to0000057 Cf SKI *X TIM) REMU1IAL AEHRCOIIVK Site Names and locations: Janesville Ashbeds (JAB) Janesville Old landfill ("1978 H ) Janesville Old Dump ("1963") Janesville New landfill ("1985") (Collectively referred to as the Janesville Disposal Facility (JDF), located in Janesville, Wisconsin) Statement of Basis and Purpose: This decision document presents the selected remedial action for the Janesville Ashbeds and the Janesville Old landfill Sites (both sites are on the National Priorities List (NPL), and the contiguous sites, Janesville Old Dunp and the Janesville New landfill Sites (collectively referred to as the Janesville Disposal Facilities or JDF), located in Janesville, Wisconsin. The decision has been developed in accordance with CERCLA, as amended by SARA, and in accordance with RCRA. This decision is based on the Administrative Record for this site. The attached index identifies the items that comprise the Administrative Record, upon which the selection of the remedial action is based. The State of Wisconsin has concurred with the selected remedy. The letter of concurrence is attached to the Record of Decision (ROD) package. Description of the Selected Remedy: The selected remedy addresses the final remedy for all four sites individually; but this ROD treats the four sites as one site, the Janesville Disposal Facility (JDF). The selected remedies for the JDF are as follows: Janesville Ashbeds or JAB: Access/land use restrictions, containment of subsurface soils by maintaining the present cap and upgrading the present cap and site drainage as needed. RCRA requirements, such as groundwater monitoring, will continue. The ash pile to the south of the JAB will be removed. Janesville Old landfill or "1978" site: Access/land use restrictions, recovery and treatment of landfill gas by means of extraction and flaring (the PRPs have the option to test out of the landfill gas extraction and treatment by following Wisconsin's hazardous air contamination test out procedures and by demonstrating that the migration of explosive gases has been prevented), the upgrading of the landfill cap to meet the standards set by Wisconsin Administrative Cede (WAC) NR 504.07, and the continued monitoring of the groundwater and air. EPA Region 5 Records Ctr. 223098
Transcript
to0000057
Cf
SKI *X TIM) REMU1IAL AEHRCOIIVK
Site Names and locations:
Janesville Ashbeds (JAB)Janesville Old landfill ("1978H)Janesville Old Dump ("1963")Janesville New landfill ("1985")
(Collectively referred to as the Janesville Disposal Facility (JDF),located in Janesville, Wisconsin)
Statement of Basis and Purpose:
This decision document presents the selected remedial action for theJanesville Ashbeds and the Janesville Old landfill Sites (both sites are onthe National Priorities List (NPL), and the contiguous sites, JanesvilleOld Dunp and the Janesville New landfill Sites (collectively referred to asthe Janesville Disposal Facilities or JDF), located in Janesville,Wisconsin. The decision has been developed in accordance with CERCLA, asamended by SARA, and in accordance with RCRA. This decision is based onthe Administrative Record for this site. The attached index identifies theitems that comprise the Administrative Record, upon which the selection ofthe remedial action is based.
The State of Wisconsin has concurred with the selected remedy. Theletter of concurrence is attached to the Record of Decision (ROD) package.
Description of the Selected Remedy:
The selected remedy addresses the final remedy for all four sitesindividually; but this ROD treats the four sites as one site, theJanesville Disposal Facility (JDF). The selected remedies for the JDF areas follows:
Janesville Ashbeds or JAB: Access/land use restrictions, containmentof subsurface soils by maintaining the present cap and upgrading thepresent cap and site drainage as needed. RCRA requirements, such asgroundwater monitoring, will continue. The ash pile to the south of theJAB will be removed.
Janesville Old landfill or "1978" site: Access/land use restrictions,recovery and treatment of landfill gas by means of extraction and flaring(the PRPs have the option to test out of the landfill gas extraction andtreatment by following Wisconsin's hazardous air contamination test outprocedures and by demonstrating that the migration of explosive gases hasbeen prevented), the upgrading of the landfill cap to meet the standardsset by Wisconsin Administrative Cede (WAC) NR 504.07, and the continuedmonitoring of the groundwater and air.
EPA Region 5 Records Ctr.
223098
Janesville New landfill or "198511 site: Acoess/land usereocrnary and treatment cf landfill gas by saane of extraction ar*i(the "1985" system should be connected to the system installed at the"1978N site, if the PRPs do not tact out of the system at the "1978" site,and both should be able to be possibly upgraded to an energy conversionsystem), the upgrading of the cap to meet the standards set by WAC MR504.07 (the FBPs were able to show that the WAC MR 504.07 cap, alcng withthe repairs/inprovsaients to the leachate collection system and theinstallation of the landfill gas extraction and treatment system, willmeet or exceed the performance standards of RCRA Subtitle c/WAC NR 181.44(13)), and the continued monitoring of the grcundweter and air, alcng withthe Improving of the leachate collection system. The cap of the "1985"site shall be tied into the cap of the "1978" site.
Janesville Old Dun? or "1963" site: One no action alternative UBSchosen for this portion of the JDF, but access/land use restrictions (tiedin with the restrictions selected for the JAB site) and groundwatermonitoring will need to be continued, along with the other sites withinJDF.
Overall JDF groundwater contamination: Groundwater use restrictionsfor the entire JDF area and the extraction and on-site treatment of thegroundwater with the extraction veils placed between the JDF and the RockRiver. The groundwater will need to be extracted and treated, as long asthe groundwater downgradient of JDF contains contaminants that exceed theWAC MR 140 standards. Ihe groundwater extraction and treatment system maybe combined with the system that may be implemented by Parker Pen Co.,located immediately downgradient of JDF, to address groundwatercontamination problems at their facility. The treated groundwater would bedischarged to the Rock River, and must meet ambient surface water qualitystandards prior to discharge.
Declaration:
Ihe selected remedies are protective of human health and theenvironment, attain Federal and State requirements _.at are applicable, orrelevant and appropriate, to the remedial action. These remedies utilizepermanent solutions and alternative treatment technologies to the maximmextent practicable for this site. Ihe remedies for the JDF do utilizetreatment as a principal element of the remedy, as per statutorypreference.
this remedy will result in hazardous substances remaining on-site above health-based levels, a review will be conducted within5 years after commencement of remedial action, to ensure that the remedycontinues to provide adequate protection of human health and theenvironment.
DateRegional Admini
SROIT.SOLID UPSTE "C= 1580726B DEC &. 1939 12:59R- P. 32
State Of Wisconsin \ DEPARTMENT OF NATURAL
M707
File Code: 4430DEC 2 7 1989
Mr. Valdus Adamkus, Regional AdministratorU.S. EPA, Region V230 S. Dearborn StreetChicago, Illinois 60604
The Department 1s providing you with this letter to document our position onthe proposed final remedy for the Janesvllle Disposal Facility (JDF). Theproposal as Identified 1n the draft Record of Decision Includes the following:
19BS Site A landfill gas and flaring system,upgrading the cap to NR 500 standards, andrepairing and/or Improving the leachate collection system.
Estimated Costs Construction - $2,949,000Operation and Maintenance - $39,500 to $142,00030 Year Present Net Worth • $4,521,000
197B Site A landfill gas and flaring system (or to test out of the need toInstall the landfill gas system) andupgrading the cap to NR 500 standards,
Estimated Costs Construction - $3,993,000Operation and Maintenance - $52,500 to $135,00030 Year Present Net Worth - $5,331,000
1963 Site No action other than groundwater extraction (see JDF Groundwateriand continued monitoring.
Estimated Costs Monitoring Costs (not quantified)
:SOLID UftS'E 15307266 3EC 29, 1589
Mr. Adamkus 2.
JAB Cap
Estimated Costs
JOE Ground Water
Estimated Costs
Construction - $75,000Operation and Maintenance - $14,10030-Year Present Net Worth - $ 292,000
Ground water extraction and treatment to address thecontaminated ground water.
Construction - $504,000Operation and Maintenance - $57,000 to $117,00030-Year Present Net Worth - $2,184,000
The tota? 30-year present net worth for the JOF remedial action Isapproximately $12,000,000. We understand that If the potentially responsibleparties do not agree to fund the remedy, the State of Wisconsin willcontribute 50% of the remedial action costs associated with the JanesvllleNational Priority List (NPL) site*.
We alw understand that our staff will continue to work 1n close consultationwith your staff during the pre-deslgn, design, and construction phases of thisproject.
Thank you for your support and cooperation In addressing the contaminationproblem at JOF. If you have any questions regarding this matter, pleasecontact Mr. Paul Ofdier, Of rector of the Bureau of So7fd and Hazardous WasteManagement, at (608) 266-1327.
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ACRONYM LIST FOR JANESVILLE DISPOSAL FACILITIESJANESVILLE, WISCONSIN
AR Administrative RecordARAR Applicable or Relevant and Appropriate StandardsCERCLA Comprehensive Environmental Response,,
Compensation, and Liability Act of 1980COJ City of JanesvilleFS Feasibility StudyJDF Janesville Disposal FacilitiesPPC Parker Pen CompanyRI Remedial InvestigationRI/FS Remedial Investigation/Feasibility StudyRCRA Resource Conservation and Recovery ActROD Record of DecisionUSEPA United States Environmental Protection AgencyVOC Volatile Organic CompoundsMDNR Wisconsin Department of Natural Resources
SUHMUV QT REMEDIAL ALnaWMTVE SELECTION
JMQ5VIIJDB AJNIESVIIU OLD LWCFHL ("1S78")
JWCESVTLIB CUD DCKP ("1963")JANESVH1E NEW LMCFTLL ("IdeS")
OMBTKED TO FdM 1HB JN4ESVTLU DISPOSAL FTSCTLTCTIOCKEED IN JAME5VHI2, WSOGN5DI
CCXXMEER 1989
TABLE OF CONTENTS
Page
I. SITE LOCATION AND DESCRIPTION 1
II. SITE HISTORY, ENFORCEMENT ACTIVITIES ANDSITE STUDIES 3
A. Site History 4B. Enforcement 4C. Site Studies 4
III. COMMUNITY RELATIONS 6
IV. SCOPE AND ROLE OF THE RESPONSE ACTION 6
V. SUMMARY OF CURRENT SITE CONDITIONS AND SITE RISKS 7
VI. FEASIBILITY STUDY;DESCRIPTION OF REMEDIAL ALTERNATIVES 10
VII. PROPOSED PLAN 13
VEIL DOCUMENTATION OF SIGNIFICANT CHANGES TO THE PROPOSED PLAN 14
IX. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 15
X. THE SELECTED REMEDY 19
XI. COMMUNITY ACCEPTANCE 24
XII. STATE ACCEPTANCE 24
XIII. STATUTORY DETERMINATIONS 24
XIV. SUMMARY 28
ATTACHMENTS:
1. RESPONSIVENESS SUMMARY
2. LETTER FROM THE WDNR TO THE U.S. EPA DATED DECEMBER 27, 1989
CCKBINED TO FGR1THE JANESVXLLB DISPOSAL FJOIJTY (JET)UDCKEED IM JANESVTLLB, WISQGK5I1I
I.
Two sites included en the national Priorities List (NFL), the JanesvillsAahbeds ("JAB") and the Janesvills Old Landfill (the "1978 site", closed in1978), have been combined in this Record of Decision (POO) along with twoncn-NPL sites, the Janesville Old Dump (the "1963 sits", closed in 1963) andthe Janesville New Landfill (the "1985 sits", closed in 1985). Together,thess four sites comprise the Janesville Disposal Facility ("JOE"). Ins JOPis located in the north west corner of Janesville, Wisconsin (ses Figure 1)and occupies a total of approximately 65 acres south of Blade Bridge Roadand east of the Chicago-Milwaukee Railroad. The Rack River is locatedapproximately 1200 feet to the west of JOP. Ins Janesville CurrentlyOperating Landfill is located immediately north of JDF was not addressed inthe JDF study and is not addressed in this ROD. Individual sita locations(see Figure 2) and descriptions are as follows:
A) The Janesville Old Dump Site ("1963 site") operated frcn 1950 until1963, occupies approximately 15 acres and is located at the western portionof the JDF. The "1963" site operated as general refuse dump acceptingunknown types of wastes. The "1963" sits was an abandoned sand and gravelpit. The Janesville Ashbeds are located atop the northwest corner of the"1963" site and a recycling firm now occupies the northeast portion of thesits. The "1963" site is not on the NPL, but is included in this POObecause of its proximity -to the JAB and because it is a solid wastemanagement unit under the Comprehensive Environmental Response,Compensation, and Liability Act of 1980, as amended (CERCLA)/ResourceConservation and Recovery Act (RCRA) Consent Order. The RemedialInvestigation (RI) has shown that the "1963" site may be contributing to thegroundwater contamination downgradient of the JDF.
B) The Janesville Old Landfill ( "1978 site") operated from 1963until 1978, occupies approximately 18 acres and is located in the centralportion of the JDF. The "1978" site accepted both municipal and industrialwastes, including dried sludges from the Janesville Ashbeds and was licensedby the Wisconsin Department of Natural Resources (WCNR). The "1978" sitewas an abandoned sand and gravel pit. The "1978" site does not have anybottom or side liners, but was capped with variable soils, including siltysand, sandy clay, and sand and gravel, at the time of its closure in 1978.The "1978" site was listed on the NPL on September 21, 1984 after it wasshown that the groundwater around the site was contaminated with inorganicand organic corpounds.
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C) H» Janesville New landfill ("1985 lit*") operated from 1978 until1985, occupies approximately 16 acres and is located on the eastern side ofthe JET. The "1985" cite accepted municipal and industrial wastes includingdried sludge* from the Janesvills Aehbeds and MM licensed to accept solidwastes by the WCNR. The -1985" sit* is not on the HFL, but is included inthis BOO because of its proximity to the "1978" eite and became it is aKSA regulated unit under the CTRCLA/RCRA Oonsent Order, The N198SN site is
under the federal Itoeource Conservation and Recovery Act (RCRA) asa facility that closed under interim status. The "1985" site is located inan extension of the sane abandoned sand and gravel pit as is the "1978"site. The "1985" site has clay liners and siding and was capped with claywhen it closed in 1985. The site also has a leachate collection system.The "1985" site has had a history of poor cap maintenance and high levels ofgas emissions. The RE has shown that the "1985" site may be contributingto the groundwater contamination at the JDF, is contributing to thecontamination of the air around the JDF, and has excessively high leachatehead levels within the leachate collection wells.
D) The Janesville Aahbeds or "JAB", operated from 1974 to 1985 and arelocated on top of the northwest comer of the "1963" site. JAB consisted offive (5) ashbeds in which industrial liquids and sludges were deposited andallowed to evaporate or dry. The resultant dried sludge was then rflipr*ndof in the "1978" site, and upon its closure, the dried sludge was disposedof in the "1985" site. The WCNR issued a plan approval for the JAB in 1974and it was licensed to accept hazardous wastes by the WCNR in 1983. Thesite has been RORA regulated since November 1980. The JAB site was listedon the NFL on September 21, 1984 after it was shown that the groundwateraround the site was contaminated with inorganic and organic compounds.Beginning in 1983, portions of the JAB were closed, with the whole siteclosing in 1985. Closure of the JAB consisted of excavating most of thecontaminated soils, backfilling, and capping with clay. Presently, anabandoned ash pile remains on site.
The Rock River (see Figures 1 and 2) is the primary surface water body inthe JDF area, flowing from north to south in the vicinity of JDF. The RockRiver is considered an effluent stream with groundwater discharge supplyingbase flow conditions. Other water bodies located near the JDF are theexcavations created by the sand and gravel mining. One pond is locatedimmediately south of the "1978" and "1985" sites. These excavation pondsare thought to be in direct contact with the groundwater.
The JDF area is underlain by sand and gravel outwash deposits andgroundwater is present under water table conditions. The thickness of thesand and gravel deposits varies from approximately 80 to 350 feet in theimmediate vicinity of the JDF. The depth to groundwaber varies withtopographic elevation, but generally is 80 to 100 feet below ground surfacein the upland areas and within 10 feet in the low lying flood plain areasdirectly adjacent to the river. The groundwater discharges into the RockRiver. Groundwatar flow direction in the JDF is toward the southwest;toward the Rock River. There are no municipal supply wells in the immediateproximity of the JDF and no private wells exist in the line of the plume
tte JET and the Bode River. The closest downgradient private walla high capacity wall onoa uaad for industrial purposes at tha Paxfcar Pan
, but preuuitly Pufter Pan Company is connected to City water and nolonger uses tha wall. Apprcodjnately 47 private water supply veils aralocated north of Black Bridge Road and vast of U.S. 9ft 51. These veils anconsidered to ba upgradient or somewhat sidegradient of tha JET.
XX. gmt prgTCBoT. BffCRCBffiyr frrTiYiTl«f fH?
A. Sits History
1. The "1963" site was closed in 1963 after reaching} capacity. Theaita was an unengineered dtspmsal area with no liner, leachate collectionsystea or cap. Based on information provided by tha City of Janesville,closure of tha "1963" site consisted of tha placement of a final cover overthe aits, lha material used for tha cover was obtained from a borrow source
the site and the nature of tha materials was not documented.
2. lha "1978" site was closed in 1978 after reaching its capacity. Italso was constructed without a liner or leachate collection system, but wascapped with a 2 foot layer of clayey material.
3. The "1985" site was also closed after reaching its design capacity.The "1985" site was constructed with a 5 foot thick clay liner and leachatecollection system. The leachate is collected and discharged to a City ofJanesville sanitary sewer. The landfill was capped with 2 feet of clayinstalled in two 1 foot lifts compacted in place. Final closure activities,in compliance with Wisconsin Administrative Cede interim status Chapter MR181.44(12), were completed by October 19, 1985. Following tha final shapingof the site and placement of the clay cover, 6 inches of topsoil, seed,fertilizer and mulch were applied. Facility Closure Documentation Approvalwas received from the WCNR on November 11, 1986 and the City of Janesvilleresponded to the conditions in the WCNR Closure Approval Letter on April 8,1987.
4. JAB beds 1 and-2 were closed in 1983 ard 1984. Bed 1 was excavatedin January 1983 by the City of Janesville and 1,175 tons of the excavatedmaterial was placed in the "1985" sits. Bed 2 was excavated to a depthapproximately 3 feet below the bottom of the waste, in April of 1984.Approximately 3,175 tons of material was loaded into licensed hazardouswaste hauling trucks ard disposed of at Browning Ferris Inc. (BFI) facilityin Winthrop Harbor, Illinois. Miscellaneous rubble material was encounteredat the base of the excavations in beds 1 and 2 ard the excavated areas werebackfilled with sand and gravel to conplunent the surrounding grade. Beds 3,4 and 5 were closed completely in 1985 following a request by the U.S. EPAand the WCNR that no more waste be accepted after the summer of 1985. Tharemaining wastes in Beds 3, 4 and 5 were removed by backhce, loaded ontotrucks, and disposed of at an off-site licensed hazardous waste disposalsite. After analysis of the underlying clay liners, the remainingcontaminated material in the three beds were removed. Following thiscleanup, each bed was backfilled with on-site sand ard gravel to a heightconsistent with the surrounding contours and capped with 2 feet of clay.
The day cover was graded, sloped, and covered with 6 inches of top soil andseeded. Final facility Closure Documentation Approval was received from thaWO*t on November 10, 1986 and the city of Janesville responded to thaconditions in tha closure approval latter on Dampjjst 9, 19M.
B. fitfOKoeasnt
Preliminary assessment*, sit* inspection raporta and Hazard Ranking Systen("HRS") scoring pactagas, all oonductad in 1983, for tha JAB and tha "1978"sites indicatad that thara exists actual or potential for release* ofhazardous substances into tha environment which say poaa a risk to human*and/or tha environment. Tha aitaa' HRS aoores were high enough (abova tha28.5 out off) so that both aitaa wara included on tha NFL in September1983.
Notice lattara informing 24 potentially rasponaibla parties ("ERP»")(including tha sites' owner/operator, waste generators and transporters) oftheir potential CEROA liability for tha JAB and "1978" sites, and offeringthan the opportunity to perform the Remedial Investigation/Feasibility Study("RI/FS"), were nailed via certified nail on November 27, 1985. During thacourse of the RI/FS negotiations, it was agreed by all parties to combinethe four sites that comprise JEF into a single RI/FS under the jointauthority of CERCLA and RCRA. The U.S. EPA, HCMR and 15 PRPs signed aConsent Order under the joint authority of CE8CXA and RCRA in the fall of1986, with the effective date of December 8, 1986. The Consent Order setaforth tha agreement that tha RRPs will conduct an RI/FS at the JET under thedirect guidance of the U.S. EPA and the WCNR. The PRPs hired WarzynEngineering, Inc. to conduct the RI/FS.
Negotiations for the remedial design/remedial action (RO/RA) with the PRPswill proceed according to U.S. EPA general guidances and policies. Theparticipants in the negotiations will likely include the PRFs, WCNR andCERdA and RCRA offices of U.S. EPA.
