PIIL&05

STATEMENT OF WORK FORA REMEDIAL INVESTIGATION AT THE

DUNN LANDFILL(CITY DISPOSAL CORPORATION LANDFILL),

DANE COUNTY, WISCONSIN

(PELA File No. 450202)

Prepared for

Waste Management of Wisconsin, Inc.N96 W13503 County Line Road

Menomonee Falls, Wisconsin 53051-1606

By

P. E. LaMoreaux & Associates, Inc.Consulting Hydrologists, Geologists

and Environmental ScientistsPost Office Box 2310

Tuscaloosa, Alabama 35403

September 24, 1986

RELaMoreaux & Associates

The following revisions are referenced by Section and Page numberto the "Statement of Work for a Remedial Investigation at the DunnLandfill (City Disposal Corporation Landfill), Dane County, Wisconsin."

Section Page

2.1 11 Sentences 4 through 7 (inclusive) should be deleted infavor of language in the Administrative Order.

3.1 16 The last paragraph should be deleted as inappropriate.

3.2e. 23 The following should be inserted following the lastsentence of the Section (3.2e).

"As an aid in determining the type andextent of contamination at the site, sub-surface samples (e.g., split-spoon samples)

will be collected during the drilling andinstallation of leach ate wells (Section 3.5),nested wells, and water-table wells (Section

3.6). Samples collected will be described,subjected to field screening techniques, and

appropriate intervals will be analyzed basedon results of field determinations tosupplement soil sampling."

3.3 25 The first complete paragraph on the page is modifiedto read as follows:

"Samples of surface-water runoff from the

ditch traversing the site will be collectedconcurrently with soil samples from the ditch(Sections 3.2e.4 and 3.2e.5) and analyzed asdescribed in Section 3.8. Any surface seepsdetected will be sampled (samples of water

B36B/1 RELaMoreauxot Associates

Section Page

3.5 26

and sediment will be collected) and analyzedas described in Section 3.8. Appropriatefield screening techniques may be applied tomaximize the effectiveness of sampling ef-forts."

Section 3.5, Installation of Leach ate Wells, is modified

to read as follows:

"At least three (3) leach ate wells will beinstalled. One well will be located betweenexisting wells B-15 and B-18. Locations ofadditional wells will be based on results ofme geopnysicai survey. Known extent or

landfilling, cell design, and previous stud-ies. Sites for leach ate wells will be moni-

tored for organic vapors using an HnUphotoionizer during well drilling and in-

3.6

3.6

sta Nation."

28 The reference tochanged to Figure

Figure 1 in line2.

1 of the page is

28 The following should be added in continuation of thefirst paragraph:single monitoring

"At least four well nests and fivewells will be installed during Phase

III of the well installation program (Figure 2)."

3.7 30 The first full sentence on the pageas follows:

"Gamma logs will2- inch diametercessible, (B-6R,

be performed onmonitoring wells.

B-7R, B-9R,

——————————— Dft a

is modified to read

iexistingif ac-B-12R,

Mrvnai rv SL Acc/N/Mjtae ——B36B/2

Section Page

B-16R, and B-19R) and selected 4-inchdiameter monitoring wells (B-14 and B-17)."

3.8 30 Section 3.8, Monitoring and Analyses, is modified toread as follows:

The existing semi-annual monitoring proyram should continue

until completion of the RI. All newly installed monitoring

and leachate wel ls and selected existing monitoring wel ls and

four (4) nearby private wells will be sampled for analyses to

characterize the chemical character of groundwater and to

assess the movement of contaminants. The first round of

water samples collected from the wells given above will be

analyzed tor priority pollutants and parameters "listed below

that are not included in the priority pollutants list.

Water levels in the wells will be measuredprior to sampling. Wells will be evacuated of

sample collection. Samples will be collectedand analyzed in accordance with standardprocedures. Color, odor, and turbidity willbe recorded."

B36B/3 RE-LaMoreaux& Associates

Section Page

Indicator Parameters

AmmoniaBoronNitratepHPhenolSpecific conductanceTemperatureTotal dissolved solidsTotal Kjeldahl nitrogenTotal organic carbonVolatile organics

Water-Quality Parameters

BicarbonateCalciumCarbonateChlorideMagnesiumPotassiumSodiumSulfate

Primary Drinking-Water Parameters

ArsenicBariumCadmiumChromiumFluoride

LeadMercurySeleniumSilver

Secondary Drinking-Water Parameters

CopperIronManganeseZinc

Water samples will be collected from all newly installed monitoring andleachate we l l s and the fol lowiny sites (Fiyure 2):

Existing WellsB-6R B-9A B-12R B-15 B-17B-7R B-9R B-14 B-16R B-18

Private Wells

"Ammonia and total Kjeldahl nitrogen (TKN) have been added to

the indicator parameters to aid in the evaluation of potential

sources of ground-water contamination. The Piper Trilinear

Method will be used to categorize and correlate the water-quality

parameters."

B36B/4 RE.LaMoreaux& Associates

Section Page

"The collection and analysis of water sam-ples, as described above, will be completedonce as a basis for future recommendationsregarding potential items such as:

• well abandonment or replacement;• sites for continued monitoring;• frequency of continued monitoring; and• off-site ground-water sampling."

"Based on the results of the first round ofsampling, an alternate sample analysis plan,using selected parameters, for subsequentsamples will be submitted to U.S. EPA forapproval."

B36B/5 RELaMoreaux & Associates

STATEMENT OF WORK FORA REMEDIAL INVESTIGATION AT THE

DUNN LANDFILL(CITY DISPOSAL CORPORATION LANDFILL),

DANE COUNTY, WISCONSIN

(PELA File No. 450202)

Prepared for

Waste Management of Wisconsin, Inc.N96 W13503 County Line Road

Menomonee Fails, Wisconsin 53051-1606

By

P. E. LaMoreaux & Associates, Inc.Consulting Hydrologists, Geologists

and Environmental ScientistsPost Office Box 2310

Tusc»ioosa, Alabama 35403

August 28, 1986

-—RE LaMoreaux & Associates

IP11L4:CONTENTS

I. Introduction —————————————— —————————————— 1

1.1 Remedial Investigation———————————————— 1

1.1.1 Objectives—————————————————— 11.1.2 Scope——————————————————.-—— 2

II. Task 1 — Description of Current Situation ———————— 3

1.1 Introduction—————————————————————— 31.2 Site background———————————————————— 31.3 Hydrologic setting—————————————————— 51.4 Additional description of

current situation ——————————————————— 81.4.1 Site background —————— ————————————— 81.4.2 Nature and extent of problem—————-———— 81.4.3 History of response actions———————————— 91/4.4 Define boundary conditions———————————— 91.4.5 Site map —————————————————————————10

III. Task 2 — Plans and Management——————————————11

2.1 Introduction——————————————————•—————112.2 Quality assurance and

sampling plans ——————————— ——————————122.3 Health and safety plan ———————————————122.4 Community relations ———— ————— — — —— —13

