosion could contribute to some movement ofcontaminants, but is not considered a primary pathway because the Site has a relatively flat,vegetated topography. Potential exposure should be limited because of Site access control andthe minimal transport of soil off-Site by erosional processes.

Migration of contaminants via groundwater could occur by infiltration through the granularsoils and waste with dissolution of chemical constituents. These chemical constituents couldthen migrate to the water table from percolation through the unsaturated zone (water tabledepth approximately ranges between 18 ft and 24 ft). Subsequent transport could then occur

\*^ by groundwater flow and/or dispersion. Based upon analysis of samples from well P17B andP17C, contaminants (xylenes, THF, 2,4-dimethyIphenol and benzoic acid) were found at orbelow the surface of the bedrock interface (bedrock depth is approximately 50 ft).

Surface water does not appear to be a direct pathway for contaminant migration, due to lack ofan established surface water drainage system. Furthermore, it appears the drainage ditch eastof the Site and Sundby's pond to the south are not groundwater discharge points. Thisconclusion is based on water quality results and inferred groundwater flow paths.



Page 3-4

PRELIMINARY ASSESSMENT OF BASELINE RISKS TO HUMAN HEALTH ANDTHE ENVIRONMENTThe purpose of a Baseline Risk Assessment (BRA) is to characterize the nature and estimatethe magnitude of potential risks to human health and the environment which may be posed bycontamination at the Site. By assuming no further remedial activities take place, risksidentified in the BRA provide a basis for comparing the efficacy of each alternative in reducingSite risks.

The RI/FS for the Hagen Farm Site is being conducted in an iterative manner, with an initialgoal being to address the potential risks and corresponding remedial options related only tothe source area of contamination. In later phases of the RI/FS, potential risks associated withcontaminated groundwater will be addressed.

Information is insufficient to perform a quantitative risk assessment which addresses allrelevant contaminants and exposure pathways. The objective of this preliminary assessment isto provide a qualitative evaluation of probable pathways of exposure to likely contaminants.Following completion of all the investigative activities at the Site, a detailed BRA will bedeveloped and appended to this report. The following sections describe the overall approachto the BRA and include an assessment of Site conditions, where applicable.

General ApproachGuidance for conducting BRA at Superfund sites is described in U.S. EPA documents entitledRisk Assessment Guidance for Superfund. Volume 1 - Human Health Evaluation Manual(December 1989) and Volume 2 - Environmental Evaluation Manual (March 1989) and will beused as a basis for this assessment.

Assessment of risks from environmental contaminants involves identification of contaminantsof most concern, routes of contaminant migration, and populations potentially exposed to thecontaminants. This information is then integrated to estimate contaminant exposure toindividuals, which in turn can be compared to chemical toxicity information to estimate healthrisk.

The BRA includes evaluation of risks as they presently exist, assuming current land useconditions prevail at the Site. It also includes an evaluation of potential future risks byassuming plausible future land use changes.



Page 3-5

The BRA is organized into the following components:

• Human Health Evaluation- Contaminants of Potential Concern- Exposure Assessment- Toxicity Assessment- Risk Characterization

• Environmental Evaluation

Contaminants of Potential ConcernIn this component of the risk assessment, the results of chemical analysis of environmentalsamples are evaluated to determine the nature and magnitude of contamination. These dataare compared to data from background samples, as well as sampling and analysis qualitycontrol data, to distinguish site contamination from naturally occurring chemicals. This alsoallows for the identification of chemicals which may be artifacts of sample collection andanalysis. Chemicals considered to be Site contaminants are further evaluated as "chemicals ofpotential concern" in the BRA

Direct characterization of waste samples included analysis of semivolatile organic chemicals,pesticides/PCBs and metals. In addition, groundwater, leachate and soil gas samples werecollected and analyzed for these parameters and volatile organic chemicals. The following listof chemicals was selected as chemicals of potential concern for waste based on their presence

<^ in waste, groundwater, leachate and/or gas.

. benzene . phenol . dieldrin

. ethylbenzene . 4-methylphenol . 4,4-DDE

. toluene . 2,4-dimethylphenol . 1,4-dichlorobenzenexylenes . benzoicacid . 4-chloro-3-methylphenolchlorobenzene . vinyl chloride . benzyl alcohol

. 2-butanone . 1,2-dichloroethene . bis(2-chloroisopropyl)ether

. 2-hexanone . naphthalene . mercury

. tetrahydrofuran . barium



Page 3-6

Exposure AssessmentThe objective of the exposure assessment is to estimate the types and magnitude of exposure tochemicals of potential concern at and migrating from the Site. Pathways of potential exposure(e.g., direct contaminant contact with waste) are characterized, as are populations potentiallyexposed (e.g., location and activity patterns). For pathways which present realistic exposures,estimates of contaminant intake for exposed populations are calculated.

Contaminant intake estimates incorporate information such as contaminant concentration,frequency of exposure and exposure duration, and are calculated for applicable routes ofcontaminant entry into the body (e.g., ingestion, dermal absorption or inhalation). Whenavailable, site-specific exposure information is used. When unavailable, standard exposureassumptions are applied. The contaminant intake estimates are intended to represent"reasonable maximum exposures" which are greater than average exposures, but within therange of possible exposures. Contaminant intake estimates are subsequently evaluated withlexicological information to estimate risk.

To fully address potential risks, evaluation of contaminant exposures considers two scenarios:present exposure, based on current Site conditions and future exposure, based on assumptionof future events or conditions.

Current Potential Exposure. Wastes at the Site are covered with approximately 1 to 3 ft of soil,much of which supports thick vegetation. However, some areas of the Site are not vegetated

s^ and show exposed waste material. Therefore, a potential exists for direct human contact withwaste. The most likely population group which may come in contact with the Site isanticipated to be periodic trespassers. This population group is small, because the Site issecured from incidental trespass by a private fence and because the location is in a rural areawhich is not heavily populated. These individuals may incur contaminant exposure by skincontact with waste and by incidental ingestion of waste material adhering to hands. Apreliminary analysis of this pathway is presented in Appendix C

At present, the subsurface wastes do not appear to be a source of appreciable contaminantrelease for exposure via inhalation of volatilized chemicals. A preliminary evaluation ofambient air quality at the Site boundary did not identify a gradient of VOC emissions. In



Page 3-7

addition, active generation of landfill gas, which can facilitate VOC emissions, is not occurringat the Site. The minimal levels of VOC emissions which may be occurring as a result ofdiffusion would be expected to be reduced to insignificant levels off-Site through air dispersion.Further quantitative evaluation of this pathway will not be included in the BRA, because actionoriented alternatives for the Source Area (e.g., vapor extraction) will eliminate potentialsources for gas emissions.

Contaminants contained in the waste have affected groundwater in the vicinity of the Site.Evaluation of both current and future potential health risks associated with groundwaterexposure will be addressed in subsequent steps of the FS.

Potential Future Exposure. Should the source material be disturbed in the future, direct^ contact with contaminants identified in wastes is a potential exposure pathway. Although

unlikely, the absence of institutional controls restricting development, make different futureland use conditions possible. The most plausible exposure potential under this scenario may beto workers constructing a future on-Site building or workers performing Site remediation. Inthis case, contaminant exposure may occur via dermal absorption of contaminants throughdirect contact with wastes, inhalation of dusts and volatile contaminants and incidentalingestion of contaminants adhering to the hands. The magnitude of potential exposure andrisk via this exposure pathway will be quantitated and included in the BRA.

In the future, the contaminated wastes are expected to be a continuing source of contaminant* release to the aquifer. Should the contaminants migrate to existing private wells, contaminant

exposure via groundwater use and consumption may occur. Future residential development ofproperty adjacent to the Site is also a potential future outcome. Should development occurdowngradient of the Site, residents using water from the contaminated aquifer may incur riskof adverse health effects. Health risks associated with groundwater use will be addressedfurther in subsequent steps of the FS; existing analysis is documented in Appendix C.

Toxicity AssessmentIn this section, the lexicological characteristics of the chemicals of potential concern arepresented. The potential adverse health effects of chemical exposures are described, as well as

Feasibility StudySource Control Operable Uni't


Page 3-8

information on the relationship between the magnitude of the exposure (dose, frequency andduration) and the toxic response it produces (dose-response relationship). The dose-responserelationship for each chemical is addressed in the risk assessment by considering toxicity valuesdeveloped by the U.S. EPA Toxicity values have been derived for noncarcinogenic effects andcarcinogenic effects of the chemicals and are termed reference doses (RFD) and slope factors(SF), respectively. Specific toxicity values have been developed for varying exposureconditions, including chronic versus subchronic duration and oral versus inhalation exposureroutes. Appropriate toxicity values are identified for contaminants of potential concern.

Risk CharacterizationThe risk characterization integrates information described in previous portions of this section.Potential health risks are addressed for current and future land use conditions below.

WCurrent Site Conditions. Under existing conditions, individuals trespassing on-Site may incur ahealth risk from exposure to wastes present at the surface. Because the Site is located in arural area and is secured by fencing, this population is likely small. Quantification of thesepotential risks will be presented in the BRA. VOC emissions from the Site were notconsidered appreciable based on the lack of landfill gas production and the absence of a VOCgradient in ambient air at the Site boundary. Thus, potential health risks via this pathway arenot considered appreciable.

Some small degree of VOC air emissions may be occurring based on the presence of VOCs inL soil gas. Although risks associated with this pathway cannot be quantified, dispersion of

atmospheric contaminants released would likely substantially reduce off-Site contaminantconcentrations. A preliminary evaluation of ambient air quality did not identify a Site-specificVOC gradient.

Future Site Conditions. Potential risks associated with contaminants under future conditionsare based on the assumption of future development. Some degree of health risk may exist forworkers active in on-Site construction, or to those performing Site remedies through activitieswhich disturb the waste materials and allow direct contact or inhalation of contaminated dustsand VOCs. This exposure period would likely be relatively short (months), thus reducing



Page 3-9

health risks which are based on lifetime exposure. Future development in the vicinity of theSite may be residential. Installation of a shallow private well may result in exposure tocontaminants in groundwater and corresponding health risks.

Environmental AssessmentThe objectives of this component of the BRA are to characterize the natural habitats whichmay be influenced by the Site, and to appraise the actual or potential adverse effectscontaminants have on these habitats. Evaluation of adverse effects on domesticated animals isalso appropriate in this section.

Relative to the human health assessment described in the previous four components, themethodology for an ecological assessment is much less defined. However, the overall approachto environmental assessments is analogous to that of human health assessments, and includesidentifying contaminants of potential concern, pathways of contamination migration andpopulations (flora and fauna) potentially affected by Site contamination. To the extentpossible, actual adverse impacts to natural habitats are determined. Similarly, the potential forfuture environmental impact is also described.

Prior to disposal activities, land comprising the waste disposal area was excavated for its sandand gravel. Thus, natural habitat existing prior to mining operations at the Site weredestroyed. At present, the waste disposal area is covered with a layer of soil material whichsupports vegetation primarily consisting of grasses and other verbaceous plants, with some

^^ small trees. This area is likely frequented by wildlife; the most noticeable including birds, smallmammals and deer. Although an inventory of plant and animal species has not beenperformed, the Site is not known to be inhabited by rare or endangered species. Land in thevicinity has been developed for agricultural, mining and commercial purposes. Sensitiveecological habitats (e.g., wetlands) are not in close proximity to the Site and therefore,migration of Site contaminants via groundwater or surface erosion will not impact these areas.The potential adverse impacts of Site wastes on the surrounding ecology are not consideredappreciable in comparison to the loss of habitat which historically occurred during the activesand and gravel mining phase of the Site and that are occurring now as a result of surroundingagricultural, sand and gravel mining and commercial land use.

[skb-601-30c]13452-MD

SECTION 4roENTIFICATION AND SCREENING OF TECHNOLOGIES

Technology screening and alternative development were previously conducted in theAlternatives Array Document (Warryn, October 1989), discussed with the WDNR and U.S.EPA. The conclusions of this previous document are now carried through into detailedanalysis of alternatives (Section 6).

REMEDIAL ACTION OBJECTIVESRemedial action objectives are developed to address long-term goals of protecting humanhealth and the environment, as well as Site-specific goals of reducing the release ofcontaminants to sub-waste soils and groundwater.

^ A number of VOCs have been identified as common in the groundwater, and therefore arealso likely associated with the waste. Some semivolatiles and inorganics have also been foundin groundwater, but below regulatory levels. Therefore, the Remedial Action Objective for theSite is to reduce the concentration of the VOCs in the waste and subwaste soils topredetermined clean-up goals. Determination of these goals will ultimately be based on Stateand Federal groundwater standards. Soil and waste clean-up levels have been developed(Appendix C) which can be used as a guide for determination of treatment effectiveness.

Alternatives must be formulated to address the specific circumstances of the source areas,contaminant releases, contaminant types, distribution, transformation, and migration for bothcurrent and potential future exposure pathways. Constraints that affect configuration of thealternatives have been identified considering physical conditions, public health, andenvironmental and administrative needs. The major constraints are:

• Need for treatment for the reduction in toxicity, mobility or volume of identifiedcontaminants or contaminated media.

• Waste and contaminated soil located directly below the waste is considered collectivelyas the source.

• No adequate source of clean water at the Site.

• Land Disposal Restrictions are applicable to excavation of waste from the Site.



Page 4-2

GENERAL RESPONSE ACTIONSAttaining the response objectives will require the use of contaminant source control measures.Source control objectives may be met using removal, treatment, disposal, isolation and/orclosure measures. The major strategies would include removal and disposal of contaminatedmaterials (with or without treatment), removal and/or destruction of contaminants using in-situ methods, or isolation of the areas and limiting infiltration using barriers, such as caps.Institutional measures, including restrictions on land use and providing an alternate watersupply, may also be appropriate.

Groundwater control response actions, including barriers, extraction and injection were notconsidered in this report because groundwater remedies are not within the scope of sourcecontrol. However, they will be considered later in a subsequent Groundwater ControlOperable Unit (GCOU) FS.

General response actions and associated technology groups identified for consideration are:

General Response Action Remedial Technology

No Action None

Institutional Controls Deed RestrictionsAccess Restrictions

Containment Capping

Direct Soil/Waste Treatment BiologicalChemicalPhysicalThermal

In-Situ Soil/Waste Treatment BiologicalChemicalPhysicalThermal

Disposal On-SiteOff-Site



Page 4-3

IDENTIFICATION AND SCREENING OF REMEDIAL TECHNOLOGIESIn this step, the range of potentially applicable technology types and process options areidentified and reduced by evaluating and screening the options. The purpose of the screeningprocess is to select a limited number of promising technologies for consideration in assemblingremedial action alternatives. A decision is made whether to retain or eliminate an identifiedtechnology type or process option based upon effectiveness, implementability and cost.

Effectiveness is the primary criterion used to screen technology options, and is evaluatedrelative to the end result; i.e., the ability of the technology to meet the remedial actionobjective.

Implementability considers the technical and institutional feasibility of the technology.Technical implementability addresses a range of factors relevant to obtaining, installing, andusing a particular technology. Some remedial technologies are proven and readily available,while others are in the research and development stages. Insufficiently developed technologiesare generally screened out. Site conditions must be compatible with a given technology'scapability, considering for example, depth to bedrock, space requirements, etc. Institutionalimplementability considers a range of factors relevant to the testing, review, approval orpermitting of a particular technology.

Cost plays a limited role in the screening of technologies. Cost will become a more importantcriterion later in Section 6, Detailed Analysis.

Institutional MeasuresA variety of institutional measures may be required as part of remedy, or combined with anynumber of technology based alternatives. Typical institutional measures include deedrestrictions.

Deed restrictions would be appropriate for properties where contaminated materials remain inplace. The feasibility of deed restrictions depends on whether there are authorities willing toimpose them.


Hacen Farm SiteJuly 5, 1990

Page 4-4

ContainmentAreas A, B and C contain municipal waste. Area A appears to have been additionally used byUniroyal to dispose solvents, other organic materials and scrap vinyl. Infiltrating precipitationcan carry these contaminants to the water table. Capping of the landfill will minimizeinfiltration through waste left in place, while also limiting the migration of contaminants to theair. A variety of capping methods are available for consideration.

Capping is retained as a technically feasible option, and could be implemented based onARARs, health risks or other response objectives,

Direct Soil/Waste Treatment (On-Site)Direct on-Site treatment of the waste and contaminated soils can be divided into fourcategories: biological, chemical, physical and thermal destruction.

Biological. Composting is a biological treatment technology that involves the controlledaerobic biological degradation of excavated, contaminated soil or waste. The excavatedmaterial is placed on a low permeability liner, aerated and heated to encourage microbialdegradation of organic contaminants. Moisture and nutrients are added by irrigation.Depending on the level of contamination, collection and treatment of VOCs may be necessary,requiring air emissions to comply with the substantive requirements of applicable ARARs.This technology has been used with success. The main expense of this treatment option isexcavation of the contaminated material. Another biological treatment technology is leachateheaping. This technology involves the excavation of the soil or waste, placing it in a lined cell,and recirculating the leachate produced back through the waste. Due to the complexity ofhazardous waste environments and associated uncertainties of microbial activity, biologicaldegradation process can take a substantially longer time to achieve remediation than othertechnologies. Meeting cleanup criteria may be difficult because of these uncertainties. Due toadded environmental and health impacts related to the composting activity, that option will notbe retained for further consideration. However, the leachate heaping option is somewhat moreviable and implementable and will therefore be retained.



Page 4-5

Chemical. Chemical treatment processes include dechlorination processes, wet air oxidationand oxidation.

Dechlorination processes are only suited for the treatment of halogenated wastes. However,halogenated wastes make up only a small portion of the total waste volume at the Site.Therefore, dechlorination will not be retained.

Wet air oxidation treats liquid waste or solid waste that has been made into a slurry. To treatthe contaminated soil/waste by the wet air oxidation process, all large pieces of waste would beshredded and large quantities of water would be added to increase the waste surface areaavailable for reaction. Due to the lack of a high capacity clean water source on-Site, wet airoxidation is not retained as a treatment option.

The oxidation treatment process involves mixing ozone, hydrogen peroxide or permanganatewith the contaminated soil/waste, thereby oxidizing the organics. Mixing equipment similar towhat is used for composting may be used for oxidation. The implementability of this treatmentoption is similar to composting, discussed earlier. The major cost for these technologies is theexcavation and mixing of the material. Oxidation is not retained as a viable option because ofdifficulties similar to those of composting, cited above.

Physical. Physical treatment options include thermal volatilization, solvent extraction, soilwashing and solidification/stabilization.

Thermal volatilization requires a large energy demand to volatilize the organic compoundsfrom the soil/waste into the atmosphere. The need for emission controls, the energy demandand the volatility differences of organics present in the soil/waste at the Site make thistreatment option unsuitable.

Solvent extraction and soil washing are similar in cost once the waste and soil are excavated.Pretreatment of the waste, such as screening or grinding of large materials, may be necessary.Solvents used in solvent extraction should be low in toxkity since residual concentrations mayremain in soil. A liquid waste stream from the solvent extraction and soil washing processeswould need treatment, such as distillation or carbon adsorption. Discharge of the treatedliquid would need special consideration due to the lack of available sewers or surface water.



Fage 4-6

Solvent extraction and soil washing are primarily applicable to removal of non-volatileorganics. Other options such as vapor extraction are more applicable to the volatiles andsemivolatiles of concern at this Site, Soil washing theory assumes that a substantial portion ofthe contamination is associated with the finer particles of a contaminated matrix. Theseparticles are separated from the remaining matrix and treated either by incineration,biodegradation or solidification/stabilization. Material high in organic content, such as refuse,is not effectively treated by soil washing, because a large percentage of the contaminationwould be adsorbed to larger particles, such as wood or plastic.

Solidification/stabilization involves the mixing of the soil/waste with a binding agent, such ascement or polymer, to improve the physical characteristics of the waste. This treatmentencapsulates the contaminants, reducing their mobility. This technology is proven forinorganics, but is unproven for organics. Because the contamination present at the Site ispredominantly organic compounds, this technology is eliminated from further consideration.

Thermal Destruction. There are many different thermal destruction treatment optionsavailable; however, most are not well suited to this Site. Fluidized bed and molten salt are allnew and relatively unproven technologies for the treatment of hazardous wastes. Also, thesetechnologies are not intended for a heterogeneous waste, such as found at the Site. BecauseSite waste would also produce a high ash content, these treatment options are not retained.

Rotary kiln and multiple hearth incineration are proven technologies for treatment ofcontaminated soil. Infrared incineration is relatively new; however, recent studies indicate thistechnology to be effective in treating contaminated soil. Rotary kiln, multiple hearth andinfrared treatment technologies are retained for further consideration.

Direct Soil/Waste Treatment (Off-Site)Treatment options available off-Site include RCRA licensed incinerators.



Page 4-7

Hauling the contaminated soil/waste to a RCRA licensed incinerator is an option that shouldbe compared to installing an on-Site mobile incineration unit. At this time, there is noevidence that technically favors the off-Site treatment option. Treatment efficiency for anon-Site incineration system should be similar to the treatment efficiency of an off-Site facility.Considering the additional potential impacts related to waste transportation, off-Site treatmentat a RCRA licensed incinerator will not be retained as a technology.

In-Situ Soil/Waste TreatmentA variety of in-situ options exist for treating the VOC contaminated soils/waste. They can beclassified as biological, chemical, physical and thermal.

Biological. Bioreclamation of the unsaturated soil/waste would involve seeding thecontaminated area with microorganisms and nutrients. This is still a developing technology,and can take substantially longer than other treatment technologies. Also, meeting cleanupcriteria may be difficult. It will not be retained for further study.

Chemical. In-situ chemical treatment of contaminated wastes is difficult to control. The abilityto obtain and control the desired reaction in a soil/waste matrix would have to bedemonstrated. The implementability limitations, and uncertainties regarding effectiveness ofthis technology, are fairly serious. Therefore, the technology is not retained.

Physical. Physical treatment methods include vapor extraction, steam heating/extraction,flushing and solidification/stabilization.

Vapor extraction at ambient temperatures is a practical method of removing the VOCcontamination at the source. It also has demonstrated source effectiveness in the removal ofsemi-volatiles. A vacuum is applied at some collection point or series of collection points,which may be either wells or perforated pipe laid in trenches. Soil gases and contaminantvapors migrate toward the collection points. The gases may require treatment prior todischarge. This is typically accomplished using an adsorbent bed, a catalytic combustion deviceor a fume incinerator. With appropriately placed extraction wells and/or trenches, and bycontrolling pressure within the unsaturated zone, contaminant vaporization can be controlledto effect contaminant removal. Unsaturated soil heterogeneities can present difficulties in



Page 4-8

control and effectiveness. However, since the depth of waste is relatively shallow and abovethe groundwater, and the soils are mainly permeable sands, vapor extraction would be aneffective treatment option. The basic feasibility of vapor extraction at this Site wasdemonstrated by the shallow soil gas survey conducted during the RI. Vapor extraction will beretained.

