Unilateral Administrative Order - Muskego Sanitary Landfill ...

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: REGIONS 

77 WESt JACKSON BOULEVARD 

CHICAGO, II.. 606044590 

IJEC 0 9 

RE: Muskego Sanitary Landfill Super fund Site, 

Unilateral Administrative Order 

Remedial Design/Remedial Action 

Dear Sir or Hada:ni:: 

(J5) 

11355" 

REPLY TOTHIE; ATTENTION Of: 

Enclosed please find a Unilateral Administrative Order issued by 

the U.S. Environmental Protection Agency under Section 106 of the 

Comprehensive Environmental Response , Compensation and Liabi 1 ity 

Act of 1980,, aia amended by the Superfund Amendments and 

Reauthorization Act of 1986 (CERCLA) , 42 U.S. c. § 9601, et :sec|;. 

Please note that the Order allows an opportunity for a conference 

if requested within ten (10) calendar days after issuance o:l: the 

Order; and specifies a date and location for the conference. 

If you have any questions regarding the Girder, feel free to 

contact Thomas Krueger, Assistant Regional Counsel, at. (312) 886- 

0562 or Bill Haubold, Remedial Project Manager,, at (312) 353- 

6261. 

Sincerely yours, 

, William E. Huno, 

Waste Management D ivls i 

Enclosure 

cc :: Mark Giesf eldt 

Wisconsin Department of Natural Resources 

Is/

cc: Sue Mencohi 

Deborah Garber 

Tom Xruegei 

Tom Marks 

Susan Pastor, Public Affairs 

Sheila Huff, Department of Interior 

Tony Audia (5MF8-14)

ywiiEOjEiniwiis 

February 17, 1993 

If HI.. Lima S, Seglin 

Senior Environmental Counsel 

Waste Management,, Inc. „ 

300::i ButtiEirfield Road 

Oak Brook, II. 60521 

REGION !ii 

77 WEST JACKSON BOULEVARD 

CHICAGO,, I'L 80604-3590 

Ra: Muskeqo Landfill 

Adiiitinistrative Order V-W-92-C173 

Dear Ms,. Seglin: 

This letter is in response to your January 20,, 1993 letter 

regarding deed restrict ions for the Anaiuut: facility property, It 

is U.S. EPA's view that the AnamaK: facility property is', at least 

partially, a part of the Muskego Sanitary Landfill site,, Figure 

i-2 of the ReigDueidial DeiEiiign/Renedial Action Work: Plan sh,o«s 

portions of the Old, Non-"Contigiiousr and Soiuitlleaet Fill Areas 

extiuiiding onto the forhmer Anaiiax: facility property., U.S., EPA 

therefore believes that the fEttateiDiient in your letter that this 

property is not part of the lldUskego site is mistaken, 

Your letter also indicates that a deed restriction was recorded 

in the office of the Waukeeha County Register of Deeds on January 

11:1,, 1993.. However,, your letter does not discuss wn,at steps Waste 

Management of Wisconsin,, Inc. (WIPlfl) has taken to comiply with, 

paragraph 32 of the Adiiinistrative Order„ wihich required mmi to 

record a copy of the Order within !:i days of the effective date of 

the Order (iDeceniLber 29,, 1992;), Please provide me details 

concerning WMWI' s cocmpliance with, this XHEiiquirenient as qiuickly as 

possible., 

If you have any questions,, please contact xne at (31.2) 353-6261. 

Sincerely,, 

William J., Haubold 

Ruedial Project Manager 

Attacliiiient

cc:: Ton Krueger/ OIRC 

Gairy Edeistein/ WDNR 

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.— APPROXIMATE PROPERTY LiNE 

•—— APPROXIMATE L:M:TS OF RtriJSE 

^ ArrROXissaTE LOCA7:0« Or 

LEACHATE COLLECTiQ-- PQ-S-TS 

*_ LEACHATE HEAD WELL LOCATiOri 

i GROUNDWATER OBSERVATiON WELL AND 

P:£20M£TR:C LOCATiOrs 

HOT-S 

=- GAS EXTRACTION WELL LOCATION 

1. gASE MAR WAS PROVIDED Bt WASTE 

MANAGEMENT Of KiSCGNSiri. JrsC. 

AND :S A~ AERIAL SURVEY PERFORMED 

§Y ilBQ-METRiC fN&SNEfRSNO, 

INC., SHEBOYGAN, WJSCONSJN. DATE 

Or FLiGHT NOV. 2?, :3S2. 

2. TOPOGRAPHY :5 BASED ON U.5.G.5. DATUss 

3. CONTOUR INTERVAL iS TWO FEET, 

s, GRIG BASED GN WiSCQNSIri STATE 

PLANE COORDINATE SYSTEM, 

5. PROPERTY LiNES. LIMITS OF REFUSE. 

WELL LOCATIONS AND LEACHATE 

COLLECTION POINTS OBTAINED FROM 

inrORMATiuN PROviDED ON WAR2YN 

PLAN SHEET HO. D? OF REMEDIAL 

:wVESTiGATiQ«/FEASIB-L.TY STUDY, 

MUSKEGO SANITARY LANDFILL. 

1-2 

EXiSTiNG S-TE CGNDit-ONS 

•e.

UNILATEl 

ATTACHMENT 1 

flNISTRATiyEORDER

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

Region V 

In The Matter Of: ) 

Muskego Sanitary Landfi11 

Source Control Operable Unit 

Muskeqo, Wisconsin 

) 

) 

) 

Respondents listed in Attachment: 4 

Proceeding Under Section 106 (a) of the 

) 

) 

U.S. EPA 

Docket, tyo. 

v.W- v* r~T"77 

!l " " i(l Comprehensive Environmental Response, 

Compensation, and Liability Act of 1980, 

as amended (42 U.S.C. 9606(a)) 

) 

) 

) 

" •'• ' J 

ADMINISTRATIVE ORDER 

FOR REMEDIAL, DESIGN AND REMEDIAL ACTION

TABLE OF CONTENTS 

I. INTRODUCTION AND JURISDICTION 1 

II. FINDINGS OF FACT 2 

III. CONCLUSIONS OF LAW AND DETERMINATIONS 18 

IV. NOTICE TO THE STATE 19 

V. ORDER 19 

VI. DEFINITIONS 20 

VII. NOTICE OF INTENT TO COMPLY 22 

VIII. PARTIES BOUND 22 

IX. WORK TO BE PERFORMED 24 

X. FAILURE TO ATTAIN PERFORMANCE STANDARDS 30 

XI. EPA PERIODIC REVIEW 31 

XII. MODIFICATIONS TO WORK 31 

XIII . ENDANGERMENT AMD EMERGENCY RESPONSE 32 

XIV. EPA REVIEW OF SUBMISSIONS 33 

XV. PROGRESS REPORTS 34 

XVI. QUALITY ASSURANCE, SAMPLING AND DATA ANALYSIS 34 

XVII. COMPLIANCE WITH APPLICABLE LAWS 36 

XVI I I. REMEDIAL PROJECT MANAGER 36 

XIX. ACCESS TO SITE NOT OWNED BY RESPONDENTS 37 

XX. SITE ACCESS AND DATA/ DOCUMENT AVAILABILITY 39 

XXI. RECORD PRESERVATION 40 

XXII. DELAY IN PERFORMANCE 42 

24

XXIII. ASSURANCE OF ABILITY TO COMPLETE WORK 42 

XXIV. REIMBURSEMENT OF RESPONSE COSTS 43 

XXV. UNITED STATES NOT LIABLE 44 

XXVI. ENFORCEMENT AND RESERVATIONS 44 

XXVII,. ACCESS TO ADMINISTRATIVE RECORD 46 

XXVIII,. EFFECTIVE DATE/TERMINATION 46 

XXIX. OPPORTUNITY TO CONFER 47


Region V 

In The Matter Of: ) 

) 

Muskego San itary Landf :i. 11 ) 

Source Control Operable Unit ) 

Muskego, Wisconsin ) 

) 

) U.S.. EPA 

Respondents listed in Attachment 4 ) Docket No., 

) 

Proceeding Under Section 106(a) of the ) 

Comprehensive Environmenta1 Response, ) 

Compensation, and Liability Act of 1.980,, ) 

as amended (4 2 U. S,. C. 9 6 06 (a}) ) 

ADMINISTRATIVE ORDER 

FOR REMEDIAL DESIGN AND REMEDIAL ACTION 

I,. INTRODUCTION AND JURISDICTION 

1. This Order directs Respondents to perform, a remedial, design 

for the remedy described in the Record of Decision dated June :i.2, 

1992, and Scope of Work for the Muskego Sanitary Landfill, site, 

Source Control Operable Unit, and to implement the design by 

performing a remedial action,. This Order is issued t.o 

"'•

State Highway 24 (

Galvanizing, Inc. were present at the Site,. 

d., Respondent Aldrich Chemical Company! Inc. arranged,, by 

contract, or agreement„ or otherwise, for the disposal or 

treatment,, or arranged with a transporter for transport for 

disposal or treatment, of hazardous substance::; owned or possessed 

by Aldrich Chemical. Company, Inc. at the Site. Those hazardous 

substances included flammable liquids and other chemicals., 

Hazardous substances of the sane kind as those owned one: possessed 

by Respondent Aldrich Chemical Company, Inc. were present at the 

Site. e. Respondent All en- Bradley Company,, Inc. arranged, by 

com tract or agreement,, or otherwise, for the disposal or 

treatment, or arranged with a transporter for transport for 

disposal or treatment,, of hazardous substances owned or possessed 

by Alien-Bradley Company, Inc., at the Site. Those hazardous 

substances included grinding compounds,, liquid waste and slag. 

v ; Hazardous substances of the same kind as those owned or possessed 

by Respondent Alien •"Bradley Company, Inc. were present at the 

Site. f'. Respondent Allied Signal Corporation is a successor in 

interest to Bostrom Seating Inc.. Bostrom Seating Inc. arranged,, 

by contract or agreement,, or otherwise, for the disposal or 


disposal, or treatment, of hazardous substances owned or possessed 

by Bostram Seating Company at the Site,. Those hazardous 

substances included industrial liquid wastes., Hazardous 

substances of the sane kind as those owned or possessed by 

Bostrom Seating Inc., were present at the Site. 

g., Respondent American Motors Corporation arranged ., by 

contract or agreement,, or otherwise, for the disposal or 

treatment,, one: arranged with a transporter for transport for 


by American Motors Corporation at the site. Those hazardous 

v..,.-' substances included waste oils,, paint sludge and other sludges, 

and waste liquids-;„ Hazardous substances of the same kind as 

those owned or possessed by Respondent American Motors 

Corporation were present at. the Site,. 

h. Respondent American Can Company is the successor in 

interest of Amer icology. Ameri.oology arranged,, by contract or 

agreement, or otherwise, for the disposal or treatment,, or 

arranged with a transporter for transport for disposal or 

treatment, of hazardous substances owned or possessed by 

Americology at the Site. Those hazardous substances included 

liquid industrial wastes. Hazardous substances of the same kind 

as those owned or possessed by Airier icology were present at the 

Site. i,. Respondent Ampco Metal Inc., arranged! by contract or 


arranged with a transporter for transport for disposal or

treatment,, of hazardous substances owned or possessed toy Ampco 

Metal Company at the Site.. Those hazardous substances included 

liquid industrial wastes. Hazardous substances of the sane kind 

as those owned or possessed by Respondent Ampco Metal Company 

were present at the Site. 

j. Respondent. Amron Corporation arranged, by contract or 

agreement,, or otherwise, for the disposal or treatment., or 


treatment,, of hazardous substances owned or possessed by Amron 

Corporation at. the Site. Those hazardous substances included 

waste oils, nitric acid, phosphoric acid, zinc stripper,, spent 

chemicals and other liquid wastes., Hazardous substances of the 

same kind as those owned or possessed by Respondent Anron 

Corporation were present at the Site., 

k. Respondent Beatrice Company is a successor in interest 

to Pfister and Vogel. Tanning Company., Pfister and V'ogel Tanning 

vk \ Company arranged, by contract or agreement, or otherwise, for the 

disposal or treatment, or arranged with a. transporter for 

transport for disposal or treatment,, of hazardous substances 

owned or possessed toy Pfister and Vogel Tanning Company at the 

Site, Those hazardous substances included sludges and flammable 

solvents, Hazardous substances of the same kind as those owned 

or possessed by Pfister and Vogel Tanning Company were present at 

the Site„ 

1. Respondent Beazer East,, Inc.. is a successor in interest 

to Theim Corporation. Theim Corporation arranged, toy contract, or 

agreement, or otherwise,, for the disposal or treatment,, or 


treatment, of hazardous substances owned or possessed by Theim 

Corporation at the Site.. Those hazardous substances included 

waste chemicals,, powder and glue., Hazardous substances of the 

same kind as those owned or possessed by Theim Corporation were 

present at the Site., 

V..X in. Respondent Browning Ferris Industries of Wisconsin is a 

successor in interest to Town and Country Disposal Service,, Inc. 

Town and Country Disposal Service,, Inc. accepted hazardous 

substances for transport to, and disposal or treatment, at the. 

Site,, and selected the Site for disposal or treatment:. Those 

hazardous substances included various industrial wastes. 

Hazardous substances of the same kind as tltose disposed of by 

Town and Country Disposal Service,, Inc. were present at the Site., 

n. Respondent Brunswick Corporation is a successor in 

interest to Ozite Carpet. Ozite Carpet arranged,, by contract or 



treatment, of hazardous substances owned or possessed by Ozite 

Carpet at the Site, Those hazardous substances included sludges. 

Hazardous sutostanoes of the same kind as those owned or possessed 

by Ozite Carpet were present at the Site.

,. Respondent Caterpillar, Inc. arranged, by contract or 

agreement, or otherwise,, for the disposal, or treatment, or 

arranged with a transporter for transport: for disposal or 

treatment, of hazardous substance!-; owned or possessed by 

Caterpillar, Inc.. at the Site. Those hazardous substances 

included corrosive liquids, including paint strippers and other 

hazardous wastes., Hazardous substances of the sane kind as those 

owned ox possessed by Respondent Caterpillar,, Inc., Mere present 

at the site. 

p. Respondent Cudahy Tanning Co., Inc., arranged,, by 

contract or agreement, or otherwise, for the disposal ox: 


disposal or treatment, of hazardous substances owned or possessed 

by Cudahy Tanning Co., Inc. at the Site. Those hazardous-! 

substances included leather scraps contain ing chromium,, and 

sludges., Hazardous substances of the same kind as those owned or 

possessed by Respondent Cudahy Tanning Co.,, Inc.. were present at 

the site. 

q,, Respondent: Dings Company,, Magnetic Group arranged,, by 

contract or agreement, or otherwise, for the disposal or 

treatment , or arranged with a transporter for transport for 


by Dings Company, Magnetic Group at the Site., Those hazardo>us 

substances included waste cutting oils,. Hazardous substances of 

the same kind as those owned or possessed by Dings Company, 

Magnetic Group were present at the Site., 

r., Respondent E,. Z. Paintr Company arranged, by contract or 

agreement, ot otherwise, for the disposal or treatment:,, or 

arranged with a transporter for transport for disposal, or 

treatment,, of hazardous substances owned or possessed by E.,Z. 