IV. Task 3 -- Site Investigation————————————————————14

3.1 Introduction ——————————————————————143.2 Soil sampling ——————————————————————203.3 Surface-water monitoring —- — ———— — — ----233.4 Geophysical survey- ——————————— —— - — -—253.5 Installation of leachate wells— ————————— -263.6 Installation of piezometers, nested

wells and water-table wells -- — — — ----- — ---273.7 Downhole geophysics --- — --- — - — -- — -------293.8 Monitoring and analyses ------ — -- —— — -- — --303.9 Air sampling -- ———— --- —— -- — ————— —— -32

V. Task 4 -- Analysis of Data—————————————————————33

VI. Task 5 -- Reports -——————————————————————————34

RELaMoreaux& Associates —

ILLUSTRATIONS

Page

Figure 1. Cell design plan and location oflandfilled area—————————————————————————— 4

2. Location of data collection sites atthe City Disposal Corporation Landfill,Dane County, Wisconsin ——————————————•—24

—————— R ELaMoreaux & Associates

STATEMENT OF WORK FOR CONDUCTINGA REMEDIAL INVESTIGATION AT

DUNN LANDFILL(CITY DISPOSAL CORPORATION LANDFILL),

DANE COUNTY, WISCONSIN

I. INTRODUCTION

The purpose of the Remedial Investigation (Rl) is to determine

the nature and extent of contamination at the City Disposal Corporation

Landfill site in Dane County, Wisconsin. The purpose of the Feasibility

Study (FS) is to determine an appropriate remedial action, if required,

based on the Rl data and report. All personnel, materials and services

required to perform the RI/FS will be provided by the Potentially

Responsible Parties (PRP).

1.1 Remedial Investigation

1.1.1 Objectives

The objectives of the Remedial Investigation are to:

1. Determine the characteristics and extent of contaminants

that may be present at the site.

2. Define the pathways of migration if contamination is de-

tected .

3. Define physical features that could affect contaminant

migration, containment or remediation.

VS21/*4—————————————————————REUMoreauxa Associates—

4. Quantify risks, if'any, to human health and the environ-

ment.

5. Compile information necessary to support the Feasibility

Study.

1.1.2 Scope•

The remedial investigation consists of five tasks:

Task 1 -- Description of Current Situation

Task 2 — Plans and Management

Task 3 -- Site Investigation

Task 4 — Site Investigation Analysis

Task 5 — Remedial Investigation Report

i ij VS21/#5————————————————————————————— RELaMoreaux& Associates—

II. TASK 1 — DESCRIPTION OF CURRENT SITUATION

1.1 Introduction

The following sections provide a historical perspective and

brief hydrologic description of the site. A complete description

of the current situation will be developed during .the site inves-

tigation which will provide the information specified in Section

1.4.

1.2 Site Background

The Ounn Landfill (City Disposal Landfill) is located on

approximately "3B acres 'in tne sou'tnern 'nair or Section "3D, "Town-

ship 6 North, Range 10 East in Dane County, Wisconsin.

The site was first utilized in 1966 and -closed in January

1977. The site was operated in compliance with NR 151 and

licensed throughout the operational period in accord with current

regulations. The site was subdivided into twelve cells (Figure

1) of which cells 1, 2, 3, 4, 6, and 12 were filled or partially

filled. The cell plan is based on engineering plans completed by

Soil Testing Services of Wisconsin, Inc. Cells 1 and 12 were

utilized from initial disposal until 1974. Cells 2, 3, 4, and 6

were filled or partially filled from 1974 until closure in 1977. An

area designated for industrial waste disposal (a portion of cell

12) was located in the eastern portion of the site. Industrial

wastes were disposed in cell 12 from 1966 through March 1975.

VS21/02/#6 RELaMoreaux & Associates

IMP tOUflce; MODIFIED FROM t/SOS T.I MINUTi OUAOHAMaLES. KU11AHO, VH3COHSIH. !»•».

FIGURE 1. CELL DESIGNPLAN AND LOCATION OFLANDFILLED AREA.

EXPLANATION

I B I CELL LOCATION AND NUMBERL _ J

LANOFILLED AREA PRIORTO 1975

LANDFILLED AREA, 1075-1977

tCALI IN FItT

Ptmpmtmd fey:P.E. LAMOREAUX * ASSOCIATES. INC.

Interpretation of aerial photography indicates agricultural

usage at the site in September, 1962. Only cell 1 was in use in

May of 1968. By October, 1975, ceil 2, a part of cell 3, the

southeastern one-fourth of cell 4, the southern one-half of cell 6

and a part of cell 12 were being utilized. Cells 1 and 12 (ex-

cept for that in use) were covered and graded. By September,

1976, cells 2 and 6 and the eastern parts of ceils-3 and 4 were

active. Vegetative cover was present on the eastern part of cell

1, but was absent near cell 12.

There were no activities at the site in June, 1978. The fill

area was graded and cells 2 and 6 and parts of cells 3 and 4

were barren. The vegetative cover at cells 1 and 12 was similar

to that recorded by the September, 1976 aerial photographs.

The entire fill area was reclaimed by August, 1978. This

reclamation was confirmed in subsequent aerial photographs.

1.3 Hydrologic Setting

Surfictal geology at the site is typical of that which occurs

in other glaciated areas. The site is situated on an end moraine

which, because of its proximity to the glacier, is characterized

by poorly sorted and stratified materials. The depth to bedrock

at the site is estimated to be from 50 to 150 feet beiow the land

surface. The lack of site-specific data precludes the delineation

of the top of bedrock.

VS21/02/#8 PE.LaMof8aux & Associates

The principal lithologies at the site are sand, silty sand,

and a mixture of sand and gravel. These materials are generally

overlain by a discontinuous layer of silty clay which has a

maximum thickness of about 20 feet.

There was limited data available from drillers' logs for

domestic wells or from published reports. The drillers logs do

not provide sufficient information for detailed correlation of

geologic units at the site. A review of logs does indicate that

the unconsolidated deposits at the site are underlain by a sand-

stone. A thick dolomite underlies this sandstone.

Two surface-water systems, Badfish Creek and Grass Lake,

are near the landfill. Badfish Creek is approximately 400 feet

east of the landfill. Grass Lake is approximately 850 feet north-

east of the landfill. Grass Lake, with an area of about 30

acres, receives runoff from about 230 acres to the east of Bad-

fish Creek. The Lake is a perched surface-water body that is

underlain by 5 to 20 feet of impermeable cJayey sediments.

Drilling data from investigations made at Grass Lake by

Warzyn Engineering, Inc. and drilling at the site indicate that

Badfish Creek is underlain by clay and silt. The clay and silt

are approximately 15 feet thick adjacent to Grass Lake and thin

to the south.

Badfish Creek, a man-made channel, intercepts runoff west

of Grass Lake. The Madison sewage treatment plan discharges

treated effluent into Badfish Creek. Treated effluent.

VS21/02/»9_________________________ 0_. ..__ ., . .————————————————————————— R ELaMoreaux & Assooates

discharged at the rate of 24 to 52 million gallons per day, con-

stitutes the majority of flow in Badfish Creek (Warzyn, 1981).

Interpretations of water levels in Badfish Creek, and from

local monitoring wells indicate potential recharge of the ground-

water system by the surface-water bodies. However, although

data adjacent to the landfill are sparse, the water level in a

monitor well is generally above the water level in -Badfish Creek,

thus indicating Badfish Creek may be a gaining stream.