Steam-heating and extraction is essentially a high temperature version of vapor extraction,where steam serves as a hot carrier gas. There is an additional benefit of effective physicalcleaning of soils/waste. Steam is injected into unsaturated soils/waste, and causes vaporizationof volatile contaminants as it moves through contaminated areas. The steam is removed by

^ applying a vacuum at collection points. The steam and contaminants are then condensedabove ground, and the condensate can be treated. The highly volatile contaminants and somesemi-volatiles can be removed at ambient temperatures, without expending additional energyon steam production. The small amount of semi-volatiles present are not enough to warrantthe use of this technology; therefore, this technology is not retained.

Flushing is used to remove and transfer contaminants to a liquid medium, most commonlywater, where they are then collected and treated. A flushing solution, such as water or anaqueous surfactant solution, would be suitable. The solution is applied in some manner abovethe contaminated unsaturated soils/waste. The solution then trickles down through thecontaminated soils/waste and is collected using a groundwater extraction system. Normally,either a shallow trench or spray system is used to distribute the flushing solution and shallowwells or trenches are used to collect the solution along with groundwater. This is a fairlyinefficient means of collecting soluble VOCs from shallow soils/waste. Control of flushingeffectiveness would be difficult at the source, because of heterogeneities in contaminatedunsaturated fill and soils/waste. Therefore, this technology is not retained.

Solidification/stabilization involves the mixing of the soil/waste with a binding agent, such ascement or polymers, to physically bind the contaminated soil/waste to reduce the leachability ofthis material. This in-situ process uses a series of augers to mix the soil while adding thebinding agent. This technology has not been well proven for the treatment of material



Page 4-9

contaminated with organic compounds. Since the contamination present at the Site ispredominantly organic compounds, this technology is eliminated from further consideration.

Thermal. In-situ vitrification (ISV) has been successful in treating radioactive wastes and isreceiving some interest for remediating contaminated soils. The technology is accomplished byinstalling electrodes vertically in boreholes, applying a high voltage, and heating the soils/wastemass as result of the electrical resistance of the mass. Soils are melted at the high temperaturesdeveloped, and then cool to form a glassy solid which immobilizes residual contaminants. Ahood is erected over the area to collect and treat off-gases. This technology is best appliedwhere the glassy solid product is beneficial in immobilizing contaminants that are not

^ destroyed during processing. Due to the lack of oxygen in the melt, organic compounds areonly partially degraded by pyrolysis. Oxygen, supplied as air for combustion in the off-gascollection system, reduces the volatized organics to nonhazardous compounds. The largequantity of nonhazardous industrial scrap vinyl observed during the test pit excavation wouldresult in large quantities of hazardous off-gases requiring excessive amounts of air for theirdestruction. Existing off-gas collection and treatment system designs are not sized to handlethe high organic content at the Site (Personal Communication, Geosafe. June 1990). A largercapacity off-gas collection and treatment system than is currently available would have to bedeveloped and tested before the process could be used at this Site. Additional off-gastreatment would include scrubbers, similar to those used for incineration, to remove the largequantity of acid gases. A cost estimate for using ISV at the Site prepared by the ISV vendorwas approximately equivalent to on-Site incineration. For these reasons, ISV has beeneliminated from further consideration.

DisposalDisposal would include the excavation and landfilling of the waste. The materials (apart frompossible treatment process residuals) that may require disposal are the soils/waste. The LDRsforbid the direct disposal of the soils/waste into a land disposal facility (e.g., landfill) withoutprior treatment.

WARZYN



Page 4-10

TECHNOLOGIES CARRIED THROUGH INITIAL TECHNOLOGY SCREENINGConsidering Site and contaminant characteristics, response objectives and identifiedconstraints on the response, the following technologies were retained for use in developingalternatives:

___General Response Action___ _____Technology_____

1. Containment Capping

2. Direct Soil/Waste Treatment (On-Site) Biological TreatmentMobile Incinerator

3. Direct Soil/Waste Treatment (Off-Site) None

4. In-situ Soil/Waste Treatment Vapor Extraction

5. Disposal None

These technologies will be used for alternative development in Section 6.

[skb-601-30d]33452.74-MD

SECTIONSDEVELOPMENT OF ALTERNATIVES

The primary objective of this phase is to assemble the remaining remedial technologies carriedthrough the initial screening into remedial action alternatives that protect human health andthe environment. The alternatives need to encompass a range of appropriate wastemanagement options. Alternatives were developed that only address source control.Consideration of the off-Site contaminated groundwater will be provided during subsequentanalysis of remedial alternatives.

ALTERNATIVE DEVELOPMENTFrom the remaining general response actions and remedial technologies listed in the previoussection, several alternatives were assembled whose general response actions involved treatmentand containment options. A No Action alternative is also included to provide an assessment ofthe consequences of taking no response action at this time.

The following is a list of alternatives:

Alternative 1: No ActionAlternative 2: CappingAlternative 3: In-Situ Vapor Extraction and CappingAlternative 4: Waste Consolidation with Biological Treatment, Vapor Extraction and

CappingAlternative 5: Waste Excavation with On-Site Incineration, Vapor Extraction and

Capping

A description of each of these options follows:

ALTERNATIVE 1: NO ACTIONThis alternative is evaluated as required by the NCP to determine the public health, publicwelfare and environmental consequences of taking no further action.

ALTERNATIVE 2: CAPPINGThe intent of this alternative is to provide for final grading and capping to improve surfacewater drainage and reduce infiltration. Short-term soil/bitumen and clay caps are available as



Page 5-2

technology options for this use. A number of multi-media cap designs (long-term) areavailable for consideration at the detailed analysis stage.

Refuse located within Areas B and C will be consolidated into Area A before cap constructionbegins to satisfy minimum slope requirements, although additional fill material may berequired. Grading would be accomplished using conventional construction equipment. Thefinal grade would be constructed so that precipitation would be directed away from the sourcewaste. Drainage swales would be constructed to direct runoff to match existing surface flowpatterns. After the desired slope is obtained, the necessary cap materials (i.e., clay, membrane,sand and topsoil) would be placed. It is assumed that a clean clay borrow source, if needed,can be identified and secured within a reasonable haul distance.

The cap would be designed to cover the main waste disposal area (Area A). The area to becapped is approximately 240,000 sq ft (5.5 acres).

ALTERNATIVES: IN-SITU VAPOR EXTRACTION AND CAPPINGVapor extraction is used primarily for treating VOC and semi-volatile contamination. A vaporextraction system is relatively inexpensive and allows for process flexibility during remediationactivities. The major costs for this technology are the installation of extraction and injectionwells. The number of wells used may vary during operation to improve system efficiency. Bytreating the soils/waste in place without excavation, contaminant exposure to the atmosphere isavoided.

In this alternative, buried waste and soil would be treated in place using vapor extraction. Gasis extracted from the soils/waste from extraction wells or trenches placed strategically on-Site.The gas travels from the wells or trenches through header pipes using a blower. The off-gaseswould be treated, if necessary, and discharged to the atmosphere.

A low permeability cap installed over the Site would serve three purposes. First, it wouldimprove system efficiency by increasing the radius of influence of the wells. Second, a capwould reduce leachate production by reducing infiltration. A low moisture content in the

Feasibility StudySource Control Operable Uiut


Page 5-3

soils/waste would also improve system performance. Finally, a cap would minimize thepotential exposure of contaminated waste to the public.

ALTERNATIVE 4: WASTE CONSOLIDATION WITH BIOLOGICAL TREATMENT,VAPOR EXTRACTION AND CAPPINGLeachate heaping was retained because of the ease of implementation. Also, because thewastes would be contained within a lined and capped cell, contaminant mobility would bereduced during treatment.

Alternative 4 involves incorporating non-native materials from Areas A, B and C into anupgraded facility within the area of contamination (AOC) (see Drawing 13452-F16). Wastewould be consolidated using conventional excavation equipment. Dewatering should not benecessary, because the water table is below the predicted depth of refuse. Leachate producedin the cell would be recirculated back through the waste to promote biological activity withinthe cell. Nutrients and microorganisms may be added to leachate to enhance biodegradation.

Under this scenario, a large depression would be created by waste excavation exposingcontaminated soils. This depression would be filled with imported clean fill materials and thecontaminated soil would be treated with vapor extraction.

ALTERNATIVE 5: WASTE EXCAVATION WITH ON-SITE INCINERATION, VAPOREXTRACTION AND CAPPINGThis alternative incorporates waste excavation with on-Site incineration and disposal. Theexcavation activities are the same as described in Alternative 4. On-Site materials handling,staging, containerization and storage may also be required. Waste would be characterizedprior to incineration. Treatment residuals, such as ash and scrubber water, would be furthertreated, if necessary, and disposed of on- or off-Site.

Under this scenario, a large depression would be created by waste excavation exposingcontaminated soils. This depression would be filled with imported clean fill materials and thecontaminated soil would be treated with vapor extraction.

Iskb-601-30e]13452.74-MD

SECTION 6DETAILED ANALYSIS OF ALTERNATIVES

This detailed analysis of alternatives is performed on a limited number of feasible alternatives.The U.S. EPA and the WDNR have identified possible ARARs associated with eachalternative. This analysis of alternatives provides sufficient information to allow decisionmakers to compare the alternatives, select an appropriate remedy for the Site, and todemonstrate compliance with CERCLA statutory requirements in the Record of Decision(ROD).

ANALYSIS CRITERIAAlternatives are compared against nine separate criteria. These nine criteria are subdividedinto threshold, primary balancing and modifying criteria.

The threshold criteria are:

1. Overall Protection of Human Health and the Environment; and2. Compliance with ARARs (or provide grounds for involving a waiver).

These criteria must be met for the alternative to receive further consideration.

The five primary balancing criteria are:

1. Long-Term Effectiveness and Permanence;2. Reduction in Toxicity, Mobility and Volume Through Treatment;3. Short Term Effectiveness;4. Implementability; and5. Cost.

The balancing criteria provide a relative comparison of the alternatives. By comparing theadvantages and disadvantages of each alternative's balancing criteria, the decision maker canrank the alternatives by their overall performance with the criteria. In accordance with theMarch 1990 NCP, more importance will be placed on the long-term effectiveness andtreatment criteria.



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The modifying criteria are:

1. State Acceptance; and2. Community Acceptance.

These criteria are considered in the final remedy selection. The final statement concerning theState acceptance criterion is provided by the State during the plan's public comment period.The community acceptance criterion is not evaluated until after the plan's public notice period.

The following subsections describe the nine criteria used in the evaluation of alternatives.

Threshold CriteriaOverall Protection of Human Health and the Environment. Exposure and contaminantmigration pathways are identified that would or would not be addressed by each alternative.Methods by which each alternative would eliminate, reduce or control existing and potentialrisks are discussed for each alternative. Adverse effects of the alternatives on human healthand the environment are also considered.

Compliance with Applicable or Relevant and Appropriate Requirements (ARARs).Chemical-specific, action-specific and location-specific federal ARARs and more stringentState ARARs are identified for each alternative. The alternatives are evaluated based on theirability to comply with the ARARs. The grounds for invoking a waiver are also evaluated ineach case. Table 5 lists probable ARARs for the alternatives presented in this report. TheARARs listed in Table Al were identified by the U.S. EPA and the WDNR in response to theAlternatives Array Document (Warzyn, October 1989) prepared for the Site.

Primary Balancing CriteriaLong-Term Effectiveness and Permanence. An evaluation of long-term effectiveness includesan evaluation of the magnitude of total residual risks due to untreated waste and wastetreatment residuals remaining on-Site. The primary focus of this criteria is the extent andeffectiveness of the controls that may be required to manage the residual risks. The long-termreliability of the remedial measures is also assessed, including the potential need forreplacement. The magnitude of residual risk and the adequacy and reliability of controls willalso be evaluated.



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Reduction in Toxteitv, Mobility or Volume Through Treatment. Likely reductions in toxicity,mobility or volume of the hazardous constituents addressed by each alternative are identifiedand considered in the analysis. A distinction is made between inherent mobility (consideringthe waste matrix and/or chemical form of the contaminants) and containment. Containmentby itself does not constitute mobility reduction.

Within this criterion the following points will be discussed:

• Treatment process used and materials treated;• Amount of hazardous materials destroyed or treated;• Degree of expected reductions in toxicity, mobility or volume;• Degree to which treatment is irreversible; and• Type and quantity of residuals remaining after treatment.

Short-Term Effectiveness. An evaluation of short-term effectiveness includes consideration ofpotential effects on the local community and workers during implementation of an alternative.Also considered is the adequacy of available personal protection for on-Site constructionworkers. Potential environmental impacts of the alternative are considered, as are theeffectiveness and reliability of mitigative measures.

The following points will be discussed in this regard:

• Protection of community during remedial actions;• Protection of workers during remedial actions;• Environmental impacts; and• Time until remedial action objectives are achieved.

Implementabilitv. Items considered to assess the technical feasibility of the alternatives includethe constructability and reliability of technologies. The ease of taking additional actions andthe compatibility of the alternative with potential future remedial actions are also considered.An overall determination of administrative feasibility is made considering likely permittingrequirements, coordination with other agencies, and the time required for these steps. Theavailability of resources and services required by each alternative is shown by commercial



Page 6-4

availability, use at other sites, or the existence of similar permitted facilities in or near theregion.

The following points will be considered within the implementability criterion:

• Technical feasibility of the alternative;• Administrative feasibility of the alternative; and• Availability of services and materials.

Cost. Cost figures obtained from readily available sources (e.g., Means Site Work Cost Data,1990) are used to estimate costs for each of the alternatives for comparison purposes.Approximate capital and long-term O & M and present worth costs are also considered. Thesecost estimates should not be considered the actual cost of designing and implementing aremedial action, but rather relative costs among the alternatives using consistent assumptionsand estimating methods. According to the U.S. EPA document "Draft Guidance forConducting Remedial Investigations and Feasibility Studies Under CERCLA", October 1988,cost estimates provided in the FS are expected to provide a level of accuracy of +50 to -30percent. More detailed cost estimates will be prepared during the design phase.

Modifying CriteriaState Acceptance. This assessment reflects the State's preference or concerns aboutalternatives. This criterion has not been addressed in this report, but will be addressed in theROD after agency review of the FS Report.

Community Acceptance. This assessment reflects the community's preferences or concernsabout alternatives. This criterion has not been addressed in this report, but will be addressedin the ROD after public comments on the FS are received.

The following subsections present the analysis of each of the six alternatives developed inSection 5, assessed against the nine criteria.

ALTERNATIVE 1: NO ACTIONDescriptionAlternative 1 is the No Action alternative. Under this scenario, no remedial measures wouldbe implemented at the Site. Although Site access is presently restricted by a chain link fence,



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which would be maintained, the possibility of on-Site exposure of individuals to contaminatedsurface soil remains. However, the possibility of exposure is remote.

The Site has a high potential for infiltration of runoff, because the Site is relatively flat andlacks substantial surficial soils. Since the Site stopped accepting waste nearly 25 years ago, it islikely most free liquids may have leached into the high permeability subwaste soils. Thesubwaste soils may now be acting as the source if the waste has released most of itscontamination. On-going source material analysis being conducted during the RI will provideadditional information in determining the potential of the waste itself to act as a source ofcontamination.

Overall Protection of Human Health and The EnvironmentThis alternative will provide no protection from health and environmental threats posed bySite contaminants. Existing risks from direct contact and inhalation will continue under thisalternative.

Compliance with ARARsEvaluation of compliance with ARARs is not necessary for the No Action alternative.

Long-Term Effectiveness and PermanenceThis criterion describes residual risks remaining following implementation of the remedy.Other factors addressed include the long-term management of treatment residuals, long-termreliability of engineering and institutional controls and the potential need for replacement ofthe alternative.

• Magnitude of Residual RiskResidual risks following implementation would exist as described in the preliminaryassessment of baseline risks.

• Adequacy and Reliability of ControlsControls are not implemented with this alternative.

Reduction in Toxicity, Mobility or Volume Through TreatmentFactors considered with this criterion are presented below:



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• Availability of Services and MaterialsNot applicable.

CostCosts applicable to this criterion are presented below:

• Capital CostsNone.

• Operating and Maintenance CostsNone.

• Present Worth CostNone.

State AcceptanceIn a letter from the WDNR, dated February 21, 1990, the WDNR expresses a preference forin-situ waste treatment options.

Community AcceptanceThis criterion will be addressed in the ROD after public comments on the FS are received.

ALTERNATIVES CAPPINGDescriptionThe major elements of this remedy may include:

• Institutional controls; and• Capping.

Institutional controls would include land and groundwater use restrictions, zoning restrictionsor some combination of controls.

Land use restrictions would likely be in the form of deed restrictions. Restrictions would beincorporated into the property deeds of potentially contaminated areas, limiting the use ofaffected land.



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Local agencies could establish zoning restrictions for potentially contaminated areas limitingthe use of affected land. Zoning restrictions would likely only be applicable to the Site itself,and possibly adjacent areas.

Capping involves improving the existing cover or upgrading the existing cover to a moresophisticated cap and providing cover/cap maintenance. Capping will occur within the Regionof Maximum Contamination (see Drawing 13452-F16). The Site was originally closed duringthe mid-1960's in accordance with standard operating practices at that time. According toTM-1, surficial soils are minimal.

The Site presently does not meet minimum slope requirements as required by ARARs. Agrading layer of approximately 37,000 cu yds of fill will be placed over the Site to allow for cap

\^ construction with a minimum slope of 3 percent. Refuse, non-native materials and soil fromdisposal Areas B and C will be used for fill to bring the cover to grade before a cap isconstructed. A source of clean fill to supplement fill from Areas B and C is assumed to belocally available at nearby sand and gravel quarries. Any unexpected wastes (such as drums ofsolvents) that are uncovered in Areas B and C shall be removed from the Site and disposed asper applicable State and Federal regulations.

Capping would consist of upgrading the existing cover to meet the requirements for facilitieswithout an operating license (i.e., an NR 181.44(12) cap) upgrading the existing cover to meetthe requirements of a RCRA Subtitle D cap (i.e., an NR 504.07 cap), or upgrading the existingcover to meet the closure requirements for facilities with an operating license including aRCRA Subtitle C cap (i.e., an NR 181.44(13) cap).

Option 2a. An NR 181.44(12) cap (Option 2a) consists of the following components:


A. A minimum of 6 in. of vegetated topsoil.

2. Clay Capping Layer



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• Treatment Process Used and Materials TreatedNo treatment process is proposed.

• Amount of Hazardous Materials Destroyed or TreatedNot applicable.

• Degree of Expected Reductions in Toxicity, Mobility or VolumeNo reduction in toxicity, mobility or volume of the source is expected.

• Degree to Which Treatment is IrreversibleNot applicable.

• Type and Quantity of Residuals Remaining After TreatmentNot applicable.

Short-Term EffectivenessThis criterion addresses additional risks to workers, the community or the environment duringimplementation of the remedy. In addition, the time required to achieve effectiveness isdiscussed. Evaluation of this criterion is not applicable for this alternative because no remedialaction occurs. Therefore, the following considerations are irrelevant with the No Actionalternative.

• Risks to Community During Remedial Actions• Risks to Workers During Remedial Actions• Environmental Impacts• Time Until Remedial Action Objectives are Achieved

ImplementabilityFactors considered with this criterion are presented below:

• Technical FeasibilityNot applicable.

• Administrative FeasibilityIn general, Alternative 1 is administratively feasible, but the lack of response to the short-term and long-term risks may not be acceptable to other federal or state agencies.



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Test Plot 3 of the Omega Hills study was similar in design to the proposed NR 504 cap for theSite. However, instead of common earth material, clay was used for the layer above the sanddrainage layer in the Omega Hills study. The study suggests that development andpropagation of cracks (relating to freeze/thaw and desiccation) in the cover soils dominates thefactors controlling percolation performance. The apparent impact of desiccation cracks in thecover soils indicates that drought conditions may be more damaging to cover performance thana continuous supply of moisture. Therefore, a proposed cover design should seek to reduceboth freeze/thaw cracking and desiccation cracking.

The observed hydrologic response of Test Plot 3 indicates the sand lateral drainage layerprovides an effective barrier to upward migration of moisture from the clay barrier layerduring drying periods, thereby minimizing desiccation cracking. Soil moisture measurementsobtained at the test plots demonstrated that the moisture content of the lower clay barrierremained very stable (desiccation was not occurring).

Cracking of the upper clay layer of Test Plot 3 apparently allows percolation of moisture to thesand drainage layer. However, observed percolation through the lower clay barrier hasremained low (1.6 in. during the period September 1988 through August 1989), indicating themaintenance of original low permeability porous media flow conditions in the lower claybarrier.

See Drawing 13452-A4 for a typical detail of a modified NR 500 cap structure.

Option 2c. Upgrading the existing cap to be consistent with NR 181.44(13) (Option 2c) wouldinclude:


A. Be at least 2-ft thick.

B. Support vegetation that will effectively minimize erosion without the need forcontinuing application of fertilizers, irrigation, or other man-applied materials toaid viability and persistence.

feasibility StudySource Control Operable Unit


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C. Be planted with persistent species that will effectively minimize erosion, but doesnot have a root system that will penetrate beyond the vegetative top cover andmiddle drainage layer.

D. Have a minimum slope of between 3 to 5% after allowance for settlement andsubsidence and slopes no steeper than 25%.

2. Drainage Layer

A. Be at least 12-in. thick with a saturated variable or constant head permeabilitynot less than 1 x 10'3 cm/s.

B. Have final bottom slope of at least 3%, after allowing for settling and subsidence.

C. Be overlain by a graded granular filter or synthetic filter fabric to preventclogging from fines,

D. Be designed so that discharge flows freely in the lateral direction to minimizehydraulic head on, and flow through, the low permeability layer.

3. Low Permeability Layer (has two components)

A. Upper Component

1) Consists of material which is designed, constructed and installed to preventthe migration of any liquid into the material during the entire long-term careperiod (e.g., synthetic membrane).

2) Be protected from damage by at least 6 in. of bedding material classified asSP, both above and below the layer required in Subparagraph 1. Thebedding material shall be free of rock, fracture stone, angular grains, debris,cobbles, rubbish, roots or any other materials which could potentially

Source Control Operable UnitHagen Farm Site

July 5,1990Page 6-13

damage the layer required in Subparagraph 1. The middle drainage layermay also serve as the upper bedding material if it meets the specifications.

3) Have a final slope (in contact with the bedding material) of at least 3% afterallowances for settling.

4) Be located 1 ft below the maximum recorded depth of frost penetration inthe area.

B. Lower Component

1) Consists of at least 2 ft of clay.

2) Have a saturated undistributed hydraulic conductivity of not more than1 x 10"? cm/s.

3) Be compacted to 90% modified proctor density.

4) Be constructed in lifts which do not exceed 8 in. after compaction.

4. Grading Layer

A. Clean fill and waste excavated from Areas B and C placed over the Site to obtaina minimum slope of 3%.

See Drawing 13452-A5 for a typical detail of a NR 181 cap structure.