C. Site Studies
The JDF area has been the subject of many independent studies to determinespecifics for each of the individual sites. Sons of these studies/reportsdeal with the RCRA requirements of the JAB and the "1965" site. The paststudies/reports can be found within the Administrative Record as referencedin the Administrative Record Index attached to this ROD. The RI Report,the FS Report and the Preliminary Health Assessments for JAB and the "1978"sites are also included in the Administrative Record and their results aresummarized in this ROD as follows:
1. Preliminary Health Assessments for JAB and "1978" sites:
Preliminary Health Assessments for JAB and tha "1978** site were conducted bytha Wisconsin Division of Health and prepared for the Agency for ToxicSubstance and Disease Registry (ATSCR) as par Section 104 (i) (7) (A) ofCERX£A. The reports are dated April 14, 1989, but utilized data gatheredonly through the first round of the RI. The Health Assessments' conclusions
and lauaaMoUliutti state that oontaBinatad groun.lMatar is the main concernat thi* tiaa, and reccaaairito that tha residential walls locatad to thenorthwest of JDT be tested. The Aaaaaaaanta alao ' **'• ""r frfl that »ore weekba dona to avaluata the potential of air contamination and that nor*Information ba obtained regarding the municipal walls. Moat, if not all, ofXISCR'a concern* war* -nlli annul in eubeeojuant RZ phases, including thaaaapling of tha residential walla locatad to tha northwest of JET. thehaalth •aaani'imMifr. alao recommended that air saaplea for volatile organic* baoonductad in residencee that lia over tha contaminated groundwater plvrn*.Thia sanpling naada to ba conductad bafora or during tha daaigpn of thagrcundwatar renediaticn.
2. Ranedial investigation (RZ) Raport
Tha RZ field work began in Saptanbar, 1987 and was corpleted in March, 1989.Tha RZ at tha JCP oonsistad of tha installation of grounduatar nonitoringwalla, laachata neadwalla and gaa prcbea to ba oaabinad with tha existingwalla and probes to enable extensive sampling of tha laachate, groundwaterand gaa at and around tha JDF. Surface water and sediments from tha pondlocatad inaediataly south of tha "1978" and "1985* site war* sampled aa wallas surface water and sedinents frcai tha Rock River. Tha RZ Report, with anEndangennent Assessment ("EX11) included, waa completed on July 20, 1989.Tha RZ Raport as well as tha RZ work plan and Quality Assurance ProjectPlan, are part of the Administrative Record.
Tha RZ consisted of five rounds of sampling with tha following madia andparameters involved: (Sanple locations are labeled in Figure 3)
Round Z - Sampled select groundwater monitoring walla (14) and leachatawalla (7) for the full scan of Target Cdtpound List parameters andindicator parameters to determine if parameters could ba deleted from futurerounds of sampling. RO& Appendix ZX parameters ware also sampled forduring Round Z. (December 1-5, 1987)
Round ZZ - 44 groundwater monitoring wells and 10 surface water locationswithin the Rock River and the Pond south of the 1985 and 1978 sites waresampled for Volatile Organic Compounds (VOCs), Semi-volatiles, metals,cyanide and indicator parameters. (April 18-21, 1988)
Round ZZZ - 44 groundwater monitoring wells and 10 surface water and sixsediment locations within the Rock River and tha Pond south of tha 1985 and1978 sites were sampled for VOCs, metals, cyanide and indicator parameters.(July 11-15, 1988)
Round IV - first round of air sampling for VOCs and particulates froaleachata wells, gas vents, sewer blower and the ambient air. (September 26and 27, 1988)
Round V - second round of air sampling for VOCs and particulates fromleachate wells, gas vents, sewer blower and the ambient air. (December 8ard 9, 1988) t
LEGEND
^—170~-^—
X 107 3
CD
VII
SUI A
SD2 •
SGI -^
CVl ®
LH l J -
E X I S T I N G GPOui.u oiNirii.-.
[ X I S T I r i G SrOI ELIVM 10'.1
[xmiNG BUILDING;
[UGC Of W A T E R
T R E E S AUU SHRUBS
U T I L I T Y POLE
R A I L R O A D TRACK
COGE OF GRAVEL PIT
DIRT ROAO/GRAVCl ROAO/1RAIL
APPROXIMATE JAIIESVIILE DISPOSAL F A C I L I T Y L O C A T I O N
APPROXIMATE JANESVILIE PROP£»Tl L I M I I S
MONITORING WELL LOCATION »NU NUMBER
SURFACE UATER SAMPLING LOCATION AND N'JMEIK
SEDIMENT SAMPLING LOCATION AND HIIHOEH
STAFF GAUGE LOCATION AND NUMBER
GAS VENT LOCATION AND NUMBER
LEACHATE WELL LOCATION ANO NUMBER
Figure 3
NOTES
I. THE TOPOGRAPHIC BASE HAP IS A COMPOSITE OF AERIAL SURVEYS. PROVIDED BY. THE C I T Y OF JANESVILLE; THE AREA WES! OF THE $00 LINE RAILROAD
NORTH OF BLACK DRIOGE ROAO ANO W E S T OF THECHICAGO AND NORTHWESTERN RAILROAD (C AND NW. RR ) PERFORMEDOY MARK IIURO AERIAL SURVEY, MINNEAPOLIS. MINNESOTA FLOWN:1975. THE REMAINING AREA WAS PERFORMED BY A£RQ-HETR!CENGINEERING. INC. SHEBOYGAN. WISCONSIN, FLOW^ 4-16-80
*. CONTOUR INTERVAL IN PROJECT AREA - 2 FT. CONTOURS ARE REFERENCEDTO THE C I T Y OF JANESV1LLC DATUM. TO CONVERT TO U .S .G .S . DATUM.
ADO 676.58 FEET TO CITY DATUM.
3. HORIZONTAL CONTROL IS WISCONSIN STATE PLANE COORDINATE GRIDSYSTEM. THE GRID WAS LOCATED BASED ON INFORMATION PROVIDED
BY THE ROCK COUNTY SURVEYOR.
4. PROPERTY LINE LOCATION WAS PROVIDED BY THE C ITY OF JANESVILLE
AND IS APPROXIMATE IN NATURE.
5. TOPOGRAPHIC REVISION INFORMATION IN AREAS OF -1985" S ITE AND •JAB-WAS PROVIDED BY CITY OF JANESVILLE, BASED ON CLOSURE PLAN
DOCUMENTS.
6. TOPOGRAPHIC INFORMATION OUTSIDE THE STUDY AREA, NORTH OF BLACKBRIDGE ROAD, RESULTING FROM THE C I T Y OF JANESVILLE LANDFILLA C T I V I T I E S AND JANE5VIUE SANO ANO GRAVEL EXCAVATION, HAS NOT
Six residential drinking water wells, located to the northwest of the JDF,were asapled for VOO§ only by tha U.S. S* on March 27, I9t9. The purposeof these •amylaa was to screen the residential walls to determine if thaconclusions from the draft RX wars correct, and to determine if moreinvestigation say be warranted. Mb VOQi wars detected in these walls thatcould be attributed to the JDF, but tha residential area shall continue tobe monitored. „
3. Feasibility Study (FS) Report
Tha FS Report was submitted in draft form by tha Respondents to the U.S. EPAon August 7, 1989. Garments were made by the U.S. EPA and tha WQNR and thaReport was released for public cement on August 21, 1989.
III.
An RX/FS public meeting was held on August 13, 1987 to inform tha localresidents of tha Super-fund process and about the work to be conducted underthe RI. Many of the issues raised by the cconunity involved the currentlyoperating landfill north of Black Bridge Road, general health related topicsand concern about odors caused by current and past landfill activities.
TVx> information repositories have been established: at the JaneevillePublic Library, 316 South Matin Street, Janesville, Wisconsin and at thaJanesville Municipal Building, 18 North Jackson Street, Janesville,Wisconsin. According to Section 113(k)(l) of GBV2A, the AdministrativeRecord has been made available to the public at the Janesville PublicLibrary.
A public meeting, attended by nearly 40 residents, was held on May 31, 1989to discuss the findings of the RI. The Wisconsin Department of Health wasalso present at the meeting and dt«<nis!qart health related issues and thePreliminary Health Assessment.
The draft FS and the Proposed Plan were available for public oonment fromAugust 21, through September 15, 1989. A public meeting was held on August30, 1989 to present tha Proposed Plan and the FS Report. COnnents receivedduring the public ouumant period and the U.S. EPA's responses to thosecontents are included in the attached Responsiveness Sumnary. Theprovisions of Sections 113 (k) (2) (B) (i) - (v) and 117 of CERdA have beensatisfied.
IV. SCOPE AND PPL£ OF THE PEgPffifiE ACTION
The scope of this response action is to provide a final remedy to addressthe contamination and potential contamination caused by the waste dispoBPdof in each of the JCF sites. The response action will address the principalthreats caused by the sites, such as tha groundwater contamination betweenthe JDF and the Rock River and the air contamination at and near tha "1978"and "1985" sites. Tha final remedy will also include cap repair orenhancement for each of the four units within the JDF and since wastes willremain en-site, periodic monitoring will need to be maintained, as well as a
7
review of nrrrtlttusi after 5 years.
V« smftlBf Of BPff SrTB Onm'l'J- ^ ANn SITE
The RI/FS Reports nave adequately described the current conditions of thefour sites within tbt JET. Contaminants detected at JET, theirconcentrations and the affected Madia are susnarized in Table i.Contaminants found that can be associated with specific sources or sites andspecific nedia within those sites are listed in Ttables 2 through 5.
The RI Report and the EA make the following conclusions:
* Ground water in the area of JtF flows towards the southwest anddischarges into the Rock River.
* There are no residential or municipal drinking water wells in thedirect line of groundwater flow between the JCP and the Rock River.
* The JAB is contributing to groundwater contamination which excoods theFederal Maxima Containment Levels ("MCLs") and Wisconsin EnforcementStandards. This contaminant plume is heading away from the site towardthe southwest with a small ocnponent heading northwest prior to turningtowards the southwest. JAB is not believed to be contributing to aircontamination in the area of JTF or to the contamination of the Pondbut may be contributing to the contamination of the Rock River due tolocal groundwater discharge into the River.
* The JAB is contributing to the groundwater contamination of the area.The 1963 site is believed to be contributing little or no contaminationto the groundwater. The 1963 site is not believed to be contributingto the air contamination of the JDF area except for low concentrationsof methane emanating from the sits.
* The 1978 site is contributing to groundwater contamination in thearea. Concentrations of \TOCs and inorganics in the groundwaterdowngradient from the 1978 site have been found to exceed the State'sEnforcement Standards.
* The 1985 site and/or the 1978 site are contributing to thecontamination of the groundwater as detected in the monitoring wellslocated between the- two sites.
* Groundwater monitoring wells located in upgradient positions to the JDFhave shewn some contamination, but this is most likely, especially inthe case of the wells nearer to the JAB, caused by mounding effects ofthe groundwater due to the volume of wastes put into the sites.
* Samples frcn the gas vents within the 1978 site and the 1985 site andof the ambient air at the sites' borders indicate that these sites areemitting VDCs and methane into the air. Potential cancer risks due toair quality on-site is high but risks off-site are not known sinesfactors to account for atmospheric dispersion were not incorporatedinto the site's risk potential. Concentrations for methane in gasprobes in and near the "1978" and "1985" sites were found to be in theexplosive hazard range. The JAB and the "1963" sites have not beenshown to be contributing to the air contamination in the JEF area.
* The 1978 site is contributing low levels of organic and inorganiccontamination to the pond's (located just southeast of the site)surface water and sediment. The 1985 site may also be the cause of
* Refer to Section 8.3 for data sources and criteria for site contaminationcharacterization. Also, refer to appropriate appendices to determine totalchemicals Included 1n each analysis.
b Elements considered as positive detections for groundwater and surface watersamples exceeded available State of Wisconsin Groundwater Standards,Preventive Action Limits as described 1n Chapter NR 140 of the WisconsinAdministrative Code (Table 53).
c Elements considered as positive detections in subsurface soils and sedimentsexceeded the upper limit pf the common concentration range for soils asdescribed by Lindsay, 1979 (Table 53).
13076.50BJC/Jlv/MVK[jlv-400-39e]
TABLE ?
SUMMARY OF VOCs DETECTED IN GROUNDUATER"1985 Site"
First Column Is Round 2 data; Second column Is Round 3 data.Concentrations In ug/L; If no value Is reported, compound Mas not detected at contractlab required detection limit.
AJS/sss/NG[jp)-602-20d]13091.80
IABU ?
ROUNDS 2 AND 3 TCL hflAlS AND CYANIDE CONCfNTRAIIONS•IMS" Silt
Concentration* are In ug/l unless olhcrMlse noted; If no concentration reported, compoundMS not detected at contract laboratory required quant I tat Ion Halts.
13091.60AJS/sss/NC(Mpte«p-400-63)
TABLE I
ROUNDS 2 AND 3 INDICATOR CONCENTRATIONS•1985- Silt
First colujM Is Round 2 data, second coluwi Is Round 3 dataConcentrations are In Mg/L. If no concentration Is reported, compound Mas not detected at CRQL except forWells W-14 and 2 for Round 2 data In which no samples were collected for Indicator parameters
SGU?/sss/TJM[wpte>p-41? 90]
1111•
1
1•1
1111•
11I1111
TABLE 2
SUmART OF NR140 EXCEEDANCES
Monitoring Well* - *1985' Sited)
Preventive EnforcementPframtter Smelt Jp Action Limit Standard
First column ts Round 2 data; second coluan U Round 3 data.Concentrations presented in uq/l unless otherwise noted; if no concentration reported, compounds was not delected at contractlaboratory required quant it at ion Halt.
1)091.60AJS/sss/MG(wptcap-400-64)
IAIILC 3
ROUNDS 2 AND 3 INDICAIOR CONCfNlRAT IONS"19/8" Sill
First column Is Round ? data, second column If Round 3 dataConcentrations are In mq/l, If no concentration Is reported, compound was not detected at CRQl, except no saapl?scollected for Indicator parameter data. Wells W-IO Rounds 2 and 3; W-16. 3A and 4A Round 2.
First column is Round ? data; second coluan is Round 3 data.Concentrations in ug/l; if no value is reported, compound was not detected at contract lab requiredquantitat ion li«it.
AJS/sss/NfG[jpl-602-20i]13091.80
TABLE 4
SUMMARY OF METAL AND CYANIDE DETECTED IN GROUNOUATER"196J" SUE
First column is Round 2 data; second colimn is Round 3 data.Concentrations in ug/L unless stated otherwise; if no value is reported, compound was not detected at contract lab required quant itat ion Unit.
13091.60AJS/SSS/NG[J.l-602-ZOcJ
I ABLE 4
ROUNDS 2 AND 3 INOICAIOR CONCENTRATIONS"l«»(,3" Sllf
First column Is Round 2 data, second column Is Round 3 data.Concentrations are In mg/1, If no value Is reported, compound Mas not detected at CRQL exceptno samples were collected for Indicator parameter analysis. Wells W-IO and B-109Rounds 2 and 3; nd Wells W-26. W-26A and U 105, - Round ?.
W-27
4.044760
8.94
7.95
367.8372
0.41
0.400.01
1.0270?2
0.48
0.36
306.8143
2.97
0.05
335?9
0.61
0.52
31
400
5.66
0.11
i
3.048740
2.68
0.28
581.554
1.52
0.050.03
2.0 4.0454 57441 88321.78 11
0.61 8.7
50 4418. 1 SI1000 4280
2.83 0.05
0.36 5.440.06
2.0 3.0552 54592 353910.2 12.4
9.81 10.8
38 484.4 7.61550 908
0.44 0.31
1.81 0.740.03 0.03
5)3323610.9
9.94
463.670
0.73
0.08
SGW2/skb/TJM[wptemp-412-90]
1111w
\111
11II
SUMMARY
TABLE 4
OF NR140 EXCEEOANCES
Downgradlent Wells - "1963* Sited)
Piru*ter Sample ID
Btrtum W-25-01 0)W-27-01W-25-02W-25-03
Lead w-25-01W-27-03
Iron W-25-01W-25-02W-25-03
Manganese W-25-01W-27-01W-27-02W-25-03W-27-03
TMchloroethene W-25-02W-25-03
Vinyl Chloride W-25-02W-25-03W-27-03
Tetrachloroethene W-25-02W-25-03
1,1-Olchloroethene W-25-02W-25-03
1,2-Oichloroethene W-25-02w-25-03
Preventive EnforcementAction Limit Standard
200 1000
5 50
150 300
25 50
0.13 1.8
0.0015 0.015
0.10 1.0
0.024 0.24
10 100
Concentration1n Samole ^21
236232234260
57.1
76714202180
1640113099115901310
96110
1.088
2020
32
2337
(1) Downgradlent Wells - '1963' Site: W-25 and W-27(2) Units 1n ug/L unless otherwise noted.(3) W-25-01 Indicates Well W-25 Round 1 data; -02 Indicates Round 2;
Fint column is Round 2 dttt; second colu«n It Round 3 d«t». . , ,. ,Concentrations in ug/L; if no value is reported, compound was not detected at contract lab required quant itat ion licit.
AJS/dU/NfG[dlk-400-36]
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1ABK ^
ROUNDS 2 AND ) INDICAIOR CONUNJBAI IONSJAB
Upgradienl Wei It DotooTadlent Hells
W 10 B 105 U 21 i 109 60U 6B B 104 W-?8 U-28A US ||-St y_?1
First Coltwn is Round 2 data second colywt is Round ) data.Concentrations are in M/l. If no value is reported compound was not detected at CRQl except no samples were collected for indicator parameter analysis.Hells U-IO. 1-109 and V-2). Rounds 2 and ); and Uells B 105. 60U. 6B. B-104; Round 2.
SGll/skb/TJH(wptnp-412-90)
£
Iron
lead
Manganese
THchlorotthene
Vinyl Cnlorlde
TABLE 5
OF NR140 EKEEDANCES
Upgradltnt Vtlls -
Sample ID
¥-21-02(3)B-109-02W-21-93
W-10-02
W-21-02B-109-02W-21-03
W-21-02B-105-028-109-02W-21-03B-105-038-109-03
W-21-02B-109-02W-21-03B-109-03
1,1-DUMoroethene B-109-02B-109-03
1 ,2 -Dich lo roe thene B-109-02B-109-03
PreventiveAction Limit
150
5
25
0.18
EnforcementStandard
300
50
50
1.8
0.0015
0.024
0.015
0.24
10 100
ConcentrationIn Sample (?]
17204230892
5.2
7921100797
501804929100120
47415
63
120100
(1) Upgradlent Wells-JAB: W-10, W-21, B-105, 8-109(2) Units are 1n ug/L unless otherwise noted.(3) W-25-01 Indicates Well W-25 Round 1 data; -02 Indicates Round 2;
contamination found in the pond.* The contamination of the groundwater at and near the JEF may be
influenced and/or combined with contamination from sources outside ofthe JET area. Other potential or actual sources of contaminationincludes the Parker Pan Facility, located just vast of the JET, thacurrently operating landfill just north of the JOT, and other potentialsources which aay be located upstream from JET, on the Rock River.
* Doungradient Rock River surface water and sediment has shown somecontamination with volatile organic and inorganic compounds. Tha exactsource of the contamination can not be determined but the compoundsfound are similar to those found at the JET and at the Parker Pen site(located between JET and the Rock River).
* Parker Pen Co. lies between the JET and the Rock River. High levels ofVOC and chromium contamination were found ianediately down gradientfrom Parker Pan. The high levels are attributed to past releases atthe plant including a 1985 spill of TCE and a possible rupture or leakof a sewer line leading from Parker's old plating facility (source ofthe chromium). The WCNR is conducting a separate investigation of thecontamination caused by Parker Pen.
The RI Report contains an Endangerment Assessment which characterizes thenature and estimates the magnitude of potential risks to public health andthe environment caused by the contaminants identified at the JDP. Tha EA,utilizing data obtained from the RI, has identified the following pathwaysor routes of actual or potential contamination that may reach thepopulation and/or the environment and which need or may need to beaddressed through sane type of remedial action:
a. Individuals breathing contaminated air, assuming they are exposedto concentrations measured in ambient air on-site;
b. Hypothetical users of private well water, assuming a private wellis installed within the contaminated aquifer in the future;
c. Children which may swim in the pond immediately south of the "1985"and "1978" sites; and -
d. Environmental damage to the organisms within the Rock River and/orthe pond located south of the "1985" and "1978" landfills.