Ground water occurs within both the unconsoiidated glacial

and alluvial deposits and bedrock units underlying the site.

Ground-water flow between the sand and gravel deposits and the

bedrock is unrestricted except in areas where silt and clay occur

between the two units. Regional data indicates that the units

may be separate but "leaky" aquifers.

Ground water occurs under water-table, semi-confined, or

confined conditions because of the variable permeability of the

silt and clay that locally overlie the bedrock. Water-table condi-

tions occur within the shallow unconsoiidated deposits in the

immediate area of the landfill. This same shallow aquifer is

confined or semi-confined immediately northeast of the landfill

where Badfish Creek is adjacent to Grass Lake.

Water-table maps prepared from monitoring data at the

landfill and at Grass Lake for March and September 1983 conform

to regional piezometric maps with the slope of the hydraulic

gradient to the northeast. Interpretation of the limited water-

level data indicates a ground-water mound beneath the landfill.

VS21/02/*10 RELaMoreaux & Associates

8

This mound is attributed to downward percolation of fluids from

the landfill into the underlying ground-water system. There

also appears to be a ground-water high northeast of the landfill.

The cause of this high will be investigated as part of the Reme-

dial Investigations (Task 3).

1.4 Additional Description of Current Situation

With the foregoing referenced studies as a database, addi-

tional information will be collected during the Task 3 investi-

gation. These data will be collated and formalized to provide the

following:

1.4.1 Site Background

A summary will be prepared of the regional location, per-

tinent area boundary features, and general site physiography,

hydrology, and geology. The general nature of the problem will

be defined, including pertinent history relative to the use of the

site for hazardous-waste disposal.

1.4.2 Nature and Extent of Problem

A summary of the known actual and potential health and

environmental effects will be prepared. This may include, but is

not limited to, the types, physical states, affected media and

VS21/02/*m________________________ ««-.,.——————————————————————————— RE. La MoreauxA Associates—

pathways of exposure; contaminated releases such as leach ate or

runoff; and any human and/or environmental exposure. Empha-

sis will be placed on describing the threat or potential threat to

human health and the environment.

1.4.3 History of Response Actions

A summary of any previous response actions performed by

local, state, federal, or private parties, will be presented. This

summary will address any enforcement activities undertaken to

identify responsible parties, compel private cleanup, and recover

costs. A list of reference documents and their location will be

included.

1.4.4 Define Boundary Conditions

Site boundary conditions have been established to limit the

areas of on-site investigations. The boundary conditions have

been set so that the Task 3 investigation will provide sufficient

information on the contaminated media to define pathways of

contaminant migration and to support following activities (e.g.,

the feasibility study). The boundary conditions will also be

used to identify boundaries for site access control and site

security.

VS21/02/#12________________________ „.-,,. « . •_,_———————————————————————— RE.LsMoreaux& Associates

10

1.4.5 Site Map

An accurate topographic map of appropriate working scale

has been prepared for Waste Management of Wisconsin, Inc.

(WMWI). The base map, with a scale of 1 inch to 100 feet (1n =

100') and 2-foot contour intervals, was prepared by Aero-Metric(

Engineering using April 1983 aerial photography. 'Surveying willfbe required to establish horizontal and vertical controls for sites

of the work. Surveying will be provided by WMWI.

A legal description of the WMWI property and area covered

by agreement between WMWI and Mr. and Mrs. Glenn E. Blatter-

man was prepared by O'Onofrio, Kottick and Associates, Inc. in

1981.

In May 1981 Waste Management of Wisconsin, Inc. entered

an agreement with Mr. and Mrs. Glenn E. Blatterman for pur-

chase of 37.676 acres of the Blatterman property and an ease-

ment for access. The purchased property encompasses the area

of landfill. Legal agreement limits work to monitoring of and

work on wells in existence at the Blatterman property, therefore

it will be necessary to seek concurrence with Blatterman prior to

initiation of work.

VS21/02/#13 RELaMoreaux& Associates—

111. TASK 2 — PLANS AND MANAGEMENT

2.1 Introduction

Plans for the site investigation are established and present-

ed in Task 3 of this document. Personnel requirements, sched-

ules, Program for Quality Assurance (QAPP) and Health and

Safety Plan (HASP) will be developed prior to initiation of the

RI/FS. All plans will be submitted to U.S. EPA (EPA) and the

Wisconsin Department of Natural Resources (WDNR) for review

and comment. Revised plans will be submitted to EPA and WDNR

within 30 calendar days of receipt of EPA and WDNR comments.

TbA €J? A, HtW, -wstafy, w* 'wViYrrs , t£ Tte ^pprova'i i/r ^e revised

plans. In the event of any disapproval, EPA will specify, in

writing, both deficiencies and recommended modifications. Plans

will be amended and resubmitted to EPA within two weeks of

receipt of the notice of deficiencies. Upon approval by EPA

these plans will be incorporated into the approved work plan.

Actions specified in the Rl work plan will be in accordance

with applicable Federal, State, and local laws and regulations.

Federal, State or local permits required for performance of the

Rl will be obtained.

VS21/02/#14 R ELLaMoreaux & Associates

12

2.2 Quality Assurance and Sampling Plans

A sampling plan will be prepared that addresses all field

activities necessary to obtain additional data (specified in Task

3). The plan will contain a statement of sampling objectives,

equipment specifications, parameters to be analyzed, preservation

of samples, sample location, frequency and schedule. The plan

will use field screening techniques to eliminate samples that

require no off-site laboratory analysis. The Quality Assurance

Plan (QAP) will contain other elements as required in the Admin-

istrative Order and by EPA guidance.

2.3 Health and Safety Plan

A Health and Safety Plan will be prepared and submitted

prior to initiation of the Rl. The plan will address potential

hazards to which the investigation team and the surrounding

community may be exposed. The plan will address applicable

regulatory requirements, describe personnel responsibilities,

need for protective equipment, procedures, protocols, decon-

tamination, training and medical surveillance. Procedures for

protecting third parties will be provided. The plan will be con-

sistent with EPA Standard Operating Safety Guides.

VS21/02/#15 RELaMoreauxoi Associates —

2.4 Community Relations

Community relations activities will be performed as specified

in the Administrative Order.

VS21/02/316 R ELaMoreaux & Associates

14

IV. TASK 3 — SITE INVESTIGATION

3.1 Introduction

The site investigation will be based on, and supplement the

database for the site. Hydrogeologic, water-quality, and waste-

characterization data have been collected at the site since 1976.

Reports and collected data concerning the site are listed chron-

ologically as follows:

1. "Preliminary Feasibility Study with Regard to Expan-

sion of the Existing City Disposal Company Sanitary

Landfill at the Glenn Blatterman Property on Sand Hill

Road South of Madison, Wisconsin;" by Soil Testing

Services of Wisconsin, Inc., 1973.

2. "City Disposal Company, Solid Waste Disposal Expan-

sion in the Town of Dunn, Wisconsin," by Soil Testing

Services of Wisconsin, Inc., 1974--a and b.