For each of the cap systems, actual soil specifications will be established at the design stagebased on an evaluation of necessary soil characteristics and available materials. In addition, foreach of the cap system alternatives, the additional capping materials and grading layer wouldbe placed directly over the existing cover material. Existing trees on the Site would have to beremoved to accommodate each type of cap.



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Overall Protection of Human Health and the EnvironmentThis criterion addresses the adequacy with which the alternative can provide protection ofhuman health and the environment by controlling exposures to contaminants.

This alternative would protect human health from threats posed by direct contact with wastesby providing a barrier to direct exposure. Future direct contact with wastes and correspondingrisks are directly related to the likelihood of future Site development. This possibility will bereduced through institutional controls. Health risks of contaminants currently present ingroundwater would remain. However, future degradation of groundwater quality andassociated risks would be lowered by reducing the leaching of contaminants to groundwater.This alternative would also reduce potential risks from inhalation exposure to VOCs; however,the baseline risks via this pathway are considered minimal. Site contaminants are not posingappreciable risk to the ecology in the vicinity of the Site.

Compliance with ARARsProbable ARARs for Alternative 2 are summarized in Table 5.

ARARs considered with this criterion are presented below:

• Compliance with Chemical-Specific ARARsChemical-specific ARARs identified relate primarily to groundwater quality standards.

Groundwater quality ARARs are discussed with the No Action alternative. Futureleaching of contaminants from waste and soils to groundwater will be reduced because ofthe cap repair or enhanced capping options.

• Compliance With Location-Specific ARARsLocation-specific ARARs were not identified for this alternative.

• Compliance With Action-Specific ARARsAs discussed with the No Action alternative, the Site presently does not meet any State orFederal closure requirements. Capping will address these requirements by installing a low-



Page 6-15

cover over the waste. The particular cap chosen will depend on which requirements theagencies determine are applicable or relevant and appropriate.

Long-Term Effectiveness and PermanenceThis criterion describes residual risks remaining after implementation of the remedy. Otherfactors addressed include the long-term management of treatment residuals, long-termreliability of engineering and institutional controls and the potential need for replacement ofthe alternative.

• Magnitude of Residual RiskThe remaining residual risks are related to exposures to contaminated groundwater, air and

, . waste. Capping would reduce risk from direct contact with residual wastes by eliminatingexposure. Exposure to waste and corresponding risk; however, would occur should the Sitebe disturbed in the future by an event such as development with the construction of abuilding. Institutional controls would minimize the possibility of future Site development.

This alternative is expected to reduce residual risk from groundwater exposure byminimizing infiltration of precipitation and associated continued contaminant leaching togroundwater. Contaminants and associated health risks currently present in groundwaterand unsaturated zone soils would remain.

Residual risks associated with exposure to volatilized contaminants are expected to be^ reduced with a cap by reducing the rate of VOC diffusion and emissions from the waste.

• Adequacy and Reliability of ControlsRemediation of contaminated groundwater and subwaste unsaturated zone soil may benecessary and is the focus of the GCOU.

This technology is considered reliable in minimizing continued impact of wastes ongroundwater and in preventing contact with wastes.

Replacement of this remedy is not anticipated. Long-term management of this alternativewould include continued groundwater monitoring and maintenance of the integrity of thecap.



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• Treatment Process Used and Materials TreatedNo treatment process is proposed with capping.

• Amount of Hazardous Materials Destroyed or TreatedNot applicable.

• Degree of Expected Reductions in Toxicity, Mobility or VolumeThe institutional controls will not result in a reduction in toxicity, mobility or volume ofcontaminants.

Option 2a or Option 2b will not reduce the toxicity or volume, but would reduce themobility through reduction in the migration potential of contaminants as compared to theexisting cover. Option 2a or option 2b both require a clay capping layer that has a hydraulicconductivity of less than 1.0 x 10' cm/s. The clay capping layer will substantially reduce thepermeability of the overall cap as compared to the existing cover. Option 2b consists ofthree layers, including topsoil layer, cover layer and clay capping layer. While theadditional cover layer component of Option 2b does not substantially reduce thepermeability of the cap by itself, the cover layer does protect the clay capping layer fromroot penetration, potential frost damage and increases the evapotranspiration. Therefore,Option 2b may aid in further reducing the percolation of rainwater through the cap toremaining waste and subwaste soil as compared to cap repair.

Option 2c will not reduce the mobility, but may reduce the migration potential ofcontaminants as compared to the existing cover. Option 2c consists of three layers,including vegetated top cover, drainage layer and low permeability layer. The variouslayers of Option 2c will enhance drainage and increase evapotranspiration, therebyreducing the amount of infiltration that reaches the low permeability layer. In addition, theupper component of the low permeability layer minimizes the migration of liquids throughthe cap. Therefore, Option 2c may aid in reducing the percolation of rainwater through thecap to the remaining waste and subwaste soil.



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Upgrading the cap through any of the options presented will not result in a reduction intoxicity or volume of remaining wastes.

• Degree to Which Treatment is IrreversibleNot applicable.

• Type and Quantity of Residuals Remaining After TreatmentNot applicable.

Short-Term EffectivenessThis criterion addresses additional risks which may be posed to workers, the community or theenvironment during implementation of the remedy. In addition, the time required to achieveeffectiveness is discussed.

• Risks to Community During Remedial ActionsImplementation of this alternative would not be anticipated to pose additional risks to thecommunity from exposure to contaminants in waste. Construction activities associated withcapping will cause some increase in the potential for vehicular accidents.

• Risks to Workers During Remedial ActionsIf soil/waste materials are disturbed during capping activities, remediation workers mayincur contaminant exposure (through direct contact with contaminated wastes or inhalationexposure to VOCs). This exposure can be minimized by use of personal protectiveequipment.

• Environmental ImpactsImplementation of this alternative is not anticipated to pose additional risk to theenvironment.

• Time Until Remedial Action Objectives are AchievedCapping would provide immediate protection from direct contact exposure to soil/waste.This remedy would also be expected to immediately reduce the rate of contaminantleaching from waste to groundwater by reducing infiltration of precipitation. Performingthis technology is anticipated to require approximately 12 months.



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ImplementabilityImplementability considers factors such as technical feasibility, administrative feasibility andavailability of services and materials. These factors are presented below:

• Technical FeasibilityAlternative 2 is technically feasible. Institutional controls and capping technologies arerelatively easy to technically implement.

A cap is basically a simple system, easy to understand and relatively easy to design. Option2a or Option 2b use common materials and construction techniques, and experiencedcontractors are available in this area. Option 2c involves more complex materials andconstruction techniques and experienced contractors are more limited, but even these capsand contractors qualified in then- construction are becoming more common. Caps ingeneral are considered reliable technologies. A cap should not interfere with undertakingadditional future remedial actions, if actions are necessary. A cap would be constructedover the existing cover material, requiring the removal of existing trees.

• Administrative FeasibilityThis alternative is administratively feasible, although not without some difficulties. Whilethe capping technologies are relatively easy to implement from an administrativestandpoint, institutional controls in the form of zoning restrictions may be more complex.Difficulty in implementing zoning restrictions may arise, because zoning is a third party,local agency responsibility, over which long-term control may be difficult.

Institutional controls may include land and groundwater use restrictions, zoning restrictionsor some combination of controls.

• Availability of Services and MaterialsRequired services, materials and equipment are available to implement this alternative. Itis assumed that appropriate materials to perform capping could be obtained from a borrowsource located within four miles of the Site.



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CostCosts applicable to this criteria are presented below:

• Capital CostsThe major capital costs of this alternative are the costs for installing a grading layer toincrease the slope to meet minimum requirements and cap repair or construction of eithera NR 500 or NR 181 cap. Grading layer installation will cost approximately $550,000 and isincluded in the costs of all three options. Capital costs are estimated to be $1,579,000,$2,087,000 and $2,751,000 for Options 2a, 2b and 2c, respectively.

• Operation and Maintenance Costsv The annual operation and maintenance (O & M) costs of this alternative includes cap

maintenance and monitoring. O & M costs are estimated to be $8,899 per year.

• Present Worth CostThe 30-year present net worth (PNW) (5% discount rate) associated with the above costsare estimated to be $1,716,000, $2,224,000 and $2,888,000 for Options 2a, 2b and 2c,respectively.

A summary of costs for Alternative 2 is presented in Table Bl of Appendix B. Two factorsthat could substantially affect the capital and PNW costs for cap construction are haulingdistances and unit price estimates for borrow materials.

<^State AcceptanceIn a letter from the WDNR, dated February 21, 1990, the WDNR expressed a preference forin-situ waste treatment options.




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ALTERNATIVES: IN-SITU VAPOR EXTRACTION AND CAPPINGDescriptionThe major elements of this alternative include:

• Institutional controls;• Capping;• In-situ vapor extraction; and• System monitoring.

Due to their high vapor pressure, VOCs, and to a lesser degree semi-volatiles, exhibit a strongtendency to establish an equilibrium between the liquid and gaseous states. In the unsaturatedzone, VOCs will volatilize and become trapped in pore spaces. A vacuum applied to thesystem, flushes clean air through the pore spaces taking the VOCs out of the soil. VOCsdissolved in the soil moisture or adsorbed to the soil will continue to partition to the clean airuntil these contaminants have been substantially removed.

Vapor extraction systems can be designed to allow some process flexibility after the system isinstalled. Vacuum strength applied to extraction wells screened at different depths can bevaried during the treatment period thus customizing the system to varying subsurfaceconditions. The number of extraction wells will depend on the zone of influence attainable inthe subsurface environment. Factors which affect the zone of influence such as conductivity ofthe soil or waste may be provided from the source characterization. However, only after thevapor extraction system is installed and operating will its impact be fully known. Therefore,the design will be performed in a stepwise fashion beginning with a minimum number of wellsto successfully pilot test the system. Additional wells would be installed as necessary.Extraction wells will be connected by a header pipe system with a blower to create a vacuum.Treatment of the extracted air using carbon adsorption, UV radiation or fume incinerationmay be necessary. Carbon adsorption is a likely method and used in developing the costestimate (Appendix B). Injection wells which force air into the system may be added toimprove the system efficiency, although forcing air through a landfill could triggerunderground fires due to the exothermic nature of aerobic biodegradation. However, the lackof methane at the Site indicates a deficiency of readily biodegradable material necessary forsufficient biological activity to make fires an expected problem.



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A permanent low permeability cap will be installed prior to installation of the vapor extractionsystem according to NR 500 requirements for solid waste closure. Materials from Areas B andC will be excavated and included as part of the grading layer below the cap. Any unexpectedwastes (such as drums of solvents) discovered during excavation will be characterized, removedfrom the Site and disposed as per applicable State and Federal regulations. A cap will improvesystem efficiency by increasing the zone of influence and reducing moisture content of thesoils/waste. A cap will also reduce leachate production.

Excavated Areas B and C, the sand and gravel piles and other disturbed areas on-Site will begraded and landscaped after implementation of the remedy. During all construction work,fugitive paniculate emissions will be minimized through common construction dust controlmeasures.

Site characterization activities to date have not identified any free solvent or other highconcentrations of volatiles in the waste materials that could be expected to create substantialvolatilization. Continuous monitoring for VOCs in the air will be conducted and excavationwill be discontinued upon detection of excessive VOC concentration. The waste materialswhich contain high concentrations of volatile materials such as drums and areas saturated withfree liquid and which would be the likely source of excessive VOC emissions, if present, will becarefully removed and packaged or overpacked for off-Site disposal.

A substantial portion of contamination may be within the subwaste soils. The silty sands andsand and gravels of the subwaste soils are well suited to vapor extraction due to their relativehigh permeability. The nonuniform distribution in size of the waste materials can createpreferential flow paths resulting in irregular shaped zones of influence. However, VOCs, andto a lesser extent, semi-volatiles isolated from the zone of influence, will be drawn eventually tothese preferential flow paths by concentration gradient effects.

In addition to the benefits of VOC removal through vapor extraction, some aerobicbiodegradation of volatile and non-volatile organic compounds will occur within the soils/wasteas a result of fresh air moving through it. If less volatile compounds persist within the sourceand lead to further groundwater contamination despite extraction efforts, the system may bemodified to enhance the aerobic destruction of these compounds. Water, possibly with



Page 6-22

nutrients, could be added to the soils/waste to enhance biological activity. Water with orwithout additives could be added to the system by increasing the moisture content of theinjected air. Pumps, meters, etc., necessary for implementing this system, could be added to thefull scale vapor extraction system if operating data indicate this system augmentation isdesirable. Tests for enhancing biodegredation can be performed once the vapor extraction isoperational. Though this system would not be installed with the initial installation, the cost ofthis contingency is included in the cost estimates presented later in this section.

Modifying the vapor extraction system for biological treatment of the source is Site dependentand its degree of success cannot be predicted until in-situ treatability studies are performed.The WDNR has, however, expressed some reservations about the application of bio-enhancement technologies.

Monitoring will likely involve a long-term monitoring program for the subwaste soils andsystem off-gases, as well as ambient air monitoring. Installation of sampling probes throughthe cap for subwaste monitoring would be designed to minimize the permeation of runoff.


The cover or cap component of this alternative would provide protection from risks due todirect exposure to wastes at the surface of the Site by preventing direct contact. Future directcontact with wastes and corresponding risks are directly related to the likelihood of future Sitedevelopment; development will be minimized by implementing institutional controls. Healthrisks of contaminants currently present in groundwater would remain. However, futuregroundwater quality is expected to improve, thereby reducing associated risks. This will beaccomplished by decreasing contaminant leaching through vapor extraction and capping. Thisalternative would also protect human health from volatilization and inhalation exposure toVOCs by decreasing the contaminant source. Site contaminants are not posing appreciablerisk to the ecology in the Site vicinity.


Hagen Farm SiteJuty 5,1990

Page 6-23

Compliance With ARARsProbable ARARs for Alternative 3 are summarized in Table 5. ARARs considered with thiscriterion are presented below:

• Compliance With Chemical-Specific ARARsChemical-specific ARARs identified related primarily to groundwater quality and airemission standards.

Groundwater quality ARARs (NR 140) are discussed with the No Action alternative.However, future leaching of contaminants from waste and soils to groundwater will besubstantially reduced because of vapor extraction.

Air emission standards (NR 445) will be evaluated to determine if an off-gas treatmentsystem is necessary.


• Compliance With Action-Specific ARARsAction-specific ARARs identified relate to closure requirements, monitoring requirementsand air emission regulations.

As stated earlier, the Site does not meet State and Federal closure requirements. A solidwaste landfill cap will be placed over the treated area (i.e., Area A).

Groundwater monitoring is not part of the scope of the SCOU. A groundwater monitoringprogram will likely be a part of the GCOU and provide information on the effectiveness ofboth the chosen source and groundwater control measures.

Air emission regulations will be met by treating off-gases from the extraction system. Notreatment may be required if effluent system concentrations are below applicable standards.



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Long-Term Effectiveness and PermanenceThis criterion describes residual risks remaining following implementation of the remedy.Other factors addressed include the long-term management of treatment residuals, long-termreliability of engineering and institutional controls, and the potential need for replacement ofthe alternative.

• Magnitude of Residual RiskResidual risks remaining following alternative implementation are related to exposures tocontaminated groundwater, air and waste. Capping would eliminate residual risk fromdirect contact with wastes by eliminated exposure. Exposure to waste and correspondingrisk, however, would occur should the Site be disturbed in the future by an event such as

\ development with construction of a building. The potential health impact of this risk willbe substantially reduced by vacuum extraction removal or reduction of the hazardous VOCcontent in the waste. Additional volatile and semivolatile organic compounds could beremoved or reduced through system modifications that enhance biological degradation ofthese compounds, should those modifications be considered necessary and in-situ studiesprove viable. Institutional controls would minimize the possibility of future Sitedevelopment. Following implementation of vapor extraction, risks from residual organiccompounds would be minimized. Risk from semivolatile/metal/PCB residuals would beminimized by capping the waste.

This alternative is expected to reduce residual risk from groundwater exposure by^-^ minimizing infiltration of precipitation and associated contaminant leaching to

groundwater through vapor extraction and capping. However, vapor extraction will addressonly contaminants which can volatilize at ambient temperature. Compounds of thesemivolatile, pesticide/PCB and inorganic analysis categories will remain. The potential forthese compounds to impact groundwater is dependent on factors including water solubility,organic carbon binding affinity and the rate of infiltration of precipitation.

Following implementation of vapor extraction, residual risks from contaminants which mayvolatilize to air would be reduced to a minimum.



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• Adequacy and Reliability of ControlsRemediation of contaminated groundwater and unsaturated zone soils may be necessaryand will be the focus of the groundwater operable unit analysis.

Technologies addressed in this alternative are considered reliable with the exception of abio-enhancement option in minimizing continued impact of wastes on groundwater inpreventing contact with wastes.

Replacement of the cap is not anticipated to be necessary. Long-term management of thisalternative includes periodic monitoring of groundwater quality. In addition, maintenanceof the integrity of the cap may be needed in the long-term.


• Treatment Process Used and Material TreatedAlternative 3 uses in-situ vapor extraction to remove volatile and semi-volatilecontamination from the Site. Some form of off-gas treatment, such as carbon adsorption orfume incineration, may be added to the system should emissions exceed regulatory limits(i.e., NR 445). For carbon adsorption, the contaminants would be destroyed by incinerationduring regeneration of spent carbon. A system modification may involve adding moisturewith or without nutrients to the injected air to enhance biological activity should thistreatment enhancement be considered necessary.

• Amount of Hazardous Materials Destroyed or TreatedThe amount of contaminants present at the Site is not known. The heterogeneous natureof waste makes source definition difficult, if not impossible. However, the volume ofcontaminated waste is approximately 68,000 cu yd and the volume of contaminated soil,between waste and water table is approximately 112,000 cu yd.

• Degree of Expected Reductions in Toxicity, Mobility or VolumeVapor extraction will reduce toxicity, mobility and volume by removing a high percentageof the contaminant. How much contamination is removed is a function of the time allowedfor treatment. Based on current literature, the greatest amount of contamination would be


Hagen Farm SiteJuty5,1990

Page 6-26

removed during the first year of operation. A substantial portion of volatile compoundscan be removed with vapor extraction, although semi-volatile compounds will be reduced bya lower percentage. Case histories presented in a review of soil vapor extraction systems(Hutzler, et al., 1988) showed that reduction of VOCs ranged between 20% to 90% withoperating periods of less than one year. Destruction of less volatile organic compoundsmay be achieved biologically through the addition of water either with or without nutrientsto the soils/waste. This enhanced biological activity can be evaluated during the designprocess.

• Degree to Which Treatment is IrreversibleVapor extraction is an irreversible process.

• Type and Quantity of Residuals Remaining After TreatmentTreatment residuals from this technology include the spent carbon if used for off-gastreatment. The amount of carbon used will depend on the amount and type ofcontaminants extracted from the Site, and can only be accurately estimated after the pilottesting phase. Spent carbon will either be regenerated or disposed as a hazardous wasteaccording to prevailing regulations.

The reduction in toxicity, mobility or volume related to institutional controls, capping andmonitoring is discussed under Alternative 2,


• Risks to Community During Remedial ActionsImplementation of this alternative is not anticipated to pose additional risks to thecommunity, assuming air contaminant monitoring at the Site boundary does not identifyunacceptable levels. Construction activities associated with capping will increase to someextent the potential for vehicular accidents.

• Risks to Workers During Remedial ActionsIf soil/waste materials are disturbed during cover repair/capping activities, remediationworkers may incur contaminant exposure (e.g., direct contact with contaminated wastes).


Haeen Farm SiteJuly 5,1990

Page 6-27

In addition, exposure to VOCs in vapor extractor off-gases may occur. These areanticipated to be below current workplace standards for airborne chemicals. Exposure toboth VOCs and wastes can be minimized by the use of personal protective equipment. Inaddition to risks associated with contaminant exposure, workers will be at some risk ofinjury and death from construction activities.

• Environmental ImpactsImplementation of this alternative is not anticipated to pose additional risk to thesurrounding ecology.

• Time Until Remedial Action Objectives are Achievedv^' Protection from heath risks associated with direct contact with soils will occur immediately

after covering the Site. Continued contaminant impact on groundwater and potential VOCrelease from wastes will be reduced substantially at first and to a lesser degree over timefollowing implementation of the alternative. Since a time-consuming permitting processwould not be required before installation and operation of a vapor extraction system,remediation of the Site can begin shortly after design approval. Based on soil vaporextraction case histories (Hutzler, et al., 1988) time for remediation of a Site rangesbetween less than one year to three years. Due to the uncertain effects related to vaporextraction of refuse, a conservative estimate of five years is assumed for remediation toallow for potential delayed diffusion from this portion of the Site. Also, determining theextent of contamination in the subwaste soils can help in judging the length of timenecessary to complete the remedy. However, site characterization activities to date havenot indicated the presence of free liquid solvent which would tend to increase remedialtime and cost.

ImplementabilityImplementability considers factors such as technical feasibility, administrative feasibility andavailability of services and materials. These factors are presented below:

• Technical FeasibilityVapor extraction has become a common method for the remediation of unsaturated soilscontaminated with VOCs and has been proven technically feasible in these instances. The



Page 6-28

municipal and industrial refuse present at the Site does create some uncertainty indesigning an extraction system. Wide variability of conductivities within the refuse willcreate non-uniform zones of influence from the extraction system. However, as operatingconditions are controlled, extraction efficiency can be maximized in the refuse.

Augmentation of biological destruction of organics in contaminated soils throughenhancement of vapor extraction technology has met with limited success. At this point,this technology would be considered unproven.

• Administrative FeasibilityMonitoring of the off-gas would be necessary to establish compliance with air discharge

^ regulations. Coordination with the WDNR and U.S. EPA will be necessary to determinewhen the source has been sufficiently remediated. A treatment permit may be required foran off-gas treatment system. Permanent gas probes will be used for long-term monitoring.

• Availability of Services and MaterialsThis alternative requires available materials and no shortages are anticipated. Engineeringjudgment will be needed throughout remediation to adjust system parameters to maximizeperformance. Vapor extraction and in-situ biological treatment have been used atnumerous sites and the technology is readily accessible for implementation at the Site,however the combination of these two technologies has only been used at a few sites.

^> The implementability of institutional controls, capping and monitoring are as discussed forAlternative 2.

CostCosts applicable to this criterion are presented below:

• Capita] CostsThe major capital costs of this alternative are the costs for treating the waste and soil in-place with vapor extraction including possible bio enhancement and installing a cap.Capital costs are estimated to be $2,679,400.



Page 6-29

• Operation and Maintenance CostsThe O & M costs of this alternative include system supervision, off-gas treatment andmonitoring, and cap maintenance and monitoring. O & M costs are estimated to be$80,751 per year for years 1990-1992, for vapor extraction only; $150,257 per year for years1993-1995, for vapor extraction with enhanced biological treatment; and $8,899 per year foryears 1996-2020, for cap maintenance.

• Present Worth CostsThe PNW associated with the above costs is estimated to be $3,299,000.