The following indicator chemicals were considered to be representative ofsite contamination and to pose greatest potential health risk:
Ttm risks associated with each of the potential pathways using the indicatorchemicals for the JET are as follows
•. Under currant site conditions, a potential health riskidentified for individuals exposed to contaminant* identifled in asfcient airen-sit* via inhalation of volatile contaminants. A calculated carcinogenicrisk, using the contaminants nsthylene chloride, benzene and vinyl chloride,of 7.0E-O4 (or seven people out of 10,000) VMS identified with theassumption that these individuals would be exposed to average contaminant
Ttrations measured on the landfill property. A higher risk (1.2E-02)would result if it is awmiwrt that the individuals are exposed to only
M contaminant concentrations. Thsss risk estimates, however, did notincorporate factors which would account for atmosphericdispersion/degradation of the contaminants off-site. Risks to subchronicnon-carcinogenic health hazards associated with air contamination at JDP arelisted in the FS as low, with a total exposure pathway hazard index of lessthan a value 0.05 for maximum exposures to both children and adults.Chronic non-carcinogenic health hazards are also low, with a total exposurepathway hazard index of 0.23 with an average concentration of 0.025 (HazardIndex values of over 1 indicate there may be potential health risksassociated with exposure to the chemicals evaluated) .
f . For grourdwater consumption, potential carcinogenic risks rangedfron approximately 1.4E-03 from exposure to average site contaminantconcentrations to 1.2E-02 from exposure to i"»yimw site contaminantconcentrations. Potential risk to the adverse non-carcinogenic effectswhich may result from a subchronic exposure period for both children andadults, assuming exposure to maximum contaminant concentrations, have beencalculated as having the hazard index value of 18 for children and 12 foradults. Average concentration exposures would give subchronic hazard indexvalues of 0.8 for children and 0.57 for adults. Potential risk to non-carcinogenic effects which may result from chronic exposure were calculatedfor the non-carcinogenic compounds, acetone and 1,1,1-trichloroethane andthe total pathway risk was calculated to have a maximum hazard index of 0.82and an average value of 0.034.
g. Health risks for children which may swim in the landfill pond weredetermined to be 1.5E-08 (total cancer risk from dermal absorption ofcontaminants and incidental ingestion of water) . The FS states that thelandfill pond does not present risks significantly higher than what would beexpected from other surface water bodies. Potential risk to non-carcino-genic health effects were estimated only for incidental ingestion of watercontaminated with 1,1-dicnloroethane and was determined to be very low witha hazard index of 1.2E-07.
h. The EA within the RI Report concludes that the exposure ofenvironmental organisms to contaminants identified from the JCFinvestigation is very low due to the low concentrations of chemicalsidentified in the Rock River and in the landfill pond's surface water andsediments. According to the EA, it appears that there is little potentialfor adverse effects to the aquatic organisms in the Rock River or in thelandfill pond ecosystems because the lowest reported toxic concentrations
10
(Aabient Mater Quality Criteria) in any freshwater ooganiM are nor* than1000 tiaes greater than what is yi'aaaiit in tha surface water or sediments
Ths analytical methods used in making the risk calculations ars describedwithin tha EA portion of the RI Report.
Ths potential exposure pathways ars listed in Figure 4 and in Table 6.Sunutries of tha cancer and non-carcinogenic (chronic and subchronic) risksassociated with tha overall JET ara listed in Tables 7 and 8. Table 9shows state and federal enforcement standards that apply to tha indicatorchanicals for the JCP aits.
Within tha FS Report, several technologies and process options werepresented for the sites comprising the JET. Criteria used to evaluate thaalternatives for applicability at these sites and to conduct tha initialscreening of the alternatives for each of tha sites ara explained within thaFS Report. Stannaries of the alternatives retained for final considerationat the four sites comprising JDF and the alternatives to address the overallsits problems are listed below. More detailed descriptions can be foundwithin the FS Report.
TOE "1985* STTEALXEBNXnVB 1 - HO JtfXICNUnder this alternative, tha public health, public welfare and environmentalconsequences of taking no further action at tha "1985" site will beevaluated. ARARs concerning landfill gas (HLFGN) emissions and landfillcapping will not be net with this alternative.
ALTERNATIVE 2 - ACCESS RESTKICnCK3, CCNIAINMQfr OF HASTE, RECOVERY. OPIAMFILLGAS AND KNTFGKDGThis alternative will involve the use of deed and land use restrictions toassure that future use of this sits does not increase the release orpotential release of hazardous substances to the environment or becomedangerous to the life or health of tha people. A fence will be installedeither around the entire site or only around the gas vents, to restrictaccess. This alternative also calls for the extraction and treatment oflandfill gas at and near the 1985 site. Gas extraction wells would beinstalled at various locations within the landfill to recover IPG. Thevarious LFG extraction wells would be connected by a gas header pipe systemto a mechanical blower, which will create zones of low pressure within thelandfill and induce gas flow into the wells. The landfill gas that isextracted would then be flared off. The landfill gas system may be built tobe converted at a later date to an energy conversion system.
The waste containment portion of this alternative calls for the present capto be evaluated and improved either by cap repair or cap enhancement. Caprepair could consist of site regrading and placement of additionalcompacted clay to improve drainage and repair cracks. Enhanced cappingwould consist of either upgrading the existing cap to meet tha requirements
Unlikely, allhoufhprivate wells nolsailed, datasuoaests privatewells not currentlyimpacted. However,potential for futureprivate well Impactexists
Ves. childrenobserved playing Inpond
Ves
Likely None; currentIv. VetItodcrate; private wellusers could be eip«sedIn fu'ure throwfhconlaalnant alarat Ion ornew private wellInstallation.
Very low. let. forcontaminant concentrations chllditnlow p)*ylr In
Very l«», contaminantconcentrations low.
Aa*lent Air Direct contact,volal(Illationfro* landfill
Jlnesvlllc residents. Inhalation Ves Moderate Ves
1)076.SOBJC/jlv/AJS(jlv-400 )9j)
lAUlf
HA/ARI) INDICES FOR NON-CARCINOGENIC EFFECIS FROM SUBCHRONIC EXPOSURETO MAXIMUM AND AVFRAT.L CONTAMINANI CONCCNIftAl IONS
Groundwater
Nethylene chlorideMAX 1 BUMAverage
AcetoneMax 1 KMAverage
1.1 -01 chloroe thaneMaxlMMAverage
1,1.1-IrlchloroethaneMix 1 MiaAverage
TetrachloroetheneMax 1 MiaAverage
b1s(2-ethylhexyl)phthalateMaxIwMAverage
ArsenicMax (MMAverage
ChildIngest Ion Inhalation
4.8E-016.7E-03
9.6C-02 1.2C-022.9E-03 3.7E-04
2.0E-04 6.4E-041.3E-04 4.3E-04
1.6E-03 l.BE-037.1E-04 7.7E-04
1.6E«011.8E-OI
2.8E-02I.OE-02
l.3E*006.0E-OI
AdultIngest Ion Inhalation
3.5E-014.8E-03
6.9E-02 4.0E-032.1E-03 I.2E-04
1.4E-04 2.1E-049.2E-05 1.4E-04
1.1E-03 5.7E-045.1E-04 2.6E-04
I.IE*011.3E-OI
2.0E-027.0E-03
9.6L-014.3E-OI
SurfaceWater Aflblent AirChild Child
Ingest Ion Inhalation
..
4.0E-042.1E-04
I.2E-07 8.1E-042.9E-04
4.4E-024.9E-03
__
_.
-_
MWItlafcalatlon
—
l.4E-)47.lE-il5
2.6E-049.7E-05
1.5E-021.6E-U3
—
..
—
TABLE 7 (continued)
Intake Route TotalMax I MMAverage
Exposure Pathway TotalMaxlMMAverage
GroundwaterChild
inqestlon
1.8E+018.0E-01
18
Inhalation
1.4E-021.6E-03
.8E*01
.OE-01
AdultIngest ion Inhalation
1.2E«01 4.8E-035.71-01 5.2E-04
1.2E*015.7E-OI
SurfaceWaterChild
Ingest Ion
1.2E-07
1.2E-07
Aablent AirChild
Inhalation^^ • ••••••••M*
4.5E-025.4E-03
4.5E-025.4E-03
«*nr~TiKalalToTi
1.5E-02I.flE-03
1.5E-0?1.6E-0)
Hazard Indices Mere calculated only when Critical Toxlclty Values were available (Table 8.6). Therefore, only InJIcator:healc* Is with U.S. EPA verified reference doses are shown In this table. A1C values were used as health-protectiveestimates for AIS values when A1S values were not available.
\ subchrontc exposure Is an Indefinite period of tlae often considered to be In the range of 101 of an Individual'sllfespan.
(--) Indicates that either no reference dose for the exposure route was available (Inhalation), or that the compound wastot detected In the Medlun (surface water - Ingestlon).
UC/Jlv/NWKrjlv-400-39n]1)076.50
EXl
TABLE 7
INDICES FOR MQNCARCINOGENIC SFFECTS FROM CHRONIC"TOKMlMUH AND AVERAGE CONTAMINANT CONCENTRATIONS
AettontMaxliAverage
1,1,l-Tr1chloroethaneMaximumAverage
Intake Route TotalMaximumAverage
Exposure Pathway TotalMaximumAverage
Groundwater
Lifetime Averaot
Inhalation
Air
7.4E-012.3E-02
1.2E-025.6E-03
7.5E-012.9E-02
5.7C-021.7E-03
8.3E-033.3E-03
6.5E-025.0E-03
8.2E-013.4E-02
Lifetime Average
Inhalation
1.9E-02l.OE-03
2.1E-012.4E-02
2.3E-012.5E-02
2.3E-012.5E-02
Since potential cancer effects were considered the most severe health thr«»ifrom chronic exposure, hazard Indices (HI), were calculated for exposure t:only non-carcinogens. His were calculated from lifetime averageconcentrations.
U.S. EPA verified reference doses for l,2-d1chloroethene were not availableand thus, non-carcinogenic hazard was not quantified.
Since exposure to surface water was defined as a subchronlc exposure,calculation of risk to noncardnogenlc effects from chronic exposure was notapplicable.
13076.50WC/Jlv/JOO[jlv-400-39r]
1I1•ii
i
iaw1
1
TAJLE A•»
CANCER RISK FROM EXPOSURE TO MAXIMUM AND AVERAGE^^ CONTAMINANT CONCENTRATIONS
' Maximum Contaainant Levels fHCt) are enforceable standards defined under the Safe Drinking wate-Act, to determine safe levels of a given contaainant in the public drinking water supply. TheMCL is defined as the allowable lifetime (70 yr) exposure (2 L/d) to a given contaminant for anaverage adult (70 kg) not to be exceeded without risk to health. Factors involved in itsdetermination include gastrointestinal absorption, a safety factor to protect potentiallysensitive populations and the economic and technical feasibility of clean-up.
Maximum Contaminant Level Goals (MCLG) are the non-enforceable health guidelines for acontaminant level in drinking water which would cause no known or potential adverse effect.MCLG. which are always less than or equal to MCLs, do not consider factors related to clean-up.
^ Health Advisories (HA) are non-enforceable standards provided by the EPA Office of Drinking Wate-which represent concentrations of contaminants in drinking water which are not anticipated tocause adverse health effects. The HAs were determined from toxicity data describing non-carcinogenic end points only and are calculated for acute (1 day), subchronic (10 day) and longe-term (months to years) exposure scenarios. In their derivation, it is assumed a 10 kg child(infant) consumes one liter of water per day and that a 70 kg adult consumes 2 J''"-s of waterper day. Since the cis ijomer of DCE usually predominates in environmental sa«t>'-i, values arefor cis-DCE.
c Chapter NR 140 of the Wisconsin Administrative Code defines standards for state j'oundwaierquality. "Enforcement Standards' and "Preventative Action Limits* are health-tusra concentrationof contaminants which when attained or exceeded require appropriate mitigative arsons.
13076.508C/jlv/AJS[jlv-400-39qj
11of a Wisconsin Administrative Code (WAC) NR 504.07 cap or upgrading theexisting cap to neat the requirements of a RCRA Subtitle C/WAC Ml 181.44(12)cap for RCRA interim status facilities or RCRA subtitle C/WSC Ml 181.44(13)cap for RCRA licensed facilities (see Figures 5 and 6 for typical capdesigns). The WAC NR 504.07 cap is we stringent than the cap that isapplicable to this site, the RCS* Subtitle C/WAC NR 181.44(12) cap forinteriB status facilities, since the VAC NR 504.07 cap requires an extrasoil layer to account for frost line protection.
The monitoring portion of this alternative calls for the continuedmonitoring of the groundwater and air, and the long-term maintenance of thecap in accordance with the appropriate Wisconsin Administrative Codes.ARARs regarding IPS emissions and landfill capping will be addressed by thisalternative. Estimated costs are based on ranges depending on what type ofcapping is selected.
Estimated Construction Cost: $1,141,000 - $5,278,000Estimated Annual O&M Cost: $39,000 - $142,000Estimated 30 Year Present Net Worth: $2,713,000 - $6,850,000
THE "1978* SITEAUHFNAITVE 3 - NO ACTIONUnder this alternative, the public health, public welfare and environmentalconsequences of taking no further action at the "1978" site will beevaluated. ARARs concerning IIG emissions and landfill capping will not bemet with this alternative.
AUEEFNATIVE 4 - ACCESS RESTRICTIONS, CCKIAINMEWr OF WASTES AND SUBSURFACESOILS, AND 1HE RECOVERY OF LANDFILL GASThe access restrictions and landfill gas recovery/treatment portions of thisalternative are the same as within Alternative 2 for the "1985" site. Thecontainment of wastes and subsurface soils includes evaluating the presentcap, and upgrading it to meet either the requirements of WAC NR 504.07 ormeet the requirements of RCRA Subtitle C/WAC NR 181.44(13). Groundwater andair monitoring will continue as well as the long-term maintenance of thecap. ARARs regarding LPG-emissions and landfill capping will be addressedby this alternative. Estimated costs are based on ranges depending on whattype of capping is selected.
Estimated Construction Cost: $3,993,000 - $6,617,000Estimated Annual O&M Cost: $52,500 - $135,000Estimated 30 Year Present Net Worth: $5,331,000 - $7,956,000
THE "1963* SITEAUTEFNATIVE 5 - NO ACTIONUnder this alternative, the public health, public welfare and environmentalconsequences of taking no further action at the "1963" site will beevaluated. There are no ARARs that need to be complied with regarding thecapping of the "1963" site.
I Figure 5
TOPSOILLAYER -
6' .
COVER LAYER -
CLAY CAPPINGLAYER
COMMON EARTH
COMPACTED CLAY
•COMMON EAP.TM
*• THE COVER LAYER WAS SPECIFIED AT 30 I,',. AS A WCP.S" CASE SC-S-"::TO ADDRESS THE CONCERNS OF NR 50^.07 (5).
SCALE: 1" » 4'
3Q91 A43
WAPZVNSTRUCTURE OF SUBTITLE 0 CAP i«RPER NR 504.07REMEDIAL INVESTIGATION ANDFEASIBILITY STUDYJANESV1UE DISPOSAL FACILITY
v,
VEGETATEDTOP LAYER
DRAINAGE *LAYt*
LOWERPERMEABILITYLAYER
sV
~~"~ COMMON EARTH ^
X
SAND & GRAVEL DRAINAGE £
I \SI >-.
rj COMPACTED CLAY *
/-SAND BEDDING—*r
\ MEMBRANi
^-SAND BEDDING
L LOWE=COMPONENT
— UPPERCOMPONENT
THE DRAINAGE LAYER WAS SPECIFIED AT 21 IN. TO MEET THE RECL'IREME'iTTHAT THE UPC£R COMPONENT OF THE LOW PERMEABILITY LAYER BE LOCATED AT LEAS'12 IN. BELO« THE MAXIMUM RECORDED DEPTH OF FROST WHICH WAS ESTIMATEDTO BE 36 IN.
AUTONKCIVI 6 - ACCESS RESIKECTIC*e, AND OKDONSHr OF WASTES AIDSOBSUREAC8 SOUSAccess restrictions will include deed and lard use restriction* for theproperty comprising the 1963 site for the purpose of assuring that futureuse of the site does not increase the release or potential release ofhazardous substances to the environment or become a threat to public health.The containment of wastes and subsurfaos soils is to be accomplished byfirst evaluating the present cap, and by upgrading the landfill cap toobtain a consistent two feet of fine-grained soil cover over the entirelandfill or to meet the standards set by RCRA Subtitle D/WAC NR 500regulations. Continued groundwater monitoring will be part of thisalternative to evaluate the effectiveness of the landfill cap and long-termmaintenance of the cap will continue. Estimate costs are based on rangesdepending on what type of capping is selected.
Estimated Construction Cost: $1,902,000 - $2,840,000Estimated Annual O&M Cost: $27,200Estimated 30 Year Present Net Worth: $2,321,000 - $3,259,000
THE JAB SHEALTERNATIVE 7 - NO ACTIONUnder this alternative, the public health, public welfare and environmentalconsequences of taking no further action at the JAB will be evaluated.ARARs regarding this site will not be addressed.
ALTERNATIVE 8 - ACCESS RESTRICTIONS, CCNEADMEMF OP SUBSURFACE SOILS ANDM2NTTCRINGThe access restrictions will be similar to those applied by Alternative 6for the 1963 site. This alternative also calls for the containment of thewastes (which have already been substantially removed) and the subsurfacesoils. Containment options include evaluating the present cap, andupgrading it to meet either WAC NR 504.07 standards or RCRA Subtitle C/WACNR 181 standards, the monitoring of the groundwater and air emissions, andthe maintenance of the cap will continue. Estimated costs are based onranges depending on what type of capping is selected.
Estimated Construction Cost: $75,000 - $1,160,000Estimated Annual O&M Cost: $14,100Estimated 30 Year Present Net Worth: $292,000 - $1,377,000
ALTERNATIVE 9 - NO ACTICHUnder this alternative, the public health, public welfare and environmentalconsequences of taking no further action at the overall JDF site pertainingto groundwater will be evaluated. ARARs regarding groundwater contaminationwill not be addressed by this alternative.
ALTERNATIVE 10 - GOJNDWATER USE RESmtCTKNSThis alternative will promote the use of deed and groundwater userestrictions for the area within the groundwater plume, and between the JDFand the Rock River. Groundwater monitoring will need to be continued.ARARs regarding groundwater contamination will not be addressed by this
13
alternative. Costs associated with this Alternative are related to thecosts of continued groundwatar monitoring utilizing the monitoring veilsalready in place.
Estimated Construction Cost: Kay be some repair costs associated withthe monitoring wells, such as re-development costs.
Estimated Annual o&M Cost: $55,000Estimated 30 Year Present Net Worth: No Estimate Available
AUBRCVIIVB 11 - OCCNDWMHl EXIBACnCN AMDThis alternative calls for the installation of groundwater extraction wellsto intercept the groundwater contamination plume. The groundwater wouldthen be sent through a groundwater treatment system consisting of an airstripper designed to reduce the concentration of VOCs prior to discharge tothe Rock River. If appreciable amounts of chromium or other inorganics aredetected in the recovered groundwater, additional treatment for the removalof these inorganics will be required prior to discharge. Consideration willneed to be given to the contamination being caused by the Parker Pen Sitelocated immediately downgradient of JDF, whereby if Parker Pen agrees tocarbine resources with the JDF remedial action, then the groundwaterextraction wells can be placed down gradient from Parker Pen and ARARs willbe obtained. If Parker Pen decides not to combine resources with the JDFremedial action, then the groundwater extraction wells called for by thisalternative may be placed downgradient of JDF but upgradient of Parker Pen.ARARs will be addressed downgradient of JDF with regard to groundwatercontaminants.
Estimated Construction Cost: $504,000Estimated Annual O&M Cost: $71,900 - $146,000Estimated 30 Year Present Net Worth: $2,184,000
AIHERNATIVE 12 - QRQONDKNEER IN-SITU TREATMENTThis alternative involves the in-situ treatment of the grourdwater by meansof extracting the groundwater, supplementing it with nutrients and oxygenand recharging it back into the aquifer to enhance biodegradation of thegroundwater contaminants in place or in-situ. A portion of the extractedgroundwater would still need to be treated by air stripping, as inAlternative 11, and discharged to the Rock River, to enable the in-situtreatment to maintain a "closed-loop" injection-recapture system.
Estimated Construction Cost: $1,426,000Estimated Annual O&M Cost: $69,400 - $240,000Estimated 30 Year Present Net Worth: $4,797,000
VII. PROPOSED PIAN
The U.S. EPA's Proposed Plan was released for public content from August 21through September 15, 1989 and the PRPs, through their Steering Committee,requested and received an extension to the comment period giving them untilSeptember 20, 1989 to submit their oonrents. In the Proposed Plan the U.S.EPA stated that the preferred alternatives were as follows:
14
"1985" Site: Preferred Alternative: Compliance with the applicablerequirements of RCRA which will include the components of Alternative 2;access restrictions, recovery and treatment of landfill gas, and RCRASubtitle C/current state capping requirements which may be met by WAC NR181.44(13) closure, along with the enhancement of the leachate collectionsystem. Groundwater and air monitoring will also be continued, (allapplicable RCRA requirements will still apply to this site. The remedyproposed for the "1985" site does not conflict with the applicable RCRArequirements);
"1978" Site: Preferred Alternative: Alternative 4; access restrictions,recovery and treatment of landfill gas, and the containment of wastes andsubsurface soils complying with the standards of VAC NR 504.07;
"1963" site: Preferred Alternative: Compliance with the applicablerequirements of RCRA which will include the components of Alternative 6;access restrictions, and the containment of wastes and subsurface soils bymaintaining and upgrading the present cap and site drainage as needed;
"JAB": Preferred Alternative: Alternative 8; access restrict ions,containment of subsurface soils by maintaining and upgrading the present capand site drainage as needed, and continued groundwater monitoring. (Allapplicable RCRA requirements will still apply to this site. The remedyproposed for the JAB does not conflict with the applicable RCRArequirements). The ash pile remaining onsite will also be removed? and
JDF GRCUNDWATER: Preferred Alternatives: Alternatives 10 and 11;groundwater use restrictions and groundwater extraction with on-sitetreatment with discharge to the Rock River.
After the public comment period and ccninents from the Community and the PRPswere received, a 60 day technical negotiation was conducted between the U.S.EPA, WCNR and the PRPs, pursuant to Section XXVI of the RI/FS Consent Order.The following significant changes were warranted after all ccntnents and theresults of the technical negotiation were evaluated. Specific responses toccninents from the public and the PRPs are addressed in the attachedResponsiveness Surmary.