3. "Grass Lake Investigation, Madison Metropolitan Sew-

erage District, Town of Dunn, Dane County, Wiscon-

sin," by Warzyn Engineering, Inc., 1981.

4. "Town of Dunn Landfill, Site Evaluation of Water

Quality Monitoring" by Warzyn Engineering, Inc.,

1983.

5. "Grass Lake Investigation; Evaluation of Remedial

Measures," by Warzyn Engineering, Inc., 1984.

15

6. "Summary Report of Existing Data, Town of Dunn

Landfill—City Disposal, Dane County, Wisconsin," by

P. E. LaMoreaux & Associates, Inc., 1984.

The 1974 report by Soil Testing Services of Wisconsin, Inc.

was prepared to evaluate subsurface conditions and to design

future landfill operations in conformance with requirements

(Chapter NR-151) of the Wisconsin Department of Natural Re-

sources. The report provided information regarding the popula-

tion served, types of material to be disposed, land use, geology,

topography, and drainage patterns. Specific aspects of the

investigation included:

1. The installation of 16 soil borings;

2. The installation of PVC well points;

3. Soils descriptions;

4. Potential for leachate movement;

5. Interpretation of local hydrology;

6. Landfill design criteria.

The 1981 investigation of Grass Lake by Warzyn Engineer-

ing,̂ Inc. provided the results of a study of tbA o.o_ta.o.tiaJ. b.y-

drauiic connection between the Madison Metropolitan Sewerage

District (MMSD) sewage effluent ditch and Grass Lake. In the

site investigation, Warzyn:

1. Completed six shallow auger borings in the dike which

separated the effluent ditch from Grass Lake:

2. Collected soil samples by split-spoon techniques;

VS21/02/«18 — PE LaMoreaux A Associates

Yb_

3. Performed field bail-down tests to determine the per-

meabilities of subsoil horizons;

4. Analyzed representative soil samples;

5. Installed PVC pipe and screen in the borings;

6. Installed galvanized pipe and well points.

Warzyn analyzed the data and provided recommendations

regarding the need to monitor water levels and water quality,

initiate a weed-cutting program, review other phases of investi-

gations of Grass Lake, and to perform a cost-benefit analysis of

remedial measures to mitigate flow through the dike.

Warzyn, in a 1983 letter report:

1. Evaluated the methodology of DNR sample collection on

September 12, 1983;

2. Evaluated DNR analytical procedures;

3. Provided a hydrogeologic/water-quality evaluation at

the site;

4. Evaluated whether the site had a water-quality impact

on Badfish Creek.

As the result of a Dane County Circuit Court decision in

September, 1982, Warzyn Engineering, Inc. (1984) evaluated

engineering alternatives primarily regarding the prevention of

potential muskrat damage to the dike which separated MMSD's

effluent ditch and Grass Lake. Warzyn concluded that installa-

tion of metal muskrat barriers in conjunction with an annual

weed-cutting program would be the most reasonable and cost-

effective measure.

VS21/02/S19____________________________., ._ . .-—————————————————————————R£LaMoreaux& Associates—

17

In 1984, P. E. LaMoreaux & Associates, Inc. (PELA) pre-

pared a summary report of existing data for the site. The

objectives of the study were to obtain and evaluate available

data, prepare a summary assessment of site conditions, identify

areas where additional information was needed, itemize additional

work required to define the hydrogeology at the landfill and

assess the potential impact of the landfill on water quality. ;

The following conclusions were included in the July 1984

study report.

1. No volatile organics were detected in the private wellwater samples.

2. Interpretation of aerial photography and review of dataand records on site chronology indicate that the maxi-mum area of disposal of industrial wastes is limited tothe extent of works shown on October 2, 1975, photo-graphy.

3. Site specific geologic information is generally consistentwith the available regional data. However, maximumdepth of any boring or well on the site is 50 feet.The site specific data collected to date are inadequateto characterize fully the lithology of the glacial depos-its or to delineate configuration of the top of bedrockat the landfill site.

4. Publicly available data indicate that the depth to thebedrock surface ranges from approximately 50 to 150feet below land surface at the Dunn Landfill site.

5. Available data indicate that the uppermost bedrockbeneath the landfill site is a sandstone unit underlainby a thick sequence of dolomite.

6. Water-table conditions exist in the immediate area ofthe landfill, within the shallow unconsoiidated deposits.Site specific water-table maps prepared show conform-ity with regional piezometnc maps, with the hydraulicgradient to the northeast.

7. The amount of data available to evaluate the water-table configuration is limited. However, two anomalousfeatures are noted:

VS21/02/#20 RELaMoreaux& Associates —

18

a. The apparent ground-water high that occursbelow the landfill area, and

b. The ground-water high to the northeast towardwells B-14 and B-17 which could be caused bythe thickening of the surficial silt and clay.

Data indicate that the ground-water high ormound is less than 4 feet in height.

8. Data available from reports and engineering plans pre-pared by Soil Testing Services indicate that the baselevel of the landfill (approximately 937 feet MSL) isabove the water table.

9. Grass Lake is underlain by a sequence of clayeysediments of varying thickness. The surface-waterelevation of Grass Lake is higher than the elevationsof the ground-water system. Analysis of availabledata indicates no direct hydraulic connection betweenthe two systems.

Badfish Creek is both an influent and effluent stream.This interrelationship of the ground-water system andBadfish Creek is dependent on the nature of thelithology underlying the creek and seasonal hydrologicconditions. Data available are not sufficient to ad-dress this interrelationship in detail.

10. Data are not sufficient to assess the hydrology of thedeeper, glacial, water-bearing zones or the relation-ship of the ground water in the glacial material andwater in the bedrock aquifer(s).

Only one nest of monitoring wells has been establishedat the landfill site. Both of the wells are completed inthe glacial deposits -- 30 feet and 50.5 feet below landsurface. The higher water-level elevation in theshallower well may indicate that ground water has thepotential for downward leakance from the shallow zoneto the deeper zone. Water levels indicate that thewater-bearing zones penetrated by the two wells arenot in direct hydraulic communication at that location.

11. Analyses of water samples from monitoring wells indi-cate elevated concentrations for some parameters in theimmediate area of the landfill.

12. A review of water quality data indicates inconsistentand erratic values (pH, specific conductance, totalhardness, iron, sulfate, and chloride) occurringrandomly throughout the period of record (1974 -1983). The highest concentrations of the parameters

VS21/02/#21 RELaMoreaux& Associates —

19

analyzed and lowest pH values measured occur fromwater in wells B-15 and B-18. Refuse material waspenetrated during the drilling of B-15. The well isscreened approximately 8 feet below the base of therefuse material. For the purpose of evaluation ofground-water quality, well B-15 should be considereda leachate well.

13. On the basis of one sampling effort and analyses ofground-water samples for volatile organic compounds,the highest concentrations occur near the area ofdocumented industrial waste disposal near monitoringwells B-15 and B-18. Lower levels of organic com-pounds were detected in water from other monitoringwells.

The distribution of organic compounds is not consistentwith distribution of indicator parameters. Factorswhich could contribute to the detection of these or-ganic compounds include:

1. Well construction,2. Ambient conditions,3. Sample collection techniques,4. Laboratory techniques,5. Industrial waste disposal,6. Chemicals disposed with domestic solid waste,7. Unknown sources.