A summary of costs for Alternative 3 is presented in Table B2 of Appendix B.

State AcceptanceIn a letter from the WDNR, dated February 21, 1990, the WDNR expressed a preference forin-situ waste treatment options.


ALTERNATIVE 4: WASTE CONSOLIDATION WITH BIOLOGICAL TREATMENT.VAPOR EXTRACTION AND CAPPINGDescriptionThe major elements of this alternative may include:

• Institutional controls;• Waste consolidation;• In-situ biological treatment;

Vapor extraction of sub-waste soils;• Capping; and

System monitoring.

Placement of a RCRA hazardous waste outside the Area of Contamination (AOC) of aSuperfund site is forbidden under the LDRs. However, consolidation of waste within the AOCis permitted and boundaries would have to be negotiated and established prior to commencing



Page 6-30

any design or field work. The AOC for the Site includes Areas A, B, and C described in theRI, and is comprised of two regions; a region of maximum contamination (approximatelyArea A) and a region of minimum contamination (approximately Areas B and C).

Area A was the main disposal area (approximately 5.5 acres) which received most of themunicipal and industrial wastes. Areas B and C include scattered areas of refuse close to thesurface. No industrial waste was observed in test pits located in Areas B and C, and less than50 percent of the soil gas samples taken from Areas B and C contained contaminants.

Alternative 4 includes upgrading and retrofitting the existing disposal facility into a treatmentcell within the region of minimum contamination of the AOC. Treatment involvesrecirculation of leachate through the waste to promote biological activity. This facility wouldinclude a low permeability liner with a leachate collection system. To make best use of thelimited area available for this new facility, waste and soil will be removed from the proposedcell location and stored within the region of maximum contamination. The liner will beconstructed as close to the water table as allowed by Wisconsin regulations to maximize theavailable volume of the treatment cell.

Upon completion of the liner and leachate collection system, waste and soil moved duringupgrading, as well as non-native materials located within the region of maximumcontamination, will be moved into the new facility. Before placing material into the cell,descriptions and quantities of this material will be recorded and samples may be taken foranalysis to accurately characterize the waste. This information will be used to establishtreatment goals and design parameters. Some processing of the waste may be necessary, suchas shredding and screening of the larger materials, to facilitate an even distribution of theleachate through the waste during treatment. Any unexpected hazardous waste (such as drumsof solvents) discovered during excavation shall be characterized, removed from the Site anddisposed as per Federal and State regulations.

Site characterization activities to date have not identified any free solvent or other highconcentrations of volatiles in the waste materials that could be expected to create substantialvolatilization. Continuous monitoring for VOCs in the air will be conducted and excavation



Page 6-31

will be discontinued upon detection of excessive VOC concentration. The waste materialswhich contain high concentrations of volatile materials such as drums and areas saturated withfree liquid and which would be the likely source of excessive VOC emissions, if present, will becarefully removed and packaged or overpacked for off-Site disposal.

Once the disposal area has been upgraded, a high permeability cap will be placed over thewaste to allow infiltration of precipitation. Leachate will be collected and recirculated backthrough the waste, possibly using buried perforated pipes. Treatment of the waste will occurthrough biological decomposition either by aerobic or anaerobic processes. Leachate sampleswill be analyzed for a range of chemical parameters to assess treatment effectiveness.Enriching the leachate prior to recirculation with nutrients or process-specific microorganisms

^ may be done to improve treatment. Leachate generation may exceed the infiltration rate;therefore, a fraction of the leachate may have to be treated to meet ARARs and discharged toa surface water. Leachate generated from the treatment cell would be considered hazardous.Leachate treatment has been included in the cost estimate for this alternative.

The length of time for complete treatment will depend on the cleanup criteria established bythe U.S. EPA and WDNR, the level of initial contamination and the treatment's efficiency.The effectiveness of the leachate recirculation is dependent on the ability of the system tocreate a biologically favorable environment throughout the waste. Due to the heterogeneity ofthe waste, providing an even distribution of the leachate may be difficult.

The cavity left by the waste removal will be filled with soil followed by a low permeability cap.The cap will be constructed with adequate sideslopes to provide positive drainage away fromthe area. The sub-waste soils will be remediated using in-situ vapor extraction. The systemproposed for this alternative is similar to Alternative 3; however, the extraction wells would bescreened only in the sub-waste soils.

Monitoring under this alternative would be the same as proposed in Alternative 3.



Page 6-32


This alternative will adequately protect human health threats from direct exposure to wastes byproviding a barrier to contact with contaminants. Protection is also achieved for risks fromcontinued release of contaminants to groundwater by consolidating the source in a landfill withleachate collection. Contaminant degradation will also occur through biological treatment.Contaminants remaining in groundwater beneath the waste may continue to present a risk tohealth. Future contact with residual waste will be directly related to the likelihood of futuredevelopment of the landfill. This possibility will be reduced by implementation of institutionalcontrols. This alternative will also provide protection from risks related to VOC emissions.Adverse impacts to surrounding ecology are not considered appreciable at the Site. Duringconstruction and implementation of this alternative, additional risks may be incurred by thecommunity and workers, particularly while wastes are being excavated.

Compliance with ARARsProbable ARARs for Alternative 4 are summarized in Table 5. ARARs considered with thiscriterion are presented below:

• Compliance With Chemical-Specific ARARsSee Alternative 3.

• Compliance With Location-Specific ARARsLocation-specific ARARs for siting hazardous waste landfills (i.e., NR 181.51) may beapplicable to Alternative 4.

• Compliance With Action-Specific ARARsAction-specific ARARs identified relate to closure requirements, monitoring requirements,air emission regulations, landfill design requirements and LDRs.

For discussion of monitoring requirements, see Alternative 3.



Page 6-33

Only non-native materials (i.e., municipal and industrial waste) will be consolidated.Subwaste soils will remain in place and remediated using in-situ vapor extraction. Closureof the subwaste soils will meet WDNR solid waste closure requirements, NR 506.08(3)-(5),504.07, 516.07 WAC.

Air emission regulations will be met for particulate emissions during construction and off-gas treatment of the vapor extraction system.

The treatment cell will be constructed according to state and federal hazardous wastelandfill requirements, NR 181 WAC, 40 CFR 264.301.

The LDRs do not apply to Alternative 4, because waste will remain within the AOC,although the AOC would need to be negotiated and established prior to commencing anydesign or field work. Therefore, waste does not need to be pre-treated prior to depositionin the treatment cell.


- Magnitude of Residual RiskResidual risks remaining following implementation of this alternative are related primarilyto those associated with current groundwater contamination. Consolidation andcontainment of wastes in the landfill will prevent direct exposure to the contaminants andminimize the potential for further groundwater impacts. In addition, biological treatmentof wastes is anticipated to reduce risks associated with wastes by degrading contaminants.Treatment of excess leachate will be sufficient to meet State and Federal ARARsconcerning surface water quality. Health risks resulting from future direct contact withwastes will be directly related to the likelihood of future disturbance (e.g., future Sitedevelopment). This possibility will be reduced by implementing institutional controls.



Page 6-34

• Adequacy and Reliability of ControlsContaminants remaining in groundwater may require further remediation, which will bethe focus of the groundwater operable unit analysis.

This alternative is considered reliable in preventing further impact of waste on groundwaterand preventing direct exposure to wastes. Success has also been achieved for degradationof organic chemicals with biological treatment in controlled laboratory conditions.However, the efficacy of this technology is not as well established in actual field scaleapplications in sites with complex contaminant profiles.

The need for replacement of this remedy is not anticipated. Long-term managementconsiderations for this alternative include monitoring of groundwater quality andmaintenance of the integrity of the landfill cover.

Reduction in Toxicitv, Mobility or Volume Through TreatmentFactors considered with this criterion are presented below:

• Treatment Process Used and Materials TreatedTreatment processes used in Alternative 4 include in-situ biological treatment (or leachaterecirculation) and vapor extraction.

• Amount of Hazardous Materials Destroyed or TreatedLeachate recirculation could potentially reduce 100% of the VOC contamination, if theprocess is given enough time. Leachate recirculation will be used to treat the expected68,000 cu yd of waste. The approximate 112,000 cu yd of contaminated sub-waste soils willremain in place and be treated using vapor extraction.

• Degree of Expected Reductions in Toxlcity, Mobility or VolumeBiological treatment will reduce toxiciry, mobility or volume of the organic contaminants bybiologically degrading them to nontoxic compounds, such as carbon dioxide or methane.



Page 6-35

The area involved in remediation would be substantially greater than for the otheralternatives, because waste from the area of maximum contamination (approximately 5.5acres) would be moved to the area of minimum contamination (approximately 4.5 acres).The treatment cell and the contaminated subwaste soils (treated with vapor extraction)would therefore involve an area of approximately 10 acres and thereby increase thepotential for groundwater contamination.

• Degree to Which Treatment is IrreversibleBiological treatment is an irreversible process.

• Type and Quantity of Residuals Remaining After TreatmentA percentage of the generated leachate will be treated to surface water quality standards toavoid build-up on the liner. The reduction in toxicity, mobility or volume and vaporextraction is discussed in Alternative 3.


• Risks to Community During Remedial ActionsAdditional risks to the community are possible during implementation of this alternative,although air contaminant monitoring at the Site boundary may help identify unacceptablelevels and require follow-up actions during construction. Activities associated withconstructing a landfill will increase the vehicular accidents due to increased traffic in thearea.

• Risks to Workers During Remedial ActionsRemediation workers will likely be exposed to soil/waste material during theimplementation of this alternative, particularly during consolidation of wastes. Potentialroutes of exposure include direct contact with wastes and inhalation of VOCs and dusts.Exposure to contaminants can be minimized by the use of personal protective equipment.In addition to risks associated with contaminants, construction activities will present routinerisks of injury for remediation workers. The possibility of encountering drums containinghazardous materials may be hazardous for Site workers.



Page 6-36

• Environmental ImpactsAdditional risks to the environment are not anticipated during implementation of thisalternative.

• Time Until Remedial Action Objectives are AchievedProtection from direct contact with soils/waste will occur immediately followingimplementation of the alternative. Continued contaminant impact on groundwater fromwastes and sub-wastes and sub-waste soils will also be reduced upon completion ofimplementation. However, site remediation may not begin for approximately 3 to 5 yearsafter design approval due to procedural and substantive requirements for characterizationand designing new treatment and disposal facilities and performing treatability studies.Time necessary to implement this alternative will be approximately between 10 and 20 yearsand is dependent on the ability of treatment system effectiveness.

ImplemcntabilityFactors considered with this criterion are discussed below:

• Technical FeasibilityEven though leachate recirculation is a fairly new technology, the process consists ofcommon technologies, including leachate extraction and irrigation. Modifying the processto include the addition of nutrients or microorganisms to the leachate prior to recirculationwould be straightforward.

• Administrative FeasibilityCooperation from the WDNR will be needed to expedite the landfill siting process soremedial activities may begin immediately. Also, coordination with WDNR will benecessary during remedial activities to determine when clean up criteria have been reached.Permits will be required for construction of a treatment cell.

• Availability of Services and MaterialsRequired services, materials and equipment are available to implement this alternative. Itis assumed that appropriate soils to construct the liner and cap can be obtained from aborrow source located within four miles of the Site.



Page 6-37

CostCosts applicable to this alternative are presented below:

• Capital CostsThe major capital costs of this alternative are the costs for waste consolidation, landfillconstruction, vapor extraction and closure. Capital costs are estimated to be $12,894,000.

• Operation and Maintenance CostsThe O & M costs of this alternative include leachate recirculation system maintenance,nutrient costs (if necessary), vapor extraction system supervision, off-gas monitoring andcap maintenance and monitoring. O & M costs are estimated to be $159,776 per year foryears 1990-1995, and $63,797 per year for years 1996-2020.

• Present Worth CostThe PNW associated with the above costs is estimated to be $14,129,000.




ALTERNATIVE 5: WASTE EXCAVATION WITH ON-SITE INCINERATION, VAPOREXTRACTION AND CAPPINGDescriptionThe major elements of this alternative may include:

• Institutional controls;• Excavation of waste;• Incineration of waste;



Page 6-38

• Vapor extraction of sub-waste soils;• Capping; and• System monitoring.

Institutional controls would include deed restrictions to limit future Site activities.

Excavation of waste and soils would be accomplished using standard engineering andconstruction practices and equipment. As part of the excavation process, the existing treeswould have to be removed and disposed, and a staging area for the untreated material andprocess equipment would be required. Conventional equipment, such as front-end loaders orbackhoes, and conventional unit operations such as screening, sorting and grinding apparatuswould be used to handle the material and to condition for treatment, as part of the feedpreparation stage. Large pieces of debris would be removed in the feed preparation processand must be disposed of either separately at an appropriate facility, or ground and returned tothe untreated material. Any unexpected hazardous wastes (such as drums of solvents)discovered during excavation shall be handled, characterized, removed from the Site anddisposed as per Federal and State regulations. Air emissions from excavation activities will becontrolled as described for Alternative 4.

A treatability study would be necessary prior to full scale treatment. This study would consistof two phases: source characterization and a test burn. Source characterization includesdetermining the chemical and physical composition of the waste. Additional sourcecharacterization has been proposed at the Site that will provide information on thecomposition of the waste. The inherent heterogeneity of the waste will make a thoroughdescription of the waste composition difficult.

Chemical information needed for process design includes the quantity and distribution oforganic compounds in the waste. "Hot spots" of organics will reduce destruction efficienciesby overloading the incinerator. Initial source characterization indicated highly concentratedregions of scrap vinyl which may need to be mixed with soil or other inorganic materials. Also,the presence of toxic metals, sulfur and halogens in the waste material must be known. Highconcentrations of volatile heavy metals will add to the difficulties in meeting air standards anddisposing of off-gas treatment residuals. Those heavy metals not volatilized will also contribute



Page 6-39

to the difficulties in disposal of the bottom ash. Sulfur and halogenated compounds in thefeed, such as the scrap vinyl, contribute to acid gas production which is removed duringscrubbing. High concentrations of this material could result in substantial scrubber costs.

Physical information needed for process design includes moisture content and size anddistribution of waste materials. A high moisture content in the waste will impact furnacedesign, fuel requirements, off-gas treatment systems and waste feeding. Based on the RI, thewaste is located in the unsaturated zone, and thus problems related to moisture content willprobably not be substantial. Large items such as refrigerators and boulders would need to bescreened and reduced to manageable size using a shredder or trammel mill before feeding tothe furnace. Mixing waste with high and low heating values may be necessary to achieve

L greater uniformity in the feed material.

An extensive source characterization is difficult due to the heterogeneity of the waste;therefore, a test burn would be necessary. The test burn would help determine processparameters for scale-up to a full scale incineration system.

For purposes of this discussion, it is assumed that the full scale system would be a mobile rotarykiln incinerator. Waste burns in a drum while being agitated as the drum rotates. Of thedifferent incineration technologies available, rotary kiln incineration is the most applicable toburning refuse. Fewer restrictions are placed on the feed characteristics of rotary kilns thanother incineration technologies; therefore, less processing of the feed material is required. An

\~s auxiliary fuel such as natural gas is necessary to maintain high enough temperatures to achieveadequate destruction of contaminants. Natural gas is available immediately adjacent to theSite.

Two types of ash will be generated from this system; bottom and fly ash. Bottom ash iscomprised of heavier inert material not collected as fly ash in the off-gas treatment system.Both waste streams may contain quantities of toxic metals that would make disposal difficult.Further treatment, such as solidification/stabilization, may be necessary prior to off-Sitedisposal.



Page 6-40

Off-gas scrubbers are used to remove acid gases and some particulates. The lack of a sufficientscrubber water source and sanitary sewer service for disposal of contaminated scrubber water isa potential problem for this remediation alternative. Scrubber water will be obtained byinstalling water supply wells into the sandstone upgradient of the Site. The spent scrubberwater will be treated, recirculated when possible, and then discharged to the stream southeastof the Site. Treated scrubber water will meet ARARs for surface water quality.

The excavation will be filled with soil followed by a low permeability cap. In-situ vaporextraction will be used to remediate the sub-waste soils. This technology is described inAlternative 3.

Monitoring under this alternative would be the same as proposed under Alternative 3.


This alternative will adequately protect human health threats from direct exposure to wastes.Protection is also achieved for risks from continued release of contaminants to groundwater byremoving and destroying contaminants. Contaminants remaining in groundwater maycontinue to present a risk to health. This alternative will also provide protection from risksrelated to VOC emissions. This alternative is not anticipated to result in adverse impacts onthe surrounding ecology. This alternative may present additional risks to the communityduring implementation through exposure to incinerator off-gases. Additional risks toremediation workers may also occur as a result of excavating wastes and handling treatmentresiduals.

Compliance with ARARsProbable ARARs for Alternative 5 are summarized in Table 5. ARARs considered with thiscriterion are presented below:



Page 6-41

• Compliance With Chemical-Specific ARARsSee Alternative 3.


• Compliance With Action-Specific ARARsAction-specific ARARs identified relate to excavation, closure requirements, incineration,monitoring, air emissions, discharges to surface waters and LDRs.

For discussion of closure requirements, monitoring and air emissions, see Alternatives 3and 4.

For this alternative, only non-native material (i.e., municipal and industrial waste) will beexcavated for treatment. The remaining soils will be treated using in-situ vapor extraction.

Incineration of waste will follow applicable State and Federal regulations, including NR181.45 WAC and 40 CFR 264 Subpart O.

Incineration is the best demonstrated available technology (BDAT) for the listed wastes,F003 and F005, reportedly disposed at the Site. However, treating wastes to meet LDRtreatment standards may not be necessary if a treatability variance is granted.


• Magnitude of Residual RiskResidual risks remaining following the implementation phase of this alternative are relatedprimarily to those associated with groundwater contamination. Incineration is anticipatedto destroy the organic chemical component of the waste which will eliminate continuedimpact of wastes or groundwater. Vapor extraction will reduce impact of contaminants



Page 6-42

remaining in the subwaste soils. Residual ash will not pose a risk as it will be disposed of ina licensed on-Site landfill, although treatment standards prior to disposal may apply (i.e., 40CFR Part 268).

• Adequacy and Reliability of ControlsContaminants remaining in groundwater may require further remediation which will be thefocus of the GCOU.

This alternative is considered reliable in destroying organic chemicals in waste andpreventing continued impact of sub-waste soils on groundwater.

v The need for replacement of this remedy is not anticipated. Long-term managementconsiderations for this alternative include monitoring of groundwater quality andmaintenance of the integrity of the landfill cover.


• Treatment Process Used and Materials TreatedTreatment processes included in Alternative 5 are on-Site mobile rotary kiln incinerationand vapor extraction. Incineration will be used to destroy volatile and semivolatile organiccontamination present in the waste materials. Vapor extraction will be used to remove

^-^ these same compounds from the sub-waste soils for treatment by either carbon adsorptionor flame.

• Amount of Hazardous Materials Destroyed or TreatedThe amount of waste to be incinerated is approximately 68,000 cu yds. The amount of sub-waste soils treated by vapor extraction is approximately 112,000 cu yds.

• Degree of Expected Reductions in Toxicity, Mobility or VolumeThe LDRs are applicable to the Site because F003 and F005 listed wastes were reportedlydisposed in the landfill. Therefore, excavated material may have to be treated to U.S. EPAstandards before the material may be land disposed. These standards are based onconcentrations obtainable when the BDAT is used. The BDAT for F003 and F005 waste is



Page 6-43

incineration; therefore, this technology should reduce the toxicity of the waste and satisfythe treatment requirements of the LDRs.

• Degree to Which Treatment is IrreversibleIncineration is an irreversible process.

• Type and Quantity of Residuals Remaining After TreatmentIncineration produces three residuals; bottom ash, fly ash and scrubber water. Both ashresiduals, after passing the LDR treatment standards, will be disposed in a RCRA licensedlandfill. Scrubber water, containing trace amounts of organic and inorganic compounds,will be treated on-Site and discharged to the stream southeast of the Site.

The reduction in toxicity, mobility or volume of institutional controls, capping, vapor extractionand monitoring is discussed for Alternatives 2 and 3.


• Risks to Community During Remedial ActionsAdditional risks to the community are not anticipated during implementation of thisalternative, provided off-gases from incineration do not exceed safe health-based levels.Activities associated with construction of this alternative will increase the potential for localvehicular accidents due to increased traffic in the area.

• Risks to Workers During Remedial ActionsRemediation workers will likely be exposed to soil/waste material during theimplementation of this alternative, particularly when transporting waste. This may alsooccur during the handling of incinerator ash and scrubbing water. Potential routes ofexposure include direct contact with wastes and inhalation of VOCs and dusts. In addition,workers may be exposed to incinerator off-gases. Exposure to contaminants can beminimized by the use of personal protective equipment. In addition to risks associated with



Page 6-44

contaminant exposure, risks of injury will rise with increased construction activities in thearea. The possibility of encountering drums containing hazardous materials duringexcavation activities may be hazardous to Site workers.

• Environmental ImpactsAdditional risks to the environment are not anticipated during implementation of thisalternative.

• Time Until Remedial Action Objectives are AchievedProtection from direct contact with soil/wastes will occur immediately followingimplementation of the alternative. Continued contaminant impact on groundwater fromwastes and sub-waste soils will also be reduced upon completion of this alternative.However, Site remediation may not begin for roughly three to five years after designapproval due to procedural and substantive requirements in siting and design of atreatment facility, obtaining air and water quality permits, and performing necessary testburns. Time necessary to implement this alternative will be one year.

ImplementabilityFactors considered with this criterion are discussed below:

• Technical FeasibilityMobile rotary kiln incinerators are a relatively common technology for treatment ofcontaminated waste and would be technically feasible to implement.

• Administrative FeasibilityIssues related to administrative feasibility include disposal of process residuals. Ash fromthe incinerator will be disposed of in a RCRA licensed landfill unless it fails to pass LDRconcentration requirements, in which case further treatment will be necessary. A WPDESdischarge permit will be required before treated scrubber water is disposed of in surfacewater.

• Availability of Services and MaterialsMaterials, services and equipment are available to implement this alternative. Largequantities of water will be needed for a scrubber, since no water supply exists on-Site.



Page 6-45

Water will be obtained from new wells installed upgradient from the Site.

The implementability of institutional controls, capping, vapor extraction and monitoring isdiscussed for Alternatives 2 and 3.

CostCosts applicable to this alternative are presented below:

Capital CostsThe major capital costs of this alternative are the costs for waste excavation, incineration,vapor extraction and Site closure. Capital costs are estimated to be $59,410,000.

• Operation and Maintenance CostsThe O & M costs of this alternative include system supervision, off-gas monitoring and capmaintenance and monitoring. O & M costs are estimated to be $80,751 per year for years1990-1995, and $8,899 per year for years 1996-2020.

• Present Worth CostThe PNW associated with the above costs is estimated to be $59,858,000.