Paintr Company at the Site. Those hazardous substances included 

acetone, alcohol, waste oil,, polyviny 1 acetate and polyviny 1 

alcohol. Hazardous substances of the same kind as those owned or 

\, .' possessed by Respondent E,.Z., Paintr Company were present at the 

Site. s. Respondent Envirex Inc. arranged,, by contract or 

agreement,, or otherwise, for the disposal or treatment, or 


treatment,, o>f hazardous substances owned or possessed by Envirex 

Inc. at the Site. Those hazardous substances included liquid 

wastes and paint wastes., Hazardous substances of the same kind 

as those owned or possessed by Respondent Envirex Inc., were 

present at the Site. 

t., Respondent. General Electric Company arranged, by 

contract or agreement., or otherwise, for the disposal or 


disposal or treatment,, of hazardous substances owned our possessed 

by General Electric Company at the Site. Those hazardous 

substances included acids,, liquid waste and powder, Hazardous

substances of the same kind as those owned or possessed by 

Respondent General Electric Company were present at the Site,. 

u., Respondent Harn isohfeger arranged,, by contract or 

agreement,, or otherwise, for the disposal or treatment„ or 


treatment, of hazardous substances owned or possessed by 

Harnischfeger at the Site., Those hazardous substances included 

industrial liquid wastes., Hazardous substances of the same kind 

as those owned or possessed by Respondent HarniscltiLfeger were 

present at the Site,. 

v,. Respondent Hydrite Chemical Company arranged,, by 

contract or agreement.,, or otherwise, for the disposal or 

treatment., or arranged with a transporter for transport for 


by Hydri te Chemical Company at the Site.. Those hazardous 

substances included sodi.urn carbonate,, sodium chloride, sodium 

v i metasilcate, phosphates and other chemicals., Hazardous 


Respondent Hydri te Chemical Company were present at the Site,. 

w. Respondent Inryco Corporation arranged, by contract or 



treatment, of hazardous substances owned or possessed by Inryco 

Corporation at. the Site, Those hazardous substances included 

sludges„ waste paint and lacquer thinners., Hazardous substances 

of the same kind as those owned or possessed by Respondent Inryco 

Corporation were, present at the Site., 

x,. Respondent Laidlaw Waste Systems,, Inc.. is the successor 

in interest to Sanitary Disposal Service., Sanitary Disposal 

Service accepted hazardous substances for transport to, and 

disposal or treatment at the Site,, and selected the Site for 

disposal or treatment.. Those hazardous substances included 

various industrial wastes,. Hazardous substances of the same kind 

V...x as those disposed of by Sanitary Disposal Service were present at 

the site. 

y, Respondent Law Tanning Co. arranged,, by contract, or 



treatment, of hazardous substances owned or possessed by Law 

Tanning Co. at the Site,. Those hazardous substances included 

leather scraps containing chromium. Hazardous substances of the 

same kind as those owned or possessed by Respondent. Law Tanning 

Co,, were present at the Site., 

;>;,. Respondent Louis Alien Division of Magnetix, Inc.. 

arranged, by contract or agreement, or otherwise,, for the 

disposal or treatment,, or arranged with a transporter for 

transport for disposal 1 or treatment,, of hazardous substances 

owned or possessed by the Louis Alien Division of Magnetix, Inc. 

at the Site. Those hazardous substances included industrial

liquid wastes. Hazardous substances of. the same kind as those 

owned or possessed by Respondent Louis Alien Division of 

Magnetix, Inc. were present at the Site,. 

aa» Respondent Master Lock. Company arranged,, by contract or 

agreement, or otherwise, for the disposal or treatment, or 

arranged with a transporter for transport, for disposal or 

treatment, of hazardous substances owned or possessed by Master 

Lock Company at the Site., Those hazardous substances included 

industrial liquid wastes., Hazardous substances of the same kind 

as those owned ox possessed by Respondent Master Lock Company 

were present, at the Site., 

bb., Respondent Metals Transport Company,- Inc, accepted 

hazardous substances for transport to, and disposal or treatment 

at the Site, and selected the Site for disposal or treatment. 

Those hazardous substances included metal--bearing slag., 

Hazardous substances of the same, kind as those disposed of by 

Metal Transport Company, Inc. were present at the Site. 

cc. Respondent Midwest Tanning Company arranged, by 

contract, or agreement, or otherwise, for the disposal or 

treatment, or arranged with a transporter for transport, for 


by Midwest Tanning Company at the Site,. Those hazardous 

substances included waste liquids and sludges. Hazardous 


Respondent Midwest Tanning Company were present at the Site. 

dd. Respondent PPG Industries arranged, by contract or 



treatment, o>f hazardous substances owned or possessed by PPG 

Industries at the Site. Those hazardous substances included 

paint wastes and. sludges. Hazardous substances of the same kind 

as those owned or possessed by Respondent PPG Indlustries were 

present at the Site. 

ee. Respondent Pressed Steel Tank Co.., Inc., arranged, by 

contract or agreement, or otherwise, for the disposal, or 



by Pressed Steel Tank Co.., Inc.. at the Site. Those hazardous 

substances included sludges and liquid wastes,. Hazardous 


Respondent Pressed Steel Tank Co.., Inc., were present at the Site, 

ff. Respondent PVL Partnership is a successor in interest 

to Pfister and Vogel Tanning Company,. Pfister and Vogel Tanning 

Company arranged,, by contract or agreement,, or otherwise,, for the 

disposal or treatment, or arranged with a transporter for 

transport for disposal or t.reatment, of hazardous substances 

owned or possessed by Pfister and Vogel Tanning Company at the 

Site, Those hazardous substances included sludges and flaiunable 

solvents, Hazardous substances of the same kind as those owned

or possessed by Pfister and Vogel Tanning Company were present at 

the Site, 

gg. Respondent RAPCO Leather Company arranged, by contract 

or agreement.,, or otherwise, for the. disposal, or treatment,, or 


treatment,, of, hazardous substances owned or possessed by RiHPCO 

Leather Company at the Site. Those hazardous substances included 

waste liquids and sludges. Hazardous substances of the sarnie kind 

as those owned or possessed by Respondent RAPCO Leather Company 

were present at the Site,. 

hh, Respondent Rexnord Incorporated arranged,, by contract 

or agreement., or otherwise, for the disposal or treatment, or 


treatment,, of hazardous substances owned or possessed by Rexnord 

Incorporated at the Site„ Those hazardous substances included 

various industrial wastes., Hazardous substances of the same kind 

v j as thO'se owned or possessed by Respondent Rexnord Incorporated 


i:i.„ Respondent St.. Luke's Hospital arranged, by contract or 



treatment, of hazardous substances owned or possessed by St., 

Luke's Hospital at the Site. Those hazardous substances included 

medical waste. Hazardous substances of the same kind as those 

owned or possessed by Respondent St.. Luke's Hospital were present 

at the Site., 

j j., Respondent Star Line Trucking Company accepted 


at the Site,, and selected the Site for disposal or treatment,. 

Those hazardous substances included fly ash., Hazardous 

substances of the same kind as those disposed of by Star Line 

Trucking Company were present at the Site,. Respondent Star Line 

Trucking also arranged, by contract or agreement, or otherwise,, 

^.....-' for the disposal or treatment, or arranged with a transporter for 

transport for dlsposal o>r treatment, of hazardous substances 

owned or possessed by Star Line Trucking Company at the Site.. 

Those hazardous substances included various industrial wastes., 

Hazardous substances of the same kind as those owned or possessed 

by Respondent Star Line Trucking Company were present at the 

Site. kk:, Respondent Teledyne Wisconsin Motors arranged, by 

contract or aipMiienent, or otherwise,, for the disposal or 


disposal or 'fcxeatment,, of hazardous substances owned or possessed 

by Teledyne Wisconsin Motors at the Site.. Those hazardous 

substances included liquid wastes and waste oil. Hazardous 


Teledyne Wisconsin Motors were present at the Site., 

11. Respondent Trinity Hospital arranged, by contract or



treatment, of hazardous substances owned or possessed by Trinity 

Hospital at the Site, Those hazardous substances included 

medical waste. Hazardous; substances of. the same kind as those 

owned or possessed by Respondent Trinity Hospital were present at 

the Site. 

inm., Respondent Vulcan Materials Company arranged,, by 

contract or agreement,, or otherwise, for the disposal or 

treatment, or arranged with a transporter for transport, for 


by Vulcan Materials Company at the Site., Those hazardous 

substances included metal-bearing slag. Hazardous substances of 

the same kind as those owned or possessed by Respondent Vulcan 

Materials Company were present at the Site. 

nn. Respondent W.A. Krueger Company arranged,, by contract 

or agreement, or otherwise!, for the disposal or treatment, or 


treatment, of hazardous substances owned or possessed by W.A. 

Krueger Company at the Site. Those hazardous substances included 

waste ink and glue. Hazardous substances of the same kind as 

those owned or possessed by Respondent W.A. Krueger Company were 

present at. the Site, 

oo., Respondent Wayne Chemical Corporation arranged, by 

contract our agreement, or otherwise, for the disposal or 



by Wayne Chemical. Corporation at the Site. Those hazardous 

substances included waste chemicals„ Hazardous substances oof: the 

sane kind as those owned or possessed by Respondent Wayne 

Chemical Corporation were present, at the Site. 

pp., Respondent Wisconsin Bell Telephone Company arranged, 

by contract or agreement, or otherwise, for the disposal or 



by Wisconsin Bell Telephone Company at the Site., Those hazardous 

substances included various industria 1 wastes,. Hazardous 


Respondent Wisconsin Bell Telephone Company were present at the 

Site,. qq. Respondent Wisconsin Electric Power Company arranged,, 

by contract or agreement, or otherwise, for the disposal or 



by Wisconsin Electric Power Company at. the Site. Those hazardous 

substances included transformers and fly ash.. Hazardous 


Wisconsin Electric Power Company were present at the Site. 

rr,. Respondent Zununach-Peerless Chemical. Coating Co,.

v 

arranged,, by contract or agreement, or otherwise, for the 

disposal or treatment,, or arranged with a transporter for 

transport for disposal or treatment„ of harcardoius substances 

owned or possessed; by Zummach- Peer 'less Chemical Coating Co., at 

the. Site.. Those hazardous substances included paint dust and 

powders. Hazardous substances of the sane kind as those owned or 

possessed by Respondent Zi-uniiiach-Peerles-is Chemical Coating Co. 


ss., Respondent Jack Quigley operated the Site prior to 

1970. During the time that the Site was operated by Jack 

Quigley, hazardous substances, including some or all of those 

described in this Section, were disposed of at the Site. 

tt. Respondent Prestige Foods is a successor in interest to 

Patrick Cudahy Company., Patrick Cudahy Company arranged, by 

contract or agreement, or otherwise, for the disposal, or 

treatiient,, or arranged with a transporter for transport for 


by Patrick Cudahy Company at the Site. Those hazardous;; 

substances included industrial wastes.. Hazardous substances of 

the same kind as those owned or possessed by Patrick Cudahy 

Company were present at the Site. 

4. The Respondents identified in paragraph 3 are collectively 

referred to as "'Respondents „" 

5. On September 15, 1985, (50 Fed. Reg.. 37956),, pursuant to 

section 105 of CERCLA, 42 U.S.C. 9605, EPA placed the Huskego 

Sanitary Landfill Site on the National Priorities List, set forth 

at 40 C.F.R. Part 300,, Appendix B. 

6. To study and undertake response activities in phases,, EPA 

divided the Site into operable units. The operable units tor the 

Site are the Source Control Operable Unit and. the Groundwater 

V J Operable Unit. This Order addresses the Source Control Operable 

Unit,, 

7. From August 14, 1937 through November 4, 1992,, Waste 

Management: of Wisconsin (WMHI) , under EPA's oversight,, has 

undertaken a Remedial Investigation of the Site. WMWI has also 

undertaken separate Feasibility Studies for each Operable Unit of 

the Site., These activities have been perfooned pursuant to 

CERCLA and. the National Contingency Plan, 40 C.F.R. Part 300. 

WMWI has perfonned this work under an Administrative: Consent 

Order (AGO) signed, on August 14, 1967. 

8. Pursuant, to section 117 of CERCLA, 42 U.S.C. 9617, EPA 

published; notice of the completion of the FS and of the proposed 

plan for remedial action on November 12,, 1991, and provided 

opportunity for public comment on the proposed remedial action.

Similarly, Respoiikllents were given an opportunity to comment on 

the proposed remedial action and supplenient, the Administrative 

Record. 

9. The decision by EPA on the remedial action to be implemented 

for the Source: Control Operable Unit is embodied in an Interim 

Action Record of Decision ('"ROD" 1 }, exeouted on June 12,, 199;;!, on 

which WDNR had a reasonable opportunity to review and comment, on 

and which WDNR has given its concurrence,, The ROD is attached, to 

this Order as Attachment 1 and is incorporated by reference., The 

ROD is supported by the Administrative Record which contains the 

documents and information upon which EPA based the selection of 

the response action. The U.S. EPA's selected response action set 

out in the ROD has been determined to provide adequate protection 

of public health,, welfare and the environment; meet, all Federal 

and State environmental laws;: and be cost effective. The Source 

Control Operable Unit is the first of two phases for the project. 

This SCOU is consistent with the Final Remedy in that it. prevents 

contaminant movement into the ground water from the source areas, 

10.. Contaminants were detected in soil, groun.dwat.er and 

sediments at. the Site,. Groups of contaminants included. BETXs 

(Benzene, EthyIbenzene,, Xylene,, and Toluene) , chlorinated ethenes 

and ethanes, inorganics,- Polychlorinated Biphenyls (PCBs)„ and 

pesticides., Specific chemicals are listed in the ROD,, under 

Section V (Site Characteristics) and the Remedial Investigation, 

Section 4 (Nature and Extent, of Contamination) ,. 

11. The Remedial Investigation results indicate that there has 

been a release of. hazardous substances into the groundwater and 

in the soils at the Site,. There are multiple source areas and 

groundwater pathways at the Site in which contaminants are 

located. Section 4, Nature and Extent of Contamination, of the 

Remedial Investigation report specifically indicates 

contaminants,, location of contaminants,, and concentrations of 

contaminants at. the Site,. Several, contaminants were found in 

exceedance of Federal Maximum Contaminant Levels (MCLs) and WDNR 

Enforcement Standards (ESs} including; benzene, 1,2•••• 

dichloroethane, tetrachloroethylene, trichloroethylene, and vinyl 

chloride. A more comprehensive: list can be found in Section 4 of 

the RI. 