The "1985" Site: The preferred remedy will still comply with theapplicable requirements of RCRA, which include the components of Alternative2, as previously stated, but the capping requirements for the "198511 sitemay be met by WAC NR 504.07. This cap, along with the improvements to theleachate collection system and the extraction and treatment'of landfill gas,can moet or exceed the performance standards obtained by a RCRA SubtitleC/WAC NR 181.44 (12) or (13) cap. The WAC NR 504.07 cap is more stringentthan the cap that is applicable for this site, the RCRA Subtitle C/WAC NR181.44(12) cap for interim status facilities, since the WAC NR 504.07 caprequires an extra soil layer to account for frost line protection. The NR504.07 cap in conjunction with the improvements to the leachate collectionsystem, will be able to maintain a leachate head level of one foot or l€
35
above the site liner. All applicable RCRA requirements will still apply tothis sit* and to the rented/ selected.
The "1978" Site: The preferred remedy will still consist of theelements within Alternative 4, except that the PRPs have the option toeither implement the landfill gas extraction and treatment portion of thealternative or to test out of the need to nplenent the landfill gasextraction and treatment by 1) installing additional gas probes to verifythat the requirements of WAC NR 506.07(3) are met, and (2) following thehazardous air contaminant test out procedures specified by the WCNR, asallowed by WAC HR 506.08(6) .
The "1963" Site: Eftsfri on concents and further review of the data, theno action alternative was proposed, along with the deed and land userestrictions and continued monitoring. Alternative 5 is now the preferredalternative for the "1963" site.
The "JAB" Site: No changes. Alternative 8 is still the preferredalternative.
JDF Groundwater: No significant changes. Alternatives 10 and 11 arestill the preferred alternatives. The PRPs raised the issue of utilizingalternative concentration limits ("Ads") instead of using the federalmaximum concentration limits ("Mds) /Wisconsin Deforcement Standards asguidelines on when groundwater extraction and treatment is necessary. TheU.S. EPA, in consultation with the WCNR denied this request because of RCRArequirements for corrective action and due to WAC NR 181 and WAC NR 140standards.
Another issue regarding the groundwater extraction and treatment is that thesystem be combined, therefore avoiding unnecessary duplication of effortswith the extraction and treatment system that may be installed by ParkerPen, immediately downgradient of JDF. The U.S. EPA and the WCNR agree thatduplication should be avoided and will agree to this request as long as theperformance standards are met between JDF and the Pock River and ifassurances can be given that once Parker Pen has met its cleanup goals, thesystem will still be operated as long as is needed to meet the performancestandards for the JDF as stated in this ROD.
Comments received during the public conment period are presented along withthe U.S. EPA response to each, in the attached Responsiveness Summary.
IX. SUWARY OF COMPARATIVE ANALYSIS
The alternatives for the "1978" site, JAB, the "1985" site, the "1963" siteand the overall JDF groundwater remedy have been evaluated within the FSusing nine criteria. The nine criteria are sunrarized as follows:
OVERALL ITOTBCTION OF HUMAN HEALTH AND THE ENVHttMEHT addresses whether ornot a remedy provides adequate protection and describes how risks posedthrough each pathway are eliminated, reduced or controlled tl\roughtreatment, engineering controls, or institutional controls.
16
OQNFUNICE MnH ARABS (APPLICABLE OR RELEVANT AND APFRCCKEKTE FHCPIREMENTS)addresses whether or not a remedy win meet all of the applicable orrelevant and appropriate requirements of other Federal and Stateenvironmental statutes and/or provide grounds for invoking a waiver.
HN3~TERM EFFECTIVENESS AND PERMANENCE refers to the ability of a remedy tomaintain reliable protection of human health and the environment over tineonce cleanup goals have been net.
REDUCTION OP TCKECITY, M3BELFTY, CR VOUME is the anticipated performance ofthe treatment technologies a remedy may employ.
SfERr-TEPM EFFECTIVENESS addresses the period of time needed to achieveprotection, and any adverse impacts on human health and the environment thatmay be posed during the construction and implementation period until cleanupgoals are achieved.
IMPlEMENTAHELrrY is the technical and administrative feasibility of aremedy, including the availability of materials and services needed toimplement a particular option.
COST includes estimated capital and operation and maintenance costs, and netpresent worth costs.
STATE ACCEPTANCE indicates whether, based on its review of the RI/FS andProposed Plan, the State concurs in, opposes, or has no comment on thepreferred alternatives at the present time. The State's acceptance isaddressed later within this ROD.
GCMKNTTY ACCEPTANCE will be addressed later within this ROD.
Seven of the nine evaluation criteria (excluding state acceptance andcommunity acceptance) are summarized in Table 10. State and contunityacceptance will be discussed later in this ROD.
The following briefly describes hew the proposed alternatives for the 1985,1978, 1963 and JAB sites and the JDF Groundwater compare to the otheralternatives and how they stand up to six of the eight criteria (comnunityand state acceptance criteria are discussed later within this ROD).
OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT: The proposedalternatives will provide significant protection of human health and theenvironment. This combination of alternatives will eliminate the potentialand future threats caused by the contamination to the groundwater and to theair by restricting access to the sites or portions of the sites, byextracting and treating the groundwater and by extracting and flaring thecontaminated landfill gas prior to its migration off-site. Proper closureof the sites, including improvements or upgrading of the caps such as; alandfill cap at the "1985" site meeting the standards of WAC NR 504.07 inconjunction with leachate collection repairs and/or improvements for the1985 site, which will then meet or exceed the standards of a RCRA Subtitle C
Table 10
Alternative I Alternative 1 Alternative 3 Alternative < Allernal i»e 6
I recreate I* dull Ifenhanced cap*Ingoccurs tut duringinstallation •( UStyttem. Adequatecontrols CM beImplemented.
Watte and SuHurfacetolls • minimal ritkfor contact; lamdfm•0*4 - minimal rtjk;troumdwaler-rltk Itdiscusied In All.f-12; ambient air en-tit* - carcinogenicriikt of 7.0C-W to1.2C-02.
Imcreaie In dustduring constructionof enhanced cap andIK tyttem. Adequatecontrol! cm b«implemented.
Watte *nd subsurfacetoils - minim*! rlikfor conttct; Ground-water ri>k it dit-cinsed in Alt. 9-12.Ambient Air - •!««•litt net considered <source because Miitfk<t burntc.
Incrrot In dun duringconitrvction of tnh«nc«dcap. Adequate control!can bt loplfBtntcd.
Protect Ion ofwartert during
lime untilprotection Isachieved
«et applicable. Noactions taken.
potential ritk fromambient air inhala-tion continues atlong at IFG emissionsoccur at substantiallevel! which may lastfor the not 16years.
(nhanced cappingcould take 2 yeanallowing fordesign, kidding,com tract leu anddown time duringwinter. A IFGtyttem could takelake 1 year withtreatment of IFGemiiilmns. ambientair quality wouldbe Improved almostImmediately.Fencing could takeseveral weeks.
Not applicable. Noactions take*.
potential rlil forambient air inha-lation continues aslong as LFC emissionsoccur at substantiallevels which may lastfor the neit 9 yean.
protection required Net applicable. Noagainst dust and VOC actions taken.emissions duringcamping, and dust.VKs and combustiblegates during instal-lation of IFt system.
(financed capping Net applicable. Aircould take 2 years unlikely contributor,allowing (or detign, Ground*atcr it dit-bldding, construction cussed in Alt. 9-12.and down lime duringwinter. A IFG systemcould take 1 year.Wltk treatment of IFGemissions, ambientair quality would beImproved almostImmediately. Fencingcould take severalweeks.
enhanced capping couldtake 2 ycart allowing fordesign, bidding, construc-tion and down time duringwinter. Fencing couldtake several weeks.
?.
t(ft(t i»tnet>
• r.tgnitudt o(rtMdu*) rok
Sgbttantlal riskrruint freo aoblentair contaminationwhich will likelyoccur at long at IFCIt generated, lltkrelated to ground-water It dltcutted letAlt. 9-12
lltk Is sub-stantially reduceddue to Ift fystn.Ittk related togroundwaler Isdlscutsed In Alt.9-12.
Substantial riskremains fro* aabientair contaminationwklcb will likelyoccur as long at I ftIs generated, llskrelated to ground-water It dltcutted InAlt. 9-12.
litk It substantiallyreduced due te UGtyste*. litk relatedto greundwater Itdiscussed in Alt.9-12.
lelatt'tlr lew risksentl prtienlly.lltk related toground»ater Itdiicutted in Alt.9-12.
Nitk related to efficiencyof cap to reduce Infiltra-tion of precipitation isunknown, lltk related togroundwater It discussedin Alt. 9-12.
( f ft Ct I'tflf SS O f net applicable. M(Cur t i s , engineering controls
implemented.
legibility ofControls
Not Applicable. Noengineering controlsImplemented.
Fencing, taprepair and enhancedcapping and IFG arewell establishedtechnologies,legular inspections:and maintenance isrequired for eachtechnology.
likelihood offailure is small atlong as regular0 1 « It performed.
Not applicable. koengineering controlsimplemented.
Not Applicable. NOengineering controlsImplemented.
fencing, enhancedcapping and IK are•ell establ ishedtechnologies.legular inspectionand maintenance isrequired for eachtechnology.
likelihood of failureit small as lonq asregular 0 i H isperformed.
tenon$. enhancedcapping ani KG are•ell establishedtechnologies.legular inspectionand maintenance itrequired for eachtechnology.
Not Appl icable. Noengineering controlsimplemented.
Fencing and enhancedcapping are veilestablished technologies,legular imped ion andmaintenance it requiredfor each technology.
likelihood of (allure itsmall at long as regular CI It it performed.
1. leductlon of
loiieiiy. nobility
or volume
No reduction intoiicitr, mobility orvolume.
Substantial reduc-tion U toilcltv,mobility and volumeof I Ft. No reduc-tion Ir Mbllity oftoll cor. xinants,but maj reduce the•igratio* potentialdue to cap repairor enhancedcapping.
No reduction l«toilclty. mobility orvolume.
Substantial reduc-tion <• toiicitr.mobility and volumeof IFC. No reductionIn mobility of solicontaminants, but mayreduce the migrationpotential due toenhanced capping.
me reduction intoticity, mobility orvolume.
Will not result in areduction in loiicity.mobility or volume, butmay reduce the migrationpotential of contaminantsdue to enhanced capping.
Table 10 cont.
Cvtlvailon racier
1. Short-term
effectiveness
• Protect Ion ofCo-Mily duringremedial actions
• Protection ofworkers duringremedial actions
• Time untilprotection Isachieved
Alternative 7
Vasie - most. If motall removed; Subsur-face soils - most, ifnet all contaminatedtmils removed,minimal risk forcontact; Groundvater- tisk related toground-water Isdftcussfd in Alt .9-12; Ambient air -JAI net considered asource because wasteremoved.
Not applicable. «oactions taken.
Not applicable. Airunlikely contributor.Croundwater isdiscussed in Alt.9-12.
Al te rna t i ve E
Increase in dustduring constructionof enhanced cap.Adequate controls canbe implemented.
»1sk due to contactwith wast* It minimalsince most. 1< Mtall waste removed.Some risk related Uefficiency of cap loreduce UTIItratiomof precipitation topotentially rrmalnlngcontaminated sum-surface tolls, tlskrelated to ground-water ti discussed inA l t . 9-1?.
not applicable. Airunlikely contributor*"d ground>ater isdiscussed i« A l t .9-12.
Not applicable, lodirect engineeringcontrols implemented.
No reduction inloiictty. nobility orvolume.
tlsk due contact wilkwatt* It minimalsince matt. If mottil waste removed.Some risk related toefficiency of cap toreduce In M lira t Ionof precipitation topotentUlly remainingcontaminated sub-surface soils, listrelated to ground-water Is discussed InAl t . 9-12.
Fencing, cap repairand enhanced cappingare well establishedtechnologies, leg-ular Inspection andmaintenance isrequired for eachtechnology.
likelihood of failureis small as long asregular 0 1 M Isperformed.
Vill Mt result in areduction intoilcilv. mobility orvolume, but mayreduce the migrationpotential ofcontaiiitanti due tocap repair e>renhanced capping.
Potential futureritkt to arearesidents wouldttill eiist due tocontaminantmigration.
not applicable.since no act ionlalen.
Not applicablesince no actiontaken.
No reduction intoiicitj. mobi l i tyor volume ofground-ail r contam-inants would heachieved.
Potential risks wouldk« low at long aseiposure to contamin-ated groundwater Iscontrolled byenforcement of userestrictions.
effectiveness wouldJtpend upon theabi l i ty to enforcegroundwater uterestrictions both on-and o f f - s i t e .
lellakilltv dependantupon the ability lotnforce grounc—atrryse restrictions bothon- and o f f -s i te .
•o reduction Inloilcity. mobility orvolume of groundwatercontaiinanls would beachieved.
lisks would ke lowtine* groundwalerti tract ion andtreatment It provided
Methods employed arcgenerallyconventional andef lec t i ve .
Methods employed aregenerally reliablewi th a lowprobability offailure.
No reductions Utoiicity. mobility orvolume of contam-inants would keachieved. However.aquif.tr clean-upwould be achieved kygroundwatereitraction.
llskt would ke lowtine* both In-sltuand directaroundvattr treatmentit provided.
Methods employed arce f f ec t i ve , alihovc^in-situ groundwatertreatment is some-what less conven-tional than directmethods.
Methods employed aregenerally reliableulth a low probabil-ity of failure.
Some reduction j»toiicity and volumeof ground.iter con-taminanis would beprovided by in-siiukiorec tarnation.
•alu/i n«i factor
4. ImpleMniability
• Technicalfeasibil i ty
• AdBiniitrat iveFeasib i l i ty
• Avai l tb i l i ly ofServicei aneMaterials
S. Compliance with
AlAll
• Chc*ical-Specific
-' ie*nati«e 1
Net applicable. Neengineering controlsimplemented.
Generally adminis-t rat ively feasible IfAgency wil l acceptresidual risks.
Net applicable. Noservices or materialsrequired.
(minion rate levelswould Mt likelycomply with NR 445.AlAls related toSrovndwatcr are
iscussed in Alt.9-12.
tltcrnat ive 7
fence and IfCsystem arerelatively easy toImplement. Imple-menting a N« intype cap may bedifficult due totl«t» SlOMS.
LfG system requiresapproval for elec-trical, supple-mental fuel con-nection and dis-charge of conden-sate/leachate toezislinq leactiatecollection syste*.
Services andmaterialsavailable.Materials toconstruct cap arcassumed to beavailable locally.
Paniculate emis-sions can becontrolled ti Metrequirements. AMISrelated to ground-water are discussedtn Alt. 9-12
Alternative 3
Not applicable. Moengineering controlsimplemented.
Generally adminis-tratively feasible IfAgency will acceptresidual risks.
j
Net applicable. Noservices or materialsrequired.
(•its ton rates wouldMI likely complywith M 44$. AIAP.Srelated to ground-water are discussedin Alt. 9-12.
Attrrnat ive 4
fence and IfC syste*are relatively easyto implement. Nl 181•yJH C4* fiit -- w i i -
ficv.lt to impleMntdue to steep slopes.
LfG system requiresapproval for elec-trical, supplementalfuel connection anddischarge of conden-sate to ciistingleachatc collectionsystem. Enhanced capmay eitcnd beyondproperty boundarieson south tide, soaccess permission itrequired.
Services andmaterials available.Materials toconstruct cap areassumed to beavailable locally.
Paniculate andMissions can becontrolled to Metrequirements. AlAlsrelated to ground-water are discussedin Alt. 9-12
Altcrnat ive 5
mot applicable. Noengineering controlsimplemented.
Generally adminis-tratively feasible ifagency will acceptresidual r isks.
Not applicable. Noservices or materialsrequired.
LfG Mt considered aproblem so wouldlikely comply withNl 14S. AMksrelated to ground-water are discussedin Al t . 9-12.
A 1 1 f rrtJ> 1 i »r f
fence is easy toimplement. Cap is d i f -f i cu l t to impUo."- '_ • •'numerous trees and e i i s l -ing structures en-sue.
A substant '»! r«rt of theconstruction a c t i v i t i e swould occur outsideproperty l imits, sc ecces ipermission is required.
Services and materialsavai lable. Materials toconstruct cap are assumedto be available locally.
Paniculate emissions canb« central led lo meetstandards, (million ratelevels likely to comply asLfG Mt considered aproblem. ARA«i related toground-water are discussedin Al t . 9-12.
• Action-Specif ic Some groundwatermonitoring IsCurrently beingprovided. Someclosure and long-termcare it currentlyprovided. Probablemil related lo IFCemissions would notbe Mt. Ihc ciistingcap does MI MCI*• 111 or Nl SOOdesign standards.
• Appropriateness n«y be Justifiableof waiver for capping AlAls.
b. t ro iect i tn ol lisk to human i.««ltnfro* LfG emissions Is
Human health and Mt controlled. Illkto human health from
the environment direct, contact withwaste Is minimal.lisk to human healthand the environmentfrom groundwater con-tamination Is dis-cussed In Alt. 9-12.
KU requirements'per 40 Cfl 2*1. 2i2and 21) could iVMt. SOM c Inureand long-term careIs currently pro-vided and addi-tional activitiescan be provided.The ciisting capdocs MI MetNl 111 or Nl $00design standardsbut design stan-dards can be Mt.
lot required. Haybe justifiable forcapping AlAls.
list to hu*anhealth fro* vOCs InUC emissions willbe substantiallyreduced, lisk tohuman health fro*direct contact withwaste Is minimal.•isk to humanhealth and Ihcenvironment fro*groundwatercontamination Isdiscussed In Alt.9-12.
SOM groundwatermonitoring tscurrently required.however may not MelNl MO requirements.Site closed prior toMill or Nl SOO solong-term carerequirements may netbe Mt. The enslingcap docs net MCINl SOO or •• IIIdesign standards.AlAfti related lo IfGraiment would notbe Mt.
Net required.
lisk to human healthfrom IFG emissions isMt controlled, liskto human health fro*direct contact withwiste or subsurfacesoils It minimal.lisk to human healthand the environmentfro* groundwatercontamination Isdiscussed tn Alt.9-12.
KIA requirements per40 Cfl 2(1, 2U and2(1 could to Mt.Current closure stan-dards likely MI MIby the eilsting coverbut design standardscan be met (eiccptNt 111 slope require-ments). Nl 400requirements can bemet.
Not required.
lisk to human healthfro* VOCs in LfCemissions will besubstantial lyreduced, lisk tohuman health fro*direct contact with•astc and Subsurfacesoil is minimal.lisk to human healthand the environmentfro* groundvitercontamination isdiscussed U Alt.9-12.
AUIs related togroundwater•mnllr-riM would Mlbe MI. Slie closedprior to Nl SOO. soclosure and long-termcare requirementiwould Mt be Ml.Ihc efisting coverdoes not MCI Nl SOOdesign standard!.
Not required.
lisk to human healthfro* IfG emission isminimal, lisk tohuman health fromdirect contact withvaslc and subsurfacesoil Is minimal.•isk to human healthand the environmentfro* groundwatercontamination isdiscussed in Alt.9-12.
KM requlrcM«tt per 40Cfl 2(1. 2U aad 2i) couldbe Mt. Curreit closurestandards Mt likely Mtby the ciitttng cover butdesign standards can be•et (eiccpt Nl III sloperequirements). *> 400requirements can te vet.
Not rcquirrc
lisk to h^mjn health fro*IFC emission it minimal.lisk to human health fro*direct contact «ilh wasteand subsurface soil is• inimal. lisk to humanhealth and the environMntfro* groundwatercontamination is discussedin A l t . 9-12-
Table 10 cont.
{valuation factor
4. ImmleeHfHtkility
• TeckaUal
Altemati.e tl irrmli.e 9 A l t e r n a t i v e Alternative II -A l t e rna l i
Ammlntstratlvtfeatikilit?
— - — .» ,
Net applicable. Keengineering controlsimplemented.
Generallyadministrativelyfeasikle If agencywill accept residualrisks.
- •> r -n« i i»r i.
Fencing and catrepair or enhancedcapping are easy toimplement.
A portion of the capmay citend bevond theproperty boundarieson the west . Accesspermission would berequired.
not applicable. Noengineeringcon 1 ro 1 simplemented.
Cenerallyadmin is t rat ive lyleasible if agencywill acceptremiinin; r isks.
Not applicable. Neengineering controlsImplemented.
Generallyadministrativelyfeasikle. However,obtaining deedrestrictions enprivate ly -ownedproperty may kedifficult and tiM-consuming.
Technically feasible.Alternative employsconvent lama 1, rcli-mkle tedmvalmjles.
Administrativelyfeasible. However.obtaining permits andeasemMis fer of f -site construction mayW Jiffi^ult AAd•v miiricuii mm]tiM-consuming.
Technically feasible.Although, in. s i tutreatment of ground-•ater is soMwhatless conventionalthan direct treatmentMlhods.
Administrativelyfeasible. However,obtaining permits forinjection wel Is andeasements for o f f -s i te construct i&r, t&fpresent somed i f f i cu l t i es .
Scrvicti andMaterials
of Not applicable. Noservices or uterialsrequired.
Services andMterials available,futerials toconstruct cap areassumed to beavailable locally.