MAL/BJC/vIr/WB/DWH[skb-601-30f]13452-MD

SECTION?COMPARISON OF ALTERNATIVES

In Section 6, the five alternatives were individually assessed against the nine evaluation criteria.In this section, a comparative analysis is .conducted to evaluate the relative performance ofeach alternative in relation to each of the nine criteria. The purpose of this comparativeanalysis is to identify the advantages and disadvantages of each alternative relative to oneanother, so the relative strengths (to be evaluated by the U.S. EPA and the WDNR) can beidentified. It is these strengths combined with risk management decisions made by the decisionmakers, that will serve as the rationale for selecting a preferred alternative and provide atransition between the RI/FS and a ROD.

OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENTAt present, a quantitative baseline risk assessment has not been performed for the Site. Thus,

V^ the nature and magnitude of potential human health and environmental threats have not beendetermined for "No Action" Alternative (1). The following is a qualitative comparison of theanticipated protectiveness of each alternative.

Alternative 1 (No Action) will not provide protection from risks associated with Sitecontaminants. Alternatives 2 through 5 will protect against risk associated with direct contactwith wastes by preventing exposure through capping, although direct contact with wastes in thefuture will depend on the likelihood of future Site development.

None of the proposed alternatives will provide protection from risks which may be associatedwith contaminants currently existing in groundwater. Existing groundwater contamination willbe addressed in the GCOU. Continued groundwater impacts from Site contaminants will bereduced by Alternatives 2 through 5. The greatest degree of protection will be provided byAlternatives 3 through 5, which are anticipated to prevent continued groundwater impact.Alternative 3, In-Situ Vapor Extraction, would provide substantially more protection fromexposure to the waste during implementation than Alternatives 4 and 5, because treatmentwould be in-situ and excavating the waste is unnecessary. Alternative 5, Waste Excavation withOn-Site Incineration, may pose added risks to the community and workers due to increased



Page 7-2

hazardous air emissions. Alternative 2 is considered somewhat less protective thanAlternatives 3 through 5. Additional threats to the surrounding ecology are not consideredappreciable for each alternative.

COMPLIANCE WITH ARARSAlternative 1 does not meet the state and federal landfill closure requirements. Groundwatermonitoring will not be part of this phase of the RI/FS; a groundwater monitoring plan will bepart of the GCOU. The LDRs may be in effect for Alternatives 4 and 5. Alternative 4 involvesconsolidating the waste within the area of contamination; therefore, the LDR treatmentstandards would not apply. Alternative 5 involves incinerating the waste to destroy thecontaminants. If the LDR treatment standards cannot be met because of the complexity of thecontaminated matrix, a treatability variance may be granted.

N»--'

LONG-TERM EFFECTIVENESS AND PERMANENCEResidual risks associated with direct contact with wastes will be reduced by each alternativethrough capping, which will prevent direct exposure to wastes. Alternatives 4 and 5 will reducethese risks to a further extent by degrading contaminants in wastes. Risks associated withdirect contact with waste materials as a result of future Site development will be minimized byalternatives through implementation of institutional controls.

Residual risks associated with contaminated groundwater were considered greatest forAlternative 2, because vapor extraction of subwaste soils was not a component of this

\^s alternative. Alternatives 3 through 5 provide the lowest residual risks from groundwaterexposure.

Preliminary remediation goals have been developed for contaminants in wastes by assumingthat exposure to contaminated groundwater and direct exposure to waste may occur. Thepreliminary clean-up levels, as well as a detailed description of the methods used to derivethem, are presented in Appendix C.

Alternatives 1 and 2 will not be effective in achieving preliminary clean-up levels, becauseactive responses to remove contaminants are not components of these alternatives.Alternative 3 is anticipated to be effective in achieving clean-up levels for volatile chemicals,



Page 7-3

but will not directly address chemicals with low volatility (e.g., phenols and barium); however, aportion of semivolatile organics will be reduced through vapor extraction. Furthercontaminant characterization of wastes will likely show that concentrations of manycontaminants are below the preliminary clean-up levels.

Alternative 4 is anticipated to be effective in achieving preliminary clean-up levels throughbiological degradation. However, the efficiency of biological treatment in the degradation oforganic constituents of concern is not certain. Alternative 5 is anticipated to be effective inachieving preliminary clean-up levels through contaminant destruction (incineration). Each ofAlternatives 2 through 5 are anticipated to require system monitoring and maintenance of theintegrity of the landfill cover materials.

REDUCTION IN TOXICITY. MOBILITY OR VOLUME THROUGH TREATMENTAlternatives 3 through 5 remove or destroy the contamination at the Site. However, since it isassumed that much of the contamination may have leached from the waste into the subwastesoils beneath the waste, in-situ vapor extraction, proposed in Alternatives 3 through 5, willremove the FOQ3 and F005 contamination. With in-situ vapor extraction, off-gas treatmentwith carbon adsorption and regeneration by incineration, may be used to destroy thecontaminants.

Alternative 4 uses leachate recirculation in the waste to promote biological degradation of thecontamination. Reduction of the contamination down to desired levels may be difficult due tothe uncertainty of biological processes. During treatment, the waste will be within a RCRA-type landfill where migration of contaminants into the groundwater will be reduced.

Alternatives 1 and 2 do not provide treatment of either the waste or the subwaste soils.However, Alternative 2 does provide a low permeability cap to reduce the migration potentialof the contaminants into the groundwater.

SHORT-TERM EFFECTIVENESSAlternatives 4 and 5 will require the longest time to permit due to the procedural andsubstantive requirements to site new disposal and treatment facilities. At least one, and as



Page 7-4

many as two to three years, may be required to secure air and water quality discharge permits,and perform the necessary treatability studies and test burns. These steps would likely requireseveral years to complete before a full scale system would be operational.

Additional risks posed to remediation workers and the community during the implementationphases of the remedies were anticipated to be greatest for Alternative 5 and related topotential exposure to incinerator off-gases. However, these risks are anticipated to be lowprovided monitoring of air contaminants at the Site boundary reveal acceptable levels.Alternatives which required excavation of Site wastes (Alternatives 4 and 5) may pose thegreatest potential risk to remediation workers via direct exposure to wastes, dusts and VOCs.However, the levels of potential contaminant exposure to remediation workers could beminimized by the use of personal protective equipment in each alternative. Alternatives 1, 2and 3 are anticipated to pose minimal risks to remediation workers and the community.Additional risks to the surrounding ecology were not considered appreciable for eachalternative.

IMPLEMENTABILITYAlternatives 1 and 2 are the easiest to technically implement compared to the other threealternatives. The most difficult alternative to implement would be Alternative 5. Difficultiesassociated with this alternative include accessing a supplementary fuel source on-site, disposingof the ash, supplying sufficient water needed for the scrubbers, and treating and disposing thecontaminated scrubber water. Alternatives 3 and 4 would both be relatively straightforward toimplement technically.

Alternatives 1 and 2 may be administratively difficult to implement, because they may not beacceptable to the agencies due to the lack of treatment. Alternatives 3 and 4 will needcoordination with the agencies to establish remediation criteria. Alternatives 4 and 5 mayrequire a wastewater discharge permit for discharging treated leachate or scrubber water to asurface water.

Alternative 1 does not involve tasks which require materials or services; therefore, it is theeasiest to implement of the five alternatives from the standpoint of availability of services and



Page 7-5

materials. Alternatives 2 through 4 require services and materials that should be available. Itis assumed that appropriate material to perform capping could be obtained from a borrowsource located within four miles of the Site. For Alternative 5, materials and services areavailable, but their availability is more restricted than the other alternatives.

COSTCosts summarized here are presented in more detail in Appendix B.

Alternative 1 is the No Action option and involves no direct monetary costs.

Alternative 2 includes containment and involves a capital cost ranging from $1,579,000 to$2,751,000 (depending on which cap option is selected), O & M costs of $8,899, and a PNWranging from $1,716,000 to $2,224,000.

Alternative 3 includes in-situ vapor extraction and capping, and involves a capital cost of$2,679,400, O & M costs ranging from $150,257 to $8,899, and a PNW of $3,299,000.

Alternative 4 is the biological treatment, vapor extraction and capping option, and involves acapital cost of $12,894,000, O & M costs ranging from $159,776 to $63,797, and a PNW of$14,129,000.

Alternative 5 includes waste excavation with on-site incineration, vapor extraction and capping,and involves a capital cost of $59,410,000, O & M costs ranging from $80,751 to $8,899, and aPNW of $59,858,000.

STATE ACCEPTANCEIn a letter from the WDNR, dated February 21, 1990, the WDNR expressed a preference forin-situ waste treatment options.

COMMUNITY ACCEPTANCEThis criterion will be addressed in the ROD after public comments on the FS are received.

MAL/BJC/vlr/WB/DWH/GEAfskb-601-30g]13452-MD

8

SECTION 8REFERENCES

Driscoll, F. G., 1986. Groundwater and Wells, 2nd ed. Johnson Division, St. Paul.

Hutzler, N.J., Murphy, B.E., Gierke, J.S. State of Technology Review Soil Vapor ExtractionSystems, Michigan Technological University, August 1988.

Patterson, G. L., 1985. Investigation of the Groundwater Conditions at the Hagen LandfillSite, Stoughton, Wisconsin, U.S. Geological Survey.

Verschueren, K., 1983. Handbook of Environmental Data on Organic Chemicals, 2nd ed., VanNostrand Reinhold Co., New York.

Warzyn Engineering Inc., 1990. Technical Memorandum - Number 2, RemedialInvestigation/Feasibility Study, Hagen Farm Site, Warzyn Job No. C13452.

Warzyn Engineering Inc., 1989. Alternative Array Document, RemedialInvestigation/Feasibility Study, Hagen Farm Site, Warzyn Job No. C13452.

Warzyn Engineering Inc., 1989. Technical Memorandum - Number 1, RemedialInvestigation/Feasibility Study, Hagen Farm Site, Warzyn Job No. C13452.

Warzyn Engineering Inc., 1988. Site Evaluation Report, Hagen Farm Site, Stoughton,Wisconsin, Warzyn Job No. C13114.

Warzyn Engineering Inc., 1982. Hagen Property, Hydrogeologic Investigation, Stoughton,Wisconsin, Warzyn Job No. C10579.

MAL/vlr[skb-601-30i]13452-MD

Table 1

EP Toxicity and Flamnabillty Test ResultsComposite Drill Cuttings

Hagen Farm SiteStoughton, Wisconsin

Lab No. Results Maximum*Sample Description (mg/L) Concentration (mq/L)

Flashpoint (°F) <200

EP Tox Metals:

Arsenic 0.003 5.0

Barium 0.80 100.0

Cadmium 0.03 1.0

Chromium O.05 5.0

Lead 0.76 5.0

Mercury <0.0002 0.2

Selenium <0.002 1.0

Silver O.01 5.0

Method Reference: EPA-600, "Methods for Chemical Analysis of Water andWastes," March 1983.

* Maximum concentration of contaminants for characterization of EP toxicity,from Wisconsin Administrative Code, Chapter NR 181.14, 5a.

PFJ/vlr/AJS[vlr-400-21a]]13452.74

TABLE 2

Source Characterization SunmaryAnalytical Results of Refuse Samples

Hagen Farm FSConcentration

Compound

Inorganic (mg/kg)AluminumArsenicBariumCadmiumCalciumChromiumCobaltCopperIronLeadMagnesiumManganeseMercuryNickelPottasiumSodiumVanadiumZinc

Semivolatlies (ug/kg)1,4-DichlorobenzeneNaphthaleneDiethylphthalateDi-n-ButylphthalateFluorantheneButylbenzylphthalatebis(2-Ethylhexy1)PhthalateDi-n-Octyl PhthalatePhenanthreneUnknown Semivolatiles(2)

GeometricMean

7,6903.196.81.3

23,10010.729615.6

11,10024.4

14,8003290.1221.6659

1,55018.474.8

280464813067220

3,41032053

2,120

Number ofU)Maximum Samples

13,0004.6

2,5501.8

43,90016296160

15,900107

26,5006600.42387

1,1404,92029.8499

280*46*48*69067*

18,000120,0005,300

67*1,261,985

10101081010110101010106101021010

21131897210

TABLE 2(Continued)

Page 2 of 2

Concentration

Compound

Pesticide/PCB's (ug/kg)Dieldrin4,4'-DDE4,4'-DDD4(4'-OOTPCB-1242PCB-1248PCB-1254

GeometricMean

11.618.211.919.2104.8338222

Maximum

11.618.212819.2284338222

Number ofU)Samples

Notes

U) Out of 10 total sampling locations (Test Pits RS01 to RS10), excludingRS08 duplicate.

(2) Sum of tentatively identified compounds.

* Indicates concentration is below method quantitation limit. Value isestimated.

JGV/vlr/PFJ[vlr-400-21]13452.74-MD

TABLE 3

Groundwater Quality SuimaryVOCs and Semi-VOCs at Source Characterization Wells

Hagen Farm FS

Concentrations (ug/L)

No. Wells WithMaximum AverageU) Detection!?)

VOCs

Semi-VOCs

2-Butanone 4,400,000 2,620 3Toluene 20 20 1Ethyl benzene 2,400 99 3Xylenes 35,000 1,066 5Tetrahydrofuran 630,000 5,695 5

Benzoic Acid 29,000 780 22 ,4-Dimethyl phenol 330 153 24-Methylphenol 6,100 243 2Phenol 5,600 3,816 11,4-Dichlorobenzene 10 10 1Benzyl Alcohol 26 26 1Bis(2-Chloroisopropyl) Ether 19 19 1Naphtalene 8 8 14-Chloro-3-Methylphenol 7 7 1Diethylphthalate 5 4.5 1Bis(2-Ethylhexy1)Pbthalate 34 18 3Di-n-Octyl Phthalate 5 5 1

Notes

(1) Geometric averages for positive detects at each well are calculated forduplicate analysis and multiple rounds, where applicable. Geometric averagewere then calculated using one single or, where more than one sample wasobtained from a given well, average value for each well (5 wells).

(2) Out of five wells. Some wells had more than one sample analyzed asindicated in (1).

PFJ/vlr/JGV[dlk-402-35]13452.74-MD

cTABLE 4

AIR QUALITY SAMPLING RESULTSHAGEN FARM SITE

STOUGHTOH, WISCONSIN

HF-AA-01-01Volume = 24338 CC


COMPOUND (1)

AcetoneBenzeneBromodichloromethaneBrocnoformBronmne thane2-ButanoneCarbon TetrachlorideChlorobenzeneChlorodi bromomethaneChloroethaneChloroformChloromethaneHexaneHeptane1.1-D i chIoroethane1.2-Dichloroethane1.1-Dichloroethenetrans-1,2-DJchloroethene1.2-Dichloropropanecis-1,3-Dichloropropenetrans-1,3-DichloropropeneEthylbenzenetn-Di Chlorobenzenep-Dichlorobenzeneo-DichlorobenzeneMethylene ChlorideStyrene1,1,2,2-TetrachloroethaneTetrachloroetheneToluene1.1.1-Trichloroethane1.1.2-TriChloroethaneTrichloroetheneTrichlorofluoromethaneo-Xylenem,p-XylenesVinyl ChlorideIsopropylbenzene

DETECTIONLIMIT

(Total ng)

26191721282014162819161521191818161615161720221920192113121215IB121622471620

Totalng mg/M3 LO

230 9.5e-0352 2.1e-03

210 8.6e-03

8 3.36-04

20 8.2e-0421 8.66-04

12 4.9e-04

8600 3.5e-016 2.56-04

16 6.6&-0496 3.96-0377 3.2e-03

10 4.1e-041400 5.8e-0217 7.0e-0420 8.2e-04

Totalng mg/M3 LO

82 3.0e-0325 9.1e-04

120 4.4e-03

540 2.0e-02

27 9.8e-04

26 9.4e-04

6 2.2e-04

4400 1.6e-014 1.5e-04

8 2.9e-04210 7.6e-0333 1.2e-03

8 2.9e-04 J2900 1.1e-01 E22 8.0e-04 J44 1.6e-03 J


Totalng mg/H3 LQ

18 1.0e-03

110 6.16-03

3 1.7e-04

13 7.26-046 3.3e-04

2.Be-04

1700 9.5e-022 1.1e-04

13 7.2e-0460 3.3e-0324 1.3e-03

5 2.8e-04970 5.4e-026 3.3e-049 5.0e-04


Totalng mg/M3 LQ

27 Lie-03

561

167

2.3e-034.1e-05

1.2e-04

6.6e-042.9e-04

12 4.96-04

3 1.2e-04

1800 7.4e-025 2.0e-04

10 4.1e-04 J79 3.2e-0340 1.6e-03

6 2.5e-04 J450 1.8e-02 E13 5.3e-04 J22 9.0e-04 J

1 J

(1) All of the samples were analyzed for thelist above. If no value reported, the compounduas not detected.

CAU/SGU/GEA

TABLE 4AIR QUALITY SAMPLING RESULTS

KAGEN FARM SITESTOUGHTON, WISCONSIN

COMPOUND (1)

AcetoneBenzeneBromodichloromethaneBromoformBromomethane2-ButanoneCarbon TetrachlorideChlorobenzeneCh torod i brocnomethaneChloroethaneChloroformChtoromethaneKexaneHeptane1.1-Dichloroethane1.2-Oichloroethane1.1-0 i ch Loroethenetrans-1,2-Dichloroethene1.2-DichIoropropanecis-1,3-Dichloropropenetrans-1,3-DichLoropropeneEthylbenzenem-D i chlorobenzenep-D i chIorobenzeneo-DichlorobenzeneMethylene ChlorideStyrene1,1,2,2-TetrachIoroethaneTetrachloroetheneToluene1.1.1-Trichloroethane1.1.2-TrichloroethaneTrichloroetheneTrichloroftuoromethaneo-Xylenem,p-XylenesVinyl ChlorideIsopropylbenzene

DETECTIONLIMIT

(Total ng)

2619172128201416281916152119181816161516172022192019211312121518121622471620


Totalng mg/H3 LO

43 1.1e-03

84 2.2e-03

6 1.6e-04

22 S.Se-0412 3.1e-04



METHOD BLANKVolume =

Totalng mg/H3 LQ

40 7.4e-0449 9.0e-04

49 9.0e-042 3.7e-05 J

6 1.1e-04 J

10 1.8e-04 J

Totalng mg/M3 LQ

Totalng mg/M3 LQ

120 4.86-0342 1.7e-03

58 2.3e-031 4.0e-05

5 2.0e-04

13 5.2e-0410 4.0e-04

16

4

35006

159762

104801828

4.2e-04

1.0e-04

9.2e-021.6e-04

3.96-042.5e-031.6C-03

2.6e-041.3e-024.7e-047.3e-04

J

J

SJ

JEJJ

18

14

48006

139369

114502131

3.3e-04

2.6e-04

8.8e-021.1e-04

2.4e-041.7e-031.3e-03

2.0e-048.3e-033.9e-045.7e-04

J

J

SJ

JEJJ

10

19

580012

76158

74401619

4.0e-04

7.5e-04

2.3e-014.8e-04

2.8e-042.4e-032.36-03

2. Be- 041.7e-026.3e-047.5e-04

J

J

SJ

J

JEJJ

1 2.6e-05 3.76-05 1 4.06-05

(1) Alt of the samples were analyzed for thelist above. If no value reported, the compoundwas not detected.

CAU/SGU/GEA

cTABLE 4

AIR QUALITY SAMPLING RESULTSHAGEN FARM SITE

STOUGHTON, WISCONSIN

COMPOUND (1)

AcetoneBenzeneBromodichLoromethaneBromoformBromomethane2-ButanoneCarbon TetrachlorideChlorobenzeneChlorodibromomethaneChIoroethaneChloroformChlorotnethaneHexaneHeptane1.1-Dichloroethane1.2-Dichloroethane1.1-Dichloroethenetrans-1,2-Dichloroethene1.2-Dichloropropanec i s-1,3 -D i chIoropropenetrans-l,3-DichloropropeneEthylbenzenem-D i chIorobenzenep-Dichlorobenzeneo-D i chIorobenzeneMethylene ChlorideStyrene1,1,2,2-TetrachloroethaneTet rachIoroetheneToluene1.1.1-Trichloroethane1.1.2-TrichloroethaneTrichloroetheneTrichlorofluoromethaneo-Xylenem,p-XylenesVinyl ChlorideIsopropylbenzene

DETECTIONLIMIT

(Total ng)

2619172128201416261V16152119181816161516172022192019211312121518121622471620

HF-LA-LH01-01Volume = 4079 CC

HF-LA-LH01-91Volume = 3884 CC

HF-LA-TB01-01Volume =

METHOD BLANKVolume =

Totalng mg/H3 LQ

Totalng mg/M3 LQ

3300 8.1e-011300 3.2e-01

8900 2.2e+00

1800 4.6e-011600 4.1e-01

11000 2.8e+00

20 4.9e-03

4900 1.2e+00 S

7 1.7e-03 J

7800 L9e+00 S

490 1.2e-0l E80 2.0e-02

16 3.9e-0316000 3.9e+00 S1200 2.9e-01 E

Totalng

32

mg/M3 LQTotalng mg/M3 LQ

J

230 5.6e-02190 4.7e-022600 6.4e-0112000 2.9e+007200 1 .8e+00

SSS

220 5.7e-02170 4.4e-02

12000 3.1e+009100 2.3e*00

SS

30

20 5.1e-03

42 Lie-02

9400 2.4e+00 S

12 3.1e-03 J

5300 1.4e+00 S

950 2.4e-01 E50 1.3e-02

27 7.0e-038200 2.1e+00 S2600 6.7e-01 S

140 17

860

11

(1) All of the samples were analyzed for thelist above. If no value reported, the compoundwas not detected.

CAU/SGU/GEA

r

Table S

Summary of Probable ARARsSource Control Operable Unit Feasibility Study

Hagen Farm Site

Chemical-Specific_____ARARs

State:NR 140 UAC -Groundwater QualityStandards

Alternative 1No Action

A; Will not be met.Alternative addressessource control only.

Alternative 2Capping

See Alternative 1,

Alternative 3In-Situ Vapor

Extraction & Capping

See Alternative 1.

Alternative 4Waste Consolidation

w/ BiologicalTreatment, Vapor

Extraction £ Capping

See Alternative 1.

Alternative 5Waste Excavation

w/ On-Siteincineration, Vapor


See Alternative 1.

NR 445 UAC - Air NI NIEmission Standards

Federal:none

Location-Specific Alternative 1 Alternative 2____ARARs____ ____NpÂction ____Chapping

State:NR 181.51(2)(i) WAC NI NI- Facility LocationCriteria

Federal:none

NOTES: NI Not identified as an ARAR for this alternative,A Applicable.RA Relevant and Appropriate.

A; Can be met withavailable off-gastreatmenttechnologies.


Extraction

See Alternative 3. See Alternative 3.

NI




NI


w/ On-SiteIncineration, Vapor


A; Incinerationsystem wi11 meetapplicableregulations.

cTable 5 (cont.)

Summary of Probable ARARsSource Control Operable Unit F e a s i b i l i t y Study

Hagen Farm Site

Action-Specific____ARARs

State:NR 181.44(12)(a)4UAC - Removal ofcontamination tobackground levels.