1.2.. Groundwater is the primary migration pathway for 

contaminants at the Site. Groundwater flow away from the Site is 

predominantly along the Southern and Southeastern flow paths., 

Along the Southern flow path groundwater is potentially affected 

by the Old Fill Area, Non-Contiguous Fill Area, and the former 

rendering plant lagoons, The Southeastern flow path is 

potentially affected by the Non-Contiguous Fill Area, the

Southeast Fill Area, and the former rendering plant lagoons,, 

Private wells are located downgradient from these source areas 

and could potentially be affected by contaminants., A majority of 

these private wells have been converted to public drinking water 

supply,, Exposure to landfill gas, through either methane 

migration in the soils or Volatile Organic Contaminant (VOC) 

iinigration in the air, is also a concern at the Site,. Inhalation 

of landfill gas is of concern due to the potential presence of 

unacceptable levels of VOCs that may cause a health risk,, Direct 

exposure to contaminated soil or waste is currently not a concern 

at. the Site, Future exposure nay be a concern if the cover is 

not adequately improved and Maintained. 

13. There are approximately 130 homes within one-ha HE' mile of 

the Site., This converts to a population of 325, assuming there 

are 2.5 persons living in each home,. There are approximately a 

dozen homes downgradient that potentially could be affected by 

groundwater contamination. All of these homes have been or will 

be connected to public water for consumptive purposes.. Therefore 

these homes do not draw water from the groundwater potentially 

affected by contamination, The land surrounding the Site is 

currently a mixture of private homes, smal 1 ••••scale agriculture,, 

medium-sized farming, and industrial use, Residential 

development is progressing westward along Janesville Road toward 

the Site,. This is an indicator that future land use of property 

nearby the Site could be primarily residential,, Public Health 

concerns are expressed in greater detail in the Public Health 

Assessment for the Site, in addition the Baseline Risk 

Assessment in the El presents current and potential risks to 

human health, welfare and the environment., 

14.. There have been two drum removal actions at the Site, The 

first was the excavation and removal of free liquid, drums and 

contaminated soils in an area east of the Won-Contiguous Fill 

Area. The solid materials were transported to the Adams Center 

Landfill in Ft,, Wayne, Indiana while the liquids were transported 

to the SCA Incinerator in Chicago, Illinois., This action took 

place under the supervision of WDNR officials. The second 

removal was in a drum, trench area discovered during the EX in the 

Non-Contiguous Fill Area, Through a Unilateral Administrative 

Order issued on January 4,, 1991, U.S. EPA ordered. WMHI to remove 

the drums and surrounding contaminated soils. Excavation of the 

drum trench, began in April 1991 and. was completed in May 1991, A 

total of 989 drums were excavated along with approximately 2,500 

cubic yards of surrounding contaminated soil, The soils were 

excavated to a depth of approximately 25 feet below the original 

surface grade until ground water was encountered, 

15.. The selected remedy for the source control operable unit is

primarily designed to prevent percolation through wastes and into 

the groundwater. Included in this remedy is a multi-layer cap 

over the source areas, leachate control systems in the Old and 

Southeast Fill areas,, landfill gas control in the Old, Non- 

Contiguous and Southeast Fill areas, and In-situ Vapor Extraction 

(ISVE) in portions of the Non-Contiguous Fill Area,, A more 

detailed description, of the remedy can be found under the 

Selected Remedy section (IX.) of the ROD,. 

1.6. The main component of the source control remedy is the 

multi-layer cap over the source areas., The clay component of the 

cap is designed to minimize percolation into and through the 

waste masses and carry contamination into the groundwater. The 

multi-layer cap will ibe designed to direct rainwater and snowmelt 

away from the waste masses and protect the clay layer from frost 

penetration. The leachate control component of the remedy will 

iy i reduce the buildup of contaminated liquids within the waste 

masses and minimise seeping of these liquids into the 

groundwater.. The landfill gas control and ISVE systems will 

remove contaminants within wastes and so 1.1 s respect ive ly. 

Ill,. CONCLUSIONS OF LAW AND DETERMINATIONS 

17. The Muskego Sanitary Landfill Site is a "'facility 111 as 

defined in section 101(9) of CERCLA, 42 U.S.C. 9601(9). 

IB., Respondents are "'persons 111 as defined as in section 101 (21) 

Of CERCLA, 42 U.S.C. 9601(21). 

19., Each Respondent is a ""liable party" 1 as defined in section 

107 (a) of CERCLA, 42 U.,S,.C., 9607 (a), and is subject to this 

Order under section 106(a) of CERCLA, 42 U.S.C. 9606(a). 

20. '"Hazardous substances 1 " as defined in section 101(14) of 

V...-'' CERCLA, 42 U.S.C. 9601 (14), have been disposed at the Facility, 

21. These hazardous substances have been and continue to be 

released from the Site into the soil, groundwater, sediment and 

air,. 

22. The past disposal and current migration of hazardous 

substances from the Site are a. '"release" 1 as defined in section 

101(22) Of CERCLA,, 42 U.S.C. 9601(22). 

23.. The potential for future migration of hazardous substances 

from the Site poses a threat of a '"release 11 " as defined in section 

101(22) Of CERCLA, 4 2 U.S.C. 9 601(22). 

24.. The release and threat of release of one or more hazardous 

substances from the facility may present an imminent and

V..,/' 

substantial endangerment to the public health or welfare or the 

environment. 

25. The actions required by this Order are necessary to protect 

the public health, welfare, and the environment and are 

consistent with the National Contingency Plan (NCP) ,, 40 CFR Part 

300,, as amended, and CERCLA.,. 

IV. NOTICE TO THE STATE 

26. Prior to issuing this Order, EPA notified the State of 

Wisconsin Department of Natural Resources (""WDNR 1 ") , that EPA 

intended to issue this Order, 

31. EPA will consult with the WDNR and the WDNR will have the 

opportunity to review and comment to EPA regarding all work, to be 

performed, deliverables, and any other issues which arise while 

the Order remains in effect. 

V. ORDER 

27. Based on the foregoing, Respondents are hereby ordered to 

comply with the following provisions, including but not limited 

to all attachments to this Order, all documents incorporated by 

reference into this Order, and all schedules and deadlines in 

this Order, attached to this Order, or incorporated by reference 

into this Order: 

VI., DEFINITIONS 

28.. Unless otherwise expressly provided herein., terns used in 

this Order which are defined in CERCLA or in regulations 

promulgated under CERCLA shall have the meaning assigned to them 

in the statute or its implementing regulations. Whenever terras 

listed below are used in this Order or in the documents attached 

to this Order or incorporated by reference into this Order, the 

following definitions shal1 apply: 

a,. '"CERCLA" shal.1 mean the Comprehensive Environmental 

Response, Compensation, and Liability Act of 1.930, as amended, 42 

U, S. C. 9 6 01 e t ....sec|b» 

b,. '"Day" 1 shall mean a calendar day unless expressly stated 

to be a working day,. ""Working day"" shall mean a day other than a 

Saturday, Sunday, Federal, or State holiday. In computing any 

period of tine under this Order, where the last day would fall on 

a Saturday, Sunday, Federal or State holiday, the period shall 

run until the end of the next working day, 

c. '"EPA" 1 shall mean the United States Environmental 

Protect ion Agency. 

d. '"WDNR"* shall mean the Wisconsin Department of Natural 

Resources., 

e. "National Contingency Plan"" or "NCP 1 " shall mean the 

National Contingency Plan promulgated pursuant to Section 105 of

CERCLA, 42 U.S.C. 9605, codified at 40 C.P.R. Part 300, 

including any amendments thereto. 

f. '"Operation and Maintenance 1 ' 11 or "O&M" shall mean all 

activities required under the. Operation and Maintenance Plan 

developed by Respondents pursuant to this Order and Task II,. B. of 

the Scope of Work, and approved by EPA. 

g, '"Paragraph 1 " shall mean a portion of this Order 

identified by an arabic numeral,. 

h. '"Performance Standards'" shall mean those cleanup 

standards,, standards of control f and other substantive 

requirements, criteria or limitat .ions, identified in the Record 

of Decision and Scope of Work:, that the Remedial Action and Work 

required by this Order must attain and maintain,. 

:L. '"Record of Decision 1 " or ""ROD 11 " shall mean the EPA Record 

of Decision relating to the Site, Source Control Operable Unit,, 

signed on June 1.2, 1.992 by the Regional Administrator, EPA Region 

^ , V, and all attachments thereto. 

j« "Remedial Action" 1 or "RA" shall, mean those activities,, 

except for Operation and Maintenance, to be undertaken by 

Respondents to implement the final plans and specifications 

submitted by Respondents pursuant to the Remedial Design Work 

Plan approved by EPA, including any additional activities 

required under Sections X, XI, XII, XIII, and XIV of this Order,. 

k. "Remedial Design 1 " or "ED 1 " shall mean those activities to 

be undertaken by Respondents to develop the final plans and 

specifications for the Remedial Action pursuant to the Remedial 

Design Work Plan,, 

1. "'Response Costs" shall mean all costs, including direct 

costs, indirect costs, and accrued interest incurred by the 

United States and the WDNR to perform or support response actions 

at the Site,. Response costs include but are not limited to the 

costs of overseeing the Work, such as the costs of reviewing or 

developing plans, reports and other items pursuant to this Order 

V.../ and costs associated with verifying the Work. 

m,. ""Scope of Work" 1 or '"SOW" 1 shall mean the statement of 

work for implementation of the Remedial Design, Remedial Action, 

and Operation and Maintenance: at the Site, as set forth in 

Attachment 2 to this Order, The Scope of Work is incorporated 

into this Order and is an enforceable part of this Order. 

n. ''" Sect ion"" shall, mean a portion of this Order identified 

by a roman numeral and includes one or more paragraphs. 

o., '"Section 106 Administrative Record'" shall mean the 

Administrative Record which includes all documents considered or 

relied upon by EPA in preparation of this Order.. The Section 106 

Administrative Record Index is a listing of all documents 

included in the Section 106 Administrative Record in addition to 

those already included in the administrative record attached to 

the ROD, and is attached hereto as Attachment 3., 

p., '"Site" shall mean the Muskego Sanitary Landfill Superfund

encompass ingf approximately 56 acres,, located in the city of 

Muskego, Waukesha County,, Wisconsin, as described in the Record 

of Decision,. 

q. '"State 11 " shall mean the State of Wisconsin,. 

r. "United States 1111 shall mean the United States of AinLerioa,. 

s. '"Work 1 " shall mean all activities Respondents 

are required to perform under this Order t.o implement the ROD for 

the Source Control Operable Unit, including Remedial Design., 

Remedial Action and Operation and Maintenance for the Source 

Control Operable Unit and any activities required to foe 

undertaken pursuant to this Order. 

VII,. NOTICE GIF INTENT TO COMPLY 

29,. On or before January 15, 1993, EPA must receive written 

notice from Respondents stating their unequivocal intention to 

comply with the terms of this Order, In the event any Respondent 

v , fails to provide such notice, that Respondent shall be deemed to 

have failed to comply with the terms of this Order. 

Respondent" s written notice shall, describe, using facts that 

exist, on or prior to the effective date of this Order, any 

111 sufficient cause 1 " defenses asserted by Respondents under 

sections 106(b) and 1.07(c) (3) of CERCLA, The absence of a 

response by EPA. t.a the notice required by this paragraph shall 

not be deemed to be acceptance of Respondent's assertions. 

VIII. PARTIES BOUND 

30.. This Order shall apply to and be binding upon each 

Respondent identified in Section I, their successors, and 

assigns., Respondents are jointly and severally responsible for 

carrying out all activities required by this Order., Failure of 

one or more Respondents to comply with all or any part of this 

Order shall not in any way excuse or justify noncompliance by any 

other Respondent., No change in the ownership, corporate status, 

V...y or other control of any Respondents shall alter any of the 

Respondents" responsibi1 i.ties under this Order. 

31.. Respondents shall provide a copy of this Order to any 

prospective owners or successors before a controlling interest in 

Respondent's assets, property rights, or stock: are transferred to 

the prospective owner or successor,. Respondents shall provide a 

copy of this Order to each contractor, sub-contractor, 

laboratory, or consultant, retained to perform any Work under this 

Order, on the date such services are retained., Respondents shall 

also provide a copy of this Order to each person representing any 

Respondent with respect t.o the Site or the Work and shall 

condition all contracts and subcontracts entered into hereunder 

upon performance of the Work in conformity with the terms of this 

Order, With regard t.o> the activities undertaken pursuant to this 

Order, each contractor and subcontractor shall be deemed to be

elated by contract to the Respondents within the meaning of 

section 107 (b) (3) Of CERCLA, 42 U.S.C. 9607 (b) (3). 

Notwithi-itanding the terms of any contract , each Respondent is 

responsible^ for compliance with this Order and for ensuring that 

its contractor s , subcontractors and agents comply with this 

Order, and perform any Work, in accordance with this Order. 

32.. Within five (5) days after the effective date of this Order 

each Respondent that owns real property comprising all or part of 

the Site shall record a copy or copies of this Order in the 

appropriate governmental office where land ownership and transfer 

records are filed or recorded, and shall ensure that the 

recording of this Order is indexed to> the titles of each and 

every property at the Site so* as to provide notice to third 

parties of the issuance and terms of this Order with respect to 

those properties. All such Respondents shall, within 15 days 

v i after the effective date of this Order,, send notice of such 

recording and indexing to EPA. 

33. Not later than sixty (60) days prior to any transfer of any 

property interest in any real property included within the Site, 

Respondents shall submit a true and correct copy of the transfer 

document (s) to EPA,, and shall identify the transferee by name,, 

principal business address and effective date of the transfer. 

IX. WORK TO BE PERFORMED 

34.. All aspects of the Work to be performed by Respondents 

pursuant to this Order shall be under the direction and 

supervision of a Project Coordinator qualified to undertake and 

complete the requirements of this Order.. EPA. retains the right 

to disapprove the Project. Coordinator and any,, or all, of the 

contractors and/ or subcontractors retained by the Respondents . 

Within thirty (30) days after the effective date of this Order, 

Respondents shall notify EPA. in writing of the name and 

^...../ qualifications of the Project Coordinator, including primary 

support entities and staff, proposed to be used in carrying out 

Work under this Order,. In the event EPA disapproves a Project 

Coordinator ,, selected contractor , or selected subcontractor , 

Respondents shal .1 ret a in an alternative pro j eat coordi nator , 

contractor,, or sub-contractor to perform the work:, and such. 

selection shall be made within fifteen (15) days following the 

date of EPA's disapproval,. If at any time Respondents propose to 

use a different: Project Coordinator, contractor or subcontractor, 

Respondents shall notify EPA before the new Project 

Coordinator performs any Work under this Order., 

_ _ Action 

3 5 . Within f orty~~fTve~~(45)~ "days' lii!te¥"THe~""sIgnature Date of this 

Order, Respondents shall submit a Work Plan for the Remedial. 

Design/Remedial Action at the Site ("Remedial Design/Remedial

Action Work Plan" 1 or "RD/RA Work Plan") to EPA for review and 

approval.. The. RD/RA Work Plan shall include a step-by-step plan 

for completing the. remedial design for the remedy described in 

the ROD and for attaining and maintaining all requirements, 

including Performance standards,, identified in the ROD. The 

RD/RA Work: Plan must describe in detail the tasks and 

deliverables Respondents will, complete during the remedial design 

phase, and. a schedule for completing the tasks and deliverables 

in the RD/RA Work Plan, The ED/ISA Work Plan shall be consistent 

with, and shall provide for implementing the Scope of Work,, and 

shall comport with EPA's '"Superfund Remedial Design and Remedial. 