Not applicable.No services ormaterialsrequested.
Mot applicaklt. Ho Senrlcej tftd Services tndlemicei er Mttrith eatfrlah arc readilj eattritli are retail?requested. avallaklt. oailiblc.
S. Ce«eHai»c« witli
mutt
• Ctmlcal -Specif ic
Location-Specific
IfC not considered <•rekln >• littlycow If with M 44S.AJwJh related to•roundiratcr arediictnted i* Alt.9-12.
•one Unit if led.
Paniculate niuionscan be controlled to•eet standards.(eiltion rate lerelllikely to cocply asIFG not coniidtred aprokle*. ARAtsrelated te a.round-water are discussedin All. ?.12.
Done identified.
Stale and federaloroundoatcr qualitystandards would notke aet.
Stale and Federaltreundwater qualitystandards would netbe a>et.
State and federalstandards pertainingte surface water,troundwaler and airquality should keMt.
State and Federalstandards pertainingto surface water,groundwater and airquality should be•el.
None identified ROM Identified le preklrtn No proklevtanticipated Meting anticipated Metinglocatlea-tpexific location.specific
A«A«s.
Action-Specific Soae groundwater•onitorIng isCurrently kelngpresided. S««Mclosure and lenf-ter*care Is currentlyprovided. Tkceiistlng cap does notMet current HI IIIor M SOO designstandards.
•CU requirements per«0 C» Ml IU and?») could ke Mt.SOM (reuncwateraonllerlng Iscurrently kelngpr»vlded. SOMclosure and lonq-lervcare is currentlyprovided. Theensting cap does not•eel M Id or HI iOCdesign standards.
None Identified. Sta te groundwater•onitoringrequlreMnts shculdkc Mt.
State and federalrequirementspertaining te surfacewater dtsdune, andhandling and disposalef haiarvcwitreatment processresiduals should beMI.
Slate and FederalreautreMMtpertaining to surfacewater discharge, andhandling and dupe'*1
of ha<ardouiUeaiMni procestrenduali should be•M
Appropriatenessof *ai»er
Hay be Just i f iablefor capping
xt, be Justifiablefer capping AlAts.
Dot appropriate. Not appropriate. Not required. A vaiver e»av be re-quired to allow useof injection w e ) I slor in-silubioreclaiation ofgroundwater.
t. Protect Jen ef
Health and
the CnvlrenMnt
list lo huaujn healthfroa direct contactwi th subsurface seilis aiiniMl. list tohuatan health and theemlronMnt fro*|rounj.itcr (ontii-inatlon is discussedIn All. g-12.
Ilik to huun healthfro* direct contact•ith subsurface toilIs •iniial. lisk tohuun health and theen>iron*ent fro*grvund.ater contaai-initlon Is discussed•" Alt. Ml.
list to huoanheallh Iron eipo-lure lo contaei-inatrd ground«»teris currently low.However, potentialo f f - s i t e ligraiionof contaannanis inthe future couldresult in lubstan-tlally increasedrisks to humanhealth.
Bisk to human healthfro* eioosure tocontaminated ground-water would kecontrolled as long aion- and off-sitegroundxater userestrictions CM keenforced.
lisk te huejn heallhand the (ntironMnlwould ke substan-tially reduced sincegrountfwater eitrac-tion and treatmentuould ke provided.
Disk lo hu*an heallhand the environmentwould be substan-tially reduced sincegroundwater eitrac-tlon and In-silubioreclaiation wouldbe iipleMnted.
Table 10 cont.
[««U»ltOT) ftttor AlurtutUc I Hlcr.nl i»t Allcr.nl i Alunul i»e «
il • t H
Promt Mt worth(»-yr » i\
1
10
10
10
To be oMreitcd Inthe MO <ller loenc;review •( Ik* fi.
lo be *ddreite4 InIhe MO ««er*«encr revleo «fIhe fi.
10
10
10
J
lo be AooVeitcd Inthe *00 *flcr Menrerlc« ol lh* FS.
•1 WO - 13.S9J.OOO» III - il. 617,000
m.soo to ins.ooon soo . is.331,ooo" 111 - 17,956,000
th« M» ilttr Mtncjrrn\t* •( tlM f J.
10
10
10
lo be aodrciied Inthe MO •(!"• »9encir«the MO •(!"• K>tnevie. of tlic fS.
SI.901.000«» 500 - 52.6<C.OC,
1:7.200
12.3J1.000 ' *'C
>>> 400 - 13.:59.0CO
lo bf tddrttttd in (he 0a f t e r Agency rev iew of I
». 1« be *44rctie4 InI he MO tf ter rwbllcc»««nt> e« thl (5*r« recelied.
lo be »«<lre«ie4 In U k< *44r<\\,4 In 1* b« *MrettH In U be »ddrn>fJ In lo be »4drctic4 In Ihe tthe 100 *f ter the *00 tiler public IKe iOO *(ter public lh« 100 tlltr public «l(er public CO—COM onpublic cowwnli on coiiwnti *n the tS coaaeMi M th< fS coBMnli on the fS tlie fS tre rece ived.Ihe IS >rc tre rec«U<d. »re rtctlTed. »re rcctUcd.received.
AtltrntlUt 1: M9I5* Stle - Ho Action.
»ltem«lUe 2: *ltl5* 5K( - Accen leilrlctlont. Contiinacnt •( V«Uc. leccntrj tat Irettcent ol Iwirilill Co U") •n<lnenltorlnf. i
AUernatU* ): *I9>I* Site - «o Action.
»Hern«l1te 4: *I9>I* Mle - A c c e t t leilrlctlont. twtUlnxnt •( v»»lei «»d Sul>t»r(«(t Soils. »n4 lecover, «nd 1ri<l>ent olUn4MII C4t (lit).
All«rn«li>e i: Ml*)* Slti - M Action.
Altern«tl»e i: "I9D* Site • Accen Irilrlclloni v<4 ConKlMMnt ol VUtict *«d S«l»«rl«tc %olt>.
HUrntllve 7: JAt - do Action.
AllirnttUe t: JAI - A«eii <ei tr \ i ( icni. Contilnwni of iubiurlxt Voili *nt Honiloriiuj.
Altern«ll«e I: J0( CrvMwJ.tter - «o »ci ion.
At lern t l lvc 10: JDf LrouAdxier - V« tt11 r 1< (1001.
AllernilUe 12: JOf Crou»4-«ler • In- t l ty IreitMRl.
DM).10l»l/lU/K[4U-40l-»««lbJ
Table 10 cont.
f«<tor "llfrmlivf t *llern«tite 9 «lurn«tl»f 10
) 0 I M
Promt n«l worth(JO-jrr f J\)
10
}0
)0
Cop Irpiir • 175.000• SCO - UH.OOOn in . ti.iu.ooo
JH.IOO
CK «ep«lr - 1M2.000«• SCO - 1749.000M III - 11.377,000
10
lo*-'10
No direct mnrurjrco»t>. Hooever. 10
1S04.00C 11.426.000
MJT b« iitocuite:vi[h 1«plr»tnt ing
- -irr ulerestr ic t ions. Soaeorountf.tltr•onitonng costs' u;•Iso be incurrrc.
171.500 to 1146.000 U?.<00 to 1240,000
12.IB4.000 14,79;.000
1o k( •<4rtll<4 Inlh< «OC after Mcncrreilt. •( Iht (1.
1* W (MrtltH InIH« *00 liter MtncjrrcTt«« or (ht fi.
1* k« i44rt>«>d Ilh« MM) *IKr*4e»cr r«tl<» ofIht IS.
Iht 100 <(«r jotrc; tlit tOO t t t ' r to<r«ln of tht fi. r«tlr« of lh< 'S.
to<ncjlo kf •itrtmi |nthe tOO 4f«r lotnC;rt>U. of the fi.
lo oe *44rettc4 Inthe MO ot ter puolUco««nU on Ike fS*re rccclteo.
1* ke *Mrnic4 InHie NO «ftcr *iikll«co«*enii w the fS4re recelieo.
lo ke oddrnitd In(he 100 «flerpukllc consents on(he fS orerecelted.
lo >e *t4r<\\<t IKthe WO ifter publiccontent* on the fSore received.
lo of tttrtutt Inthe NO « f le r tubllccomenli o« the fSire rccelr<«.
To ke Idorettetf Inthe 100 ilt.tr publcomenti en the f5»re recct tea.
17
cap, Meeting WC NR 504.07 standards for the 1978 site, and the upgrading ofthe JAB oep to assure proper maintenance and drainage, will help to reducethe amount of contaminants by reducing leachate generation and causing areduction in the movaaait of contamination from the site area into off-sitelocations. Capping improvements ware not deemed necessary at this time forthe n1963tt site since the site is contributing little or no contamination tothe groundwater. The no action alternatives, (Alternatives 1, 3, 7 and 9),will not provide any additional protection to human health or theenvironment as will the proposed alternatives since the contamination(groundwater and air) will not be treated and access to the sites wouldremain unrestricted. Groundwater extraction with on-site treatment,Alternative 11, is comparable with regard to overall protection with thegroundwater in-situ treatment alternative, Alternative 12, but Alternative11 is more feasible and economical than is Alternative 12. The landfillcaps not proposed do not obtain ARARs for the particular landfill, are notas protective as the capping alternative chosen, or are overly protectiveand therefore deemed impractical and infeasible for the particular landfill.
COMPLIANCE WITH ARARS: The combination of proposed alternatives will meetall State and Federal ARARs including the compliance with RCRA interimstatus and corrective action requirements for the 1985 site, the upgradingand/or enhancement of the caps at the JAB and "1978" sites, and thetreatment of contaminated air and groundwater throughout the JDF. Byextracting and treating the contaminated groundwater downgradient of theJDF, but prior to its discharge into the Rock River, the groundwatercontamination exceeding the Federal MCLs/Wisconsin Deforcement Standardswill be addressed and will meet ARARs. The no action alternatives(Alternatives 1, 3, 7, and 9), will not meet ARARs for site closure norwill they properly address the ARARs for contamination in the air and/orgroundwater. The in-situ groundwater treatment alternative, Alternative 12,would address the ARARs for the contamination found in the groundwater butthe proposed alternative utilizing on-site treatment is more practicable andfeasible because of site conditions. For the groundwater treatmentalternatives, any discharges to the Rock River will need to comply withARARs.
LONG-TERM EFFECTIVENESS AND FQMANENCE: The combination of proposedalternatives will provide reliable protection of human health and theenvironment over time. The capping options afforded by the proposedalternatives, including the actions to be taken to comply with RCRAcorrective action at the "1985" site, and the upgrading of the cap at the"1978" site, will maintain or improve the protectiveness with regard todirect contact with onsite contaminants in soil and landfill contents andwill reduce the amount of contamination reaching the groundwater by reducingleachate generation. The caps, including the present cap at the JAB, willneed to be maintained to ensure their effectiveness. Groundwater andlandfill gas extraction and treatment options afforded by the proposedalternatives will effectively prevent the spread of contamination and willcontinue to reduce the levels of contamination. Groundwater and landfillgas extraction and treatment will require monitoring and inspection toensure effectiveness. With proper maintenance, both the cappingalternatives and the extraction and treatment alternatives (groundwater and
18
landfill gam) will be reliable. The no action alternatives (Alternatives l,3, 7 and 9) would not offer any long-term effectiveness at all sinoscontaminants would continue to be released to the environnent. Capping andgroundwater extraction and treatment options not chosen would providevarying degrees of long-term effectiveness and pennanenoe (in sane instancesthe capping alternatives nay provide acre permanence) but the proposedalternatives are deemed more practicable and feasible to address siteconditions. Alternatives to address site contamination, such assolidification, incineration or other more permanent measures, were notevaluated for the JDF since no "hot spots" of contamination were foundwithin the JEF area, and to remove all the waste from the JEF would bedeemed extremely impractical and infeasible.
REDUCTION OF TOXKTIY, MDBILTIY, OR VOLUME: Proposed Alternative 2 for the"1985" site and Alternative 4 for the "1978** site including LTO recovery andflaring, will reduce the toxicity and the mobility of the contamination inthe air at and around the site. The IFG extraction and flaring alternativeswill effectively reduce the toxicity of the contaminants that are or may bemigrating off-site and will also severely restrict the mobility of thecontaminants by collecting and treating them. The groundwater extractionand treatment alternative chosen, Alternative 11, will not reduce thetoxicity, mobility or volume of the contaminants since the contaminants aresimply being transferred from the water to the air. However, if docmodnecessary, a treatment system such as an air scrubber may be installed.Alternatives not proposed either do not reduce the toxicity, mobility orvolume of the contaminants at the site or are not as practicable or feasiblefor the site conditions as are the proposed alternatives. None of thelandfill cap alternatives, selected or not selected, will reduce thetoxicity, mobility or volume of the contaminants at the JDF. However, thecapping alternatives selected will aid in restricting releases fromoccurring from the sites.
SHORT-TERM EFFECTIVENESS: The proposed alternatives will provide somedegree of short-term effectiveness. The access restriction portions of theproposed alternatives will offer immediate protection to the nearbypopulation with little or no implementation time required. The capping andcollection and treatment portions of the proposed alternatives will requiremore time to be implemented and become effective. No adverse impacts to theneighboring community or environment are anticipated during theimplementation of any of the proposed alternatives. The alternatives notproposed for this site either do not afford any protection and thereforehave no short-terra effectiveness (no action alternatives) or have similarimplementation times and effectiveness as the proposed alternatives.
IMHJEMEWrABILTTY: The alternatives within the proposed alternativesinclude differing degrees of irtplemerrbability. The access restrictionsportions of the proposed alternatives, will be easily implemented since theCity of Janesville owns the JDF Site and governs the area impacted by thecontamination. Some coordination between local agencies will be required toimplement the deed restrictions on and near the JDF Sites. The cappingportions of the proposed alternatives will be somewhat more difficult toimplement than some of the capping options not chosen, such as the no action
19
alternatives (except for the "1963" site) , but the proposed alternativesoffer greater reduction in leachate generation and attain ARARS. Theportions of the proposed alternatives regarding landfill gas and groundwaterextraction and treatment may require more studies to aid in design. Thetechnology is available and proven for the extraction and treatment oflandfill gas and the groundwater called for by the proposed alternatives.The groundwater in-situ treatanent alternative, Alternative 12, would be moredifficult to implement than the proposed alternative, Alternative 11, sincein-situ treatment requires the introduction of nutrients and oxygen into thegroundwater and its results would not be as definite as those produced bythe proposed alternative.
COST: The proposed alternatives are compared to each other with regard tothe criteria listed above and then when two or more remedies achieve thesame goal (ie. , achieve ARARS) , cost can become a determining factor.However, because the remedy(ies) at the JDF are to satisfy RCRA as well asCERdA, cost as an evaluation factor has been given less emphasis withrespect to sites which will be addressed using RCRA authorities.Construction costs and operation and maintenance (O&M) costs for eachalternative are summarized in Table 10 and within the FS. The alternativesproposed are believed to be the most cost-effective remedies to meet theobjectives of CERdA and RCRA.
X. THE SELJ*-|M> rajMjPif
Based on the findings of the RI/FS and the documents within theAdministrative Record and the results of the public comment period, theselected remedy for each of the JDF components is as follows:
THE "1985" SITE: Compliance with the applicable requirements of RCRA whichwill include the components of Alternative 2. Since the "1985" site is notan NFL site, compliance with this remedial decision will be achieved throughRCRA authorities. Alternative 2 components to be implemented include thefollowing:
* Access restrictions which will promote the use of deed and landuse restrictions to assure that future use of this site does notincrease the release or potential release of hazardous substancesto the environment or become dangerous to the life or health ofpeople; a fence will need to be installed around the machineryused to gather the landfill gas, both for the protection of thepeople and of the machinery. A fence nay need to be installedaround the landfill gas collection wells, but this can not bedetermined until f f efr the systen is designed.
An ITO extraction and flaring systen that may later be convertedinto an energy converting systen will be installed. The landfillgas extraction and flaring systen will be designed during the
Design stage, but may involve a number of IPS extractionwells which will be connected by a gas header pipe systen to amechanical blower, which in turn will create zones of low prwithin the landfill and induce gas flow into the wells.
20
to the landfill cap including the upgrading of thecap to meet the requirenenta of WC Ml 504.07. (The HOto haveshown that with the NKC NR 504.07 cap, alcog with the improvementsof the leachate collfctim system and the attraction and treatmentof LPG, the perfonnanoe standards of the WRC NR 504.07 landfillcap will meet or exceed the performance standazds for tfae RCR&Subtitle C/WftC NR 181.44 (13) cap.) The cap for the 1985 siteshould be tied into the cap for the 1978 site.
* Ctntinued monitoring including the Monitoring of the groundwaterand air, according to BGRA, and the long-tem maintenance of thelandfill cap.
* The repairing and/or the improving of the leachate collectionsystem, as required by VCKft/WC to assure that no more than one(1) foot of leachate exists above the bottcu liner.
* "1985" site clean-up goals or standards:- meet the closure performance standards as stated within
WC NR 504.07,- meet RCRA requirements for post-closure and corrective
action,- eliminate the risk caused by en-site and off-site
breathing of contaminated air caused by tJie emissions oflandfill gas, meeting the requirements of MAC NR 400standards; and
- repair and/or improve the leachate collection system toeliminate excessive head levels, (head levels will be nomore than 1 foot above the bottom liner).
* Estimated Costs:Estimated Construction Cost: $2,949,000Estimated Annual OSM Cost: $39,500 - $142,000Estimated 30 Year Present Net Worth: $4,521,OOO
THE "1978" SITE: The selected remedy will include components of Alternative4, including the following:
* Access restrictions which will promote the use of deed and landuse restrictions to assure that future use of this site dees notincrease the release or potential release of hazardous substancesto the environment or become dangerous to the life or health ofpeople; a fence will need to be installed around the machineryused to gather the landfill gas, both for the protection of thepeople and of the machinery. A fence may need to be installedaround the landfill gas collection wells, but this can not bedetermined until after the system is designed or until after theFRPs exercise their option to test out of the requirement toextract and treat the LTC as allowed by VftC NR 506.08(6) andaddress the potential for explosive gas migration.
21
* An IPS extraction and flaring system that may later be convertedinto an energy converting system. The landfill gas extraction andflaring system will be designed during the nrmnrtlal Design stage,but aey involve a nuober of IPS extraction veils which will beconnected by a gas beader pipe systeB to a Mechanical blower,which in turn will create zones of low pressure within thelanrirti? and induce gas flow into the wells. The LFG system forthe "1978" site Bay be tied into the system being recommended forthe "1985" site and «ay also eventually be tied into a systemwhich voy be developed for the currently operating landfill acrossBlack Bridge Road to the north. The EKBs have the option to testout of the requirement of implementing the IPS extraction andtreatment system by demonstrating the performance criteria of NR504.04(4) can be achieved, as allowed by WftC NR 506.08(6), and bydemonstrating that the migration of explosive gases has beenprevented. The test out procedures, if opted, will be conductedafter the new cap is in place.
* Containment of the wastes and subsurface soils by upgrading thelandfill cover to comply with the standards of WftC NR 504.07. Thelandfill cap for the 1978 site should be tied into the cap for the1985 site.
* Continued groundwater and air monitoring.
* "1978" clean-up goals or standards:- meet WAC NR 504.07 capping/cover requirements,- eliminate the risks caused by the en-site and of f-site
breathing of contaminated air* rsyyMd by the emissions oflapdffll gas by implementing the IPS extraction andtreatment system or succeeding with the hazardous a-ircontaminant test out procedures.
* Estimated Costs:Estimated Construction Cost: $3,993,000Estimated Annual O&M Cost: $52,500 - $135,000Estimated 30 Year Present Net Worth: $5,331,000
(Estimated costs are assuming that the IPG extraction andtreatment system will be implemented. The cost of the hazardousair contaminant test out procedures has not been estimated)
THE "1963" SITE: The selected remedy will include oonponents of Alternative5, the no action alternative. However, the following will still need to beinplemented: (Since the "1963" site is not on the NFL, these requirementsand any others which may arise in the future, are expected to be achievedthrough RCRA authorities.)
* Access restrictions which will promote the use of deed and landuse restrictions to assure that future use of this site does notincrease the release or potential release of hazardous substances
22
to the environment or become dangerous to tba life at l**uth ofpeopl*.
* Continued grounduater monitoring.
* "1963" clean-up goals or (
* Estimated Costs:Estimated Construction dost: Hill have acne oastsEstimated Annual OOf Cost; associated with theEstimated 30 Year Present Ret Worth: continued monitoring
THE JAB STIE: The selected remedy will Include components of Alternative 8,including the following:
* Access restrictions uhich will promote the use of deed and landuse restrictions to assure that future use of this site does notincrease the release or potential release of hazardous substancesto the environment or beorme dangerous to the life or health ofpeople.
* The containment of wastes and subsurface soils by maintaining thepresent cap and upgrading the present cap and site drainage, asneeded.
* Continue grounduater monitoring.
* Comply with all applicable RCKA requirements.
Remove and properly di«yra» of the remaining ash pile located tothe south oftheJABasperHACNRSOO- 520. The ash isregulated as a solid waste as defined by Wis. Stats. 144.01(15)
JAB clean-up goals or standards:- comply with BCRA post-closure and corrective action
otii its,- assure cap is properly maintained and assure proper site
drainage.