NR 181.44(13),506.08(3)-(5),504.07, 516.07 UACLandfill closurerequirements.

NR 181.45 UAC -Incinerationstandards.

NR 181.49(5), 508UAC - Groundwaterand leachatemonitoringstandards.

NR 400-499 UAC -emissionregulations.

NR 500-530 UAC -Solid wasteregulations.

Air


NI

A.RA; Site was notproperly closed anddoes not presentlymeet closurerequirements.

NI

A.RA; Groundwatermonitoring will beperformed uponcompletion of thegroundwater controloperable unit.

NI

NI


NI

A,RA; Site will becovered with approvedcap.

NI

See Alternative 1-



NI

See Alternative 2.

NI

See Alternative 1,



Extract ion & Capping

NI

RA; Subwaste soilsw i l l be covered withapproved cap.

NI

See Alternative 1.

NI A; Off-gasses will betreated as perregulations.

NI

A; Participate andVOC emissions w i l lcontrol led duringconstructionactivities.

NI

be




A; Only non-nativematerials w i l l beexcavated.

See Alternative 4.

A; Incinerationsystem w i l l meet allapplicableregulations.

See Alternative 1.

See Alternatives 34.

NI

NOTES: NI Not identified as an ARAR for this alternative.A Applicable.

RA Relevant and Appropriate.

Table 5 (cont.)Summary of Probable ARARs

Source Control Operable Unit Feasibility StudyHagen Farm Site

Action-SpecificARARs

Federal:40 CFR 60 - Airemissions standardsfor new stationarysources.

40 CFR 264 Subpartfi, 40 CFR 264.310(a) and (b) -Closure of hazardouswaste disposalfacilities.

40 CFR 264.301 -Landfill designrequirements.40 CFR 264 Subpart 0- IncinerationRegulations.

40 CFR 268 -DisposalRestrictions.

Land


NI

A; Site was notproperly closed anddoes not presentlymeet RCRA closurerequirements.

NI

Nl

NI


RA; Cap Options 2a &2b are not incompliance with aRCRA cap.

NI

NI


Extraction &__C_apping

NI

RA; Cap Option 2cwould not beconsideredappropriate.

NI

Nl

A; Treatment of off-gas residues may benecessary before landdisposal.

Alternative 4Waste Conscil idat ion


Extraction I Copin

NOTES: NI Not identified as an ARAR for this alternative.A Applicable.

RA Relevant and Appropriate.

RA; Subwaste soilswil 1 be covered withapproved cap.

RA; Treatment cellwill meet all RCRArequirements.

NJ

A; Waste will remainwithin Area ofContamination and,therefore, LDRtreatment standardsdo not apply.




A; Incineration systemw i l l meet applicableregulations.

See Alternative 4.

NI

A; Incineration systemw i l 1 meet allapplicableregulations.

A; Waste wil1 betreated to LDRtreatment standards.Ash, if characteristicfor metals, shall betreated further.

HAL/vlr/GEA[vlr-400-15]13452.74

SITE LOCATIONfc'a.-

LEGENrj——800—— PIEZOMETRIC CONTOUR {CONTOUR INTERVAL IS 20 FEET)

................. GROUNDWATER DIVIDE

o 849 WATER WELL AND PIEZOMETRIC ELEVATION

NOTES1. REGIONAL PIEZOMETRIC SURFACE MAP WAS OBTAINED FROM U.S.G.S.

WATER-SUPPLY PAPER 1779-U PLATE 7 DATED 1965.

northSCALE: 1" = 10,000'

APP'06-^ DATE//- 7-^1113452 A2

WARZYN L PIEZOMETRICMAP

REMEDIALINVESTIGATION/FEASIBILITY STUDYHAGEN FARM,SITETOWN OF DUNKIRK, DANE COUNTY, WISCONSIN

O 0. O Oct

c-o 2c •«O fl

VEGETATEDTOP LAYER-

\,x 1 «/ ^ 6\ Ax-;

CLAY CAPPING LAYER w

GRADING LAYER(O'-IO'J

-EXISTING- SOIL COVER

WASTE

SCALE: 1" » 4'

WMRZYNSTRUCTURE OF CAP REPAIRPER NR 181.44 (12)

Drown

REMEDIAL INVESTIGATION ANDFEASIBILITY STUDYHAGEN FARM SITE

Revisions

13452 A3

5 =1-2

VEGETATEDTOP t AYFR _____ . —

"1HOVER LAYER-.-- <[

CLAY CAPPINGt AYER i

J. ^ ^/

COMMON EARTH

SAND DESICCATION LAYER

CLAY CAPPING LAYER

6<> i\ . *

CO1— <

OJ

esj

GRADING LAYEREXISTINGSOIL COVER

WASTE

** THE COVER LAYER WAS SPECIFIED AT 30 IN. AS A WORST CASE SCENARIOTO ADDRESS THE CONCERNS OF NR 504.07 (5).

SCALE: I11 = 4

WARZYMSTRUCTURE OF SUBTITLE D CAP (NR 500)PER NR 504.07REMEDIAL INVESTIGATION ANDFEASIBILITY STUDYHAGEN FARM SITE

Revisions Dot*5-«/-13452 A4

o V v, w6"\VEGETATEDTOP LAYER —— *

DRAINAGE *1 Avro ———————i_ri I t-i\

LOWERPERMEABILITYLAYER

( *-•*f COMMON EARTH «

^ SAND & GRAVEL DRAINAGE fu S6"-V. ,

M ^CLAY CAPPING LAYER S

'-LOWERCOMPONENT

— UPPER GRADING LAYERCOMPONENT (0'-16l)

-* —— TOPSOIL

FABRIC^ SAND BEDDING

* J r n 1 ML 1 1L\ MEMBRANE^-SAND BEDDING

-EXISTINGSOIL COVER

WASTE

* THE DRAINAGE LAYER WAS SPECIFIED AT 24 IN. TO MEET THE REQUIREMENTTHAT THE UPPER COMPONENT OF THE LOW PERMEABILITY LAYER BE LOCATED AT LEAST12 IN. BELOW THE MAXIMUM RECORDED DEPTH OF FROST WHICH WAS ESTIMATEDTO BE 36 IN.

SCALE: 1

WARZYNSTRUCTURE OF SUBTITLE C CAP (NR 181)PER NR 181.44 (13>REMEDIAL INVESTIGATION ANDFEASIBILITY STUDYHAGEN FARM SITE

Revisions

13452 A5

*7j FwaEwW » A*'\/ ~^f&CoSSS^nno^/l I ' ~

iaC'3^1*' -J**J.Aft-Tjl r - •«)«

LECTNO

northLATL HAGEN FARM SITE RI/FS

1!

1

^^tir2>

WA

RZ

I

i

}

ci

îi !

i \* 1

-4 ]j \* -

,,,,

il

z\ |

i|f|iSli

—<r

~iT" F16-jj )

Appendix A

Correspondence

January 10, 1990 letter from Mark Giesfeldt, Wisconsin DNR to Mr. Jae Lee, U.S. EPAregarding Alternatives Arrary Document comments.

January 22, 1990 letter from Mr. Jae Lee, U.S. EPA, to Ms. Dee Brncich, WasteManagement of North America, Inc., regarding meeting and agenda for February 1,1990 Site meeting.

February 2, 1990 letter from Mr. Jae Lee, U.S. EPA, to Ms. Dee Brncich, WasteManagement of North America, Inc., regarding Alternatives Array DocumentComments.

February 21, 1990 letter from Ms. Terry Evanson, Wisconsin DNR, to Mr. Jae Lee, U.S.EPA, regarding issues raised at February 1,1990 Site meeting.

June 25, 1990 memorandum from Mr. Mark Lovejoy, Warzyn Engineering Inc., toproject file regarding inserting information into Wisconsin DNR letter datedJanuary 10,1990.

MAL/vIr[sss-601-09]

State of Wisconsin \ DEPARTMENT OF NATURAL RESOURCESCtrroM D. B*«dny

BOX7921Mid/con, WTtcona/n 53707

January 10, 1990

Mr, Jae Lee, Remedial Project ManagerU.S. EPA Region VRemedial Enforcement and Response BranchMI/WI Section, 5HR-11230 S. Dearborn StreetChicago, IL 60604

SUBJECT: Hagen Farm RI/FS Source Control Operable Unit, AlternativesArray Document

Dear Mr. Lee:

This letter and attachments comprise our comments on the document titled,"Alternatives Array Document, Source Control Operable Unit, RemedialInvestigation/Feasibility Study, Hagen Farm Site" received by the Departmenton November 8, 1989 and prepared by Warzyn Engineering, Inc.

We have reviewed the document and determined which State regulations apply tothe proposed remedial actions for this project. To simplify our response, wehave stated the numbered alternative, whether it is applicable (A) or relevantand appropriate (RA), listed the Wisconsin Administrative Code reference andmade a preliminary identification of Standards/Requirements. This response isattached. We have also included comments on the Alternatives Array Documentand the proposed alternatives.

If you have any questions, please call Theresa Evanson at (608) 266-0941.

Sincerely,

Mark Giesferdt, P.E., ChiefBureau of Solid and Hazardous Waste ManagementEnvironmental Response and Repair Section

Attachments (3)

cc: Sue Bangert - SW/3 w/ attachmentsMike Schmoller - SD w/ attachmentsJack Dowden - Waste Management of North America, Inc. w/ attachments

-——>>Greg Asbury - Warzyn Engineering, Inc. w/ attachments/ T. C. Wright - The Oesup Group, Inc.

HAGEN FARM SITE ARARs

Alternative

1. No Action

A or RA* Code**

RA 181.49(5)

A 181

140, 503

149

506, 514516

Preliminary Identification ofStandards/Requirements

Identify degree and extent ofcontamination; Hazardous wastegroundwater monitoring requirements

Any waste material generated duringthe remedial investigation must behandled as hazardous

Groundwater Standards, monitoringand sampling frequency

Laboratories for testing groundwatersamples

Landfill closure requirements

2. Capping withOptional Ground-water diversionbarrier

RA

RA

181.49(5}

181.44(11)-(14); 181.42

181

504, 514516

506, 512

See #1 above

Hazardous waste landfill closure,monitoring, and long-term care;gas monitoring

Manage contaminated soil excavatedfor slurry wall construction ashazardous waste

Clay specifications, cover design,gas control, landfill closure

Clay borrow sources for landfillclosure

3. Waste/SoilExcavationwith On-SiteTreatment andDisposal

181.44(12)

181.45

Excavate contaminants to backgroundor close facility as a hazardouswaste landfill

Incineration of Hazardous Waste

RCRA landfill locational criteria

* A or RA - Applicable (A) or Relevant and Appropriate (RA)**Code «• Wisconsin Administrative Code, Chapter NR series

3. continued 181.44 -181.45,181.49

504, 506,512, 514

500 - 520

445

Hazardous waste disposal licensingprocess and standards

Waste handling during excavation andtreatment; closure/storagerequirements

Solid waste disposal licensingprocess, plan review and standards

Air emission limits

4. Waste/SoilExcavation withOff -s i teTreatmentand Disposal

RA

A

181.49(5) Hazardous waste groundwatermonitoring requirements

181 All rules concerning generation,management, treatment, transport,recycling and disposal of hazardouswaste

500 - 520 Excavation, treatment, closurerequirements of solid waste (see #3above); ash disposal

502 Scrap metal recycling, wastecollection and transport

400 - 499 Air emissions, treatment

5, In-situWaste/SoilTreatment

RA 181.49(5)

181

A

A

A

A

140

508

506,516

400

514

- 49

Degree and extent of groundwatercontamination; Hazardous wastegroundwater monitoring requirements

Any waste material generated duringimplementation must be handled ashazardous

Groundwater standards, monitoringand sampling frequency

Assess affects of remedy on air,land and water

Landfill closure requirements

Air emissions, treatment

4

HAGEN FARM NPL SITE

Comments on the Alternatives Array Document and Alternatives

Alternatives Array Document

p. 4-10,11 The table titled "Technologies Carried Through TechnologyScreening" should include several additional technologiesunder #3, Direct Waste/Soil Treatment (On-Site). Theseinclude: dechlorlnation/oxidation, solvent extraction, soilwashing/fixation and rotary kiln.

p. 4-7 to The discussion of In-Situ Waste/Soil Treatment, Physical,4-10 does not appear to be complete. Solvent extraction and

stabilization/solidification are not discussed in thissection, but solvent extraction is retained forconsideration in developing alternatives.

p. 5-6, 5-7 Both pages contain references to dredged sediments or"sediments that may be removed from water bodies". Nodiscussion exists of where such sediments may originate.The small pond 1/2 mile south of the site is unlikely tohave substantial sediment contamination from the VOCs foundin the groundwater and, to my knowledge, the sediment in thepond has not been tested.

Remedial Action Alternatives

Alternative #1, No Action

Chapters NR 140 and NR 508 are legally applicable to this facility regardlessof the alternative under consideration, including "no action". Therefore,groundwater monitoring and the actions required to address the standardsexceedances are always required. Because Ch. NR 140 standards exceedancesexist at the site, a "no action" alternative would not meet the legallyapplicable state standards.

For the future groundwater operable unit, Chapter NR 181.49(5) groundwatermonitoring requirements (RCRA consistent) are relevant and appropriate to thesite, but are not legally applicable under a "no action" alternative.

Because the facility is an abandoned landfill that has never been properlyclosed, closure under NR 506.08(3) - (5), 506.07(5), 514.07, and 516.07 arelegally applicable, therefore a "no action" alternative would not meet thisstate standard either.

Attached to this letter is a copy of the 103c Notification submitted to ERA byUniroyal, Inc. in June, 1981 stating F003 and F005 solvents were disposed of

at Hagen Farm. Therefore, the "mixture" and "derived from" rules apply towaste and debris from this site. s. NR 181.12(l)(b)6 excludes mixtures ofF003 wastes and solid wastes from the hazardous waste rules provided themixture does not exhibit the characteristic of ignitability. There is noexemption or exclusion from the hazardous waste rules for F005 mixtures. Theonly possible "out" from hazardous waste regulation is if the waste materialdoes not contain any of the solvents listed in s. NR 181.16 - Table II forF005. Therefore, the requirements of Ch. NR 181 are applicable to any wastesgenerated in the remedial investigations. This includes soil cuttings andgroundwater from bailing and sampling wells. We understand that any wasteremoved from the site or moved to another location on the site would have tomeet the applicable land disposal restriction treatment standards. TheDepartment is not yet authorized to implement LDRs in Wisconsin, however, weare prepared to assist in making this determination.

Alternative #2, Capping with Optional Groundwater Diversion Barrier

Because of the NR 140 groundwater exceedances, the multi-layer soil coverspecified in Ch. NR 504.07 is applicable to this facility. Plans for thecover system should follow s. NR 514.07 requirements for engineering plans anda design report. Documentation of the completed cover system should follow s.NR 516 construction documentation requirements for report preparation, testingand plans. Both s. NR 514.05 and Ch. NR 516 are legally applicable to thisfacility.

However, due to the acceptance of listed hazardous waste, s. NR 181.44(13)Cover Standards (RCRA consistent) are relevant and appropriate and is thesystem that we support being installed at the site. Please note that our s.NR 181.44(12) existing facility cover standards are less stringent than thesolid waste cover requirements specified above, while the new facility coverstandards under s. NR 181.44(13) are based on, but slightly more stringentthat the RCRA ss.264 cover standards.

OA more complete design and groundwater modeling would have to be performedbefore we can adequately comment on the optional groundwater diversionbarrier. However, if the soil removed from the excavated trench iscontaminated, Ch. NR 181 rules regarding handling and disposal of hazardouswaste would be applicable. This could significantly affect using the soil asa backfill in the slurry trench. However, if the material is managed on-sitein a manner not constituting redisposal/placement, then the requirementsapplying to soil management from the slurry trench may be minimal.

Alternative #3, Waste/Soil Excavation with On-Site Treatment and Disposal

Because the facility accepted listed hazardous waste, any excavation of thewaste would subject the removed waste to the state hazardous waste rules (Ch.NR 181). Because s. NR 181.44(12)(a)4 is applicable, contaminants would needto be removed to background or the facility would have to be closed as ahazardous waste landfill. Ch. NR 181 would also be applicable to all on-sitedisposal of treated waste.

Incineration of waste would be subject to the requirements of NR 181.45. Allair emissions from waste/soil remediation at the facility would have to meetthe emission limits set forth in Ch. NR 445. If incineration or thermaldestruction is used to remediate the soil, the thermal treatment unit wouldneed an air pollution control permit. Other remediation techniques may alsorequire an air permit. The following table indicates the control levels thatmust be achieved for compounds found at the site:

Table 1

Allowable Air Emissions

Allowable Ambient Target EmissionCompound Air Concentration Rate flb/hr)

(ug/m3)

Tetrahydrofuran 14,160 49.1

Xylenes 10,440 36.2

Ethyl benzene 10,440 36.2

Toluene 9,000 31.2

2-hexanone 480 1,66

2-butanone & acetone N/A N/A

Benzene If emissions exceed 300 Ib/yr, emissions must becontrolled to the lowest achievable emission rate.

Alternative #4. Waste/Soil Excavation with Off-Site Treatment and Disposal

The performance based goal of the alternative should be clean closure withbackground/health based limits used for contaminant removal. Ch. NR 181 wouldbe applicable to all waste generation, management, treatment, transport,recycling and disposal of generated residues. The solid waste rules (Ch. NR500 - 520) would be applicable to excavation, treatment, and closureactivities at the site. Air management rules (Ch. NR 400 - 499) would beapplicable during excavation of the waste.

An optional element of Alternative #4 is to haul incinerated nonhazardoussoils back to the site for use as fill. Because listed hazardous wastes weredisposed of at the site, the ash would have to be delisted under the RCRAprogram before it could be considered nonhazardous. (The Department'sHazardous Waste Program generally does not make delisting determinations -that has been deferred to ERA under our rules.) If the ash were delisted, it

would be considered a solid waste and Ch. NR 500 - 520 would be applicable toash placement back on-site.

Alternative #5. In-Situ Waste/Soil Treatment

Of the four technology options listed, vapor extraction and flushing areunlikely to substantially reduce the contamination at the facility andflushing may be detrimental to the groundwater contamination. We would notsupport the implementation of these technologies unless further design andmodeling could show their overall effectiveness and that the groundwater underthe facility could be completely controlled.

State standards relating to groundwater, solid waste landfills and airemissions would be applicable to this option. Hazardous waste groundwatermonitoring requirements would be relevant and appropriate, but not legallyapplicable.

AjurtcyW»thiftflmn DC 20460

7fc v initial notification information <iic quired by Sec;ion 103IC) of tn* Compte-h* sivo environmental Response, Compcn-s.- on. and Liainhty An of l&80artd mustbe maileJ by June SK 19b1.

r*t***« lyp-c or print in ink. H you .....aoditionai space, use separate »h«t* ofpaper indicate the letter of the itemwhich applies. AI)G2019^

- 0 7 (Pi son Required to Notify:Enter the name and address of tne personOf ^rganizaiion required to notify.

UNIROYAL. Inc.

World Headquarters

Dry Middlebury CT 067M9

Si i Location:Enidr the common name (if known} andactual location of the site.

.it Orrln Ha.gcn Fara

County Trunk A

Stouehton Dane 53589

Person to Contact:Cr -f thu name, title (if applicable), andbu nusi telephone number of the personto contact regardng informationsuv tted on this form.

f i f n » n d T . t i c i Robert C* Nlles, Director Environmental Cor.trol

-2387

Dates of Waste Handling:Enl-r the years thî you estimate wastetrc ment, storage, or disposal began anden id at the site.

Fi*m(Y*»f) Unknown 15 to 17 years ago

W ;tc Typo: Choose the option you prefer to complete

Option 1: Select general waste types and source categories. Ifyo do not know the general waste types C* sources, you areen njraged to describe the site in Hem I—Description of Site.

General Typo of Waste:Pic j an X in the appropriatebo s. The categories listed;v. iaa. Check each applicable

1 B Organic*2. D Inorganics3 CB Solvents4 D Pesticides5. 3 Heavy metalsr n ^-'--j>7 D Bases0 3 PCBsS. O Mi«d Municipal Waste

10 *D Unknown1 1 3 Other (Specify)

Ho 2900-OI3V

Source of Waste:Place an X m the appropriateboxes.

1. D Mining2. D Construction3. D Textiles4. fJ Fertilizer5. O Paper/Printing6 D Leather lan.-vng7. D Iror./Steel Foundry8. D Chemical. General9. D Plaling/PclisMing

10. D Military/Ammunition11. G Electrical Conductors12. D Tiansfurmcr*13. D Utility Companies14. D Sanitary/Refuse15. D Photofimsr,16. O Lab/Hospita!17. D Unknown1B. 3 Other (Specify)

Coated__________Fabric______

Mfg.________

Option 2: This option is available to persons fsm.Var svith t"eResource Consorvaticn and Recovery Act (f \CnA) Section 3CO1regulations (40 CFn Pan 261).

Specific Typo of Waste:EPA has assigned a four-digit number to ea:'^ r iszercous v.ss-..;-listed in the reguiauons under Section 3001 ol RCRA £ r *e r ;-eappropriate four-digit number in the boxes proviiec A cs^v c;the list of hniardous wastes and codes can be obtained tyconiacting the EPA Region serving the State in which tne site islocated.

0 0 0 3 5 8 J.:-8ft

„ .». _ i2 t tV \_i wv* » —

>~c.-M vi- aparcpr-ve boni* to

!3cii>'.y Wt>«s found at the sue.I' ha "totnl faciNty waste amount" spa<s>fj c t f ic orti.T.aied combined quantiV(vuiun.c) ol ha/arJous w.ir.tcs at the siteusing cubic feet or gallons.li he "total facility area" space, give thee i mated area si*« which the facilitiesoccupy using square fe*t or acres.

Facility Type • •

1. C PilesZ C Land Treatment3. C LandfiH4. D Tanks5. O Impoundment6. D Underground Injection7. O Drums, Above Ground8. D Drums, Below Ground9. D Other (Specify)____

Facility Waste Amount

Ml*

TotaJ Facility Area

t»?i Unknown

K.,own. Suspected or Likely Releases to the Environment:Place rtn X in the appropriate boxes to indicate any known, suspected.o ikely releases of wastes to the environment.

O Known Q Suspec:ed E Likely O None

Note: Hems Hand I are optional. Completing these nams will assist EPA and State and local governments in locating and assessinghojarrtous waste sites. Although completing the items is not required, you are encouraged to do so.

£ etch Map of Site Location: (Optional)Sketch a map showing streets, highways,routes or other prorr.meni Undmarks neart site. Place an X on the rrup to indicatet sito location. Draw an arrow showingine direction north. You may substitute •

hing map showing the site location.^

Description of Site: (Optional)D :cnbe the history and present Cc< ditions of the sito. Give directions tothe * '*, and describe any nearby wells.S p r l , . lakes, or housing. Include suchtr Tmjiion as how waste was disposedai where the waste came from. Provide»!,, other information or comments whtehmay help describe the site conditions.