Action Guidance, OSWER Directive 9355.0-4A.'" The'RD/RA Work: Plan 

shall include a Sampling and Analysis Plan, Quality Assurance 

Project Plan (QAPP) (in conformance with Section XVI of this 

Order),, and Health and Safety Plan for all pre-design sampling 

effortsi including treatability studies, and shall, be consistent 

is j with the Occupational Safety and Health Act (OSHA) . The major 

tasks and deliverables described in the RD/RA Work: Plan shall 

include, but not be limited to,, the following: (1) a preliminary 

design; and (2) a final design,. The design phases shall include 

final plans and specifications,, operation and maintenance (O&M) 

plan,, construction field sampling plan,, construction quality 

assurance plan (CQAP) „ and a. contingency plan; and (3) a design 

schedule.. 

36. Upon approval, of the RD/RA Work Plan by EPA, Respondents 

shall implement the RD/RA Work Plan and submit all design 

deliverables according to the schedule in the approved RD/RA Work 

Plan,. Any noncompliance with the approved RD/RA Work: Plan shall 

be a violation of this Order,. Unless otherwise directed by EPA, 

Respondents shall not perform further Work at the Site prior to 

EPA's written approval, of the RD/RA Work Plan. 

V...y 37, Upon EPA approval,, the Final Design is incorporated into 

this Order as a requirement of this Order and shall be an 

enforceable part of this Order. 

38. The RD/RA Work Plan shall be developed in accordance with 

the ROD,, and the attached Scope of Work,, and shall be consistent 

with the Final Design as approved by EPA,, The RD/RA Work Plan 

shall, include methodologies , plans and schedules for completion 

of at. least the following: (1) selection of the remedial action 

contractor,; (2) implementation of the CQAP; and. (3) 

identification of and satisfactory compliance with applicable 

permitting requirements. The RD/RA Work Plan shall also include 

a schedule for implementing all remedial action tasks identified 

in the Scope of Work, a work plan for soil vapor extraction, and 

a quality assurance project plan (QAPP). The RD/RA Work Plan 

shall also identify the initial formulation of Respondent"s

Remedial Action Project Team (including the Supervising 

Contractor) and identify potential borrow sources for cap 

construction. Respondents shall also submit to EPA for review,, 

as part of the RD/RA Work: Plan,, a Health and Safety Plan for 

field activities required by the RD/RA Work Plan., 

39.. EPA, in consultation with WDNR will review and either 

approve, disapprovef or conditionally approve, the ED/FA Work 

Plan. If the Work Plan is disapproved or conditionally approved, 

EPA will provide, in writing, comments or modifications required 

for approval. Respondents shall, then, within thirty (30) days of 

the date of ERA'S written notification of disapproval or 

conditional approval, submit an Amended Work Flan which 

incorporates only the requ.ired comments or rnodificat ions,. EFA 

shall review the Amended Work: Plan and either approve our 

disapprove it, Failure to submit an approvable (Amended) Work 

is> /( Flan shall constitute noncompliance with this Order,. Upon 

approval by EPA, the RD/RA Work Plan is incorporated into this 

Order as a requirement of this Order and shall be an enforceable 

part of this Order,. 

40.. U]pO'i'i approval of the RD/RA Work Flan by EPA,, Respondents 

shall implement the RD/RA Work Plan according to the schedules in 

the RD/RA Work Plan., Unless otherwise directed by EPA,, 

Respondents shall not commence remedial action at the Site prior 

to approval of the RD/RA Work Plan. Respondents will be 

responsible for obtaining all State and local permits required 

for implementati on of this remedy,. 

41... 1:1: Respondents seek: to retain a construction contractor to 

assist in the performance of the Remedial Action, then 

Respondents shall submit a copy of the contractor solicitation 

documents to EPA not later than five (5) days after publishing 

'--...-'' the solicitation documents.. 

42.. Selection of the construction contractor shall be subject to 

review and approval by EPA,, in consultation with WDNR., Within 

ten (10) days after EFA approves the RD/RA Work Plan, Respondents 

shall notify EPA in writing of the name, title, and 

qua1ifications of any construction contractor proposed to be used 

in carrying out work: under this Order, If EPA disapproves of the 

select iO'ii of any contractor as the construct ion coin tractor,, 

Respondents shall submit the name, title and qualifications of a 

new contractor to EPA within thirty (30) days after receipt, of 

EPA' s disapproval of the contractor previously selected,. 

43. The Work performed by Respondents pursuant to this Order 

shall, at a minimum, achieve the Performance Standards specified 

in the Record of Decision and in Section II.I. of the Scope of

Work. 

44. Notwithstanding any action by EPA, Respondents remain fully 

responsible for achievement of the Performance Standards in the. 

Record of Decision and Scope of Work. Nothing in this Order,, or 

in EPA's approval of the Scope of Work,, or in the Remedial Design 

or Remedial. Action Work Plans, or approval of any other 

submission, shall be deemed to constitute a warranty or 

representation of any kind by EPA. that full performance of the 

Remedial Design or Remedial Action will achieve the Performanee 

Standards set forth in the ROD and in Section II.I. of the Scope 

of Work:. Respondent' s conpllance with such approved documents 

does not foreclose EPA from seeking additional work to achieve 

the appl icable performance s tandards.. 

45. Respondents shall, prior to any off-site shipment of 

v , hazardous substances from the Site to an out-of-state waste 

management facility, provide written notification to the 

appropriate state environmental official in the receiving state 

and to EPA's RPM of such shipment of hazardous substances. 

However, the notification of shipments to the State shall not 

apply to any off-Site shipments when the total volume of all 

shipments from the Site to the State will not exceed ten (10) 

cubic yards.. 

a. The notification shall be in writing, and shall include 

the following information! where available: (i) the name and 

location of the facility to which the hazardous substances are to 

be shipped; (2) the type and quantity of the hazardous substances 

to be shipped; (3) the expected schedule for the shipment of the 

hazardous substances; and (4) the method of transportation., 

Respondents shall notify the receiving state of major changes in 

the shipment plan, such as a decision to ship the hazardous 

V...y substances to another facility within the same state, or to a 

facility in another state,. 

b., All hazardous substances removed from the Facility or 

vicinity shall be disposed of or treated at a Facility approved 

by EPA's RPM, and in conpl lance with the Resource Conservation 

and Recovery Act of 1976 (RCRA), 42 U.S.C. Section 9601, et se

46. Respondents shall cooperate with EPA in providing 

information regarding the Work to the public., As requested by 

EPA, Respondents shall participate in the preparation of such 

infonnation for distribution to the public: and in public meetings 

which nay be held or sponsored by EPA to explain activities at or 

relating to the Site. 

47.. Within thirty (30) days after Respondents conclude that the 

Remedial Act ion construct ion has been fully perf orniedl,, 

Respondents shall so notify EPA and shall schedule and condluct a 

pre-certification inspection to be attended by Respondents and 

EPA. The pre-certification inspection shall be followed by a 

written report submitted within thirty (30) days of the 

inspection by a registered professional engineer and Respondents" 

Project Coordinator certifying that the Remedial Action has been 

\ ) completed in full satisfaction of the requirements of this Order. 

If, after completion of the pre-certification inspection and 

receipt and review of the written report, EPA determines that the 

Remedial Action or any portion thereof has not been completed in 

accordance with this Order, EPA shall notify Respondents in 

writing of the activities that must be undertaken to complete the 

Remedial Action and shall set forth in the notice a schedule for 

performance of such activities. Respondents shall perform all 

activities described in the notice in accordance with the 

specificat ions and schedules establ ished therein.. If EPA 

concludes, following the i initial or any subsequent certification 

of completion by Respondents that the Remedial Action has been 

fully performed in accordance with this Order, EPA may notify 

Respondents that the Remedial Action has been fully performed, 

EPA's notification shall be based on present knowledge and 

Respondent's certification to EPA, and shall not limit EPA's 

right to perform periodic reviews pursuant to section 12l(c) of 

V...../ CERCLA, 42 U.S.C. 9621(c), or to take or require any action 

that in the judgment of EPA is appropriate at the Site,, in 

accordance with 42 U.S.C. 9604,, 9606, or 9607. 

48. Within thirty (30) days after Respondents conclude that all 

phases of the Work have been fully performed, that the relevant 

Performance Standards have been attained, and that all Operation 

and Maintenance activities have been operated for at least one 

year, Respondents shall submit to EPA a written report by a 

registered professiona1 engineer certifying that the Work has 

been completed in full satisfaction of the reguirenents of this 

Order,. EPA shall reguire such additional activities as may be 

necessary to complete the Work or EPA may,, based upon present 

knowledge and Respondent' s certif icat ion to EPA,, issue written 

notification to Respondents that the Work has been completed,, as 

appropriate. EPA's notification shall not limit EPA"s right to

perform periodic reviews pursuant to section 121 (c) of CERCLA,, 42 

U.S.C. 9621(c), or to take or require any action that in the 

•jludqment of EPA is appropriate at the Site, in accordance with 42 

U.slc. 9604, 9606, or 9607. 

X. FAILURE TO ATTAIN PERFORMANCE STANDARDS 

49. In the event that EPA determine® that additional response 

activities are necessary to meet applicable Performance 

Standards , EPA nay notify Respondents that add it 1 onal. response 

actions are necessary,. 

50. Unless otherwise stated by EPA, within thirty (30) days of 

receipt of notice from EPA that additional response activities 

are necessary to meet any applicafole Performance Standards, 

Respondents shall submit for approval by EPA a Work Plan for the 

additional response activities., The work plan shall conform to 

the applicable requirements of sections IX„ XVI, and XVII of this 

Order. Upon EPA's approval, of the work plan pursuant to Section 

XIV, Respondents shall implement the work plan for additional 

response activities in accordance with the provisions and 

schedule contained therein., 

XI., EPA PERIODIC REVIEW 

51. Under section 121(c) of CERCLA, 42 U.S.C. 9621 (c),, and any 

applicable regulations,, EPA may review the Site to assure that 

the Work performed pursuant to this Order adequately protects 

human health and the environment,. Until such time as EPA 

certifies completion of the Work, Respondents shall conduct the 

requisite studies „ invest igat ions„ or other response act ions as 

determined necessary by EPA in order to permit EPA to conduct the 

review under section 121(c) of CERCLA. As a result of any review 

performed under this paragraph,, Respondents may be required to 

perform additional Work or to modify Work previously performed. 

XII. MODIFICATIONS TO WORK 

52. EPA nay determine that modifications to the Work: identified 

in this Order and attachments to this Order, may be necessary to 

achieve the performance goals in the ROD or to maintain 

consistency with the final, remedy., If EPA determines that 

modifications to work are necessary, EPA nay require Respondents 

to submit for approval RD/RA Work Plan(s) to include the 

additional response activities. EPA nay also require Respondents 

to modify any plan, design, or other deliverable required by this 

Order,, including any approved modifications, 

53. Not later than thirty (30) days after receiving EPA' r s notice 

that modifications to work are required pursuant to this Section,, 

Respondents shall submit a work plan for the response activities 

to EPA for review and approval. Upon approval by EPA, the work

plan is incorporated into this Order as a requirenient of this 

Order and shall be an enforceable part of this Order. Upon 

approval of the work plan by EPA, Respondents shall implement the 

work: plan according to the standards, specifications, and 

schedule in the approved work: plan. Respondents shall notify EP.A 

of their intent to perform such modifications, to work within 

seven (7) days after receipt of EPA's request for Modifications 

to work., 

XI11. ENDANGERMENT AND EMERGENCY RESPONSE 

54. In the event of any action or occurrence during the 

performance of the Work which causes or threatens to cause a 

release of a hazardous substance or which may present an 

immediate threat, to public health or welfare or the environment, 

Respondents shall immediately take all appropriate action to 

prevent, abate, or minimize the threat, and shall immediately 

v i notify EPA's Remedial Project Manager (RPM). If neither of these 

persons is available Respondents shall notify the EPA Emergency 

Response Branch, Region 5. Respondents shall take such action in 

consultation with EPA's RPM and in accordance with all. applicable 

provisions of this Order, including but not limited to the Health 

and Safety Plan and the Contingency Plan.. In the event, that. 

Respondents fail to take appropriate response action as required 

by this Section, and EPA takes that action instead, Respondents 

shall reimburse EPA for all costs of the response action not 

inconsistent with the NCP. Respondents shall pay the response 

costs in the manner described in Section XXIV of this Order, 

within thirty (30) days of Respondent's receipt of demand for 

payment and a Itemized Cost Summary of the costs incurred. 

55.. Nothing in the preceding paragraph shall be deemed to limit 

any authority of the United States to take,, direct, or order all 

appropriate action to protect human health and the environment or 

v....y to prevent, abate, ox: minimise an actual, or threatened release of 

hazardous substances on, at,, or from the Site. 

XIV. EPA REVIEW OF SUBMISSIONS 

56.. After review of any deliverable, plan (other than the RD/RA 

Work: Plan(s)), report, or other item which is required to be 

submitted for review and approval pursuant, to this Order,, EPA. 

may: (a) approve the submission; (b) approve the submission with 

modifications; (c) disapprove the submission and direct 

Respondents to re-submit the document after incorporating EPA"s 

comments; or (d) disapprove the submission and assume 

responsibility for performing all or any part of the response 

action. As used in this Order, the terms "'approval by EPA/" "'EPA 

approval, 111 or a similar term means the action described in 

subparagraphs (a) or (b) of this paragraph,. The WDNR shall, have 

the opportunity to review and comment on any deliverable, plan,

eport or other item which is required to be submitted for review 

and approval pursuant to this Order., 

57.. In the event of approval or approval with mod if ications by 

EPA, Respondents shall proceed to take any action required by the 

plan, report, or other item, as approved or modified by EPA. 