* Estimated Costs:Estimated Construction Cost: $75,000Estimated Annual O&M Cost: $14,100Estimated 30 Year Present Net Worth: $292,000
JDF GROUNDNA1ER: The selected remedy will include the components ofAlternative 10 and components of Alternative 11, including the following:
* The provisions of Alternative 10 will promote the use of deed andgrcundwater use restrictions for the area between the JCP and theBock River.
23
Ttm installation off grour*i**tar extraction veils to intercept thegroundwater oontanlnatlcn prior to it reaching the Rode Riw.Ihe grounduater puap and treat system aball ba constructed toallov sufficient PBJTMJB to intercept grcunduater treat as farsouth as the Wall 25 area and as car north as the Wall 9/9A area.
The development of a groundwater trealamt system that will treatthe vTXs in the groundwater by means of an air stripper or other
technology. If needed. Air emissions froa the treatmentsysten will need to meet the standards of MAC NR 400 - 499. thegroundwater extraction and treatmafc system will be designedduring the Remedial Design stage and will take into account thesysten that lay be installed immediately doungradient of the JDF,at the Parker Pen site. The grounduater Bay need to be treatedfor inorganics as well, if sanpling determines that inorganicswithin the pmpnd grounduater exceeds federal or state standards.the treated water will then be discharged into the Hock River.The grounduater will need to be extracted and treated as long asthe groundwater within, at, and doungradient of the JEP containscontaminants that exceed the WRC NR 140 standards. The treatedgroundwater will be required to Beet the water quality standardsor HAC NR 102, NR 104, NR 105, NR 106, NR 207, and the WFCESpermit requirements of NR 200 and NR 220 prior to discharge intothe Rock River.
Continued grounduater monitoring.
JCF Grounduater clean-up goals or standards:- Provide a groundwater extraction system that is as
effective or more effective than the systen proposed inthe August 1989 Feasibility Study;
- puop and treat the groundwater until no federal Mde/WACNR 140 exceedances exist between JEF and the Rock River;
- prevent contaminated grounduater frcn reaching the RodeRiver,
- eliminate the health risks associated with thecontaminated groundwater, ie. contaminants over thefederal MCIs/Wisccnsin Enforcement Standards;
- comply with RCKA, post-closure and corrective action
- meet surface water quality standards as per MAC NR 102, NR104, NR 105, NR 106, NR 200, NR 208, and NR 220, withregards to the discharge of the treated groundwater intothe Rock River; and
- meet air quality standards as per WftC NR 400 - 499 withregards to the emissions associated with the treating ofthe contaminated groundwater.
Estimated Costs:Estimated <3onstruction Cost: $504,000Estimated Annual O&M Cost: $57,000 - $117,000Estimated 30 Year Present Net North: $2,184,000
xi. oatturry
No significant issues were raised during the public meeting to alter thecomponents of the Preferred Alternatives. Changes to the preferredalternatives as stated in the Proposed Flan presented to the public, basedon caonents received frcn the public and the PRPs during the comment periodand daring the 60 day technical negotiation are « ««•**»»»* in Section VIII ofthis <for*m**rfr- Individual ooniaents and letters are summarized withinAttachment 1, the Responsiveness Summary, attached to this document.
XII •
Ihe letter stating the WCNR's acceptance of the U.S. EPA's Selected RemedialAction Alternatives is found as Attachment 2 to this document.
XIII. STATOTCBY CEIBMNATICKS
The selected alternatives for the Janesville Disposal Facility, as listed inSection VIII of this ROD, neat the statutory requirements in that they areprotective of human health and the environment, attain ARARs, utilizepermanent solutions and alternative treatment technologies or resourcerecovery technologies to the T"*y1wtirn extent practicable and have apreference for treatment as a principal element, as described below:
Protection of Human Health and the Environment;
The selected remedy, a combination of alternatives addressing eachindividual site within the JEF, will be protective of human health and theeitvironrnent through the use of land and groundwater use restrictions,containment of wastes and subsurface soils, and by the extraction andtreatment of contaminated landfill gas and the extraction and treatment ofthe contaminated groundwater.
Protectiveness will be achieved by the upgrading of the caps for the "198511and "1978" sites and by assuring the proper maintenance and drainagecontrol for the JAB. (Based on the findings of the RI, a cap upgrade wasnot deemed necessary at this time for the "1963" site) . Cap upgrades andproper maintenance practices are reliable methods to alleviate the directcontact threat from the site's contents and will also help in reducingleachate generation, thereby reducing the amount of contamination reachingthe groundwater. Since untreated wastes will remain within the sites, thegroundwater will continue to be monitored to ensure the protectiveness ofthe selected remedies.
Protectiveness will also be achieved by the extraction and treatment of thecontaminated landfill gas at the "1985" and "1978" sites (the PRPs mayexercise their option and elect to try to test out of the need to implementthe I.TC extraction and treatment at the "1978" site by following thehazardous air contaminant procedures as allowed by WAC NR 506.08(6) and bydemonstrating that the migration of explosive gases has been prevented) andof extraction and treatment of the contaminated groundwater downgradient of
25
JDF, between JDF and the Rock River. By treating the landfill gas and thegroundwater, the risks associated with the respective contamination will begreatly reduced, if not eliminated. The extraction and treatment remediesare reliable methods to assure the protectiveness of human health and theenvironnent.
The access/land vise restrictions and the groundueter use restrictionsimplemented by the selected alternatives will aid in achieving theprotectiveness of human health and the environment. The restrictions willreduce the likelihood of activities occurring on-site that may damage thesites' caps and will prohibit the installation of water supply veils in thearea occupied by the JDF and between the JDF and the Rxk River.
There will be no unacceptable short-tern risks or cross-media impacts causedby the implementation of the selected remedies.
Attainment of ARARs;
The selected remedies will be designed to meet all the applicable, orrelevant and appropriate requirements (ARARs) of Federal and more stringentState environmental laws. A list of the probable ARARs for the JDF sitesis listed within the FS. The primary ARARs that win be achieved by eachof the selected alternatives for the individual sites are as follows. EachARAR is designated as either applicable or relevant and appropriate.
Closure Requirements:
"1985" Site;* capping requirements as stated in MAC NR 504.07. (U.S. EPA,
in consultation with the WCNR, determined that the WAC NR504.07 cap in conjunction with the improvements to theleachate collection system and the extraction and treatment ofLTC, the ARARs of RCRA Subtitle C will be obtained.)
* monitoring, long-term care and closure requirements asrequired under RORA/WAC NR 181,
* are all applicable to the "1985" site.
"1978" Site;* capping requirements as stated WAC NR 504.07,* monitoring and proper cap maintenance will follow standards
stated in MAC NR 508 and WAG NR 514,* are applicable to the "1978" site.
"1963" Site;* there are no capping ARARs for the "1963" site, but cap
iinproveroents as called for by RCRA corrective action forsolid waste management units as determined by 40 OR 264 maybe applicable.
JAB Site;* capping requirements with proper cap maintenance as stated in
WAC NR 181 are applicable.
26
Contaminated Air Oonoerm:
"1985" Sit*;* National Primary and Secondary Ambient Air Quality standards
as referred to by 40 CFR 50, regarding the particulatestandards that apply to dust generating constructionactivities,
* VAC NR 400 series regulations covering the range of Wisconsinair quality requirements,
* Performance standards regarding the control of landfill gasemissions as stated in WAC NR 504.04(4) (e) and (f) and thedesign criteria as outlined in WAC NR 504.05(7) and (8),
* landfill closure requirements as stated in VAC NR 506.08(6)requiring landfill gas corjtrol/treatment system in landfillswith more that 500,000 cu yds of waste, and
* the gas monitoring requirements as stated in MAC NR 508.04(2),requiring landfill gas monitoring to assess gas migration andthe effectiveness of any landfill gas control system,
* are applicable.H1978" Site;
* same as for the "1985" site.
JDF Groundwater;* Control of hazardous pollutants as stated in MAC NR 445, which
establishes hourly or annual emission rate limits forspecific substances.
* is applicable
Contaminated Groundwater concerns:
JDF Groundwater;* MCLs as called for by the Safe Drinking Water Act, to be
met within and at the JDF and between the JDF sites and theRock River,
* Enforceable limits for substances in groundwater released froma solid waste management unit permitted under RCRA, as statedin 40 CFR 264.94,
* Groundwater quality standards as stated in WAC NR 140, and* Groundwater monitoring to be conducted at all the sites as
per RCRA closure and corrective action requirements, as statedin 40 CFR 264 requirements and within WAC NR 140/141 and NR508, are applicable to the groundwater contamination found atthe JDF.
Surface Water Concerns:
JDF;* Surface water quality standards set forth in WAC NR 102 for
the discharged treated groundwater,
27
* WC KR 104, 105 and 106 standards regarding criteria foracceptable discharge liaits as well as the limits set forth inHAC 181 217/220, and
* Federal NPCES Regulations as stated in 40 CTR 122, 125 and131,
* are applicable to the discharge of the treated groundwaterfron the JDF sites. \>
Cost Effectiveness;»
Since the JDF contains two RCRA regulated facilities, and the other two siteswithin the JDF are RCRA solid waste management units, cost effectiveness isnot of major concern in choosing remedial actions for portions of the JDFcovered under RCRA authorities. However, the selected remedies for the JDFare considered cost effective when compared to alternatives not chosen, whichmay have had a similar or greater degree of protectiveness to the environmentand to public health. For instance, Alternative 12, in-situ groundwatertreatment, yields results similar to Alternative 11, groundwater extractionand treatment, but Alternative 11 was chosen because it is estimated to behalf as costly as Alternative 12. Also, the maximum cap upgrades were notchosen for any of the JDF units, while the performance standards will stillbe achieved, so the selected alternatives are certainly more cost effectivethan some of the capping alternatives not selected. The total cost for theselected remedies at the JDF are estimated for a 30 year present net worth atnearly $12 million dollars. The costs, however, will cover the remedies forall four sites within the JDF and will address the groundwater and aircontamination problems caused by the JDF site.
Utilization of Permanent Solutions and Alternative TreatmentTechnologies or Resource Recovery Technologies to the Maximum ExtentPracticable;
The alternatives chosen represent the best balance of alternatives evaluatedto address the contamination problems found at the JDF. By extracting andtreating the landfill gas at the "1978" and the "1985" sites, the potentialhealth threats to neighboring residents will be drastically reduced, if nottotally eliminated, and the extraction and treatment of the groundwaterbetween JDF and the Pock River will offer added protection to public healthand the enviroranent. The capping alternatives chosen are not permanentremedies, and will require appropriate amounts of monitoring and maintenanceto assure the effectiveness of the cap. The land use and groundwater userestrictions implemented by the selected remedies will further assure addedprotection to the public health and the environment. The selected remediesrepresent the maximum extent to which permanent solutions and treatment canbe practicably utilized for this action. Due to the large quantities ofwaste within the JDF units, (except for the JAB, in which most of the wasteshave been removed), and the discovery of no "hot spots" within the landfills,alternatives involving the treatment or removal of the wastes were deemedimpracticable and were not carried forward.
28
Preference for Treatment as a Principal Elements
The contamination of the air by the landfill gas and the ccntamination of thegroundwatar were identified in the Remnrttal Investigation as being theprincipal threats posed by the JTF site. The selected alternatives givepreference to treatment in that both the groundwater and the landfill gascontamination prcblens will be addressed via treatment technologies. Thegroundwater will be extracted and treated by air stripping (Alternative 11)and the landfill gas will be extracted and treated by flaring (Alternatives 2and 4).
XIV. SUWAKY.
The presence of groundwater contamination and the emission of contaminantsvia landfill gas at and around the Janesville Disposal Facilities, requiresthat remedial actions be implemented to reduce the risk to public health andthe environment. The U.S. EPA believes, based on the RI/FS and theAdministrative Record, that the selected alternatives provide the bestbalance of trade-offs among alternatives with respect to the criteria used toevaluate the remedies. Based on the information available at this time, theU.S. EPA believes that the selected remedy will be protective of human healthand the environment, will attain ARARs and will utilize permanent solutionsand alternative treatment technologies of resource recovery technologies tothe maximum extent practicable.
The total estimated costs for the Remedial Action at the four sites thatcomprise the JDF are as follows:
"1985" costs, Alternative 2:Estimated Construction Cost: $2,949,000Estinvited Annual O&M Cost: $39,500 - $142,000Estimated 30 Year Present Net Worth: $4,521,000
"1978" costs, Alternative 4:Estimated Construction Cost: $3,993,000Estimated Annual O&M Cost: $52,500 - $135,000Estimated 30 Year Present Net Worth: $5,331,000
"1963" costs, Alternative 5: Will have sane costsEstimated Construction Cost: associated with theEstimated Annual O&M Cost: continued groundwaterEstimated 30 Year Present Net Worth: monitoring.
JAB costs, Alternative 8:Estimated Construction Cost: $75,000Estimated Annual O&M Cost: $14,100Estimated 30 Year Present Net Worth: $292,000
JDF GrounoTwater, Alternatives 10 and 11:Estimated Construction Cost: $504,000Estimated Annual O&M Cost: $57,000 - $117,000Estimated 30 Year Present Net Worth: $2,184,000
29
Total BBtiwted costs of the Selected Alternate
Total Estimated Cost for RCRA. (notv-CERCLA/WL) selected alternatives(Includes Alternative 2 for th» "1985" site, and Alternative 5 for the"1963" site):
Estimated Construction Cost: $2,949,000Estimated Annual OfiM Cost: $39,500 - $142,000Estimated 30 Year Present Net Worth: $4,521,000
Total for CEWttA/NPL selected alternatives(Includes Alternative 4 for the "1978" site, Alternative 8 for the JAB,and Alternatives 10 and 11 for the JDF groundwater contamination):
Estimated Construction Cost: $4,572,000Estimated Annual O&M Cost: $124,100 - $266,100Estimated 30 Year Present Net Worth: $7,807,000
Total for all JDF selected alternatives (including Alternative 4 forthe "1978" site, Alternative 8 for the JAB, Alternatives 10 and 11 forthe JDF Groundwater and Alternative 2 for the "1985" site andAlternative 5 for the "1963" site):
Total Estimated Construction Costs: $7,521,000Total Estimated Annual O&M Costs: $163,600 - $408,100Total Estimated 30 Year Present Net Worth: $12,328,000
The U.S. EiTviroranental Protection Agency (tt.S. EPA) has gathered informationon the types and extent of contamination found, evaluated remedial measure*,and has m.».nii»?jrled remedial actions to address the contamination found atand near the Janesville Disposal Facility. The Janesville Disposal Facilityconsists of two sites included on the National Priorities List (NFL), theJanesville Ash Beds and the Old Janesville landfill and two contingentsites, the Janesville Old Dump and the New Janesville Landfill. TheJanesville Ash Beds site and the New Janesville landfill are also regulatedunder the Resource Conservation and Recovery Act (RCRA). As part of theremedial action selection process, a public meeting was held on August 30,1989 to explain the intent of the project, to describe the results of theRemedial Investigation and Feasibility Study, and to receive Garments fromthe public.
Public participation in Superfund projects is required by the SuperfundAmendments and Reauthorization Act of 1986 (SARA). Comments received fromthe public are considered in the selection of the remedial action for thesite. The Responsiveness Summary serves two purposes: to provide the U.S.EPA with information about community preferences and concerns regarding theremedial alternatives and to show members of the community how theircomments were incorporated into the decision-making process. Commentsregarding information specifically contained in the Remedial Investigation/Feasibility Study (RI/FS) are not addressed in this Responsiveness Summaryas this information is contained in the reports available in the JanesvilleLibrary and at the Janesville Municipal Building. Also, comments notdirectly related to the selection of the remedial alternatives have not beenaddressed within the Responsiveness Summary.
This document summarizes the oral comments received at the public meetingheld on August 30, 1989, and the written comments received during the publiccomment period tunning from August 21 through September 15, 1989. TheSteering Committee, representing the concerns of the Potentially ResponsibleParties (PRPs), requested an additional 5 days to complete and review itscomments and concerns, and the extension was granted. Please refer toAppendix A for a complete list of cctnmentors.
The comments have been summarized and are as follows:
Comment 1: The Rock County Health Department did a risk assessmentregarding groundwater protection in the county and this [the JanesvilleSites] is one of the higher risks, in the top five, but underground storagetanks was the highest risk in the county. I believe that if money is to bespent, it should be spent to eliminate the highest risk, to prevent more ofthese problems from occurring in the future.
1: The U.S. EPA agrees that preventing further contamination,such as that which is caused by leaking underground storage tanks, is apriority and the U.S. EPA and Many states, including the Stats of Wisconsin,have set up programs to deal with these issues. Superfund was created toaddress contamination from much larger sources, such as the JCF, that canhave a greater impact on public health and the environment than the impactthat nay result from a smaller source such as underground storage tanks.Superfund is set up in such a way that those who are responsible for thecontamination are those that pay for the remedial action to address thecontamination. Only when no responsible parties are available, aregovernment funds expended on the remedial action. The money used forSuperfund actions is derived from a separate taxing revenue than the fundsthat are used to address non-Superfund issues such as leaking undergroundstorage tanks.
Garment 2: I would like to comment that given the things that have beendumped into these facilities over the years, I think it's a given that wewere going to end up with polluted groundwater and air now. We've got toclean it up. I live up here, and I'm concerned about it. I'm glad I'm nota responsible party, but maybe I am in my own little way. I think we allare and we should clean it up. I strongly recommend the alternatives youroffice is recommending namely; "1985 site" Alt. 2, "1978 site" Alt. 4,"1963 site" Alt. 6, "JAB site" Alt. 8 and "JDF Ground Water" Alt. 10 6 11.We cannot pick less than the best method when we are trying to clean up ourwater, soil and air. Alternative 11 of the "JDF Ground Water" bothers meconcerning the air contamination from the water treatment process. We don'tneed any added contamination to the air in our neighborhood.
Response 2: Thank you for your support. On the issue of aircontamination, Alternative 11 will involve the extraction and treatment ofthe contaminated groundwater between the JDF and the Pock River. Bytreating the groundwater, the organic contaminants are transferred from thegroundwater to the air. The emissions are expected to be low, but will bemonitored. If the levels emitted are causing a risk to the public health orthe environment, additional control measures will be taken such as adding anair scrubber or other source of adsorption to the treatment system. As anote, the alternative chosen for the "1963" site was changed to Alternative5, the no action alternative for reasons described within the ROD document.
Comment 3: One of the things that bothered me when I was reading throughall the literature on this is that I didn't see much emphasis on costs orrisk benefit analysis. I don't think we should squander our resources,whether they be natural resources, human resources or financial resources.We need to make the best of these resources and I'm not sure that what hasbeen proposed is the best use. I'm not condemning it. I don't know enoughabout it yet. The groundwater clean-up should be done in a cost-effectivemanner, and it ought to be monitored, and not done when it is unnecessary.I question as to whether the landfill gas flare or recovery is necessary inorder to meet air quality for the surrounding area. I believe more airquality monitoring be done before any decision is made either to go aheadwith the proposal for recovery/flaring or to not go ahead. And with regardto the proposals to replace substantially and at great expense, the caps at
the various sites, I think it might be money better spent in monitoring tosee if, in fact, any problem is being generated and to only maintain theexisting caps. If there is a problev, do something about it but spend themoney wisely and if there is no problem, don't fix it.
Response 3: See Response for Garment |4
Cdnnent 4:A) He believe that the air and water hazards as a result of the sites
have not been proven at this point, and further investigative work remainsto be done before considering actions as drastic and expensive as those inthe fact sheet and discussed at the August 30 meeting. We recommend gettingthe most effective treatment of the problem, without investing money onminimal return areas which are not a significant problem or threat to thepublic health. While it is recognized that the EPA guidelines foralternative selection does not place emphasis on cost, any rational analysismust weigh cost versus benefit prior to making final choices. We reccmnendto base treatment on actual monitoring of concentration of contaminantsmigrating off site, while allowing natural processes to degrade the materialon site.
B) With regards to the treatment of gxoundwater, decisions should bebased on the results of on-going tests, and taking into account the actualand likely uses of the water, the groundwater should be treated when and ifrequired, such as when the contamination is reaching the Rock River insufficient volume to exceed surface water quality standards. If theconcentration of the contaminants in the groundwater shows a steady increasewith time, then we should start with the treatment of the groundwater.Likewise, when the time trends show a downward trend, treatment shouldcease, thereby treating only when needed. Since we are dealing with naturalprocesses of decay and dissipation of a large volume of material, the timeperiods in which we can observe any trends or changes of significance arelong. Monitor ing should be done quarterly, but the data needs to be viewedin terms of 1 to 5 year intervals to observe trends, and to accuratelypredict when natural processes have slowed to a normal or background level,and no further precautions are needed. A panel made up of representativesfrom industry, residential, county and state groups can all participate toview the data that is collected.
C) With regard to the air quality issues, more work needs to be done,such as determining "what is the volume or mass of material being emittedversus time?" and "what is the concentration offsite?.11 If this furtherwork shows no significant health hazard is likely to occur offsite, and theaccess to the site itself is properly restricted, there would appear to beno immediate justification for any action beyond periodic monitoring. If itis shown that a significant health quality issue is at hand for personsoffsite, and that access restrictions will not provide adequate safetymeasures, then the gas vents should be evaluated in order of their severity,and be flared or burned at a raised vent cap or burner site. If it can beshown that there is a real and significant hazard to populated areas beyondthe JDF site boundaries from the landfill gas in the near term, then furtheraction on gas recovery or flaring would be initiated. In reviewing the
various reports, we were not able to establish a correlation between thedata and any significant health risks tram landfill gas beyond the overallsite boundaries. Obviously, it is iiportant that the actual measurements betaken prior to any decisions on treatment.