Current ground-water monitoring at the site consists of:

1. Water-sample collection and analyses for metals since

1976 on a quarterly basis.

2. Quarterly sample collection and analyses for VOC's

since 1982 (new monitor wells were included and in-

stalled).

Additional remedial investigations will be performed to

characterize the impact, if any, on the environment and human

health. The results of the site investigation will be used to

assess preliminary remedial alternatives and to evaluate alter-

natives during the feasibility study.

VS21/02/S22 P. ELaMoreaux & Associates

20

The proposed field investigation at the site will fulfill the

goals of the Rl as stated by EPA. Specific aspects of the field

investigation are:

1. To assess the hydraulic relationship between the

surface- and ground-water systems;

2. To assess the composition, integrity, thickness, po-

tential for leachate generation, and potential infil-

tration characteristics of the existing soil cover;

3. To determine the thickness and correlation of glacial

deposits, hydrology of deeper water-bearing zones in

the glacial deposits, and the relationships between

ground water in the glacial deposits, and bedrock;

4. To delineate extent of contaminated soils and ground

water;

5. To assess risk to human health and the environment.

The additional investigations to be carried out during this

site investigation will consist of installation of additional moni-

toring wells, collection and analysis of additional ground-water

samples, and collection and analysis of additional soil samples.

The following sections provide details on the location and meth-

ods of data collection necessary to characterize the site.

3.2 Soil Sampling

To assess the composition, integrity, and thickness of the

existing soil cover a soil survey will be performed. Information

VS21/02/#23 -—RELoMoreaux& Associates

IP1UA-21

obtained from the soil cover survey will also be used in develop-

ing a water budget for the site. Soil samples will be collected at

selected sites and analyzed to determine if contamination is

present.

Specific work items for the soil survey are:

a. A 100-foot grid system will be established on the

landfill surface. Surveying of horizontal or vertical

controls required will be provided by WMWI.

b. A field reconnaissance will be completed to map condi-

tions of visual cover, for example: vegetative stress,

erosion, exposed waste materials, leach ate seeps, etc.

c. A boring will be completed, by hand or power auger,

at each node on the 100-foot grid, to provide docu-

mentation of the thickness and lithology of the soil

cover.

d. To evaluate the permeability of the soil/cover material:

(1) Samples will be collected from at least 20 percent

(201) of the borings for analysis of grain size

distribution (including hydrometer).

(2) Bulk samples will be collected from five (5)

borings and analyzed to develop compaction test

curves. In addition, laboratory tests will be

completed to determine permeability under a range

of compaction. A relationship between compaction

and permeability will be established.

VS21/02/#24 R ELaMoreaux & Associates

(3)

22

Samples will be collected from at least 20 percent

(20%) of the borings and analyzed for moisture

content.

(4) Field density measurements will be completed for

at least 20 percent (201) of the borings - same

locations as Item (3) above. Using the density

measurement, results from compaction tests and

permeability curves, permeability will be deter-

mined for each location.

e. Soil samples will be collected from six (6) locations and

analyzed for priority pollutants. Samples will be

collected by means of push tubes to a maximum depth

of two (2) feet.

Sample locations are described as follows:

(1) Bottom of slope in vicinity of well B-15.

(2) Bottom of slope in vicinity of well B-18.

(3) Mid-way between wells B-15 and B-18.

(4) and (5) At two (2) locations along drainage ditch

east of well B-12R.

(6) Approximately mid-way between wells B-7R and

B-14.

These sampling sites have been selected on the basis

of landfill topography, surface drainage patterns.

VS21/02/S25 — P. ELaMoreaux & Associates —

23

known locations of buried industrial waste, and pro-

visions for a control sample (Sample 6).

f. Air monitoring will be performed during the augering

and sampling in accord with the health and safety

plan. The purpose of monitoring is two-fold: (1)

personal safety monitoring; and (2) qualitative mon-

itoring of site conditions. The results of the mon-

itoring will be tabulated and incorporated with data

interpretation.

3.3 Surface-Water Monitoring

Surface-water stations will be installed at locations on

Badfish Creek and Grass Lake to assess the hydraulic relation-

ship between the surface-water and ground-water systems. If

possible, staff gages located on Badfish Creek and owned by the

Madison "Metropolitan Sewerage "District IMM5D") will be used.

Proposed locations are shown on Figure 2 (actual locations are

subject to field conditions and MMSD locations). All stations will

be equipped with staff gages. Surveying of locations and eleva-

tions will be completed by WMWI to provide controls needed for

data interpretation. Staff gage readings and water-level mea-

surements in all wells (existing and newly installed) will be

obtained at least twice weekly during field work and quarterly

thereafter for the duration of Rl activities. Stream discharge

VS21/02/*26 RELaMoreauxA Associates ——

,t

EXPLANATION

B-«REXISTING MONITORINQ WELL

PROPOSED SURFACE WATERSITE AND NUMBER

> "• ac POSSIBLE WELL NEST SITELOCATION AND NUMBER

POSSIBLE SHALLOW WELL SITELOCATION AND NUMBER

PROPOSED SHALLOWPIEZOMETER LOCATIONS

LIMITS OF FILL

FIGURE 2. LOCATION OF DATA COLLECTION SITES AT THE CITY DISPOSALCORPORATION LANDFILL, DANE COUNTY, WISCONSIN.

•CAM IN rttf

25

will be measured at the three (3) sites on Badfish Creek syn-

chronously with staff gage readings.

Samples of surface-water runoff from the ditch traversing

the site will be collected and analyzed as described in Section

3.8. Any surface seeps detected will be sampled and analyzed

as described in Section 3.8. Appropriate field screening tech-

niques may be applied to maximize the effectiveness of sampling

efforts.

3.4. Geophysical Survey

An electromagnetic survey will be performed to obtain

information on subsurface and near surface conditions. A mag-

netometer survey will not be completed because the limits of the

site are well defined through previous mapping and aerial pho-

tography and, because the site was used for co-disposal, metals

identified could not be defined specifically as drums.

The grid system, established for soil sampling (3.2), will

be used for orientation and spacing of profiles. A survey

around the periphery of the landfill will aid in delineating areas

where the landfi l l may be impacting the ground water. The

survey across the landf i l l w i l l aid in defining any areas of

leach ate generation and any areas of downward infiltration into

the ground-water system.

Electromagnetic (EM) surveying is a method by which lateral

variations in the electrical conductivity of subsurface soil, rock

VS21/02/#2S— RE.LaMoreaux& Associates

26

and ground water can be rapidly detected. Subsurface con-

ductivity variations may be caused by changes in soil moisture

content, specific conductance of ground water, soTl depth and

thickness, as well as structural features such as voids or frac-

tures. Electromagnetic measurements will be obtained from the

periphery of the landfill area and at selected profiles across the

landfill. Additional EM measurements will be made- to define the

configuration of any contaminant plume that may be detected in

the landfill or around the periphery of the landfill. The survey

will use profiling techniques (fixed-depth measurements along a

traverse line) and sounding techniques (measurements to various

depths at a given location). Steps to be taken in the reduction

and interpretation of data will be as follows:

1. Selected traverses will be plotted as conductivity profiles;

2. Contour maps of subsurface conductivity will be construct-

ed;

3. Spatial changes in measured values of conductivity will be

•evaluated to determine conductivity anomalies and compared

with other data (geologic, hydrologic, and historic) for the

site.