58. Upon receipt of a notice of disapproval or a request for a 

modification, Respondents shall, within thirty (30) days or such 

longer tine as specified by EPA in its notice of disapproval or 

request, for Modification, correct the deficiencies and resubrait 

the plan, report, or other item for approval. Notwithstanding 

the notice of disapproval,, or approval with modifications, 

Respondents shall proceed„ at the direction of EPA, to take any 

action required by any non-deficient portion of the submission. 

v , 59. If any submission is not approved by 'EPA, Respondents shall 

be deemed to be in violation of this Order., 

XV,. PROGRESS REPORTS 

60. In addition to the other deliverables set forth in this 

Order, Respondents shall provide monthly progress reports to EPA 

with respect to actions and activities undertaken pursuant to 

this Order. The progress reports shall be submitted on or before 

the fifteenth day of each month fedlowing the effective date of 

this Order, Respondents" obligation to submit progress reports 

continues, until EPA gives Respondents written notice under 

paragraph 47., At a minimum, these progress reports shall: (1.) 

describe the actions which have been taken to comply with this 

Order during the prior month; (2) include all results of sampling 

and tests and all other data received by Respondents and. not 

previously submitted to EPA; (3) describe all work planned for 

the next month with schedules relating sw::h work to the overall 

^...../ project schedule for RD/RA completion; and (4) describe all 

problems encountered and any anticipated problems,, any actual or 

anticipated delay s, and solutions developed and implemented to 

address any actual or anticipated problem!-; or delays, 

XVI. QUALITY ASSURANCE, SAMPLING AMD DATA ANALYSIS 

61.. Respondents shall use the quality assurance, quality 

control,, and chain of custody procedures described in the "'EPA 

NEIC Policies and Procedures Manual,, 1 " May 1978, revised. May 1986, 

EPA-330/9-78-001-R, EPA's "Guidelines and Specifications for 

Preparing Quality Assurance Program Documentation," June 1, 1987, 

EPA's "Data Quality Objective Guidance/" (EPA/540/687/003 and 

004), and any aniendnoients to these documents,, while conducting all 

sample collection and analysis activities required herein by any 

plan.. To provide quality assurance and maintain quality control, 

Respondents sha 11::

a. As part of the RD/EA Work Plan, Respondents shall submit 

a Quality Assurance Project Plan (QAPP) to the U.S. EPA that is 

cons 1stent with the SOW,, the Amended Work Plan and EPA's '"Interim 

Guidelines and Specifications For Preparing Quality Assurance 

Project Plans 1 " (QAM-O05/80) and any subsequent amendments. The 

QAPP must: be approved by EPA prior to the comnencement of any 

sampling and analysis under this Order. 

b. Prior to the development, and submittal of a QAPP, 

Respondents shall attend a pre-QAPP meeting, if determined 

necessary,, sponsored by EPA to identify all monitoring and data 

quality objectives. U.S.. EPA, after review of the submitted QAPP, 

wi 11 either approve, conditionally approve , or disapprove the 

QAPP. Upon notification of conditiona 1 or disapproval,, 

Respondents shall make all required modifications to the QAPP 

within thirty (30) days of receipt of such notification. 

v / c., Use only laboratories which have a documented Quality 

Assurance Program that complies with EPA guidance document QAMS- 

005/80 and subsequent amendments. 

d., Ensure that the laboratory used by the Respondents for 

analyses, performs according to a method or methods deemed 

satisfactory to EPA and submits all protocols to be used for 

analyses to EPA at least 15 days before beginning analysis. 

e. Ensure that EPA personnel and EPA's authorized 

representatives are allowed access to the laboratory and 

personnel utilized by the Respondents for analyses,, 

f. Ensure provision of analytical tracking Information 

consistent, with OSWER Directive Number 9240. 0-2B, '"Extending the 

Tracking of Analytical Services to PRP-Lead Superfund Sites." 

62. Respondents shall notify EPA not less than fourteen (14) 

days in advance of any sample collection activity. At the 

request of EPA, Respondents shall allow split or duplicate 

k...,/ samples to be taken by EPA or its authorized representatives, of 

any samples collected by Respondents with regard to the Site or 

pursuant to the implementation of this Order.. In addition, EPA 

shall have the right to take any additional sample!-; that EPA 

deems necessary. 

XVII,. COMPLIANCE WITH APPLICABLE LAWS 

63.. All activities by Respondents pursuant to this Order shall, 

be performed in accordance with the requirements of all Federal 

and state laws and regulations. EPA has determined that the 

activities contemplated by this Order are consistent with the 

National Contingency Plan (NCP). 

64.. Except as provided in section 121 (e) of CERCLA and the NCP, 

no permit shall be required £or any portion of the Work conducted 

entirely on-Site. Where any portion of the Work requires a

Federal or State permit or approval, Respondent):) shall submit 

timely application!-: and take all other actions necessary to 

obtain and to comply with all such permits or approvals., 

65.. This Order is not, and shall not be construed to foe, a 

permit issued pursuant, to any Federal, or State statute or 

regulation. 

66. All materials removed from the Site shall, be disposed of or 

treated at a facility approved by EPA's RPM and in accordance 

with section 121 (d) (3) of CERCLA, 42 u.S.C. 9621 (d) (3); with 

the U.S. EPA "Revised Off-Site policy/" 1 OSWER Directive 9834.11, 

November 13, 1987; and with all other applicable Federal, State, 

and local requirements, 

XVIII. REMEDIAL PROJECT MANAGER 

^ , 67,. All. coMmuni.cati.ons, whether written or oral, from 

Respondents to EPA. shall be directed to EPA's Remedial Project 

Manager., Respondents shall submit to EPA four copies, and to 

WDNR two copies, of all documents,, including plans, reports,, and 

other correspondence, which are developed pursuant, to this Order. 

At a Minimum, Respondents shall send one copy of all such 

documents to EPA and 'WDNR by overnight or certified mail, 

EPA's Remedial Project Manager is: 

William J., Haubold 

U.S. EPA, Region 5 (HSRW-6J) 

77 West. Jackson Boulevard 

Chicago,, 11.1 inois 60 604 

(312)"353-6261 

68. EPA has the unreviewable right to change its Remedial. 

Project Manager or Alternate Remedial Project Manager., If EPA 

V....X changes its Remedial Project. Manager or Alternate Remedial. 

Project Manager, EPA will inform Respondents in writing of the 

name, address, and telephone number of the new Remedial Project 

Manager or Alternate Remedial Proj ect Manager. 

69. EPA's RPM and Alternate RPM shall have the authority 

lawfully vested in a Remedial Project Manager (RPM:) and On-Scene 

Coordinator (OSC) by the National Contingency Plan, 40 C.F.R. 

Part 300,. EPA's RPM or Alternate RPM shall have authority, 

consistent with the National Contingency Plan, to halt any work. 

required by this Order,, and to take any necessary response 

action. 

70. Within twenty (20) days after the effective date of this 

Order,, Respondents shall designate a Project Coordinator and 

shall submit thus name, address, and telephone number of the

Project Coordinator to EPA for review and approval. Respondents" 

Pro ject Coordinator shall be responsible for overseeing 

Respondenti-i" implementation of this Order., If Respondent.!-! wish 

to change their Pro;} ect Coordinator ,F Respondent s shal 1 pr ovide 

written notice to EPA, five (5) days prior to changing the 

Project Coordinator, of the name and qualifications of the new 

Project Coordinator,, Respondents selection of a Project 

Coordinator shall be subject to EPA approval, 

XIX, ACCESS TO SITE NOT OWNED BY RESPONDENTS 

71, If the Site,, the off-Site area that is to be used for 

access,, property where documents required to be prepared or 

maintained by this Order are located! or other property subject 

to or affected by the clean up,, is owned in whole or in part by 

parties other than those bound by this Order, Respondents will 

obtain, or use their best efforts to obtain, site access 

,s ; agreements from the present owner (s) within 60 days of the 

effective date of this Order. Such agreements shall provide 

access for EPA,, its contractors and oversight officials, the 

state and its contractors „ and Respondents or Respondents'' 

authorized representatives and contractors,, and such agreements 

shall specify that Respondents are not EPA's representative with 

respect to liability associated with Site activities. 

Respondents shall save and hold harmless the United States and 

its off id a Is,, agents,, employees , contractors , subco>ntractors, or 

representatives for or from any and all claims one: causes of 

action or other costs incurred by the United States on behalf of 

EPA including but not limited to attorneys fees and other 

expenses of litigation and settlement arising from or on account 

of acts or omissions of Respondents, their officers, directors, 

employees, agents, contractors,, subcontractors, and any persons 

acting on their behalf or under their control,, in carrying out 

activities pursuant to this Order, including any claims arising 

V...y front any designation of Respondents as EPA's authorized 

representative(s) under section 104(e) of CERCLA. Copies of such 

agreements shall be provided to EPA prior to Respondent's 

initial:;ion of field activities„ Respondents'' best efforts shall 

include providing reasonable compensation to any off-Site 

property owner. If access agreements are not obtained within the 

time referenced above,, Respondents shall immediately not if y EPA 

of their failure to obtain access.. Subject to the United States" 

non-reviewable discretion,, EPA may use its legal, authoriti.es to 

obtain access four the Respondents, may perform those response 

actions with EPA contractors at the property in question, or nay 

terminate the Order if Respondents cannot obtain access 

agreements.. If EPA performs those tasks or activities with 

contractors and does not terminate the Order, Respondents shall 

perform all other activities not repairing access to that 

property, and shall reimburse EPA,, pursuant, to Section XXIV of

v 

this Order, for all costs incurred in performing such activities., 

Respondents shall integrate the results of any such tasks 

undertaken by EPA into its reports and deliverables. 

Respondents shall, reimburse EPA, pursuant to Section XXIV of this 

Order., for all. response costs (including attorney fees) incurred 

by the United States to obtain access for Respondents, 

XX,. SITE ACCESS AND DATA/DOCUMENT AVAILABILITY 

72!, Respondents shall allow EPA and its authorized 

representatives and contractors to enter and freely move about 

all property at the Site and off-Site areas subject to or 

affected by the work under this Order or where documents required 

to be prepared or maintained by this Order are located, for the 

purposes of inspecting conditions,. activities,, the results of 

activities, records,, operating logs, and contracts related to the 

Site or Respondents and its representatives or contractors 

pursuant to this Order; reviewing the progress of the Respondents 

v '"' in carrying out the terras of this Order; conducting tests or 

sampling as EPA or its authorized representatives or contractors 

deem necessary; using a camera, sound recording device or other 

documentary type equipment; and verifying the data submitted to 

EPA by Respondents. Respondents shall allow EPA and its 

authorized representatives to enter the Site, to inspect: and copy 

al 1 records , files, photographs ,r documents, sampling and 

monitoring data,, and other writings related to work undertaken in 

carrying out this Order,. Nothing herein shall be interpreted as 

limiting or affecting EPA's right of entry or inspection 

authority under Federal law,. 

73. Respondents may assert a claim of business confidentiality 

covering part or all of the information submitted to EPA pursuant: 

to the terms of this Order under 40 C.F.R. 2.203, provided such 

claim is not inconsistent with section 104(e)(7) of CERCLA, 42 

V.../ U.S.C. 9604(e) (7) or other provisions of law. This claim shall 

be asserted in the manner described by 40 C.F.R. 2.203(b) and 

substantiated by Respondents at the time the claim is made, 

Information determined to be confidential by EPA will be given 

the protection specified in 40 C.,F.R,, Part 2,. If no such claim 

accompanies the information when it is submitted to EPA,, it may 

be made available to the public by EPA or the State without 

further notice to the Respondents. Respondents shall not assert 

confidentiality claims with respect to any data related to Site 

conditions., sampling, or moini.tori.ng,. 

74. Respondents shall maintain for the period during which this 

Order is in effect, an index of documents that Respondents claim 

contain confidential business information., The index shal 1 

contain,, for each document, the date, author, addressee,, and 

subject of the document. Upon written request from EPA,,

Respondents shall submit a copy of the index to EPA. 

XXI,. RECORD PRESERVATION 

75.. Respondents shall provide to EPA upon request, copies of all 

documents and information within their possession and/or control 

or that of their contractors or agents relating to activities at 

the Site or to the implementation of this Order„ including, but 

not 1 inited to sampling,, analysis, chain of custody records, 

manifests f trucking logs, receipts, reports, sample traffic 

routing, correspondence, or other documents or information 

related to the. Work. Respondents shall also make available to 

EPA for purposes of invest igation, information gathering, or 

testimony, their employees,, agents,, or representatives with 

knowledge of relevant facts concerning the performance of the 

Work, 

it , 76. Until, ten (10) years after EPA provides notice pursuant to 

v '" paragraph 47, each Respondent shall preserve and retain all 

records and documents in its possession or control, including the 

documents in the possession or control, of their contractors and 

agents on and after the effective date of this Order that relate 

in any manner to the Site., At the conclusion of this document 

retention period,, Respondents shall notify the United States at 

least ninety (90) calendar days prior to the destruction of any 

such records or documents,, and upon request by the United States,, 

Respondents shall, deliver any such records or documents to EPA... 

77. Until ten (1.0) years after EPA provides notice pursuant to 

paragraph 47 of this Order, Respondents shall preserve, and shall 

instruct their contractors and agents to preserve,, all documents, 

records, and information of whatever kind, nature or description 

relating to the performance of the Work. Upon the conclusion of 

this document retention period,, Respondents shall notify the 

V...y United States at least ninety (90) days prior to the destruction 

of any such records, documents or information, and,, upon request. 

of the United States, Respondent!-; shall deliver all such 

documents, records and information to EPA.. 

78.. Within sixty (60) days after the effective date of this 

Order, Respondents shall submit a written certification to EPA's 

RFM that they have not altered, mutilated., discarded, destroyed. 

or otherwise disposed of any records, documents or other 

information relating to their potential, liability with regard to 

the Site since notification of potential liability by the United 

States or the State or the filing of suit against it regarding 

the Site. Respondents shall not dispose of any such documents 

without prior approval by EPA.. Respondents shall, upon EPA's 

request and at no cost to EPA, deliver the documents or copies of 

the documents to EPA,.

XXII. DELAY IN PERFORMANCE 

79. Any delay in performance of this Order that;, in EPA's 

judgment., is not properly justified by Respondents under the 

terms of this paragraph shall be considered a violation of this 

Order. Any delay in performance of this Order shall not affect 

Respondents obligations to fully perform all obligations under 

the tenns and conditions of this Order. 

80. Respondents shall, notify EPA of any delay or anticipated 

delay in performing any requirement of this Order, Such 

notification shall be made by telephone to EPA's RPM or Alternate 

RFM within forty eight (48) hours after Respondents first knew or 

should have known that a delay might occur. Respondents shall 

adopt, all reasonable measures to avoid or minimize any such 

delay. Within five (5) business days after notifying EPA by 

,s< , telephone, Respondents shall provide written notification fully 

describing the nature of the delay, any justification for delay, 

any reason why Respondents should not be held strictly 

accountable for failing to comply with any relevant, requirements 

of this Order, the measures planned and taken to minimize the 

delay, and a schedule for implementing the measures that will be 

taken to mitigate the effect of the delay. Increased costs or 

expenses associated with implementation of the activities called 

for in this Order is not a justification for any delay in 

performance. 

XXIII. ASSURANCE OF ABILITY TO COMPLETE WORK 

81. Respondents shall demonstrate their ability to complete the 

Work required by this Order and to pay all claims that; arise from 

the performance of the Work by obtaining and presenting to EPA 

within thirty (30) days after approval of the RO/RA Work Plan,, 

one of the following: (1) a perfornance bond; (2) a letter of 

V...,/ credit; (3) a guarantee by a third party; or (4) internal 

financial information to allow EPA to determine that Respondents 

have sufficient assets available to perform the Work. 

Respondents shall demonstrate financial assurance in an amount no 

less than the estimate of cost for the remedial design and 

remedial action contained in the Record of Decision for the Site. 

If Respondents seek to demonstrate ability to complete the 

remedial action by means of internal financial information, or by 

guarantee of a third party, they shall re-submit such information 

annually, on the anniversary of the effective date of this Order. 

If EPA determines that such financial information is inadequate. 