0) Unless the off-site landfill gas hazard can be proven immediately,wa strongly urge that the reocranendations within this letter be adopted,establishing monitoring stations prior tift any action on flaring of landfillgases, and providing a groundwater monitoring-driven approach to groundwatertreatment*
E) Specifically, for each of the sites within JEF, we recommend thefollowing:
OVERALL SITE; Restrict access through use of a combination of physicalbarriers and "no trespassing - hazardous area11 signs at all points ofconvenient entry, as well as enforcement as required by local lawenforcement. Groundwater-use restrictions should be continued as discussedin the EPA's Preferred Alternative. These restrictions should remain inforce as long as water quality does not meet the applicable standards.
1963 Site, - No action beyond that already proposed under "overall site",this area is already becoming a less active site through natural processes.Monitoring condition, restricting access, and maintaining the cap asrequired to prevent serious deterioration are the main components of thisaction.
JAB SITE; - No action beyond that already proposed under "overall site".The existing business at this site must continue to comply with regulationsand not take any actions which would worsen the situation. Need to monitorcondition and restrict access.
1978 SITEi - No action beyond that already proposed including monitoringcondition and restrict access.
1985 SITEj - No action beyond that already proposed under "overall site".Maintain existing devices for controlling pollution in working order, andmonitor condition and restrict access.
Response 4:
A) The U.S. EPA believes that the Remedial Investigation (RI)conducted at the site over the last several years along with the otherdocuments comprising the Administrative Record, provides the necessary datato initiate the remedial actions called for in the Proposed Plan andsubsequently in the Record of Decision. Some changes have been made to thealternatives as presented within the Proposed Plan as a result of thecomment period. These changes are documented within the ROD.
Cost is an evaluation factor, even though it was given somewhat lessemphasis in this case with respect to units being addressed through RGRAauthorities, throughout the Remedial Alternative selection process. Cost is
a factor only when two or more alternatives provide similar results, thenthe more cost-effective approach is chosen. With regards to veiling costscompared to the benefits that am achieved with a certain remedialalternative; this is not considered an evaluation criteria as to whether ornot to address a contamination problea that exceeds state and/or federalstandards. In the case of the Janesville Disposal Facility, state andfederal standards are exceeded with regards to groundwater contaminationand landfill gas emissions. Therefore, these problems oust be addressed, asthey are addressed at all landfills, regardless of cost/benefit ratios.OBRCXA expresses a preference for remedies that employ treatment thatpermanently and significantly reduces the mobility, toxicity, or volume ofhazardous substances as a principal element. Enphasis is placed ondestruction or detoxification of hazardous materials rather than onprotection strictly through prevention of exposure or monitoring.
B) Based on the results of the RI Report, the U.S. EPA has concludedthat the contamination in the groundwater must be addressed. Even thoughthe affected groundwater is not currently being utilized for drinking water,the aquifer is designated as an aquifer potentially available for supplyingdrinking water, and therefore, contamination must be addressed in order tomeet ARARs (Applicable or Relevant and Appropriate Regulations). Ifseveral remedial alternatives achieve the standards set by the ARARs, thenthe most cost-effective approach, while still achieving ARARs, will beselected. With regard to the continued monitoring of the groundwater, it isrequired that if waste materials remain onsite, with or without groundwaterextraction and treatment, monitoring must continue to keep track of thecontamination emanating from the site.
C) Based on the results of the RI Report, the U.S. EPA has concludedthat the contamination caused by the release of contaminated landfill gasfrom the "1985" site and the "1978" site, needs to be addressed by recoveryand treatment methods. The Endangerment Assessment within the RI Report hasstated that the health risks associated with the release of contaminantsalong with the landfill gas are above levels considered safe for humans tobreathe if onsite near the source. The FRPs do have the option availableto them to try to test out of the landfill gas extraction and treatmentrequirements at the "1978" site, after the new landfill cap is in place, byfollowing Wisconsin's hazardous air contamination test-out procedures. Asstated above in part A of this response, CERCLA expresses a preference forremedies which employ treatment that permanently and significantly reducesthe mobility, toxicity, or volume of hazardous substances as a principalelement. Emphasis is placed on destruction or detoxification of hazardousmaterials rather than on protection strictly tlvrough prevention of exposure.More work is required prior to the actual implementation of the landfillgas extraction and flaring system, but this work will be conducted duringthe design phase of the system and will determine aspects such as the flowrates of gas and contaminants out of the vents, percentage of methane, andif additional fuel sources will be required. With regard to determining theactual risk to people breathing the air ijirediately offsite or in theadjacent neigliborhoods, continued monitoring is still required since thesource of the contamination is remaining onsite. Also, by eliminating thehigh risks associated with the on-site air contamination, any risks offsite
will also b» «liainated. Sampling the air away from the source area anddetermining an accurate health risX i* difficult, since air never travels ina straight path, so additional sampling offsite at the present tine nay notprovide any significant additional data to support or refute the decision torecover and treat the landfill gas at the source.
D) Refer to responses in parts A, B, and C of this response.
E) Overall Site: U.S. EPA agrees that access/land use and groundwateruse restrictions are needed for the protection of human health and welfare.U.S. EPA also believes that groundwater extraction and treatment iswarranted for the reasons stated above.
1963 Site: U.S. EPA's selected remedy is similar to the onementioned in this comment. After the comment period, the preferredalternative for the "1963" site was changed from Alternative 6 toAlternative 5, the no action alternative, for reasons as stated within theROD. Continued monitoring and access/land use restrictions will still applyto this site as with the entire JDF site.
JAB Site: U.S. EPA's preferred remedy is similar to the onementioned in this content. Combining site restrictions with thecontinued compliance with the applicable RCRA requirements. In addition,the preferred remedy calls for the removal of the exiting ash pile locatedto the south of the JAB along with the continued maintenance of the JABcap.
1978 Site: Based on the results of the RI, the U.S. EPA stillinsists that the present cap on the 1978 Site needs to be upgraded tomeet the relevant and appropriate requirements of Wisconsin AdministrativeCode (WAC) NR 504.07 (the regulations governing the capping and closing oflandfills).
1985 Site: Based on comments received during the comment periodand the ability of the potentially responsible parties (PRPs) to show thatthe WAC NR 504.07 cap, along with the repairs and improvements to theleachate collection system and the installation of the landfill gasextraction and treatment system, can meet or exceed the standards called forby RCRA Subtitle C/WAC NR 181.44 (13) (the regulations governing the cappingand closing of landfills, but more strict than the WAC NR 504.07regulations), the selected alternative has changed from the alternativepresented within the Proposed Plan. The WAC NR 504.07 cap, however, is morestringent than the RCRA Subtitle C/WAC NR 181.44(12) cap for interim statusfacilities, in that it provides for a frost protection soil layer. Refer tothe ROD, Section VIII for an explanation of these changes.
Ccninent 5: Many letters (see Appendix A) contained concerns relating tothe amount of money to be spent to either satisfy some regulation or to bespent without a proper cost/benefit ratio. They asked how can EPA enforcethese regulations, costing up to $17 million! even when the sites werelegally operated and closed under the regulations existing at that time?Why not monitor the situation and implement a remedy later if it is shown to
be endangering human health or the environment?
Response 5: Aspects of this comment are covered within theabove for Ooenent 4, dealing with the reasoning behind the selection of thepreferred remedies involving treatment of wastes and the addressing of thecost/benefit issue. With regards to the overall cost and the burden thataay be felt by the citizens of Janesville, the U.S. EPA feels that the costestimate is just that, an estimate, and mo b likely the actual cost will besomewhat lower. After the proposed alternatives were revised based oncomments received and discussions with the PRPs, the implementation of theselected remedies will cost an estimated $12 million. In addition, theestimated cost is carried over the estimated time period of 30 years,including the implementation and operation and maintenance of the selectedremedies. Another point to make is that this cost is covering not one site,but is addressing the concerns of four separate sites, while the overallgroundwater issue can even be considered as a fifth site. While it is truethat the City of Janesville is considered a PRP in this matter, (under theCERCLA statute, owners/operators along with generators and transporters ofhazardous substances are held liable for the release or potential release ofhazardous substances into the environment) the total financial burden of theremedial action will not fall solely on the citizens of Janesville. It isuncertain as to how the PRPs will plan on dividing the costs, but as withthe RI/PS, there were 15 parties cooperating in financing the investigation.
Due in part to the number of letters with the concerns of over spending withlittle benefit and to a provision in an agreement between the U.S. EPA, WCNRand the PRPs, these issues were discussed with the PRP Steering Camitteeduring a 60-day period prior to the signing to the FDD. The remedies asstated in the ROD have been revised sonewhat to reflect these concerns.Please refer to Section VIII of the ROD for further details.
Garment 6: We agree with the preferred alternatives selected for the JDFexcept for the alternative presented for the 1985 landfill, a RCRA-regulatedunit which is subject to RCRA corrective action. Specifically, we do notagree that a 40 CFR Part 264 cap (RCRA Subtitle C requirements as mentionedin the Code of Federal Regulations) is appropriate or required for thissite. We believe that the groundwater monitoring and corrective actionrequirements of Part 264 apply to this facility, but we do not agree thatthe Part 264 capping requirements should be required for this site. UnderPart 264 corrective action, we believe that upgrading the cap to meet WAC MR504 requirements, enhanced leachate collection and possibly groundwaterextraction, will remedy the problem of high leachate levels in the landfilland mitigate potential groundwater impacts from this unit.
Response 6: As a result of the 60-day period used to discuss the remedialaction options between the U.S. EPA, WCNR and the PRP Steering Committee,this issue was addressed. U.S. EPA stated that the Part 264 cap is not anARAR but may still be required as part of RCRA corrective action. It wasdetermined that if it can be shown, by the PRPs, that the WAG MR 504 cap andthe leachate collection system improvements combined will achieve similar orbetter results than the cap as per Part 264, then the U.S. EPA will agreewith your comment.
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Cdnaent 7: For the reasons cited below, the EPA's preferred remedies forthe 1985 site, the 1963 site, and the grourdwater remediation areinappropriate, impractical and overpcotective. in addition, the EPA hasimproperly de-emphasized cost as a factor to be considered in its selectionof preferred alternatives. For these reasons, the Ocnndttee disagrees withthe Agency's selection of preferred remedies for these sites and requeststhat the Agency modify its alternative selections in light of the followingcccments. In connection with each of its Garments, the Steering Committeewill propose an alternative remedial action which is appropriate, practical,cost effective and protective of human health and the environment.
A) "1985" SITE: The EPA's preferred remedy of a new cap for the 1985site is inappropriate, impracticable, not required by law and not costeffective. The preferred remedy identified in the Proposed Plan for the1985 Site is the installation of a new cap conforming to Wisconsin WAC MR181.44(13). This proposed remedy is not required to protect human healthand the environment, is not practicable, is not an applicable requirementunder PCRA or CERCLA, and is not cost effective for the site conditions.For the following reasons the EPA's preferred remedy is not justified andshould be modified.
1) There is no evidence that the 1985 site is a source ofcontamination sufficient to justify a corrective action consisting of atotally new RCRA closure cap on the site. There are three bodies ofevidence in the RI/FS which indicate that the 1985 site is not the source ofthe contamination. First, there is evidence that wastes are mixed with thesoils between the 1978 and the 1985 sites. The valley between the 1978 and1985 sites received clean fill during site operations. However, waste mayhave blown or eroded from the sites and mixed with fill in the valley. Soilsampling while installing well 1R has indicated this. Groundwater qualityat well 1R could be affected by infiltration of rainfall through the wastepresent in the soils or by the unlined 1978 site. Therefore, well 1R islikely not monitoring the effectiveness of existing engineering controls atthe 1985 site. A new NR 181.44(13) cap over the 1985 site would not haveany effect on minimizing contamination from waste which is outside thelimits of the 1985 site. A more appropriate remedy for this condition wouldbe to tie the 1978 site cap into the 1985 cap to cover the area between thetwo sites.
2) A comparison of VOCs detected at well 1R and VOCs detected inleachate from the 1985 site indicates the 1985 site is probably not thesource of the well 1R contaminants. Benzene, ethylbenzene, xylene, tolueneand 1,2,-Dichloroethene were detected in well 1R and in leachate from the1978 site. They were not detected in leachate from the 1985 site. This isstrong evidence that any contamination in well 1R is due to the 1978 siteand not the 1985 site. A new cap on the 1985 site would not help toremediate these contaminants.
3) Groundwater quality at wells 3 and 4, located south anddcwngradient of the 1985 site was sindlar to groundwater quality upgradientof the site at wells W14, W29 and W29A. This indicates that groundwaterquality problems between the 1978 and 1985 sites are localized and notrelated to the 1985 site. The extent and source of any groundwatercontamination between the two sites should be established before a decision
is made that a new cap on the 1985 site is necessary, Again, tying the 1978cap to the 1985 cap as part of the repair would remediate this localizedproblem.
The evidence from the KL/FS leads to the conclusion that the well 1Rcontamination was most likely due to the unlined 1978 site which is adjacentto well LR. While the proximity of the 1978 and 1985 sites makes itvirtually impossible to confirm that a particular contaminant originatedfrom a specific disposal area, carmen sense as well as the expert opinion ofWarzyn Engineering clearly indicates that the 1978 site or the waste mixedwith the soils between the two sites is the most likely source of the well1R contaminants. Thus, the available evidence does not support theselection of an NR 181.44(13) cap as the appropriate corrective action forthe 1985 site. The appropriate action for the 1985 site is the inspectionand maintenance of the existing NR 181.44(12) cap.
4) The EPA's preferred remedy is not practicable and would not bea reliable long term remedy for the 1895 site because of the siteconditions. NR 181.44(13) requires that the vegetated top cover have slopesno steeper than 25%. Slopes on the southern sides of the site are greaterthan 33%. Slopes on the western side of the site are greater than 25% andrange to greater than 33%. As a result, cover soils are likely to slide offof or erode from the synthetic liner. Regrading is impractical. Again, theappropriate and practical remedy would be to repair the existing cap andextend the cap to cover the area between the 1978 and 1985 sites.
5) The existing cap meets or exceeds State and Federal landfillclosure regulations as set out in 40 CFR 265.10 and VAC NR 181.44(12). Thefederal regulations for a cap on a RCRA facility require that the cap have apermeability equal to or less than the permeability of the liner of thefacility. The existing cap meets these requirements. WAC NR 181.44(12)requires a cap for interim status RCRA facilities to be at least 2 feet ofcompacted clay with a vegetative cover. The existing cap also meets orexceeds these requirements. The site was closed as a waste disposalfacility in 1985 under an approved closure plan, approved by the WCNR in1986. Therefore, neither the EPA nor the WCNR can require a new closure atthis time in the absence of a showing of wxi-corapliance with the existingclosure plan or further use of the site as a placement or disposalfacility. A new cap on the site is neither appropriate nor required.
6) The EPA improperly failed to consider cost in the selection ofits preferred remedy. As EPA states in the Proposed Plan, cost will becomea determining factor for RCRA remedial actions when two or more alternativesachieve the same goal. Neither the EPA nor the WCNR cite any evidence thatthe existing cap after repair would not achieve the same goal as an NR181.44(13) cap. The EPA's choice of the NR 181.44(13) cap seems to be basedon the "more is better" theory rather than on any technical justification.In the absence of a demonstrated difference in the ability of one cap overanother to achieve the required goals, cost must be considered.
7) Caissons are not needed to remediate the leachate collectionsystem. The RI suggested that more than one foot of leachate is present onthe liner at the 1985 site. The Proposed Plan therefore recommends leachatebe removed using caissons. Leachate withdrawal could be acccrplishedwithout installing caissons. Thirteen landfill gas extraction wells areincluded in the conceptual design for the landfill gas extraction system and
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these wills oould be utilized as walls to withdraw leachate in conjunctionwith the already-present leachate oollection system. Both leachat* andlandfill gas oould bs removed using this system. This would effectivelyreduce the potential for environmental degradation by: 1) reducing leachatahead on the liner and therefor*, the potential for leakage through theliner; 2) reducing the volume of landfill gas contaminants released toambient air; and 3) reducing the concentrations of VDCs in waste andleachata by withdrawing VOCs along with ihc landfill
B. "1963" SITE: The EPA'a preferred remedy for the 1963 sits isimpractical and inappropriate for the site conditions. Although it isunclear from the language of the Proposed Plan exactly what type of capupgrade the EPA prefers for the site, it would appear from the costestimates in the Proposed Plan that the EPA prefers upgrading the cover toNR 500 landfill closure standards. The proposed remedies are notappropriate and impractical for the following reasons:
1) An upgraded cap at the 1963 site is inappropriate because ofthe nature of the wastes remaining at the site. Primarily municipal wasteswere disposed of at the site and combustible wastes were burned beforeburial. The wastes have been buried at the site for over 25 years. Thereis no documentation that hazardous wastes were ever disposed of at the site,and for the reasons stated above, it is concluded that the concentrations ofany contaminants in the remaining waste are very low. Leachate was notpresent in either leachate well onsite. Soil samples collected beneath thesite at both locations did not show detectable TCL (Target Compound List)organics. This demonstrates that the potential for groundwatercontamination from the site is negligible.
The JAB occupies approximately 4 acres of the 1963 site and is alreadycapped under WCNR approved closure plan. The available evidence indicatesthat any contamination coming from the 1963 site area is due to theoperation of the JAB, which ceased in 1985. Adding a new cap over the 1963site would have no effect on this residual contamination. Since a new orenhanced cap would destroy current site usage, and since there is noevidence that the 1963 site is the source of on-going contamination, theEPA's preferred remedy is inappropriate for the site and would not be aneffective remedy.
2) An upgraded cap on the 1963 site is impractical due to currentsite conditions. JAB occupies approximately 4 acres of the 1963 site and isalready capped. The remainder of the site is privately owned by acommercial recycling facility with approximately 4.5 acres of the facility'sproperty being heavily wooded and approximately 6 acres being used forrecycling operations. Another 2 acres of the site is covered withrecyclable asphalt. Upgrading the cap would require the destruction of thewooded area and demolition of the recycling facility which would inflictfinancial costs on the present owner. The nature of the existing conditionsat the site make construction of an upgraded cap over the entire siteimpracticable.
The appropriate remedial action for the 1963 site would be carefulevaluation of the existing cover and improvement of drainage conditions asneeded. A drainage system for the area could be designed which would
11improve surface water drainage without destroying the existing land uses. Arequirement that a full new cap b» added to the site is impractical andinappropriate.
C. GRQUNDWATES REMEDIATION: The proposed punp and treat oysten isunwarranted given the lack of risk associated with the groundwator. TheAgency's proposed plan for addressing groundwater contamination at the JDFcalls for both institutional controls on the use of groundwater downgradientof the JDF and groundwater extraction and treatment. We find the use of apunp and treat solution at this site is unnecessary given the absence ofrisk associated with the potential use of this groundwater and the data uponwhich this proposed remedy is based. We list the following reasons why theAgency's proposed remedy is unwarranted:
1) CERCLA and RCRA require that a site remedy be based on therisk presented to human health and the environment. This is the principalreason for performing the detailed endangerment assessment within the RI/FS.By knowing what risks need to be reduced, a remedy can be crafted thatappropriately addresses these risks, if any. Failure to tailor the remedyto the risks presented at a site can result in remedies that are eitherunderprotective or, as in this case, remedies that are clearlyoverprotective.
The requirement that the Agency use a risk-based remedy selection process isclearly set forth in the 1986 amendments to CEK3A. The statutory languagerepeatedly refers to the selection of a remedy that is based on the "short-and long-term potential for adverse health effects from human exposure" andis "protective of human health and the environment." Moreover, in selectinga remedy, the statute again incorporates a risk-based standard byspecifically requiring that the cleanup shall "assure [] protection of humanhealth and the environment" and that the remedial actions be "relevant andappropriate under the circumstances." Indeed, in selecting applicable orrelevant and appropriate cleanup requirements, the proposed NCP (NationalContingency Plan) recognizes that several criteria must be weighed,including the characteristics of the site and circumstances of the release.Finally, EPA's draft guidance documents state that, in selecting a remedythat is "protective" of the environment under CERCLA Section 121, EPA'sapproach involves a "risk assessment" that "includes consideration of site-specific factors such as ....potential for exposure..."
With respect to groundwater remediation, the Agency, under CERCXA, isspecifically allowed to develop alternate groundwater concentration limitswhere, inter alia, institutional controls prohibit the use of groundwaterfor drinking-water purposes, and the discharge of the groundwater has aninsignificant effect on a nearby water body. By incorporating this conceptinto the cleanup standard section of the statute, Congress clearly intendedgroundwater remedies to be particularly sensitive to risk or lack thereofassociated with the contamination. The proposed NCP recognizes this intentby setting forth (i) a groundwater classification scheme, (ii) restorationtime periods and (iii) technologies to achieve groundwater cleanup based,inter alia, on the use of the groundwater, the potential for human exposureand the effectiveness of institutional controls. In addition, in theInterim Final Guidance on Remedial Actions for Contaminated Groundwater at
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Superfund Sites, the Agency recognize* that natural attenuation "may be themost practicable response" where the contamination will attenuate to health-based levels within a relatively short distance.