Site filled several years ago and presentlyused as a sheep farm.

S nature jnd Title:The person or authorized representative(jitrh as plant manager*, superintendents.tr tees or aito/n«ys) of persons requi/edtc otify must sign the form and provide amailing add/eas (if different than eddfes*in item A). For other persons providmgn. ficMioft. in* fttfn&tur* r* optonaJ.C <k tr* boxes which oest describe the

p to the sao of ihe pervon

>*»»• Robert C. Hilea

TM QN1ROTAL, Inc.

c*, Mlddlebunr IM CT 067*9

-&~ss

D Owner, PresentD Owner. Past3 TransporterQ Operator. PresentO Operator. PastD Othar

/*!l \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCYI* £±L \ REGION 55 •OAAKxV w

* 230 SOUTH DEARBORN ST.CHICAGO, ILLINOIS 60604

JAN 9 2 laa-lU*n" *• fc U'J IEPLY TO THE ATTENTION OF:

Dee BrncichWaste Management of North America, Inc.Two Westbrook Corporate, Suite 1000P.O. Box 7070Westchester, IL 60154

Re: Meeting for the Hagen Farm Site, WI

Dear Ms. Brncich

This letter is intended to inform you of a meeting regarding the above sitescheduled for February 1, 1990 fron 10:00 an to 1:00 pm, in Chicago Illinois.The meeting will be held at the Federal Building - 230 South Dearborn - llthfloor, Northwest Conference room.

The following are the meeting agenda to be discussed:

1. Discussion about the proposed remedial alternatives and selection ofcertain alternatives for the Feasibility Study (FS) for OperableUnit (00) I

2. Heed to sample and analyze the waste in the landfill to define thecharacter of the waste

3. Discussion of the soil clean-up standard., the boundary of waste tobe treated, and the definition of :t'Site" -and "Area of Concern"

4. Outline of the risk assessment for OU I and II, including theindicator compounds, pathways involved, and toxicological data

5. Discussion of the groundwater data for any additional work needed

6. Schedules for the major deliveries, such as Tech. Memo II and IIIfor OU II, Risk assessment and draft RI report for O'J II, and draftFS report for OU I

7. Other major or minor issues.

If you have any questions, please contact me at (312) 886-4749.

Sincerely yours,

lae B. LeeRemedial Project Manager

cc: T. Evanson, WDNRL. Vanderpool, ERAGr-Asbury, Warzyn

HAGAN FARM SITEWASTE CHARACTERIZATION

The source materials (waste and soil) should be sampled and analyzedfor U.S. ERA organic and inorganic priority pollutants. Split spoonsamples should be collected at 2 1/2 foot intervals from ground surfaceto top of water table and be field screened using a photoionizationdetector. The two samples having the highest level should becollected. The area containing a minimum of 12 foot depth of wasteshould be divided into four equal quadrants. Samples should becollected from the center of each quadrant. Similarly, the area ofthe landfill with a minimum of 4 foot depth of waste should be dividedinto two quadrants and samples collected from the center of each.

The samples collected should be representative of the source materialsfound at the site.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGIONS

230 SOUTH DEARBORN ST.CHICAGO, ILLINOIS 60604

IEPLY TO THE ATTENTION OF;

5HS-11

Dee BrncichRemedial Project ManagerWaste Management of North America, Inc.Two Westbrook Corporate Center - Suite 1000P.O. Box 7070Westchester, IL 60154

Re: Alternative Array (AA) Review Comments for the Source ControlOperable Unit at the Hagen Farm Site, WI

Dear Ms. Brncich:

The United States Envi-ronmental -Protection Agency (U.S. ERA) and theWisconsin Department of Natural Resources (WDNR) have received and reviewedthe Alternatives Array (AA) for the source control operable unit at theHagen Farm Site, Wisconsin. Enclosed are review comments for thedocument.

Enclosed you will also find the applicable or relevant, and appropriaterequirements (ARARs) identified for the proposed alternatives. Theevaluation of the proposed alternatives in the Feasibility study shall notbe limited to the use of these ARARs.

It is not necessary to revise the AA document for resubmittal. Theenclosed review comments shall be Incorporated into the draft FS.The draft FS report shall be submitted not later than April 13, 1990.

If you have any questions., please feel free to contact me at (312) 885-4749.

LeeRemedial Project Manager

Enclosures

cc. T. Evanson, WDNRG. Asbury, WarzynT, Wright, JesupJ, Cahn, ORC

u

Review Comments for Alternatives Array (AA) DocumentSource Control Operable Unit

Remedial Investigation/Feasibility Study (RI/FS)Hagen Farm, WI

1. Page 2-2, paragraph (para.) 2:

Please include information about the waste. The manifest fromUniroyal, Inc., indicates that F003 and F005 wastes, which are RCRAlisted hazardous waste, were disposed of at the site.

2. Page 3-3, para. 4:

The new risk assessment manual entitled "Risk Assessment Guidance forSuperfund, Hunan Health Evaluation Manual Part A, Interim Final, July1989 (9285.701A)", shall be used 1n the risk assessment. I willsupply you with a copy of this manual if you need one.

3. Page 3-4, para. 2:

The identification of site contaminants by analyzing waste samplesfor EP toxicity metals, and by inferring from soil gas and groundwaterdata does not seem sufficient to properly characterize the waste.The direct analysis of the waste for its chemical compositions andlevel of the contaminants is preferred to better define the site.

Please also include the waste characterization data provided in theSite Evaluation Report, dated Oune 1988, which identified sevencontaminants. Five of the seven contaminants were also detected ingroundwater samples collected from 1982 to 1984.

4. Page 3-5, para. 5:

The five indicator contaminants listed are potential health risks,but they do not sufficiently represent the overall site contaminationand potential health risks. Due to toxicity, exposure potential, andpotential carcinogenic effects, the following contaminants also shouldbe added as indicator contaminants, regardless of concentration:

. Vinyl chloride

. Chlorobenzene

. Ethylbenzene

. Toluene

. Trans 1,2-dichloroethene

-2-

5. Page 3-7, para. 5:

Direct contact with the contaminants shall be considered as thepotential pathway to public health. The foilowing pathways shall beconsidered in evaluating the potential risk the contaminated soilspose to the general public:

* Direct contact - via ingestion/inhalationof soil-vapor/dermal contact

* Leaching to groundwater and potential useof aquifer as drinking water source

* Inhalation of the airborne contaminants

In addition to chronic risk assessments, the acute impact to the site-workers or nearby residence also should be evaluated. The potentialvapor emission during the site construction and its impact to on-site

t> workers and residents should be evaluated.

For estimating fugitive dust from the site, the guidelines in the"Superfund Exposure Assessment Manual (SEAM)" should be followed,and the State of Wisconsin should be consulted as to therequirements of State fugitive dust emissions regulations.

6. Page 4-2, para. 2 (General Response Action/Remedial Technology):

Please include in-situ thermal treatment as a remedial technology.

7. Page 4-3 (Groundwater Controls):

Use of a slurry wall may not be a viable alternative since keying thewall into a semi-impermeable or impermeable unit may be impossible.Based on available permeability data, the sandstone bedrock isconsidered a permeable unit. A groundwater interceptor system can beconsidered. The diversion of groundwater in operable Unit I nay beuseful in limiting groundwater flow, but may impede a future pump andtreat alternatives for operable unit II (groundwater cleanup).

Please evaluate this alternative with respect to a future groundwatercleanup alternatives.

3. Page 4-5 (Biological):

The biological option of composting was identified as implementable andgenerally effective based on tht historical success of the technology.Composting may also require placement on an impermeable barrier andoperation under an air permit. Composting may not fully degrade allcompounds especially heavier organic and chlorinated organics.

-3-

9. Page 4-6 (Chemical ) :

Oxidation technology in conjunction with biological composting shouldbe evaluated as a remedial alternative. Oxidation treatment mayrequire an air permit.

10. Page 4-6 (Physical):

Although volatility differences exist, the decision to not retainthermal volatilization as a viable treatment option is premature. Themethod is comparable to the effectiveness of on-slte incineration fordestroying non-halogenated organics. It is recommended that thermalvolatization be retained for further consideration.

The primary disadvantage of solvent extraction and soil washing isthat it would generate a waste stream requiring treatment and/ordisposal. In addition, there may also be some pre-treatmentrequirements for the waste stream such as screening and particlereduction. The effectiveness of the soil -wastvfng method for removingchlorinated compounds will depend on the solvent used. The potentialsolvents used should be low 1n toxicity since residual concentrationsmay remain in the treated soils.

The use of fixation as a treatment option is identified but is notevaluated. It seems that fixation is proposed as a solidification/stabilization method. Although fixation has been proven as aneffective method for stabilizing inorganics, its applicability toorganics at the site is uncertain.

11. Page 4-7 (In-Situ Waste/Soil Treatment):

It is unclear whether the in-situ technologies were intended fortreatment of the contaminated soils only or of the waste and soil. Thegeneral drawback. of .all inîty treatment-technologies is that completeremoval of the source nay not occur since containerized waste aresuspected to be at the site.

12. Page 4-3 (Biological):

In order to bioremediate thftJWl||:J$ and unsaturated soils at the site, alarge scale infiltration gall4 $'; Wuld be needed. In addition, thehigh permeable sands would make "'the treatment of the unsaturated zonedifficult without providing fof 'treatment and hydraulic control ofthe groundwater.

-4-

Please evaluate the existing date of waste-soil in term of thresholdconcentrations of inorganics that are inhibiting to biologicaltreatment processes. E.P. Toxicity test results indicate that thelevel of cadmium (CK03 mg/T) 1s somewhat higher than the~thresholdconcentration (0.02 mg/1) for Anaerobic Digestion Processes. Checkalso the level of arsenic, chromium, copper, lead, mercury, nickel,and zinc for the threshold concentrations.

13. Page 4-8 (Physical):

Stabilization/Solidification is identified as a potential applicabletechnology but is not screened for effectiveness, implementability andcost.

14. Page 4-10 (Institutional Measures):

Please include the provision of drinking water as an institutionalmeasure for consumers with potentially contaminated drinking waterwells near the site.

15. Page 4-10 (Technologies Carried Through Initial Technology Screening)

The technologies presented hare are inconsistent with the retain/notretain status stated in the previous section.

Item 3, Direct Waste/Soil' Treatment (on-site) , does not includedechlorination, oxidation, solvent extraction soil washing, fixation,rotary kiln, multiple hearth, and Infrared treatment as retainedtechnologies.

Item 5, In-Situ Waste/Soil Treatment, includes solvent extraction andinjection grouting; however, these options were not identified and/orretained during the screening process in the previous section.

16. Page 5-1 (Alternative 2):

As mentioned in Comment #7, fftf ii| of a vertical barrier to impedeIcachate generation and contjjjffîjtofl migration is not e f fec t ivealternative. This alternat^|:^^nes that beside transient waterassociated with infiltrationF^lîJldwater also comes in contact withthe waste. The RI, though, that the groundwater table iscurrently lower than the dei pf Nown waste. The slurry wall mayalso not be an effective metfi|t ^ ;di vert ing groundwater since thewall is proposed to be keye<f;;|rtW;iandstQne bedrock, which ispermeable. -~^""^1.:

-5-

If groundwater diversion is required due to fluctuations in the watertable, the use of a groundwater interceptor system is preferred to beevaluated as an alternative rather than a slurry wall.


Please specify the criteria how to define the extent of contaminatedsoil and waste.

The biological treatment option of bioremediating excavated waste/soilin a RCRA regulated landfill was not previously identified and screenedas a potential remedial technology. The efficiency of this alternativeshould be evaluated in depth (see comment #12).

. j 18. Page 5-5 (Alternative 4):IffF

Please specify the type of treatment for off-site treatment.

To haul incinerated soils back to the site for use as fill should notbe considered as an optional element of the alternative, because thehazardous waste can not be disposed to a non-RCRA landfill site.


The alternative does not include biological treatment, although it waspreviously retained as a screened-alternative. .-If-biologicaltreatment is being screened out, justification should be presented.

As stated previously, in-situ alternatives, with the possibleexception of vitrification, do not eliminate the waste source if

y. |j containerized waste are burled.

Soil flushing is not retained is * potential remedial alternative inSection 4 of the report, yet ft '1| retained as a remedial alternativein Section 5. Please clarify this inconsistency.

20. Page 6-1 (Location-Specific ARARs):

Please include and evaluate the "Flood-Plain" requirement.

Review of Applicable or Relevant and Appropriate Requirements (ARARs)Alternatives Array (AA) DocumentSource Control Operable Unit

Hagen Farm, HI

Action Specific ARARs

1. No Action

2. Capping with Optional Groundwater Diversion Barrier

(a) If the waste is left in place, the following RCRA requirements areRelevant and Appropriate (RA).

264 Subpart G : General requirements regarding closureof hazardous waste disposal facilities

264.310 (a) : Final cover design requirement

264.310 (b) : Protect and maintain surveyed benchmarksused to locate waste cells

264.310 : 30 year post-closure care and groundwatermonitoring

(b) There are no RCRA ARARs for the construction of a vertical barriersuch as a slurry wall unless soil contaminated with the listedsolvents are excavated from the unit.

If contaminated soil 1s excavated for construction of slurry wal l ,and disposed off-site, It only can be land-disposed in a RCRAlandfill and 40 CFR 268.41 (Land Disposal Restrictions (LOR)) areapplicable.

If contaminated soil 1s mixed with a solidifying material such asbentonite In-situ and flOt in a separate unit, then there are noARARs applicable or relevant and appropriate. However, if themixing occurs in a taftji, or a separate definable unit, then ARARSsuch as 40 CFR 264.190*192 (new tank system) and 268.41 (LDR) areapplicable.

If excavated soil is clean (not RCRA waste), then no ARARs areapplicable or relevant or appropriate.

-2-

3. Waste/Soil Excavation with Optional On-site Treatment and Disposal

(a) If the excavated waste is treated on-site, and placed to the newcell constructed on site, the following ARARs are applicable. (Inthis case, the new cell constructed on site is considered as a newunit,)

The following ARARs are also applicable if the excavated waste istreated in-situ in a new cell constructed on-site.

263 Subpart D : LOR Treatment Standards

264.301 : Minimum technology requirements

264.310 : Cell closure with final cover

264 Subpart G : Closure and post-closure

(b) If incineration is used to treat the waste, 40 CFR 264 Subpart 0is applicable.The ash must be tested using the TCLP for F003 and F005, and mustbe disposed of only in the RCRA landfill.

(c) If the residue of treatment other than in-situ treatment is to beland disposed, it must be placed in- a RCRA landfill and it wouldhave to meet the treatment standard of 40 CFR 268.41 (soil anddebris are not subject to the treatment standards prior toNovember 8, 1990).

(d) Relevant design and operating requirements of 40 CFR 264 (e.g. tankunit) are applicable for each treatment methodology.

4. Waste/Soil Excavation with Optional Off-site treatment and Disposal.

The following ARARs are applicable.

268. Subpart 0 :; LOR

Other requirements will apply depending01 facility where wastes are disposedof, nature of treatment, etc. Disposalmust be in a RCRA disposal facility.

264.117 : Groundwater monitoring

-3-

5. In-situ Waste/Soil Treatment

No ARARs are applicable, but may be relevant and appropriate.

By-product of various in-situ treatments may trigger ARARs - such asdisposal of water used in soil flushing.

VJ

State of Wisconsin \ DEPARTMENT OF NATURAL RESOURCESSecretary

Box 7921Mtdbon, \YisconaSn 53707

February 21, 1990 FILE REF: 4440

Jae B. LeeUS EPA, Region VWaste Management Division, 5HS-11230 South Dearborn StreetChicago, IL 60604

SUBJECT: Follow-up of Issues Raised at the February 1, 1990 Meetingon the Hagen Farm NPL Site

Dear Mr. Lee:

This letter serves as a State response to several issues raised at theFebruary 1, 1990 meeting held to discuss ARARs and remediation alternativesfor the Hagen Farm Landfill Site. The issues and responses are detailedbe!ow.

Promulgation of the NR 600 Series Codes and Their Effect on Selection ofRemedial Alternatives

Two related issues arose during our recent discussions on Hagen Farm. Thefirst was whether Wisconsin's existing or proposed RCRA hazardous wasteregulations (i.e., ch. NR 181 and ch. NR 600 - 685 series, respectively) allowfor the use of the "area of contamination" (AOC) concept at Superfund sites inWisconsin. The second issue involved whether any of the proposed actions atHagen Farm constituted "placement" of RCRA hazardous waste (as definedpursuant to the area of contamination concept), thus triggering the State's •hazardous waste regulations.

In response, it is our understanding that the "area of contamination" conceptis a legal interpretation set fofth in the final 1990 NCP. This legalinterpretation establishes what ifctyrttttutes "land disposal" of RCRA Subtitle Cwastes at any federal Superfund flti. Therefore, it is our understanding thata state (such as Wisconsin) need' 'ntt have an equivalent "AOC" provision inorder for this concept to be utilized at a Wisconsin Superfund site. Withrespect to the second issue, it Is mir understanding that placement does notoccur when wastes are: treated ift*|Jtu; capped in place; consolidated withinthe AOC; or processed within th« A&C (but not a separate unit) to improve its

structural stability. Thus, if the federal Superfund and federal RCRAprograms agree that the construction of a new "RCRA land disposal cell" withinthe AOC is not placement, then the State would likely accept that decision,provided ARARs are followed.

NR 140 and Separation of Groundwater Impact

Under ch. NR 140, Wis. Adm. Code, the Department cannot allow new landdisposal facilities to be constructed in areas of existing groundwatercontamination. Chapter NR 140.28 allows exemptions to this policy, providedthe facility design will achieve the lowest possible release of thecontaminant currently found in the groundwater, that any further release ofthe contaminant will not exceed the preventative action limit and that therewill be no increased threat to public health or welfare from-further releaseof the contaminant. In addition, the contaminated groundwater must bsundergoing remediation with a goal of meeting the enforcement standards setout in ch. NR 140. This has in the past involved a groundwater gradientcontrol or extraction system. Therefore, ch. NR 140 would not exclude the"RCRA cell" alternative as long as the exemption criteria could be met.

Applicability of NR 181 Feasibility Report/Plan of Operation Requirements to a"RCRA Cell11

Under Superfund, the administrative requirements of the hazardous wastefacility siting process would be waived, but all substantive requirements ofthe hazardous waste rules (ch. NR 181 or after December, 1990, ch, NR 600 -685) must be met. This applies to both State and Local requirements.Therefore, the substantive requirements of the feasibility study/plan ofoperation process for siting a hazardous waste facility would have to be metin the Remedial Design phase of the project. This information would be

U subject to the same review given any new hazardous waste disposal facility.

Undertaking the substantive requirimtMs of a feasibility report/plan ofoperation for a "RCRA land d1spoiiijV-^11" is a significant effort.Essentially, a complete field stui ];|! id be necessary in the area chosen forthe "RCRA cell" before the deslgn^îpe unit could be developed. The fieldwork performed to date for the RJ i Jd7be relevant to the new cell, but wouldnot be adequate for development of 1|i$ tell. We anticipate that the RemedialDesign would need to be undertaken W-pKases with the following minimum issuesaddressed: the substantive requirements of the feasibility report; thesubstantive requirements of the plan Of operation; and the treatability study.At each phase, significant review f(ffie would be needed by the Department todetermine adequacy of the 1nfonut?fl :tnd to comment on the results.

Need for a Treatability Variance fromtDR In the ROD

It is our opinion that a treatability variance from LDR should be included inthe Source Control Operable Unit ROD. This would address several problems:

ra. Definition of the "AOC". By writing a treatability variance intothe ROD, construction of the "RCRA cell" would not be limited to thearea of contamination. Technical considerations for siting the cellcould make construction within the AOC difficult. With a treatabilityvariance, the cell could be developed anywhere on-site.

b. Definition of "placement". Discussion to date on the "RCRA cell"option has implicitly centered on avoiding placement of hazardous wastewhich would trigger the Land Disposal Restrictions. A treatmentvariance would directly address this issue by recognizing that LDR doesapply, but then waive the LDR standards for the site.

c. Waste Treatment Standards. The "RCRA cell" Option requires in-situtreatment to achieve LDR standards for the F003 and F005 wastes.Without laboratory end field treatment studies, we do not know if LDRfor this waste can be met with the in-situ treatments available. Thetreatment studies will not be conducted until after the ROD is signed.A treatability variance would allow a less stringent (although not lessprotective) standard to be applied to .the in-situ treatment of the wasteand may avoid the possibility of reopening the ROD after the remedialdesign or remedial action is complete.

Submittal Date for the Draft Source Control OU Feasibility Study'

The submittal date for the draft SCOU feasibility study is April, 19SO.However, the source characterization work will not be1 complete until August,1990. Therefore, it will be difficult for the State to determine chemical-specific ARARs during review of the draft FS. If unexpected contaminants(such as PCBs) are discovered in the waste, delays may occur because of theneed to reissue and re-review the draft FS. In any case, the Department willnot support the development of a draft final FS for public comment before allRI work is finished and can be adequately addressed in the remedy selectionprocess.

Remedial Options

We believe there are several drawbacks to the "RCRA cell" remedial option,including the issues of area of contamination, placement of hazardous waste,ability to meet LDR standards, technical design issues, time necessary fordevelopment of the RD, and public perception. For this reason, we arerequesting that the PRPs and ERA objectively evaluate in-situ waste treatmentoptions for this site, including vitrification.

If you have any questions, please call me at (608) 266-0941

Sincerely,

Terry Evanson, HydrogeologistEnvironmental Response and Repair SectionBureau of Solid and Hazardous Waste Management

NOTED:Sue Bangert>, Superfund Program

TAE/tae/lee22190.hf

cc. Sue Bangert - SW/3Ed Lynch - SW/3Mike Schmoller - SDJack Dowden - Waste Management of North America, IncDee Brncich - Waste Management of North America, IncT. C. Wright - The Oesup Group, Inc.