Respondents shall,, within thirty (30) days after receipt of EPA's 

notice of determination, obtain and present to EPA for approval 

one of the other three forms of financial assurance listed above., 

82. At least seven (7) days prior to commencing any work at the

Site pursuant to this Order, Respondents shall submit to EPA a 

certification that Respondents or their contractors and 

subcontractors have adequate insurance coverage or have 

indemnification for liabilities for injuries or damages to 

persons or property which may result from the activities to be 

conducted by or on behalf of Respondents pursuant to this Order, 

Respondents shall ensure that such insurance or indemnification 

is maintained for the duration of the. Work required by this 

Order. 

XXIV. REIMBURSEMENT OF RESPONSE COSTS 

83. Respondents shall reimburse EPA,, upon written demand, for 

all response costs incurred by the United States in overseeing 

Respondents' implenientation of the requirements of this Order. 

EPA. nay submit to Respondents on a periodic basis an accounting 

of all response costs incurred by the United States with respect 

, . to this Order. EPA's certified Agency Financial Management 

System summary data (Itemized Cost Summary), or such other 

summary as certified by EPA, shall serve as basis for payment 

demands. 

84. Respondents shall,, within thirty (30) days of receipt, of 

each EPA accounting, remit a certified or cashier's check for the 

amount of those costs,. Interest shall accrue from the later of 

the date that payment of a specified amount is demanded in 

writing or the date of the expenditure., The interest rate is the 

rate established by the Department of the Treasury pursuant to 31 

U.S.C. 371.7 and 4* C.F.R. 102.13. 

65, Checks shall be made payable to the Hazardous Substances 

Superfund and shall, include the name of the Site, the Site 

identification number, the account number and the title of this 

Order. Checks shall be forwarded to: 

V.y U. S,. Environmental Protection Agency 

Superfund Accounting 

"P.O. Box: 70753 

Chicago,, 111inois 60604 

86. Respondents shall send copies of each transmittal letter and 

check to'the EPA's RPM. 

XXV,. UNITED STATES MOT LIABLE 

87.. The United States, by issuance of this Order, assumes no 

liability for any injuries or damages to persons or property 

resulting from acts or omissions by Respondents, or their 

directors, officers, employees, agents, representatives,, 

successors, assigns, contractors, or consultants in carrying out 

any action or activity pursuant to this Order. Neither EPA nor 

the United States may be deemed to be a party to any contract 

entered into by Respondents or their directors, officers,

employees, agents, successors, assigns, contractors, or 

consultants in carrying out any action or activity pursuant to 

this Order.. 

XXVI. ENFORCEMENT AMD RESERVATIONS 

138. EPA reserves the right to bring an action against 

Respondents under section 107 of CERCL&, 42 U.S.C. 9607, for 

recovery of any response costs incurred by the United States 

related to this Order and not. reimbursed by Respondents. This 

reservation shall include, but not be limited to past costs,, 

direct costs, indirect costs,, the costs of oversight, the costs 

of compiling the. cost documentation to support oversight cost 

demand,, as well as accrued interest as provided in section 107(a) 

of CER.CIA, 

89.. Notwithstanding any other provision of this Order, at any 

is , time during the response action,, EPA may perform its own studies, 

complete the response action (or any portion of. the response 

action) as provided in CERCIA and the NCP,, and seek reimbursement 

from Respondents for its costs,, or seek any other appropriate 

relief. - 

90.. Nothing in this Order shall, preclude EPA from taking any 

additional enforcement actions,, including modification of this 

Order or issuance of additional. Orders,, and/or additional 

remedial or removal, actions as EPA may deem necessary, or from 

requiring Respondents in the future to perform; additional 

activities pursuant to CERCIA,, 42 U.S.C. 9606(a),, et_..se«3[«x or 

any other applicable law. Respondents shall be liable under 

CEJEtCLA section 107 (a), 42 U.S.C. 9607 (a) , for the costs of any 

such additional actions. 

91. Notwithstanding any provision of this Order, the United 

V..-'' States hereby retains all of its information gathering, 

inspection and enforcement authorities and rights under CERCLA, 

RCRA and any other applicable statutes or regulations. 

92. Respondents shall, be subject to civil penalties under 

section 10is(b) of CERCLA.,, 42 U.S.C. 9606(bj , of not more than 

$25,, 000 for each day in which Respondents willfully violates,, or 

fails or refuses to comply with this Order without sufficient 

cause., In addition, failure to properly provide response action 

under this Order,, or any portion hereof, without sufficient 

cause, may result in liability under section 107(c) (3) of CERCLA,, 

42 U.,S.C,. 9607(c) (3), for punitive damages in an amount at 

least equal to, and not more than three times the amount of any 

costs incurred by the Hazardous Substance Superfund as a result 

of such failure to take proper action.,

93. Nothing in this Order shall, constitute or be construed as a 

release from any claim, cause of action or demand in law or 

equity against any person for any liability it nay have arising 

out of or relating in any way to the Site. 

94. If a court issues an order that invalidates any provision of 

this Order or finds that Respondents has sufficient cause not to 

comply with one or more provisions of this Order, Respondents 

shall remain bound to comply with all provisions of this Order 

not invalidated by the court's order. 

XXVII. ACCESS TO ADMINISTRATIVE RECORD 

95. The Section 1O6 Administrative Order supporting the above 

Findings of Fact and Detenni.nati.ons is available for review on 

normal business days between the hours of 9:OO a.,n, and 5:OO p.m. 

at the U.S. EPA,, Region V,, 77 West Jackson Boulevard., Chicago,, 

v , Illinois. Please contact Janet Pfundheller, Administrative 

Record Specialist, at (312) 353-7626 to review the Administrative 

Record at this location. An Index of the Administrative Record 

is attached within the ROD hereto as Attachment 1.. 

XXVIII. EFFECTIVE DATE/TERMINATION 

9(5.. This Order shall be effective 20 days after the Order is 

signed by the Regional Administrator. All times for performance 

of ordered activities shall be calculated from this effective 

date. 

97. The provisions of this Order shall be deemed to be satisfied 

when EPA notifies Respondents in writing that Respondents have 

demonstrated, to U.S. EPA's satisfaction, that all tennis of the 

Order have been completed,. This notice shall not, however, 

" terminate Respondents obligation to comply with Article XXI of 

this Order (relating to record preservation),. 

XXIX. OPPORTUNITY TO CONFER 

98. Respondents nay, within ten (10) days after the date this 

Order is signed, request a conference with EPA to discuss this 

Order. If requested, the conference shall occur at U.S. EPA 

Region 5 offices,, 77 West Jackson Boulevard, Chicago, Illinois or 

a location to be determined at a later date,. This conference is 

not an evidentiary hearing, and does not constitute a proceeding 

to challenge this Order. It does not give Respondents a right to 

seek: review of this Order, or to seek resolution of potential 

liability, and no official stenographic record of the conference 

will be made, At any conference held pursuant to Respondent,'s 

request, Respondents may appear in person or by an attorney or 

other representative,. Requests for a conference must be by 

telephone followed by written confirmation mailed that day to 

William J. Haubold, Remedial Project Manager, 77 West Jackson 

Blvd.,, Chicago, II, 60604, (312) 353-6261.'

So Ordered, this 

day of December, 1992., 

BY: 

William E,, Mono 

Acting Director, 'lilaistM-s^.WfiSin.-ij^jiiaiiiSStinit: Division 

1.1,.S. Environmental Protection Agency 

Region V

v.,/ 

ATT^CBMINT 4 

INDEX OF LIABILITY

INDEX 0F LIABILITY DOCUMENTS 

09 / 2 5 / 8 6 Waste Managaaient, U,. S. ZPA 

Inc. 

0212 4 / a 7 waste Management, U, S., EPA 

Inc., 

o ::i / 2 4 / al waste Management, u. S. EPA 

Inc.. 

10/30/92 waste Management, U.S. EPA 

Inc. 

11/13/92 Waste Management,, U.S. EPA 

Inc.. 

09/09/136 Carl Wauer U.S. 

0 € / 01 / 8 7 Acme Gal. van i z ing , 

Inc.. 

11/02/92 Aciniai Gtlvanizing, U.S. Elf'A 

Inc., 

:.,:;:/!'[!'/i-i(ii Aldrich chemical U.S. EPA 

Cnipany 

:LO/io/f:i! Aldrich chaiical U.S. EFA 

C0inpa:nY 

12/1IEI/B6 Allintini lilradley Co. U..S. EPA 

11/03/92 Alien Bradley Co. U.S., EPA 

Rasponsie t:::: EPA 

I nf o rmar i o n Reque s t 

SuppIiitiiKiincai 

Riiitsponsa co EPA 

Information Raquaat 

( including 12 drivar 

affidavits) 

Supiplenental 

Riniiiponsdi: to EPA 

I nf orniat i o n Re quest 

SuppIiitiDnaiintal 

Rmisponse to EPJfi, 

Information Raquast 

(attaching siiteriiitlated 

records) 

Suppleaantal 

Rin HI i;ion!!ii€ to EP'A 

I nf oriiat i on RiiMpies t 

(attaching liquid 

wasta report 

summaries) 

Response to EPA 

Information Reqruamt 

Riiiisponainit to EPA 

Information Requamt 

Riiiiinponsiit to E;PA 

Infoniation Raqminst 

Riiiiiiiiponsiiit to EPA 

Infoinnation Raqiuast 

sniippiaiineinitai 

Riasponaiii to EPA 

Informiiiition Riiiquaiiit 

RAsponsa to EPA 

Information Raqwmst 

Si.ippl«Biiaiiirital 

Rdiifliponse to EPA 

Information Regjumtst

Author 

12/22/86 American Motors U.S. SPA 

Corp. 

11/12/92 Ampco Metal Co. U.S. EPA 

04/24/87 Aniron Corporation U.S. SPA 

11/06/92 Amron Corporation U.S. EPA 

11/04/92 Beatrice Company U.S. EPA 

11/251B2 aeatrloe company U.S. EPA 

07/06/87 Elostrom Seating U.S. EPA 

Inc., 

11./12 / 92 Bos tron Seat ing U, S.. EPA 

Inc. 

11/24/92 Browning Ferris U.S. EPA 

Indus tries 

06/04/87 Caterpillar Tractor u.S. EPA 

Company 

11./12 / 9 2 Catintrpil Lar Tractor U.. S. l-IFA 

Connpany 

12/04/ill€ Cudahy Tanning Co., U.S. EPA 

11/12/92 cudahy Tanning Co. U..S, EPA 

11/20/92 GudaJhy Tanning Co,. u,.s,, EPA 


I n f o r:ix a t i c n R e qu e s t 

Res pains; e to EPA 

Informat i a n Request 

Response t::i EPA 

Information Request 

Supplemental 

Rasponiiie to EPA 

I nf orma t, i o n Requein t 


Inôncnation Requeet 

Suppleinnnintal 

Rioiinponse to EPA 

Infooiacion Request 

Reimponse to EPA 

Infonnation Reqiunitst 

Suppleiniental 

Ruiijiiponse to EPA 

Infonnation Riiiqunimit 

Raiisponsiiii to EPA 

Infonnation Request 

Responsnii to EPA 

Infonnation 

Suppliiinantai 


Information 


Infooution Request 

Suppleiniental 



Suppliraiental 


IniElornation Request

V.,./ 

06/30/87 Dings e-^-in Response ~::: £? 

r.e ernes' 

10/26/92 Dings company U.S. EPA 

06/15/87 E.Z. Paintr Co. U.S. EPA 

11/06/92 S.Z. Paintr Co. U.S. EPA 

10/29/92 Envirax, Inc. U.S. EPA 

11/18/92 Envirisx, Inc. U.S. EPA 

05/05/87 Gditniiiral Electric U.S. EPA 

Company 

12 /1.2 / S 6 Hw:-n i. in ch I! diigiii r 

10 / :i! 0 / 92 Haoiiischf eger 

u.s. 

U.S. EPA 

11/02/92 Hydritai Chwnical U.S. EPA 

Company 

09/24/86 LmidlW !'laili-l:.iii: U.S.. EPA 

syintmis, Inc. 

11/12/92 Law Tanning Co, U.S. EPA 

12/2:3I/S6 Loiliill Alliiil U.S.. EPA 

oa/0!!!/B7 Hastiiitr Lock: Co. 

11/05/92 IttJllltillir Lock CO. 

U.S., 

U.S. EFA 

Supplemental. 

Response t::: EPA 

I n IE: o rma t i o n iR e q u e s T: 

Rmsponse to EPA 

Information Requesr 

Supplemental 

Rin mponi!!! in to EPA 

Information Requmtst 

Raiiiiponse to EPA 

Infornation Request 

Supplemental. 

Reniponse to EPA 

I nf croat i o n Reqwiis t 

RiiiiinpoiniiiNiit to EPA 

Infonnation iRiiiiq[M,iniii.t 

Riiiiinponsiiit to 

Information Rwqiieint 

Suppieiniiiitntal 

Riiitfliponsnii to EPA 

Information Rinquaint 

Riiiuiiiponsiiit to EPA 

Infonnation Riitqueiiit 

to EPA 

Information. Ruitqiiaint 

Riiiisponsnit to EPA 

Information Rinquiiniit 

Riiiispon!!i

11/12/92 Master Lock Co, U. S. EPA 

12113 / 8 6 MetaIs Transport U.S. EPA 

Co., Inc. 

11/01/92 Metals Transport U.S. £?A 

Co., Inc. 

12 /10 / 86 Midwiast Tanning Co. U. S,. EPA 

10/28/92 Midwest Tanning Co. U.S. EPA 

11/ 0::i /92 Patrick Cudahy 

Company 

12/17/86 PPG 1ndustri es 

11 /04/92 PPG Industries 

U.S. EPA 

U.S. EPA 

U.S. HPA 

11/11/92 Pressed Steel Tank: U.S. EPA 

coapany 

06/30/87 PVL Limiti!td 

Partnership 

07/17/87 Rexnordl Inc. 

11 /1 a / 9 2 RMcnord,, :i: nc. 

U.S. EPA 

U.S. EPA 

U.S. EPA 

11/09/92 St. Luke's Hospital U.S. EPA 

0:31/27/137 Star Line 

Trucking Co. 

.10/14/92 Star Line 

Trucking Co. 

U.S. 

U.S. EPA 

Supplemental 

Response '::::: EPA 

I n f oma t i ;:: r. Requ (•> s t 


I nf ornat i c n Request 

Suppleniental 


I n f o r an a c i o n Requ e s t 


Inf conation Request 

Supplemental 

Reiiiponse to EPA 


I 


I n :l: o rma t i o n Reques t 



SuppJiemental. 



Response to 



Infbnnation Request 

Response to EPA \..,'' 

Infonniation Request 

Supplemental 


Information R.equest 

Reimponse to EPA 


» 


Information Rinquest 

Supplementel 


Information R«ic[uest

V.../ 

...„.,/ „ . y

. . 

lb"/27/92 Wisconsin Electric '. 