3.5 Installation of Leachate Wells

At least three (3) leachate wells will be installed. Well

locations will be based on results of the geophysical survey,

known extent of landfilling, cell design, and previous studies.

VS21702/329R ELaMoreaux & Associates

27

3.6 Installation of Piezometers, Nested Wells and Water-Table Wells

To determine the thickness of glacial deposits, hydrology of

deep water-bearing zones in the glacial deposits, and the rela-

tionships between ground-water, surface-water, glacial deposits,

and bedrock, wells will be installed in a three (3)-phased ap-

proach. The phased approach to well installation will facilitate

use of information obtained from initial well installation to es-

tablish locations for additional wells, intervals to be screened,

number of wells required for • each well nest and appropriate

drilling techniques.

Shallow piezometers will be installed to establish 300-foot

triangular grids in Phase I of the well installation program

(Figure 2). The triangular grid pattern will be used to provide

a geometric network for computing ground-water gradient andV

flow direction. Piezometers will be constructed of 3/4 inch-ID

galvanized pipe and well points. If necessary, the grid pattern

can be expanded in any direction.

Phase II of the well installation program will consist of the

drilling of a bedrock monitoring well upgradient of the site.

The evaluation of data obtained from the drilling of this bedrock

well, which would include lithologies and hydroiogic units pene-

trated, will be used to determine the number of wells in each

well nest and the interval to be screened in each well.

Remaining wells will be installed in Phase III of the well

installation program. Probable locations for well nests and

VS21/02/«30-—RE.LaMoreaux& Associates

28

shallow monitoring wells are shown on Figure 1. The number of

wells and their locations will be based on information obtained

from Phases I and II of the well installation program.

Split-spoon samples (or an alternate method of obtaining

"undisturbed" samples) will be taken at 5-foot intervals or more

frequently where a change in lithology occurs during Phase II

and Phase III drilling. Representative samples will be retained

of each interval. An experienced PELA geologist will be present

•dcirimg TfrYiYmg *» supervise drifting operations, coTlect samples,

and prepare field descriptions of the samples and a strip chart

of the lithology penetrated during drilling. Drill penetration

rates, blow counts, and observations on top of moisture or zones

of saturation will be recorded. Descriptions of samples will be

prepared using a sand grain chart, rock color chart, and hand

lens. The geologist will also be responsible for proper labeling

of samples and documentation of sample collection. Grain-size

distribution analysis (including hydrometer) will be performed on

samples from the important hydrogeoiogic units.

The data obtained from sample descriptions and analyses

will aid in determining the hydrogeology at the site. The data

will also serve as a control for the evaluation of geophysical logs

and lithologic correlation of data from new and existing wells.

Monitoring wells will be constructed of screw-joint PVC well

screen and casing. Screened intervals will be selected by

evaluating information collected during drilling and geophysical

logging. A sand pack will extend above the top of the screen.

VS2T/02/*31R ELaMoreaux & Associates

29

and the annular space around the casing will be sealed to the

surface with a bentonite slurry. Wells will be developed by

bailing, backflushing, surging, or pumping. Water levels and

volume(s) of water1 removed during development will be recorded.

Water samples will be collected during development and field

determinations will be made for pH, temperature, and specific

conductance.

The locations and elevations of wells will be surveyed by

WMWI. Bail-down or slug tests will be performed on selected

wells to determine the hydraulic characteristics of the various

performed after Phase III well installation. However, limited

testing may be required in Phase II to define/ refine the actual

number of wells required and their location.

Water-level measurements will be performed at all new and

existing wells (per the schedule in Section 3.3). These data will

be used to prepare water-table/potentiometric surface maps.

3.7 Downhoie Geophysics

Downhole geophysical logging will be completed to aid in

selection of screen settings for wells installed under Section 3.6

and for use in correlation of lithologies penetrated in previously

drilled wells. Spontaneous potential, resistivity, and gamma logs

wilt be performed in each well (piezometers will not be logged)

installed in Section 3.S (drilling technique may preclude certain

VS21/02/S32-— RELLaMoreauxA Associates —

30

loys ) Gamma loys need to be completed only for the deepest well of eachof the well nests. Uamma loys wi l l be performed on JxUtiny £-inchdiameter monitoriny wells, If accessible, (B-bR, B-7R, B-9R, B-1<W, B-16.and B-19R) and selected 4-inch diameter monitoriny wells (B-14 and B-17).

The gamma logs from the existing wells will be compared

with drillers' logs prepared by previous investigators and cor-

related with gamma logs and sample descriptions from the new

wells to provide detailed stratigraphic correlation between all

borings around the site.

3.8 Monitoring and Analyses

The existing semi-annual monitoring program should con-

tinue until completion of the Rl. All selected existing monitoring

wells and four (4) nearby private wells will be sampled to char-

acterize the chemical character of ground water and to assess

the movement of contaminants. The water collected from all

monitoring wells and the four nearby private wells will be ana-

lyzed for the selected indicator parameters, water quality param-

eters, and primary and secondary drinking-water standards

enumerated below. Water levels in the wells will be measured

prior to sampling. Wells will be evacuated of water and allowed

to recharge prior to sample collection. Samples will be collected

and analyzed in accordance with standard procedures. Color,

odor, and turbidity will be recorded. The specific parameters

for analysis are:

VS21/02/#33— RE.LaMoreaux& Associates

31

Indicator Parameters

AmmoniaBoronNitratePHPhenolSpecific conductanceTemperatureTotal dissolved solidsTotal Kjeidahl nitrogenTotal organic carbonVolatile organics

Water-Quality Parameters

BicarbonateCalciumCarbonateChlorideMagnesiumPotassiumSodiumSulfate

Primary Drinking-Water Parameters

ArsenicBariumCadmiumChromiumFluoride

LeadMercurySeleniumSilver

Secondary Drinking-Water Parameters

CopperIronManganese 'Zinc

Water samples will be collected from the following sites (Fig-

ure 1):

8-6RB-7R

Wells

B-9A B-12RB-9R B-14

Private Wells

B-15B-16R

B-17B-18

Ammonia and total Kjoldahl nitrogen (TKN) have been added

to the indicator parameters to a«d in the evaluation of 9at&n.txaJ.

sources of ground-water contamination. The Piper Trilinear

Method will be used to categorize and correlate the water-quality

parameters.

VS21/02/#34 RELaMoreaux&Assooates —

32

The collection and analysis of water samples, as described

above, should be completed once as a basis for future recom-

mendations regarding potential items such as:

• well abandonment or replacement;

• sites for continued monitoring;

• parameters for continued monitoring;

• frequency of continued monitoring; and

• off-site ground-water sampling.