Similarly, the corrective action standards under RCRA also require a risk-based remedy. The statute requires corrective action uhere it ia "necessaryto protect human health or the environaant." With respect to groundwaterprotection, the regulations applicable to the owners and operators ofhazardous waste treatment, storage and disposal facilities allow EPA toexclude a hazardous constituent "is not capable of posing a substantialpresent or potential hazard to human health or the environment." Thisdetermination is to be based, in part, on the proximity and withdrawal ratesof users, current and future uses of the groundwater, and the potential forhealth risks caused by human exposure.
2) The proposed remedy is unnecessary because the groundwatermigrating from the JDF presents no risk to human health and the environment.In the present case, the data and the erdangerment assessment for the JDF donot warrant the use of a pump and treat system for removing the level ofgroundwater contamination found at the JDF. As described in the RI, thehorizontal and vertical extent of contaminant migration is limited becausegroundwater discharges to the Reck River, located approximately 1000-1200feet downgradient of the JDF. Thus, the existing information suggests thatthere is no potential for the contaminated groundwater to flow under thePock River or deeper into the aquifer. In addition, groundwater quality isexpected to improve with time because the primary source of contamination,JAB, no longer contains waste. Comparison of water-quality data collectedduring May, 1989 by Parker Pen suggests some improvements have alreadyoccurred since the RI data was collected in July, 1988. There also are nopresent or future users of groundwater, since the City provides drinkingwater to all facilities downgradient of the JDF and prohibits the futureinstallation of private drinking-water wells in this area. Therefore, thereis no present or future risk associated with the groundwater. Not only isthe risk to human health and the environment negligible, but thecontamination which was found will naturally dissipate as it discharges intothe nearby Rock River. The additional loading to the Rock River will beminimal, at most. The concentrations detected at the river did not exceedWAC NR 105 (Wisconsin's surface water regulations) Human Threshold Criteriaand Human Cancer Criteria for surface water quality. Contaminantconcentrations in the river were much lower than ambient water qualitycriteria for fresh water organisms. With the proposed remedial workundertaken on the remaining portions of the JDF, no new contamination willbe introduced into the groundwater. As such, the groundwater will benaturally cleaned without the need to undertake an expensive pump and treatsystem.
Finally, in the comments made at the public meeting, reference was made tocombining the JDF groundwater plan with that designed for the contaminantplume associated with Parker Pen. However, we have been informed by ParkerPen that based on its separate hydrogeolcgical study, it will recommend tothe Agency that it undertake a groundwater remediation program separate anddistinct from the Superfurd program. Given that decision by Parker Pen,installing a pump and treat system for the groundwater contamination
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associated with the JEF beormas even more questionable. Not only is thesystem unnecessary in order to remove any risk to human health and theenvironment — no risk presently exists — but will make what is already acost-intensive prograa even less cost effective.
3) The Wisconsin groundwater protection lav does not requiregroundwater punp and treat. The WCNR adopted WAC NR 140 (Wisconsin'sgroundwater quality regulation) to enable the state agency to respond in aflexible and appropriate manner to groundwater contamination situations. Inthe purpose section of the regulation, it specifically states that NR 140 isto be used to develop a "range of responses the Department may require if agroundwater standard is attained or exceeded. Given this intent, NR 140 isaimed at developing cost-effective remedies that appropriately minimize therisk to human health and the environment. Vidle MR 140 establishes certainnumerical groundwater standards (known as "enforcement standards"), it doesnot mandate a particular response to a groundwater problem nor does itmandate immediate cleanup action. Rather, the rule establishes a range ofresponses which may include a relatively simple change in operations, theclosure of a facility or active remedial action. In numerous cases, WCNRhas not required immediate remedial action but has been willing to allownatural attenuation to occur and resolve the contamination. For this site,the Agency has proposed appropriate remedial action through cappingactivities at the JDF. This work will prevent any further addition ofcontaminants to the groundwater. When this work is combined with thenatural attenuation of the groundwater (which is recognized will occur), thegroundwater will achieve the appropriate groundwater levels without the needto undertake an expensive pump and treat program.
4) The Proposed pump and treat system is not cost effective.CERCLA requires the Agency to consider the "cost effectiveness" of theselected remedy. Thus, the proposed NCP states that EPA is required "toevaluate closely the costs required to implement and maintain a remedy andto select protective remedies whose costs are proportionate to their overalleffectiveness". In the present circumstances, if the Agency proceeds with agroundwater remediation plan, which is not necessary to protect human healthor the environment, and is not mandated by state law, the Agency must selectthe most cost-effective remedial action. The proposed punp and treat systemdoes not take into account the characteristics of the JDF site and,therefore, does not meet this standard. In contrast, the FDD for the Cityof Wausau Superfund site allowed for a site-specific analysis of theappropriate pump and treat system. This flexibility allowed a system to bedeveloped which did not require the use of a stripping tower in order tomeet all applicable requireinents, including the applicable dischargestandard. A sJbnilar approach could be used in this case in order tomaximize the cost effectiveness associated with any extraction well system.
In conclusion, the Steering Committee believes that the preferred remediesfor the 1985 site, the 1963 site and the groundwater remediation aspublished in the EPA's Proposed Plan are inappropriate and impractical forthe site. Alternative remedies exist which are equally protective of humanhealth and the environment, which meet all federal and state remediationstandards, and which are more cost effective. The Committee requests thatthe EPA carefully evaluate its preferred remedies in light of the abovecomments and revise its preferred remedies accordingly. Pursuant to Section
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XXVI (Selection of Remedial Action Alternative) of the Consent Order for theJDF sites, the Committee is ready to enter into good faith negotiations withthe Agency regarding the implementation of remedial action alternatives forthe sites. The Committee will work with the Agency to design correctiveactions for the site which better address the actual conditions of each siteand which will meet all applicable requirements.
Response 7: In response to this comment and pursuant to Section XXVI ofthe JDF Consent Order, the U.S. EPA held a 60-day (frcn September 29, 1989through November 29, 1989) technical negotiation period with the WCNR andthe PRP Steering Committee (comprised of representatives from the City ofJanesville, General Motors Corporation, Parker Pen Co. and Tecumseh Co.).Ihe points addressed in this letter were discussed and some changes weremade to the U.S. ERA'S Proposed Plan, as noted within this response andwithin Section VIII of the ROD. In regard to your comment stating that theU.S. EPA has improperly de-emphasized cost as a factor to be considered inits selection of preferred alternatives, the U.S. EPA disagrees. RCRA is aparty to this project and RCRA does not consider cost to be an issue inremediation unless there are two equal processes and if one is less costlythan the other, then cost may be considered in the selection of a preferredalternative. In response to the individual points of this comment thefollowing responses are made:
A) "1985" SITE: After evaluation of public comments and additionaltechnical information received from the PRP Steering Committee, the U.S.EPA's preferred remedy as stated in the Proposed Plan has been changed, forreasons as stated within the ROD, from requiring a cap compliant with MAC MR181.44(13) to a cap compliant with WAC NR 504.07. The U.S. EPA and theWCNR, strongly believe that this remedy is both practical and cost effectivefor reasons as stated below.
A-l) The U.S. EPA (CERCEA and RCRA), in consultation with the WCNR,believe that the findings of the RI are not conclusive as to which site, the1978 or the 1985 site, or both, is responsible for the contamination foundwithin well 1R. As stated within the RI Report, well 1R is locateddowngradient of the 1985 site, and therefore, is capable of detecting anycontaminants that may be leaking from that site. Also, the RI Report statesthat the source of the contamination in well 1R is not clear; thecontamination may be from the 1978 site, the 1985 site, or both.Furthermore, the iiipgy rf well is part of the RCRA monitoring system for the1985 site. While it is entirely possible that the contamination is fromsources other than the 1985 site, the U.S. EPA and WCNR believe that thehigh leachate head levels within the 1985 site and the comparison ofcontaminants found within the leachate and in the groundwater (as noted inresponse 7A-2 below), the 1985 site cannot be ruled out as a likely sourceof the well 1R contamination. Under the hazardous waste regulations, theCity of Janesville has the responsibility of demonstrating that a sourceother than the 1985 site is responsible for the contamination. This has notbeen done.
A-2) Ihe U.S. EPA and the WCNR do not agree with this comment.According to Table 16 of the RI Report (Summary of Organic Compounds InLeachate - Round 1) results of sanples from the leachate wells at the 1978site and the leachate manhole at the 1985 site, were compared. Both sitesshowed detections of benzene, ethylbenzene, xylenes, and toluene. In fact,
15
the lev*! of toluene was found at higher concentrations within the 1985 sitethan within the 1978 site. This fact, along with the high leachate headlevels found within the 1985 site (as Mentioned later in part A-7 of thisresponse) ioplies that it is a strong possibility that the contaminationfound in well 1R Bay be attributed to the 1985 site. Therefore, it is theopinion of the U.S. EPA and the WDNR that cap improvements are needed forthe 1985 site.
A-3) As stated in the KE Report, well IK is located downgradient ofthe 1985 site. Even though grcundwater quality in wells 3 and 4, alsoaJawngradient of the 1985 site, is found to be similar to backgroundgrcundwater quality, as your oonnent mentions, the contamination may belocalized. Usually, not all wells within a monitoring system pickup arelease from a site, but if a system is working correctly, at least one wellin the system will detect a release if a release is occurring. As indicatedabove in part A-2 of this response, the 1985 site is a likely source of thecontaminants found within well 1R.
A-4) The issue regarding the side slopes and the sliding of materialsoff of the landfill slopes is no longer a major issue. The capping remedyfor the 1985 site has been changed from the NR 181.44(13) cap, as mentionedwithin the U.S. EPA's Proposed Plan and in this ccranent, to a WAC NR 504.07cap as farther described within the POD. RCRA feels that it would bejustified to require an NR 181.44(13) cap through its corrective actionauthorities, but since the WAC NR 504.07 cap, along with the landfill gasextraction and treatment, and the improvements to the leachate collectionsystem will achieve the performance standards, they have concurred on theless stringent cap. The WAC NR 504.07 cap of the 1985 site shall be tied inwith the NR 504.07 cap selected for the 1978 site.
A-5) The existing cap did meet the original closure requirements setout in WAC NR 181.44(12), but due to the findings of the RI (see response toA-2 above) and the fact that this landfill has had maintenance problems inthe past, the U.S. EPA and the WCNR feel justified in selecting/requiringcap improvements for the 1985 site. Your citation to 40 CFR 265.10 isincorrect and if the correct citation is 40 CFR. 265.310, then RCRA statesthat the closure standards and post-closure care standards for thelandfill's cap have clearly not been met. The present cap has settled.slunped and has deep cracks in the surface. Post-closure care andmaintenance have not been performed on the cap.
A-6) The U.S. EPA and the WCNR believe that the revised selectedcapping alternative, meeting the requirements of WAC NR 504.07, is the mostcost-effective capping alternative to address the frost line protection,reduction of the leachate head levels (in combination with the leachatecollection system iitprovements) and the reduction of infiltration ofprecipitation through the landfill cover. Within Warzyn's letter, datedNoventer 30, 1989, to Dan Oozza of the U.S. EPA, Warzyn states "Warzynbelieves the upgraded leachate collection system in combination with the WACNR 504 cap will substantially reduce the potential for release ofcontaminants froro the "198511 site to grcundwater."
A-7) The Proposed Plan did not state ihat caissons must be installedto address the excessive levels of leachate within the 1985 site, but merelystated that a system such as caissons nay be considered. The selectedremedy within the ROD is consistent with the Proposed Plan in that it statesthat the leachate collection system will be inproved so that one foot or
16
less of leachate head win be pmoorit above the landfill liner. The methodmy be what was suggested within this eminent, but the exact system will bedetermined within the Remedial Design stage of the project.
B) During the 60-day technical negotiation period with the PRPSteering Committee, the U.S. EPA and the WCNR determined that there are noARARs for site closure for the 1963 site. However, if contamination wasshown to be attributed to the 1963 site, "RCRA corrective action may requirecap improvements since the 1963 site is considered a solid waste managementunit, being contiguous with the JAB, a RCRA-regulated unit. The BOO,Section VIII, indicates the changes to the Proposed Plan, stating that onlyaccess/land use restrictions and continued grcundwater monitoring will bethe selected remedy for the 1963 site.
C) The selected remedy regarding the grcundwater remediation has notchanged from the preferred remedy as stated within the U.S. EPA's ProposedPlan. Responses to the oconents are as follows:
C-l) Due to contamination exceeding Federal Maximum Contaminant Levels(MCLs) and the State's Eriforcement Standards for several contaminants, theU.S. EPA (CERCLA and RCRA) and the WDNR are requiring groundwater pump andtreat as their selected remedy for groundwater remediation. Under RCRA,remediation is based on standards, such as MCLs, which may be based on risklevels. Alternative Concentration Limits (ACLs) were determined by U.S. EPA(CERCLA and RCRA) and the WCNR to be inappropriate in this case since MCLshave been exceeded for several contaminants and the site border is over1,000 feet from the point of discharge, the Rock River, with privateproperty located between the two. The aquifer that is contaminated by theJDF may be classified, as per the proposed NCP, as a Class H-B aquifer -groundwaters that are potential drinking water sources. The proposed NCPcontinues to state "For groundwater that is or may be used for drinkingwater (Class I or U) the MCLs set under the Safe Drinking Water Act or morestringent promulgated State standards, are generally the applicable orrelevant and appropriate standard.'1 The proposed NCP later states "Theseprovisions offer the choice of establishing cleanup standards at background,MCLs or alternative ccncentration limits (ACLs). In setting remediationlevels, the Superfund program generally uses the MCL or other health-basedstandards, criteria, or advisories which are equivalent of a health-basedACL under RCRA." Since there are contaminants in groundwater that exceedFederal MCLs and State Enforcement Standards, and even though there are nopresent uses of the portions of the aquifer located between the JDF and theRock River, the U.S. EPA and the WCNR are requiring groundwater pump andtreat to protect the environment (groundwater discharges to the Rock Riverand VOCs have been detected in the River) and to protect human health andwelfare by addressing the groundwater contamination through treatment whichwill quicken the time frame in which the aquifer may become safe for humanconsumption. Also, CEROA Section 121 (d) (2) (B) (ii) states that ACLs maynot be used to establish applicable standards if the process assumes a pointof human exposure beyond the boundary of the facility and if there is or maybe a statistically significant increase of contaminants at that point ofentry. Since contaminants have been detected within the Rock River,originating from either Parker Pen or from JDF, and since the RI concludesthat groundwater from the JDF area discharges into the Rock River, it can be
17
slutted that then is or may be a statistically significant increase (adetection) of contaminants from the JDF and therefore, ACLs may not be vised.
O-2) This carraent nay be answered in part by the response to C-l. Inaddition, the JAB still contains wastes, or the residuals thereof, as shownby the RI Report. So, groundwatar contaidLnatLao meg indeed continue overtine, even though the present cap at the JAB is believed to be sufficient toprevent or lessen the amount of contamination reaching the grounduaterbeneath the JAB. Also, it is difficult to state that the comparison ofwater quality data collected by Raker Pen suggests that sane improvementshave already occurred since RI data was collected one year earlier, sincedifferent labs and possibly different field and lab procedures were usedthan with the RI investigation.
With regards to containing the JDF groundwater remediation with that to bedesigned for the contamination associated with Parker Pen, the U.S. EPA andWDNR still believe the most economical approach is to carbine the twogroundwater pump and treat systems into one. If the systems are combined,the JDP Respondents must provide the assurances that the groundwater pumpand treat system will address the Md/State Enforcement Standard exceedancesfound downgradient of the JDP, even after Parker Pen has achieved itscleanup goals as set by the WCNR. If the two systems are not combined forone reason or another, then as stated within the ROD, the JDP Respondentswill implement their own groundwater pump and treat system to address theMCI/State Enforcement Standard exceedances.
C-3) WAC NR 140 does not require a groundwater pump and treat systemor any other particular technology. NR 140 does, however, require thatenforcement standards are addressed by taking one or more actions asoutlined in Table 6 of NR 140. The NR 140 requirements are inposed throughthe NR 181 corrective action requirements which are applicable to the JABand the 1985 sites. NR 181 requires that a facility remove or treat inplace those hazardous constituents that have migrated from the hazardouswaste unit. So, since State Enforcement Standards are exceeded, as statedwithin NR 140, treatment options are preferred to address these exceedances.Also, even though the 1985 and 1978 sites will receive cap ijqprovements,the area that is believed to be contributing to the major portion of thepresent contamination from the JDF, the JAB, will not receive cappingimprovements (as discussed in the response for C-2).
C-4) Of the treatment alternatives presented within the PS, addressingthe groundwater contamination, the groundwater pump and treat alternativeselected is the most cost effective. The groundwater pump and treatalternative selected (Alternative 11), as described within the ROD, is costeffective when compared to the other groundtwater treatment optical presentedwithin the FS Report, Alternative 12, Groundwater In-Situ Treatment. Bothalternatives will achieve basically the same cleanup goals. Also, themethod in which Alternative 11 is described in the ROD, the flexibility ofthe development of the system is similar in nature to that mentioned in thecomment, in that air stripping or other air treatment technologies will beimplemented if needed, as well as any treatment that may be needed toaddress inorganic parameters in the groundwater to enable any discharge tomeet the Ambient Surface Hater Quality Standards as set by the State.
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In conclusion, the U.S. £3* and the WCNR do not believe that the remedies,as stated within the ROD, are inappropriate or impractical, but are cost-effective and are necessary to assure protection of human health/ welfareand the envlxcnnent. As stated previously, changes to the U.S. Eflt'sProposed Plan, due to the public ocnnent period and the 60-day technicalnegotiation period with the JEF Steering Ocranittee, are stated withinSection VIII of the ROD.
COMMENT f
COMMENT i:
COMMENT 2:
COMMENT 3:
COMMENT 4:
COMMENT 5:
APPENDIX A
RESPONSIVENESS SUMMARY
LIST OF OOWENTCRS
NAME AN
DAVID HOMANENVIRONMENTAL HEALTH DIRECTORF80CK OOUWIY HEAIHH DEPftKTMQfT
JIM APPEL, RESUXNT
MICHAEL BGAN, RBSICBfT
SSI TBCHNOLDGIES, INC.JCHN E. ANDEPSONMICHAEL J. BGAN
VAIJJEY BANKROWLAND J. ModELtAN
PAUL T. IAR5CN, RESIEBW
OONSIGNY, ANtFEWS, HEMOMS& GRANT, S.C., ATTORNEYS AT LAWIOJIS 0. GAGE
HAROLD RELIBERG, RESIDEUT
CITY OF JANESVILLECITY MANAGERSTEVEN E. SHEIFFER
f
KANDU INDUSTRIESKENNETH E. LOHFF
SHEREX CHEMICAL COMPANY, INCARTHUR F. JACKSON
YAHR AND PELSUE, D.D.S, S.C.ROBERT G. YAHR, D.D.S.
WISCONSIN POWER AND LIGHT CO.JACK GRAWE, DISTRICT MANAGER
S.P.I.RUSSELL AND RUTH flREND
SOURCE Of COMMENT
8/30/89 MEETING
8/27/89 LETUR8/30/89 MEETING
8/30/89 MEETING
9/6/89 LETTER
9/12/89 LETTER
9/14/89 LETTER
9/14/89 LETTER
9/5/89 LETTER
9/14/89 LETTER
9/13/89 LETTER
9/13/89 LETTER
9/14/89 LETTER
9/13/89 LETTER
9/15/89 LETTER
OOMMEWr 5 CONTINUED!
COMMENT 6:
COMMENT 7:
LAW OFFICES OP fiRQMSf,BAOTnC tmCDOUGftLL, S.C.GBD. K. STEIL, SR.
GENERAL VENOMSROBERT F. YECMANS
ROBERT C. STONECLEFFE, RESIDENT
HOY MAKKKAM, RESIDENT
ERXE H. HAMIiaCN, Oft
H.E. ROB8, RESICEKT
RICHARD L. MCN&LL, RESIDENT
TED WALTCH, RESICEm*
HJPOCR, INC./RESIEEOTFRANK R. SCOTT
J.P. OJLtfN AND SCNS, INC.MARK A. GULLEN
SEDQR & HQAG, S.C.,ATTOFNEYS AT IANGIUBEKT D. SEDCR
VICTOR D. LITTLE, RESIDENT
WISCONSIN DEPARTMENT OFNATURAL RESOURCESMARK G&SFELDI FOR PAUL DIDIER
9/14/89 LETTER
9/16/89 LETTER
9/15/89
9/18/89
9/18/89
9/15/89
9/18/89
9/20/89
9/19/89
9/20/89
9/19/89
9/19/89
9/15/89
LETTER
LETTER
LETTER
LETTER
LETTER
LETTER
LETTER
LETTER
LETTER
LETTER
LETTER
JANESVILLE DISPOSAL FACILrriESSTEERING COMMITTEE INCLUDING:CITY OF JANESVILLE, GENERAL MOTORSCORP., PARKER PEN CO. ANDTECUMSEH PRODUCTS CO. WITH ASSISTANCEFROM WARZYN ENGINEERING, INC.