Power Co., 

11/05/92 Wisconsin Electric U.S. 1PA 

Power Co. 

v 

U.S. :i.r-M -(=..., 

OFFICE OF REGIONAL CO...*- 

Suppieiciencai 

Response to i-iPA 

Infcraaticn Request 

Supplemental 

Response to 'EPA 

Informat i on ReqrueiEit


REGION V 

In the Natter Of : ) 

Sanitary Landfill ) 

aiir Operable Unit } 

WlincoBinin ) U.S., HI PA 

) Docket No. V-W-' 95-C-295 

Proceeding Under Section 106 (a) of ) 

the Comprehensive Environmental ) 

Response „ Compensat ion , and ) 

Liability Act of 191:10, as amended ) 

IKIOJIOIUIIT 'TO MliliXltnSTEATrWE GffitDEE 

FOB li!fij[llJT)JAL JHIIiJ'ji'n'jM MIT) 1 FDIEIIED1E Mi ATTTO!!!! 

'"•"'' On June 6, 1995, the Acting Director of the Waste Management 

Division , Reg ion V, Uni t ed States Environmental Protection Agency 

(U.S. EPA) issued an Administrative Order (the "Order") in this 

matter to 56 named Respondents., Since the time of issuance, U.S. 

EPA has identified minor factual errors in the Order,, and has 

decided to amend the above -referenced Order to correct those 

errors. The Order, and this Amendment to the Order,, are issued 

to Respondents by the U,,S. EPA under the authority vested in the 

President of the United States by Section 106 (a) of the 

Comprehensive Environmental. Response, Compensation and Liability 

Act 'of 1980, as amended ("CERCLA") , 42 U.S.C. § 9606 (a). This 

authority was delegated to the Administrator of the U.S. EPA on 

January 23, 1987, by Executive Order 12580 (52 Federal Register 

2 9 2 6) ,. and was further delegated to the Regional Administrator on 

September 13, 1987 by EPA Delegation NOB. 14-14 and 1.4 - 14 -A, and 

to the Director,, Waste Management Division, Region V, by Regional 

\,..y Delegation. Nos. 14-14 and 14 -14 -A. 

The Order issued in this matter on June 6, 1995, is hereby 

amended as follows : 

I,, Paragraph 4, on pages 2 and 3 of the Order,, is amended to 

read : 

4. Within ten (10) dlays after the issuance of this 

Amendment to the Order,, each Respondent that owns real property 

comprising any part of the Site shall record a copy of the Order 

and the Amendment thereto in the appropriate governmental office 

where land ownership and transfer records are filed or recorded, 

and shall ensure that the recording of this Order and Amendment 

is indexed to the title of each and every property owned by said 

Respondent at the Site, so as to provide notice to third parties 

of the issuance and tennis of this Order and Amendment with

V..y 

respect to those properties. All such Respondents shall,, within 

20 days after the issuance of the Amendment to this Order, send 

notice of such recording and indexing to U.S. EPA., 

II. Paragraph 8.a., on page 6 of the Order, is amended to read: 

a. Respondent. Waste Management of Wisconsin,, Inc. 

("WMWi"), formerly known as Acme Disposal Company, is now, and 

has been since approximately 1970, the operator of the Site,. 

Since 1991, WMWI has also been the owner of the Anamax Plant 

property that is part of the Site. Daring the time that the Site 

has been operated by NMWI, by its corporate affiliates and by 

Acme Disposal. Company, hazardous substances, including some or 

all. of those described in this flection, were disposed of at the 

Site. HMHI is also a successor in interest to Best Disposal 

Service Company and United Waste Systems. Best Disposal Service 

Company, Acme Disposal Company and United Waste Systems accepted 


at the Site, and selected the Site for disposal or treatment. 

III. Paragraph 8.b., on page 6 of the Order, is amended to read: 

b. Respondent Carl Wauer is now, and has been from about 

1965, the owner of the Site. Mr. Wauer operated the Site from 

approximately 1965 until approximately 1,970, when Acme Disposal 

succeeded Mr.. Wauer as operator of the Site., During the period 

in which Mr, Wauer operated the Site,, and during the time in 

which he has owned the Site, hazardous substances„ including some 

or all of those described in this section, were, disposed of at 

the Site. 

IV.. Paragraph 8.o., on page 10 of the Order, is amended to read: 

o. Respondent 1-1 lack-hawk Leather, Ltd. arranged, by 

contract or agreement or otherwise, for the disposal or 

I , treatment, or arranged with a transporter for transport for 

'"••"' disposal or treatment, of hazardous substances owned or possessed 

by Blackhawk Leather, Ltd.,, at the Site,. Those hazardous 

substances included various process-related liquid wastes. 

Hazardous substances of the same kind as those owned or possessed 

by Blackhawk Leather, Ltd, are contained at the Site. 

V. Paragraph 8.ff., on page 14 of the Order, is amended to 

read: 

ff., Respondent Babcock & Wilcox Company arranged, by 


treatment, or"arranged with a transporter for transport for 


by Babcock & Wilcox Company•, at the Site„ Those hazardous 

substances included cutting oils, and drums containing other 

liquid industrial wastes., Hazardous substances of the same kind 

as those owned or possessed by Babcock: & Wilcox Company are 

contained at the Site.

VI., Paragraph 8.pp., on page '16 of the Order, is amended to 

read: 

pp. Respondent Envirex, Inc.. arranged, by contract or 

agreement or otherwise, for the disposal or treatment, or 


treatment, of hazardous substances owned or possessed by Envirex:,, 

Inc. /'at the Site,, Those hazardous substances included liquid 

wastes and paint wastes. Hazardous substances of the same kind 

as those owned or possessed by Envirex, Inc., are contained at the 

Site „ 

¥i:i:,. Attachment 1 to the Order is amended to substitute Babcock & 

Wilcox: Company for McDermott, Inc., (as Respondent number 32) and 

to substitute Envirex, Inc. for Rexnord Corporation fas 

Respondent number 42} ., 

VIII. Paragraph S.zz., on page 19 of the Order, is amended to 

read:; 

zz,. Respondent Vulcan Materials Company arranged, by 




by Vulcan Materials Company„ at the Site., Those hazardous 

substances included aluminum slag and other waste by-products of 

the aluminum recycling process. l-Iazardous substances of the same 

kind as those owned or possessed by Vulcan Materials Company are 

contained at the Site. 

The June 6, 1995, Order is otherwise unchanged in all respects. 

Unless expressly stated herein,, none of the requirements or 

deadlines in that Order are in any way affected by the issuance 

of this Amendment. 

\^' SO ORDERED this __(..___ day of July,, 1995. 

BY: £ /h~ 

William E, Muno 

Acting Director, Waste Management Division 

United States Environmental. Protection. Agency,, Region V

v../ 

ATTACHMENT 2 

SCOPBOFWM

December 1, 199:!! 

soon OF won: rat 

rate somes COMIBOL iii::!!;!!!;!!!:!:!:]::;!!,]!, iCiiiwioi i;ini EEinxiiM;. ACROV 

acfXTOKH ;I!.T THE 

HUSXBGQ ..SfttttTUff LMIDF1LL SITE 

M08KEGO, WISCONSIN' 

I • EEffiKiiiili! 

The purpose of this Remedial Design/ltaMdial Action at the 

Nuskego Sanitary Landfill National Priorities List (NFL) site 

(Site) „ referred to in Figure 1, is to fully implement the 

Record of Decision (BOD) for the Source Control Operable Unit 

remedy which was signed 'by the Regional Administrator on June 

\ y 12, 19 92. The iRespondeiriits shall follow the U.,8, EPA superfund 

Remedial Design and Rmedial Jkstion Guidance „ the RODIP the 

approved Remedial ]:>esi

Contiguous Fill Ax: mas .. The length , 

location,, and sdhieduls for coiuitruction of 

tha fenca will be determined during the 

design of the landfill cap, Additional 

pay be ,jr«quir«d by U.S. EPA to 

the nioititpce annas from the stone 

Ridge Recycling ejwil Disposal Center, if open 

to th* : public. Sates shsill ba installed to 

provide access for expected vehicular 

traffic. Waning signs shall be posted at 

2 00- foot intervals along the fence and 

points of entry (gates) to that site. The 

warning aigna ailull advise that the area is 

a Supiicrfttnd Sitnit or that tha area is 

hazardous duw to irastae buried within the 

soil which pomie a ritiik to people through 

diract contiuit. tha signs shall also 

provide a local contact " a telephone nuiggllMir 

to call for further information,. 

B.. :i;:iutitntio:uil icointtrols 

€.,. 

Within 60 da,ys af t«r tha affective date of the 

Adiiini«trat iv» Order , the RaapondainUit shall 

:jjiiiliinent hibit fuittinre 

dewelopneBt ( iiiKSluding,, o]iii->site excawatiotniii , 

building co:nsil±n:ictioin ,, drilling, installaLtioint of 

drinking water walls ,, or other use* of tha Site 

would ba iiuioitwistent with LmiiKljisiiiiiiiiinlîiLtiiciini 

long tann inuntinteiniance of the renedial action]! 

fov all of the Site proparty which any of thin 

cixiereinitly owirt. Tha iftaspoindenta , also vrithin 60 

day s aftwr tha af:i!!(iitetiva date of the Order, shall 

u in in their best efforts to iiiplaiment thoae suie 

dated restrictioinia on thoee portions of the Site 

property which are owned by persons other thnin 

tha Reapondants . Tha deed r estr ictions regarding 

future developniieinit of the site shall be 

oaiciiigtidared paniianent. 

upon receipt of that order r the 

RetiiipondantB ahall pxtnrida acceaa to thoae 

pojirtions of tlw Site controlled by the 

Respondents . :i::n addition r tha Reapondants shai 1 

use their baniit; effort!!! to obtain access for the 

piuirpome of iBiplenenting Wo>r]lc required by the 

Ordatr and this SOI on thoae portions of tha Site 

not presantiy oinmed or controlled by the 

Resppndeitnte „ ttiis Hqrk inoiludea without 

1 limit: at ion tlu installatidn and maintenance of a 

cap over the Fill Areas, coinBtruction of a fence 

to limit access to the source areas,

sstahlishBient of a leach ate control system in the 

old Fill Area and inprdvittMnt of the existing 

leecihate control system in the Southeast Fill 

Area, inpl«Mntation of an active landfill, gas 

control systsis. within these waste masses and 

those of the Non-contiguous Fill Area, and 

construct ion of an In-situ ( in- place ) vapor 

extraction (XSVE) system in soils of the Non- 

Contiguous Fill Area., Access , when obtained ,, 

shall be provided for representatives of the 

Respondents , as well as for the U.S. EPA and the 

Wisconsin Department of Natural. Resources (WDNR) 

and their contractors or authorized 

representatives , 

D. LmBdfill Clip 

\v / The Respondents shall design and reconstruct a 

landfill cap covering the Old, Southeast,, and 

Non-Contiguous Fill areas that will meet or 

exceed the icêûirfiments of Section MR S 04.07 ( l)- 

(7) „ Wisconsin Administrative Code (WAG) . The 

Respondents shall , during the remedial des ign 

phase, propose a cap design that will include 

construct ing the cap either as separate noncontiguous 

units or as one continuous cover., The 

proposed design shall also designate the source 

of materials to be used for the new cap., The new 

cap design may include reusing (i.e. ,- picking up 

and replacing) existing cover materials that mieet 

the standards specified in Chapter NR 504,, tote, 

presently covering the Old and Southeast. Fill 

Areas. If existing material is not to be reused 

in oonstraction of the clay layer, then new 

material shall be utilized in construction of the 

final clay layer on the existing fill areas,, The 

II. S.. EPA, in consultation with the HONE, will 

approve the final configuration of the cap and 

the materials ussd in its construction,, The cap 

shall be constructed to meet the mininuini slope 

rec|uirain.ent specified in s,, NR 506, 08(3 ) (C)(, MAC,. 

The Respondents shall iniaintain the cap for 30 

years following construct ion of the cap „ 

The landfill cap shall be constructs^ to minimi:t:e 

leachate generation by limiting percolation of 

rainwater and snowmelt through the cap system,, 

waste naterial,, and into the groundwater. This 

ci!i.|;j shall inciude,, at a iiinimum (from top to 

bottom) :

A i-ioil. layer consisting o£ at least six 

inches of topsail that vill sustain plant growth., 

Seed and fertilizer shall be applied to this 

layer to establish a vegetative cover. The 

vegetation shall be a persistent species with 

roots that will not pensitrate into lower lay are; 

An IB to 30-inch thick frost protect ion and 

rooting zone layer. This layer shall bin of 

sufficient diinpth to protect the underlying 

c:o:ni]i;>acl;:ii!i.08 (6) „ WM!« The nraiibai:!!:Ir spacing and location 

of gas extraction wells within each fill aniita, 

and the nrathod of gas condinnsate nanageiient shall 

be detsniinsd in the reiniedial design and shall be 

approved by the U.S. EWi., in consultation with 

the WDNR., Construetion p lans a nd docmentation 

for a landfill gas extraction system shall be 

prepared in accordance with ch, NR 516, His. Adm. 

Code. Debris or refuse generated by the 

4

installation of the extraction system may be 

cimsolidated within the fill areas., 

The extracted landfill cjfaiil shall be mana.ged in 

a manner consistent with ch. MR 445 r MAC 

requirements.. 

F - Luidf ill

each fill area, and thsi method of leechate 

management shall Iba determined in the nnsdial 

deimigitii and shin 11 bun approved by the U.S., EPA, in 

conwltfttion with the mm. U.S.. EPA, in 

consultation with WDI1 „ may raquire addit ional or 

sapplsiffiental laachatsi axtraction measures,, if 

needed to n»ixi«gd:i:e the amount of leschate 

withdrawn! ancll minimfz*, to the extent 

practicable, the amount of leachate collected on 

thin base of the Old Fill and Southeast Fill 

annas „ 

LniAChate 'Mill be traatund and dispoi-iad of in 

cooinpliuiciih with all applicable d ischarga and / or 

printraatniiiinit staBdinrds ,. If any laachate 

ibraatinient or pontraatiinainit is necessary „ any 

slwilga or residualni frann that traatinent vill be 

iianaEtraction 

Spiiteii „ to rsainaitdiate the contaiminatad s-i ul:i- isioiliii 

IB the vicinity the HonEtraction 

wells ,r and a sysitea for trmtating of f -gas from the 

extraction wells ,, Raicspointdents shall per f one a 

Pilot-scale Test: prior- to full-scale 

iBplasantatioiiri to iggiininidiBe the potential for air 

intrusion into the waste masses, 

li, Pilot-Scale Test Work Plan 

After cu:>nstri;|,ction of the landfill cower 

{pnrsuaintt to Section II,,Dir above, of the SOW), 

tout prior to full- scale Implemiiintat.lan of the 

:[:E¥1 systeiii, the Rsspondfliints shall design and 

iiniplsciment a pilot-scale test of IS VI:; in the Mon- 

Conticruous Pill Area (the "'Pilot-Scale Test" 1 ) . 