3.9 Air Sampling

Air sampling will be performed during site activities as a

part of the health and safety plan. The information will be used

to assess the need for personal protection and also will be evalu-

ated from the technical standpoint. Air monitoring will be

performed during the cover survey and soil sampling (Section

3.2), installation of leachate wells (Section 3.5), installation of

nested wells (Section 3.6), and monitoring and analyses (Section

3.8). Air monitoring will be performed with an HNU-photoionizer

meter or other appropriate field instrumentation.

VS2T/02/S35 ~ RE.LaMoreaux& Associates —

33

V. TASK 4 — ANALYSIS OF DATA

An analysis of all data collected during this investigation

will be made to assure that the quality (e.g. QA/QC procedures

have been followed) and quantity of the data adequately support

the feasibility study- A summary of tbua. vtjthfVA «K'.U. bo. vik,-

mitted to U.S. EPA and Wisconsin Department of Natural Re-

sources (WDNR) as the preliminary data transmittal. The an-

alysis will be transmitted within three weeks of completion of the

analytical work. The QA/QC evaluation would determine whether

the data met the requirements of the QAPP and would include an

analysis such as that for organics in EPA's Laboratory Data

Validation Functional Guidelines (R-582-5-5-01).

The results of the site investigations will be organized and

presented in a report. The data from the investigation will be

used to develop a summary of the type and extent of on-site

contamination. An Endangerment Assessment will describe the

specific chemicals at the site and ambient levels at the site, the

number, locations, and types of populations, and migration

pathways that may result in an actual or potential threat to

human health, welfare or the environment. Actual or potential

risks will be quantified whenever possible.

VS21/027*36______________________——————————— p ̂ LaMoreaux & Associates —

34

VI. TASK 5 - REPORTS

Regular progress reports will be prepared that:

1. Describe the actions taken toward compliance with the

Consent Order; v

2. Describe site activities and the results of sampling and

tests or data produced during the month;

3. Describe actual or potential problems associated with the

site investigation;

4. Describe plans for work during the next reporting period.

These reports are to be submitted to EPA and WDNR by the

10th day of each month following the effective date of the

Consent Order.

During the investigation, the EPA will be provided with

preliminary field data to inform its personnel of major project

milestones. This data transmittal would consist of providing

preliminary copies of boring logs, diagrams of monitor well

construction, notice of sampling completion, sample identification,

results, and other pertinent data.

A technical report with supporting graphics, maps, and

tables will be prepared. Basic data such as detailed lithologic

descriptions, methods and procedures, and quality assurance will

be included in appendices. The report will identify, if appro-

priate, the nature, extent, and pathways of contaminant

VS21/02/S37___________ «•-•,. . . •_.————————————————————————— RELsMoreaux & Assooates —

PiilA35

migration. Included in the report, as necessary, will be a

detailed description of recommendations for further investigation

and continued activities. The report will be submitted in draft

form for review and comment. Upon receipt of comments, a final

report will be completed.

VS21/02/338RE.LaMoreaux& Associates

STATEMENT OF WORK

FOR CONDUCTING FEASIBILITY STUDIES

for City Dispos-al Corporation Landfill

PURPOSE

The purpose of this feasibility study is to developand evaluate remedial alternatives for City Disposal Corp-poration Landfill. The Engineer wilLfurnish the necessarypersonnel, materials, and services necessary to prepare theremedial action feasibility study, except as otherwisespecified. . .

SCOPE

The feasibility study consists of seven tasks:

Task 6 - Description of Proposed ResponseTask 7 - Preliminary Remedial TechnologiesTask 8 - Development of AlternativesTask 9 - Initial Screening of AlternativesTask 10 - Evaluation of the AlternativesTask 11 - Preliminary ReportTask 12 - Final Report

A work plan that includes a detailed technicalapproach, a budget, personnel requirements, and scheduleswill be submitted for the proposed feasibility study.

TASK 6 - DESCRIPTION OF PROPOSED RESPONSE

Information on the site background, the nature andextent of the problem, and previous response activitiespresented in Task 1 of the remedial investigation will beincorporated by reference.

Following this summary of the current situation, asite-specific statement of purpose for the response, basedon the results of the remedial investigation, should bepresented. The statement of purpose should identify theactual or potential exposure pathways that should beaddressed by remedial alternatives.

TASK 7 - PRELIMINARY REMEDIAL TECHNOLOGIES

Based on the site-specific problems and statement ofpurpose identified in Task 6, develop a master list ofpotentially feasible technologies. These technologieswill include both on-site and off-site remedies, dependingon site problems. The master list will be screened based

on site conditions, waste characteristics, and technicalrequirements, as well as applicable criteria found inERA Interim Policy: "Procedures for Planning and Implement-ing Off-Site Response Actions" (50 Federal Register 45933November 5, 1985) to eliminate or modify those technologiesthat may prove extremely difficult to implement, will requireunreasonable time periods, or will rely on insufficientlydeveloped technology.

TASK 8 - DEVELOPMENT OF ALTERNATIVES

Based on the results of the remedial investigation andconsideration of preliminary remedial technologies(Task 7), develop a limited number of alternatives forsource control or off-site remedial actions, or both, onthe basis of objectives established for the response.

a. Establishment of Remedial Response Objectives

Establish site-specific objectives for theresponse. These objectives will be based onpublic health and environmental concerns, thedescription of the current situation (fromTask 1), information gathered during the remedialinvestigation, section 300.68 of the NationalContingency Plan (NCP), EPA's interim guidance,and the requirements of any other applicable EPA,Federal, and State environmental standards,guidance, and advisories as defined under EPA'sCERCLA compliance policy. (See "Revised CERCLAEnforcement Policy Compendium", of flay 9, 1985)Objectives for source control measures shouldbe developed to prevent or significantly minimizemigration of contamination from the site. Objec-tives for management of migration measures shouldprevent or minimize impacts of contamination thathas migrated from the site.

b. Identification of Remedial Alternatives

Develop alternatives to incorporate remedialtechnologies (from Task 7), response objectives,and other appropriate considerations into acomprehensive, site-specific approach.Alternatives developed should include thefollowing (as appropriate):

Alternatives for off-site treatment ordisposal, as appropriate

Alternatives which attain applicableand/or relevant Federal public healthor environmental standards

Alternatives which exceed applicableand/or relevant public health orenvironmental standards

Alternatives which do not attainapplicable and/or relevant publichealth or environmental standards butwill reduce the likelihood of presentor future threat from the hazardoussubstances. This must include analternative which closely approachesthe level of protection provided by theapplicable or relevant standardsNo action.

There may be overlap among the alternativesdeveloped. Further, alternatives outside ofthese categories may also be.'developed, such asnon-cleanup alternative (e.g., alternative watersupply, relocation). The alternatives shall bedeveloped in close consultation with ERA and theState. Document the rationale for excluding anytechnologies identified in Task 7 in thedevelopment of alternatives.

TASK 9 - INITIAL SCREENING OF ALTERNATIVES

The alternatives developed in Task 8 will be screenedby the Engineer to eliminate those that are clearlyinfeasible or inappropriate, prior to undertaking detailedevaluations of the remaining alternatives.