^ Greg Asbury - Warzyn Engineering, Inc.xMary Pat Tyson - MI/WI, 5HS-11, Region V, EPA

MEMORANDUM

June 25,1990

TO: Project File

FROM: Mark Lovejoy

RE: Hagen Farm Feasibility Study

As per WDNR review comments on the Draft FS presented in their letter to U.S. EPAdated 6/1/90, the following NR 445 emission limits should be added to Table 1 of WDNR'sletter dated 1/10/90:

Pollutant Allow. Amb. Cone. (ug/m3) Emiss. Rate

Vinyl Chloride N/A 300 Ib/yrChlorobenzene 8400 29.148 Ib/hrNaphthalene 1200 4.164 Ib/hr

MAL/jkk/GEA[ikk.106-48]13452.74-MD

CD

Appendix B

t , Cost Summary

TABLE Bl

COST SUMMARYALTERffATIVE 2 - CAPPING

HAGEN FARM SITEFEASIBILITY STUDY

Capital Costs

Grading Layer

CappingOption 2a - Cap RepairOption 2b - NR 500Option 2c - NR 181

Subtotal

Administration (5%)Engineering (20%)Contingency (20%)

Total

Operation and Maintenance Costs

Cap Maintenance

Cap Monitoring

Subtotal

Contingency (15%)

Total

$

$$$

$

Cap Repair

$550,000

$ 539,000

1,089,000

54,450217,800217,800

1,579,000

NR 500

$550,000

$ 889,000

$ 1,439,000

$ 71,950$ 287,800$ 287,800

$ 2,087,000

NR 181

$550,000

S 1,347,000

$ 1,897,000

$ 94,850$ 379,400$ 379,400

$ 2,751,000

(Annual)

$

$ 4,138

$ 3,600

$ 7,738

$ 1,161

8,899

$ 4,138

$ 3,600

$ 7,738

$ 1.161

$ 8,899

$ 4,138

$ 3,600

$ 7,738

$ 1,161

$ 8,899

30-Year Present Net Worth

(5% Discount Rate) $1,716,000 $ 2,224,000 $ 2,888,000

MAL/vlr/MKT[vlr-400-41a]13452.74-MO

TABLE 82

COST SUMMARYALTERNATIVE 3 - IN-SITU VAPOR EXTRACTION

HA6EN FARM SITEFEASIBILITY STUDY

Capital CostsSite PreparationTreatability StudyVapor Extraction SystemCap Installation (NR 500)System BioenhancementSubtotal

Administration (5%)Engineering (20%)Contingency (20%)Total

Operation and Maintenance Costs (Annual)

System Supervision and Maintenance(Years 1990-1992)(Years 1993-1995)

System Monitoring(Years 1990-1992)(Years 1993-1995)

Cap Maintenance

Cap Monitoring

Subtotal(Years 1990-1992)(Years 1993-1995)(Years 1996-2020)

Contingency (15%)(Years 1990-1992)(Years 1903-1995)(Years 1996-2020)

Total(Years 1990-1992)(Years 1993-1995)(Years 1996-2020)


(5% Discount Rate)

MAL/jlv/vKT[vlr-400-41b]13452.74-MD

594,90050,000248,900889,00065.000

$ 1,847,800

$ 92,400$ 369,600$ 369.600$ 2,679,400

46,88057,320

15,60065,600

4,138

3,600

70,218130,6587,738

10,53319,5991.161

80,751150,2578.899

$ 3,299,000

TABLE B3COST SUMMARY

ALTERNATIVE 4 - WASTE CONSOLIDATIONWITH IN-SITU BIOLOGICAL TREATMENT

HAGEN FARM SITEFEASIBILITY STUDY

Capital CostsWaste ConsolidationLandfill ConstructionVapor Extraction SystemLeachate TreatmentSite ClosureSubtotal

Administration (5%)Engineering (20%)Contingency (20%Total

Operation and Maintenance Costs (Annual)Leachate Recirculation System Maintenance

(Years 1990-1995)

Nutrient Costs(Years 1990-1995)

Vapor Extraction System Supervision(Years 1990-1995)

Off-Gas Monitoring(Years 1990-1995)

Leachate Treatment

Cap Maintenance

Cap Monitoring

Subtotal(Years 1990-1995)(Years 1996-2020)

Contingency (15%)(Years 1990-1995)(Years 1996-2020)

Total(Years 1990-1995)(Years 1996-2020)

30-Year Present Net Worth(5% Discount Rate)

$ 2,964,5001,110,0001,768,000250,000

2,799.6008,892,100

$ 444,605$ 1,778,420$ 1,778,420$ 12,894,000

$ 17,980

$ 3,000

$ 46,880

$ 15,600

$ 40,000

$ 8,276

$ 7,200

138,93655,476

20,8408.321

$ 159,776$ 63,797

$ 14,129,000

MAL/j1v/MKT [vlr-400-41d] 13452.74-MD

TABLE B4COST SUMMARY

ALTERNATIVE 5 - WASTE EXCAVATION WITHON-SITE INCINERATION

HA6EN FARM SITEFEASIBILITY STUDY

Capital Costs

Waste Excavation $ 1,714,700Incineration System $ 35,806,000Vapor Extraction System $ 1,768,000Site Closure $ 1.683,800Subtotal $ 40,972,500

Administration (5%) $ 2,048,625Engineering (20%) $ 8,194,500Contingency (20%) $ 8,194,500Total $ 59,410,000

Operation and Maintenance Costs (Annual)—————————————————————————Vapor Extraction System Supervision

(Years 1990-1995) $ 46,880

Off-Gas Monitoring(Years 1990-1995) $ 15,600

Cap Maintenance $ 4,138

Cap Monitoring $ 3,600

Subtotal(Years 1990-1995) $ 70,218(Years 1996-2020) $ 7,738

Contingency (15%)(Years 1990-1995) $ 10,533(Years 1996-2020) $ 1,161

Total(Years 1990-1995) $ 80,751(Years 1996-2020) $ 8,899


(5% Discount Rate) $ 59,858,000

MAL/jlv/MKT[vlr-400-41e]13452.74-MD

c c

o

Appendix C

Preliminary Development of Ciean-UpLevels for Waste/Soil

APPENDIX C

PRELIMINARY DEVELOPMENT OFCLEAN-UP LEVELS FOR WASTE/SOIL

Preliminary clean-up levels were derived using human health risk assessment methods whichincorporate assumptions of potential human exposure to the contaminants in waste/soil. Byassuming a level of potential exposure to the contaminants, a waste/soil contaminantconcentration can be calculated which corresponds to an acceptable level of risk to adversehealth effects. The preliminary clean-up levels presented in this section are to be implementedas a screening tool for remedial alternative evaluation. Because the clean-up levels weredeveloped using hypothetical, conservative assumptions about potential future exposure towaste, the values are not to be construed to represent waste concentrations corresponding toactual health risks.

VV The following contaminants of potential concern were used to develop clean-up levels forwaste/soil.

• Benzene • Tetrahydrofuran - Dieldrin• Ethylbenzene • Phenol - 4,4-DDE• Toluene • 4-Methylphenol • 1,4-Dichlorobenzene• Xylenes • 2,4-Dimethylphenol • 4-Chloro-3-methylphenoI• Chlorobenzene • Benzoic acid • Benzyl Alcohol• 2-Butanone • Vinyl chloride • bis(2-Chloroisopropyl)ether• 2-Hexanone • 1,2-Dichloroethene • Mercury

i , • Naphthalene • Barium

GENERAL APPROACH

Clean-up levels were developed for both the carcinogenic and noncarcinogenic effects of Sitecontaminants. For potential carcinogenic effects, a cancer risk level of 1 in 1 million excesscancers (above ordinary background cancer levels) was employed to derive clean-up levels.Clean-up levels derived from noncarcinogenic effects of contaminants correspond to a level ofhuman exposure which is not anticipated to cause adverse health effects, namely EPAReference Doses.

Appendix CHagen Farm Site

July 5,1990Page 2

Specific methods used for estimating human health risk for cancer and noncancer effects aredescribed in Risk Assessment Guidance for Superfund (1989). The basic relationships forestimating these risks are represented by the following equations:

Contaminant Human Cancer1. Cancer Risk = Concentration x Exposure x Slope

in Waste/Soil Variables Factor

Contaminant Human2. Noncancer Hazard Index = Concentration x Exposure + Reference

in Waste/Soil Variables Dose

Contaminant clean-up levels are developed by solving for the contaminant concentration inwaste/soil in equations 1 and 2. Table C-l shows the toxicity values (cancer slope factors andreference doses) used to calculate clean-up levels. Clean-up levels were derived only whentoxiciry values were available.

The human exposure term in the equations was based on assumptions for pathways ofexposure to Site contaminants. Two exposure pathways were considered for the Site andinclude: exposure to groundwater, assuming contaminated groundwater may migrate to privatewells in the future, and direct exposure to Site waste/soil by a child trespassing on-site. Inaddressing exposure for each pathway, several routes of contaminant entry into the body wereconsidered. Exposure to contaminants in groundwater was assumed to occur by ingestion ofgroundwater, inhalation of contaminant vapors and absorption of contaminants through theskin while showering or bathing. Similarly, direct exposure to contaminants in waste/soil wasassumed to occur via contact with skin and incidental ingestion of waste/soil adhering to thehands.

Table C-2 shows the human exposure relationships and exposure assumptions used to calculateclean-up levels. Exposure to contaminated groundwater was assumed to occur daily for anadult (70 kg) during a time period equal to the upper 90th percentile of occupancy at oneresidence (30 yr). Exposure to waste/soil was assumed to be incurred by a child (30 kg), onetime per week during six months of a year for a seven-year duration (ages 6 to 13). Otherspecific exposure assumptions are listed in Table C-2.


July 5,1990Page 3

Extrapolation from a concentration of contaminant in groundwater corresponding to a healthrisk to a clean-up level in waste/soil, requires an estimate of the dilution of waste/soilcontaminants when released to groundwater. The Organic Leachate Model (OLM) was usedas a basis for this estimation. The OLM was developed by the U.S. EPA, and used by theAgency in the course of its review of RCRA hazardous waste delisting petitions. The OLMapproach is outlined in the final OLM rule (51 Federal Register 41082, November 13, 1986).In the absence of site-specific leachate data, the OLM is used to predict the concentration oforganic constitutents in leachate from analyses of the waste material. The OLM is an empiricalequation derived from the Agency's leaching database. The OLM equation is:

CL = (0.00221)(CW)°.678($)0.373

where: CL = the predicted contaminant concentration in the leachate (mg/L)

Cw = the contaminant concentration in the waste (mg/L): S = the contaminant's water solubility at ambient temperature (usually between

18and25°C)(mg/L)

RI activities determined that waste/soils contained a low level of leachate, thus precludingextensive leachate sampling for contaminant analysis. In addition, some contaminantsidentified in soil gas and groundwater were not detected in available leachate samples. Forthese reasons, the maximum concentration of each contaminant identfied in groundwater wassubstituted for CL in the equation. The dilution factor for each chemical was then estimatedby the ratio CW/CL- Aqueous solubilities of the chemicals were derived from the U.S. EPAWERL Version 2.0 computerized database for water solubility data. The results of this analysisare presented in Table C-3. To arrive at a contaminant concentration in waste/soil, thecontaminant concentration in groundwater (expressed in mg/L, Table C-2), was multiplied bythe dilution factor resulting in a value expressed in mg contaminant/kg waste/soil. In the caseof inorganic constituents, a factor of 20, recommended by U.S. EPA, was used to estimate thewaste/soil to groundwater dilution.

Current EPA policy considers cancer as a "non-threshold" biological process. In otherwords, any exposure to a carcinogen, regardless of the magnitude, can lead to an incremental


July 5,1990Page 4

increase in the risk of developing cancer. For this reason, cancer risk from each exposure route(ingestion and dermal absorption) was assumed to be additive and contribute equally for anindividual exposed either via groundwater use or by trespassing on-site. Therefore, theacceptable cancer risk level for each individual route of exposure was set at 1 x 10*6 + 2 or5 x 10' . Noncarcinogenic effects of chemicals are considered to be "threshold" phenomena,indicating that a certain level of exposure must be attained before an effect is observed.Exposure below this threshold level would not produce an effect. For this reason, clean-uplevels for each individual exposure route were based on the reference dose.

TORI JMTOARY CLEAN-UP LEVELS

Table C-4 shows preliminary clean-up levels for contaminants of potential concern in Site<_> waste/soil. Clean-up levels calculated from groundwater exposure were lower than those

calculated from direct exposure to waste/soil. These values, however, are not intended torepresent absolute levels which necessarily need to be achieved because implementation ofsource control alternatives will reduce potential impacts of Site wastes on groundwater.Clean-up levels derived from noncarcinogenic effects were substantially higher than the levelsderived from potential cancer effects. In several cases (toluene, xylenes and benzoic acid),calculated clean-up levels exceed 1 x 10^ mg/kg. This high level indicates that, given themagnitude of the current reference dose and the human exposure assumptions used, exposureto pure chemicals would not be anticipated to result in an adverse health effect.

The primary objective in developing clean-up levels is to provide a screening tool for remedialalternative evaluation. Conservative assumptions were incorporated into the derivation of theclean-up levels, resulting in an estimate of a maximally exposed individual. Currently, exposureto contaminated groundwater is not occurring. Future groundwater exposure would requireinstallation and use of a private well within the zone of contamination or substantial futuremigration of contaminants to existing private wells.

Under current Site conditions, the opportunity for actual exposure to wastes are substantiallylimited by several factors including: (1) fencing surrounding the entire Site which limits


July 5,1990PageS

accessibility, (2) the fact that a majority of Site wastes are covered by vegetated soil whichwould substantially limit direct contact with waste; and (3) the small population in the vicinityof the Site which makes the incidence of Site trespass less than assumed. For these reasons, theclean-up levels presented in this report are not to be construed to represent wasteconcentrations corresponding to actual health risks posed by Site wastes.

BJC/vlr/KJD/GEA[dlk-601-17113452.72-MD

TABLE C-l

Toxicity Values for Contaminants Identified at theHagen Farm Site

Contaminant

BenzeneVinyl ChlorideEthylbenzeneTolueneXylenesChlorobenzene2-Butanone2-HexanoneNaphthaleneTetrahydrofuranPhenol4-Methy)phenol2,4-DimethylphenolBenzoic acid1,2-DichloroetheneBariumDieldrin4,4-DDE1,4-Dichlorobenzene4-Chloro-3-methylphenolBenzyl alcoholbis(2-Chloroisopropyl) etherMercury

Cancer Slope Factor(kg-day/mg)

0.0292.3

16

0.024

Chronic Reference Dose____(mq/kg-day)

0.10.32.00.020.05

0.0040.0020.6

4.00.020.050.00005

0.001

0.0003

Notes: Values were derived from the Health Effects Assessment Summary Tables,Fourth Quarter, 1989. All values pertain to the oral route ofexposure. The reference dose.jfor tetrahydrofuran was derived from theU.S. ERA - verified inhalation reference dose and provided by theU.S. ERA Environmental Criteria and Assessment Office. (--) signifiesvalue not available or not applicable.

BJC/dlk/MWK[dlk-402-87]13452.72-MD

c cTABLE C-2

Smeary of Contaminant Intake Methods and AssumptionsHagen Far» Site

Exposure Route,Equation Variable Value Used Rationale

Groundwater-IngestionIntake(ng/kg-day) = CM x IR x EF x ED

BU x AT

Groundwater-Dernalabsorption while showering or bathingAbsorbed Dose(mg/kg-day) =CW x SA x PC x ET x EF x ED x CF x DF

BU x AT

CW = Chemical Concentration in Water (mg/1)IR • Ingestion Rate (liters/day)

EF = Exposure Frequency (day/year)

ED = Exposure Duration (years)

BU - Body Weight (kg)AT * Averaging Time (days)

365

30

70

- 90th percentile of adultaverage

- Daily exposure- 90th percentile upper-bound

time at one residence

- Adult average10,960 for - Exposure duration fornoncarcinogens noncarcinogenic effects.25,570 for Lifetime for cancercarcinogens effects.

CW = Chemical Concentration in Water (mg/liter)SA » Skin Surface Area Available for Contact (cm2) 19,400

PC • Chemical-Specific Dermal Permeability Constant (cm/hr) 8.4xlO~4

ET = Exposure Time (hours/day)

EF = Exposure Frequency (days/year)

ED - Exposure Duration (years)

CF = Volumetric Conversion Factor (Iiter/cm3)

OF = Dermal Contact Fraction (%)

0.2

365

30

0.0010.5

- 50th percentile adult male

- Value for water, suggested inabsence of chemical-specificvalue

- 90th percentile suggestedvalue

- Daily activity

- 90th percentile upperboundtime at one residence

Assume 50% available fordermal contact and 50%available as vapor

Exposure Route,Equation

Waste/Soil - Dermal absorption forchild trespassingAbsorbed Dose(ng/kg-day) -

CS x CF x SA x AF x ABS x EF x ED

Waste/Soil - Incidental ingestionfor child trespassingIntake(mg/kg-day) = CS x IR x CF x FI x EF x ED

—————BU x AT———————

c cTABLE C-2(cont.)

VariableBU = Body Weight (kg)

AT = Averaging Time (days)

CS = Chemical Concentration in Soil (mg/kg)CF - Conversion Factor (kg/mg)

SA •= Skin Surface Area Available for Contact (cm2/event)

AF - Soil to Skin Adherence Factor (ng/cin?)

ABS - Absorption Factor (unitless)

EF = Exposure Frequency (events/year)

ED * Exposure Duration (years)

BU <= Body Weight (kg)

AT = Averaging Time (days)

VaUieJJsed

70

Page 2 of 3

Rationale

- Adult average10,960 for - Exposure duration fornoncarcinogens noncarcinogenic effects.25,570 for Lifetime for cancercarcinogens effects.

10-6

5,000

1.45

0.10

24

30

2557 for non-carcinogens25,570 forcarcinogens

- 50th Percentile of sum of SAfor hands, arms and legs for9 to 10 year old child

- Suggested value- Assume 10% for organic chems.No absorption of inorganics

- One event per week during 6months. Subjectivejudgement.

- Occurs from ages 6 to 13.Subjective judgement

- 50th Percentile body weight,male child 9 to 10 years old

- Exposure duration fornoncarcinogenic effects.Lifetime for cancer

. effects.

CS = Chemical Concentration in Soil {mg/kg)

1R = Ingestion Rate (mg soil/day) 100CF = Conversion Factor (kg/ing) 10-6

FI = Fraction Ingested from Contaminated Source (unitless) 1.0

- Suggested value

Assume entire areacontaminated. Subjectivejudgement.

c cTABLE C-2(cont.)

Exposure Route,Equation Variable

EF = Exposure Frequency (days/years)

ED = Exposure Duration (years)

BW = Body Weight (kg)

AT » Averaging Time (days)

Value Used

24

30

Page 3 of 3

Rationale- One event per week during6 months. Subjectivejudgement.

- Occurs from ages 6 to 13.Subjective judgement.

- 50th Percentile body weight,male child 9 to 10 years old,

2557 for non- - Exposure duration forcarcinogens noncarcinogenic effects.25,570 for Lifetime for cancercarcinogens effects.

Notes: Exposure equations and suggested exposure factors from Human Health Evaluation Manual (EPA. 1989) or Exposure Factors Handbook (EPA. 1989).

BJC/vbl/HWK[wp«isc-400-03a]13452.72-HD

TABLE C-3

Modeled Waste/Groundwater Dilution Factors

ChemicalBenzeneBenzoic acidBenzyl alcoholBis(2-chloroisopropyl) ether2-ButanoneChlorobenzene4-Chloro-3-methylphenol1,4-Oichlorobenzene1,2-Dichloroethene4,4-DDEDieldrin2,4-DimethylphenolEthylbenzene2-Hexanone4-MethylphenolNaphthalenePhenolTetrahydrofuranTolueneXylenesVinyl chloride

MaximumGroundwaterConcentration

(uq/U761,00026"19[10]b471090.140.173304,400[10]b6,10085,600630,00055037,00077

WaterSolubility

(mq/L)1,7802,9005159102002750004883,85079700C0.0400.18624000d15235000240003080000-30000065152001.1

PredictedConcentration

in Haste(ma/L)0.095

47,3031.310.160.0100.0850.06250.8970.2310.1070.06156.71

4,9570.031

4951.099

225115,367

11898,529

191

PredictedDilution

Factor13.6

77550.38.41.0

21.38.939.725.775835120.3

1,1273.14SI. 2137.440.2183214

2,6632,432

a No water solubility data were found for benzyl alcohol (phenylmethanol), the value forphenylmethane was used instead.

b The compound was not detected, so the detection limit of 10 ug/L was substituted forthe value of C.

c The value presented is the average of the water solubilities for the cis and transisomers.

d No water solubility data were found for 2,4-dimethylphenol, the value for 4-methylphenol was used instead.

e The value was obtained from the National Library of Medicine's Hazardous SubstancesDatabase.

BJC/dlk[dlk-402-87c]13452.72-MD

TABLE C-4

Contaminant Concentration in Waste Corresponding to1 x 10-6 Cancer Risk or Hazard Index of 1.0

(mg/kg)Groundwater Exposure Waste Exposure

Chemical

BenzeneVinyl ChlorideDieldrin1,4-Dichlorobenzene

Ingestion

—————— 1x10-6<L f\ 4. V

1.9 x 10-24.4 x 10-29.3 x 10-41.5 x 10-1

DermalAbsorption

While Bathing

2.3 x 10*5.4 x 10-1

1.11.8 x 102

IncidentalIngestion

7.9 x 10210.01.4

9.6 x 102

DermalAbsorption

1.1 x 1021.4

2.1 x 10-11.4 x 102

——————————————————— Hazard Index equal 1.0 ———————————————————

EthylbenzeneTolueneXylenesChlorobenzene2-Butanone2-HexanoneNaphthaleneTetrahydrofuranPhenol4-Methylphenol2,4-DimethylphenolBenzoic Acid1,2-DichloroetheneBariumBenzeneVinyl ChlorideDieldrin4,4-DDE1,4-Dichlorobenzene4-Chloro-3-methyl phenolBenzyl alcohol

3.9 x 1032.3 x 1031.9 x 1051.5 x 101

1.8--

1.9 x 10l1.3 x IQl8.4 x 102

• «R

...

1.1 x 1051.8 x 10l3.5 x 101

---,

6.3 x 10-1—----1.8

4.9 x 106*2.8 x 106*2.3 x 108*1.8 x 10*.2.2 x 103

__2.4 x 1041.6 x 1041.0 x 106*

----

1.3 x 108*2.2 x 104

NA___-

7.8 x 102-----_

2.2 x 103bis(2-Chloroisopropyl)ether --Mercury 2.1 x 10-1 NA

4.6 x 1051.4 x 106*9.2 x 106*9.2 x 1042.4 x 105

__1.8 x 1049.2 x 1032.8 x 106*

----

1.8 x 107*9.2 x 1042.4 x 105

---_

2.3 x 102----—

4.6 x 103--

1.4 x 103

6.3 x 1041.9 x 10&1.3 x 106*1.3 x 1043.2 x 104

__2.5 x 1031.3 x 1033.8 x 105

---,

2.5 x 106*1.3 x 104

NA--_-

3.2 x IQl---.--

6.3 x 102..NA

Notes: The hazard index refers to the ratio of the estimated daily contaminant intakedivided by the reference dose. (--) denotes toxicity value is not available.Clean-up levels greater than 1 x 10° (*) indicate that, based on the exposureassumptions used and the current reference dose, exposure to pure chemical isanticipated to be without risk of adverse health effect. NA denotes thatbarium and mercury absorption was not considered appreciable via the dermalexposure route.

BJC/dlk/MWK[dlk-402-87a]13452.72-MD

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WARZYN INC - FEASIBILITY STUDY (FS) - SOURCE … · GEA/vlr/GEA [vlr-106-79] 13452.74 cc: Ms. Terry Evanson - WDNR (5 copies) ... The provisions for enacting the requirements of CERCLA