Considerations to be Used in Initial Screening

Three broad considerations must be used as a basis forthe initial screening: cost, public health, and theenvironment. More specifically, the following factorsmust be considered:

1. Environmental Protection. Only thosealternatives that satisfy the response objectivesand contribute substantially to the protection ofpublic health, welfare, or the environment willbe consideced turt'ner. "Source coTftrtfialternatives will achieve adequate control ofsource materials. Management of migrationalternatives will minimize or mitigate the threatof harm to public health, welfare, or theenvi ronment.

2. Environmental Effects. Alternatives posingsignificant adverse environmental effects will beexcluded.

3. Technical Feasibility. Technologies that mayprove extremely difficult to implement, will notachieve the remedial objectives in a reasonabletime period, or will rely upon unproventechnology should be modified or eliminated.

4. Cost. An alternative whose cost far exceeds thatof other alternatives will usually be eliminatedunless other significant benefits may also berealized. Total costs will include the cost ofimplementing the alternatives and the cost ofoperation and maintenance.

The cost screening will be cpnducted only afterthe environmental and public health screeningshave been performed.

TASK 10 - EVALUATION OF THE ALTERNATIVES

Evaluate the cost-effectiveness of alternativeremedies that pass through the initial screening inTask 9. Alternative evaluation will be preceded bydetailed development of the remaining alternatives.

a. Technical Analysis

The Techn'ica'l Analysis w'lTi, as a m'ln'imum:

1. Describe appropriate treatment, storage, anddisposal technologies.

2. Discuss how the alternative does (or doesnot) comply with specific requirements ofot̂ ft.r wxi.corimfi.ri.'ta.'i. lyracyrams.^ When. a.n.alternative does not comply, discuss how thealternative prevents or minimizes themigration of wastes and public health orenvironmental impacts and describe specialdesign needs that could be implemented toachieve compliance.

3. Outline operation, maintenance, andmonitoring requirements of the remedy.

4. Identify and review potential off-sitefacilities to ensure compliance withapplicable RCRA and other ERA environmentalprogram requirements, both current andproposed. Potential disposal facilitiesshould be evaluated to determine whetheroff-site management of site wastes couldresult in a potential for a future releasefrom the disposal facility.

5. Identify temporary storage requirements,off-site disposal needs, and transportationplans.

6. Describe whether the alternative results inpermanent treatment or destruction of thewastes, and, if not, the potential forfuture release to the environment.

7. Outline safety requirements for remedialimplementation (including both on-site andoff-site health and safety considerations).

8. Describe how the alternative could be phasedinto individual operable-units. Thedescription should include a discussion ofhow various operable units of the totalremedy could be implemented individually orin groups, resulting in a significantimprovement to the environment or savings incost.

9. Describe how the alternative could besegmented into areas to allow implementa-tion in differing phases.

10. Describe special engineering requirements ofthe remedy or site preparationconsiderations.

b. Environmental Analysis

Perform an Environmental Assessment (EA) for eachalternative. The EA should focus on the siteproblems and pathways of contamination actuallyaddressed by each alternative. The EA for eachalternative will include, at a minimum, anevaluation of beneficial effects of the response/adverse effects of the response, and an analysisof measures to mitigate adverse effects. Theno-action alternative will be fully evaluated todescribe the current site situation andanticipated environmental conditions if noactions are taken. The no-action alternativewill serve as the baseline for the analysis.

c. Public Health Analysis

Each alternative will be assessed in terms of theextent to which it mitigates long-term exposureto any residual contamination and protects publichealth both during and after completion of theremedial action. The assessment will describethe levels and characterizations of contaminants

on-site, potential exposure routes, and•ptftwititfiYy tff^vc'itti •popo'i'a'i'itffi. Trit"no action" should be described in terms ofshort-term effects (e.g., lagoon failure),1i1/?R,-Vfc77t, tVf/VsWfc to *}&i.V;'i/ytK, '•JJteJlVtfJl*,,resulting public health impacts. Each remedialalternative will be evaluated to determine thelevel of exposure to contaminants and thereduction over time. The relative reduction inpublic health impacts for each alternative willbe compared to the no-action level. Formanagement of migration measures, the relativereduction in impact will be determined bycomparing residual levels of each alternativewith existing criteria, standards, or guidelinesacceptable to ERA. For source control measuresor when criteria, standards, or guidelines arenot available, the comparison should be based onthe relative effectiveness of technologies. Theno-action alternative will serve as the baselinefor the analysis.

d. Institutional Analysis

Each alternative will be evaluated based onrelevant institutional needs. Specifically,regulatory requirements, permits, communityrelations, and participating agency coordinationwill be assessed.

e. Cost Analysis

Evaluate the cost of each feasible remedialaction alternative (and for each phase or segmentof the alternative). The cost will be presentedas a present worth cost and will include thetotal cost of implementing the alternative andthe annual operating and maintenance costs. Bothmonetary costs and associated non-monetary costswill be included. A distribution of costs overtime will be provided.

f. Evaluation of Cost-Effective Alternatives

Alternatives will be compared using technical,environmental, and economic criteria. At aminimum, the following areas will be used tocompare alternatives:

1. Present Worth of Total Costs. The netpresent value of capital and operating andmaintenance costs also must be presented.

2. Health Information. For the no-actionalternative, EPA prefers a quantitative

statement including a range estimate ofmaximum individual risks. Wherequantification is not possible, aqualitative analysis may suffice. Forsource control options, a quantitative riskassessment Is not rea,uired^ For managementof migration measures, present aquantitative risk assessment including arange estimate of maximum individual risks. '

3. Environmental Effects. Only the mostimportant effects or impacts should besummarised. Reference.can be made tosupplemental information arrayed in aseparate table, if necessary.

4. Technical Aspects of the RemedialAlternatives. The technical aspects of eachremedial alternative relative to the othersshould be clearly delineated. Suchinformation generally will be based on theprofessional opinion of the Engineerregarding the site and the technologiescomprising the remedial alternative.

5. Information on the Extent to Which Remedial"Alternatives Fleet the Technical Requirementsand Environmental Standards of ApplicableEnvironmental Regulations.- This informationshould be arrayed so that differences in howremedial alternatives satisfy such standardsare readily apparent. The general types ofstandards that may be applicable at the siteinclude:

a. RCRA design and operating standards; and

b. Drinking water standards and criteria.

5. Information on Community Effects. The typeof information that should be provided isthe extent to which implementation of aremedial alternative disrupts the community(e.g., traffic, temporary health risks, andrelocation).

1. Other Factors. This category of informationwould include such things as institutionalfactors that may inhibit implementing aremedial alternative and any othersite-specific factors identified in thecourse of the detailed analysis that mayinfluence which alternative is eventuallyselected.

TASK 11 - PRELIMINARY REPORT

Prepare a preliminary report presenting the results ofTasks 6 through 10. Submit five (5) copies of the preliminaryreport to EPA and five (5) copies to the Wisconsin Departmentof Natural Resources. (Note: EPA and the State will reviewand EPA will select a remedial alternative.)

TASK 12 - FINAL REPORT

Prepare a final report for submission to EPA and theState. The report will include the results of Tasks 6through 11, and should include any'supplemental informationin appendices. Submit five (5) copies to EPA and five (5)copies to the Wisconsin Department of Natural Resources.