Tbe Raspondsnts , puriiruiant to the tiiietable 

eetablished in Section Pi',, below,, of the SOW,, 

shall siil:nit« to .U.S. El'A and WDMR,, a work: plain 

for design and iBplnientation of the Pilot->Scale 

Test for ISVEt which is subject to approval by

U.S. EPA, in consultation with WDNR. The Work 

Plan shall incltuta, at a minimua, the location 

within the 'Non-Contiguous Fill Area where the 

Pilot-Scale Test is to be conducted,, the 

operation parsanieteoi, IjiJiiu.,, number and location 

of extract ion vslls, pumping rate,, etc,,, to be 

used during than Pilot -Scale Teat, and the time 

necessary to conduct and, complete the Pilot-Scale 

Test. At the conclusion of the Pilot-Scale Test,, 

the Respondents shall present the results 

developed during ths Pilot-scale Test to the U.S. 

EPA, and WDNR. The underlying data developed 

during the Pilot-Scale Test shall be made 

available to the U.S., EPA and. WDHR within 30 days 

of the request of the II,!:!,. EPA or WDNR. 

The Respondents shall conduct sampling to 

characterize the physical parameters of tlfta sub- 

; . soils in the iNton-Contiguous Fill Area, including,, 

but not limited to,, moisture content, grain siii:e 

distribution,, and total organic carbon. As part 

of the Pilot-Scale Test Work Plan,, Respondents: 

shall include the saiipling plan necessary to 

conduct this sampling, 

2 „ Full-scale I!:!¥E jjiiplenentation 

After, the coiipletion of the Pilot-Scale Test,, the 

IMinrpondents lEibnill iiiKplemwnt the full-scale IS¥E 

of the sub-moils in the Mpn

•Feasibility Twit" 1 ) „ The Feasibility Test shall 

bin subject to tha supervision and review of thin 

U, .S., EPA, in consultation with WDNR. The 

objective o>f tha Feasibility Test is to determine 

the optimum uuwmtm of putrients to be added to 

tlcMii siuilbr soils in order to promote than natural 

microbial activities ,, without deer eas ing the 

effiiiictiviniiwiiiiii of tte reiio'ptl of the VOCs by XSVE. 

At tlui. concluinioini of the Feasibility Test period.,, 

tte Baspondeiriits shall present the results of this 

study to thin U.S., EPA' and WDNR in a written 

report. Tte data danvslopad during the 

HMiiiiMiiiLbilJ, (::•!!' Tiiwt slb|all te :iu

the Respondent* shall notify the U.S. EPA and 

HOUR of such Interruption or cessation of 

of Miiration after learning thereof., Such 

notification may initially be given orally, but 

mast be confirmed in writing within five days 

after the data on which tha oral notification iisi 

given,, The Respondents shall notify the U.S.. EPA 

and wan, of the nature and causa of the 

interruption or cassation of operation,, as wall 

as tha estiaated length of time before the 

operation of tha ISVB system will, be resumed. 

Recipients shall propose an operation and 

Maintananca (Oil) schadule, aa dcitscribed in Tanilc 

lI.Bo r to liiinit syiiitaiin interruptions. Any 

deviations froiin tha ischdidule which result in 

syatam internxptions lallwll. ba raportad aa 

describad above., In all eamas where there is an 

v f intarruption or cassation in tha oparation of the 

ISYE systemi!, whether dua to nechanical failure, 

huiian error, or to parfornii routine laiaintananoe,, 

as wall aa any other reason, tha Respondents 

shall repair„ complete maintenance, or take any 

other etspa iMicaemary to expaditiously rasiaia the 

oparation of the IBM'E system. 

5 „ femination of Operation 

The Riiitspondants shall opare.te the IS¥E systai 

until rsceipt of written approval tram E'PA for 

shutdoirn,, aftar dtuionstration that tha soil^gas 

Cleanup Standards deterinLined under Section I „ I.E., 

are mat, Upon adhiaving the soil-gas Cleanup 

Standards,, Reepondants shall submit to U.S. EPA 

and HDilt for review and approval by U..S, EFA, in 

conaultation with WD:RIP a Draft Rinadial Action 

Report containing the data establishing that tha 

Boil-gas Cleanup Standards have been achieved and 

will ba maintained, Mtspondents shall take 

iEimplas of t:;i:uiii si;iJI:i-»sdils to d.ocu»Biant the 

concentrations of cicmtaiiniiniants. The Respondents 

nay taniinata the operation of the :i:s¥E systeii 

only upon the exprass written approval of the 

U.S., EPAIP in oonsultation with MOPE,, Upon 

complete tannination of tha ISVE syatem, 

Raspondents shall ramove all equipMiimt usiiitd at 

the Site in connaction with the XSV'E systeii,, and 

shall fill and grade all eiictraction points,, 

tranches,, ate,.,, cdnstructed in connection with 

the operation of the I.SVE systan.

I, cleanup 

1 . Establishing Cleanup S tandards for soil-»gas 

A,, AM set forth, in Section H above, Una 

]R(iiiiii;|;>oii]id,i!UTl::in: aha 11 design „ construct ,, operate ,. 

implement and! maintain aim I]i:::jiEi:l»i Vapor 

Extraction cleanup action in the contaminated 

sali-soils of the Non-Contiguous Fill Area, 

Except as provided above in Section H.5., the 

Respondents shall opinrate the ISVE system until 

tlui soil -gas Cleairop Standards specified pursuant 

to paragraph I.,1,,1I!L ,, bnilowr! are mat in tbm 

co«l::aiiiLinatind fflULb-Miioilm „ The iftespondants snail 

use tlla iiiioil-gas anlyiiiiis to nodal grouxndwihtaKr 

leivels and determine how the groundwater ciaaiiraip 

Standards can be achieved ,. 

I:) , 'Ilhiiin Riiitiii:|;Ki:rii:![iiml:::ii! slball f-ally opsrats,, 

maiBtaln, and iiniplttiiieimt tbe :i:S¥E systm for at 

isaiiiit two (2) years based on the design 

paraLmeteriii: approved Iby U,.j9:, EP1. after the Pilotiiicale 

Test.. Witbiini nixnstty (90) days after the 

two year aitm:hrarsa:nr of tlte coaencament of fullscale 

opNsratioink of the ISYE system,, the 

:R«inipoi:i4ents sluill siLiilbnniit to U.S., EPA a state-oftbe-art 

G:iÊ>untemt.er/Sdil RI wl ) or thiiininailltiiir, to provide u .,:;;, EEli vitb 

the data on ipihlcb to base soil-gas Cleanup 

Standards „ TlEyiunxa soil-gajS Cleanup Standards will 

provide aim iriMpator of the level of sub-soil 

cleanup „ The |i:dtel. shall be ussd to dsteonina 

the soil-gas eleanujp standards for vocs in the 

soil-gas necessary to achieve and inaintain 

protective levels of yiOpm in the igro>und«rater,, 

The Groundnrater Cleanup Standards will be set in 

the qround Watejr opiiirabla Unit ROD,, The 

]ResipHi»n«tante shall utiliii:e all of the data 

produced during the Pilot-Scale Test,, the twoyear 

period of full-scale IS¥E operation,, as well 

as all previous! sampling and. nnonitoring 

acctivities to d»veloip tha Model.. The soil-gas 

Cleanup Standards dasignihtad by the U,. S., EP.ht, to 

be dsiteniiined Ibnuined upi;m the Model „ and the 

underlying data dsvelopad in connection with the 

fornnation of the Model IF and the cleanup level 

dsitarninad in the Record of Decision for the 

Groundvater Control Operable Unit must be 

achieved in order to elininate source area 

10

contaninant loading to tha aquifer,, and ±B 

intended, to assure that than cleanup Standards for 

tha greundvatur ara met,, 

In tile iisivant that the Respondents can. establish 

to tha satisfaction of the U.S.. EPA, iin. 

consultation with WDMR, that it would ba 

acceptable for Respondents to develop and submit 

the Model to U.S., EPA before the two-year 

anniversary deadline spine if led above, then the 

ReiKpondeinLtisi shall salagiiiit the Model upon receipt 

of written approval from U.S. EPA. At tha time 

the Respondents request approval to submit the 

Model prior to tha tiro-year anniversary deadline„ 

Respondents shall submit to U.S.. EPA and WD1NIR all 

data relied upon by tha Respondents to support 

their belief that such early submission is 

acceptable,, as well as any othar data requested 

\ , thereafter by U.S.. EPlfL, in consultation with 

WDNR. 

C,. Upon reoeipt of the state-of-the-art Model, 

the aiEisuinptioniEi used for tha Model,, tha data 

utilised to develop the Model,, and the resulting 

propdeed soil-gas concentration for each VOC 

or the, aiMitioina 1 saiipling or 

monitoring data arm dioafepirovftd by the U.S. ' 

in consultation vitb WGllllR,, then. the U.S. EPA, in 

consultation with ipn,, may provide the type of 

Modmtl , Una ni.adliiii!.- ipiiiiMUiinii iMiiurni ,, and the r Militant 

soil

temporary shutdown pursuant to Sect ion ]•][. 4.. 

lniadia.tel:ir upon completion of such sampling,, the 

Respondents shall reaotivate the XSVE system, 

Upon, approval, oil! the Field Sampling Plan and QAPP 

by U.S., EPA, in consultation vith WDNR, the 

:Reiiiipat 

of U.S.. KNL or WMr, RaapoHnLdents shall sultadt to 

U.S.. EP'l. and mil tba test results and undarlying 

data compiled in connection vith the saitpllng and 

tainting perfonned pura'uant t.o the Field Saniipling 

Plan,. The Final Soil-nts shall sultnmdt for 

approval by U,,S» m, in consultation vith WMRt, 

a nnonitoring prograB inclwllingi; numiaer of veils, 

well locatioinir samtpling parniaters,, sampling 

frequency,, and duration of samp ling, 

The RD/RA for the Soiurce Control Operable Unit to be implananted 

by the Reapondants at the Hiukego Sanitary Landfill shall 

consist of four tamtam., The Eeaipondents shall perform, the 

folloving tasks and eiacaents as described more fully herein: 

Task I:: KD/Ra Worlc Plan 

A, Site Access 

B,, Monitoring and Sampling Plans 

C, Health lit Safety Plan 

D, Pilot Scale Test Work Plan 

E, Quality Assurance Proj ect Plan 

F, Potential Hateria I Borrow Sources Riaiport 

13

Task: II: Remedial Design Project Plans 

A., Design Plans and SpecifIcations 

B., operation and Maintenance Plan 

c., construction schedule 

D,. Borrow Source Report:: 

E. construction Quality Assurance Plan 

Task III: Rsinundial Action Preparation and Construction 

A., Precoiistruction Inspection and Meeting 

l-i „ Pre-final Inspection 

c.. Final Inspect ion 

Task IV:: Reports and 

A . 

B, 

C. 

Progress Reports 

Notification of 

Action Report 

Final Report 

completion of Remedial 

The ResipHondents shall prspare and submit to the U.S. EPA, and thin 

liiniR,, for approval by if. .S. EP1IL, in eociuiiuiltation with the Win, 

an RD/RA Work Plan vndch sleiAll, docunnant the overall inianagnent 

isi tratagy for per f oraing tha design ,, cone tract ion , operation , 

luintnmance and mtmitoring of th,e Raiwndial Action. The plan 

shall docmnint tbe riiiniiponiiilbilJ.ty and authority of all 

o)]i:ganiii:ations aiihd k:ay personnel iiwolvad with tha 

liiiEplaiiMntation. The Work Plan shall also inolude a description 

of gualificatione of key 1 personnel directing the RO/EA, 

including contractor psrsomnel „ The Respondents shall siuiJbstit a 

Draft RD/RA Work Plan accoizding to the schedule identified under 

Section IV of this iSiOW, The Respondents shall submit a Final 

RD/RA Work: Plan ijcK:orporating U.S.. EPA's comments on the Draft 

Work Plan according to the schedule identified in Section IV,, 

Site access agrstsasents rwpired to iinplement the Eeisedial 

Action shall be obtained by the Resipo>ndents as required in 

the Order prior to initiation of the Resvsdial. Action or 

additional studies. Site acciuis shall e:»±end for the 

duration of the cleanup and include allowances for all 

operation and »aaintenance considerations in accordance with 

the Order. The RD/RA Work Plan shall include a plan for 

gaining access to those portions of the site which the 

Respondents do not currently own, 

14

B • Hon ii 1*ifiir 'JiiliiStL jUliilL jILiiiHliiLiLDiiiL 

Respondents shall submit detailed monitoring and sampling 

plants describing the type, frequency, amid schedule' for 

suipling and monitoring of th§ remedial action for the site., 

The Bonitoring and iii uipiing plans shall address groundvater 

and landfill gain monitoring, and how tyrannical requirements 

of. applicable permits , ami compliance with. vmstavatsr 

(leacnate) , gam and air eiiimsion iiiiitm will b« itisit for tltut 

site.. At a pixiLimuiki, tlw itoBitoriBg and isuipling prDiprami 

plans shall addrass saiaplia collectioim and analyssiii miathiads ,, 

analytical paraiunttars , f:riaq[iia!:ricyr ducration, and typia of 

nonitoring amid aaiapling nai:pir(Eitd to dnioBstratdii that thim 

Rmedial, Action maiata and :nia:JL;ntaina tllut Claaintup Standards and 

othar recpireigiiants for oparation of the ramadial actions at 

,( . tha site as specified in Section n of this SOW., 

The Respondents shall subinit to U..S, EIA and WDil for comaent 

a Health, and Safaty Plan to address the activities to ba 

piarf ormad at tha facility to conduct tha Raiaiadial Dwnigri and 

iimplamant the Rawitdial Action(s)i „ Thm lealth and Safaty Plan 

shall, ha designed to pr0tact oiiMiiita pamionnel and area 

inasMants fron physical , clttmical and all oth.ar haieards posa«d 

by this Ranadial Action. The Raspoindents may modify tna 

Health and Safety Plan daweloped for tile KI/FS to addrass tha 

activities to be perforniiad at th

described in Sect ion XX. R.I of this SOW,, the Respondents 

shall submit a draft Mark plaint for the ISVE pilot test to 

U.S.. EPA for reyiaw and approval, lint consultation with ram. 

Upon receipt of coniiiMiiniliili omt the X8VB' work, plan, the 

RMipointiiaats shall iaoorpprat* tha coiiiinaants and raaubait tha 

doowant for approval to f, !!i , EFA, in eonraltation with, TOME. 

Following approval of tba work plaint for tha pilot test, tha 

Ea«pondents shall conduct thai pilot phase of the ISVE. 

within sixty days after completion of that pilot tuist, tha 

Ratapondoitintta shall sulHiiiiiit a drift tiif]|!hia«eBta.tion plan for foil 

scale opaitratioint of tha liilPEIi; syriittaia,, am discussoitd in. S«i)tetioint 

II. H.l of this SOW,, to U.S. m for raviaw and approval, in 

cointsultation with WSMR« Fallowing approval of thia liiiVi 

inplaaentiiition plan, tha Reapondants shall incorporate tha 

contents into the de«idgn plans for approval to U..S, EPJIli,, in ,, | 

consultation with WDNR. '"'" 

h QM'P shall ba smtadttad as part: of tha ED/IEIA Work Plann to 

cover saiiplimtf a:nd analpii:La prbceduras amtd tadtoiqaes for 

saiplaits collatatad unter the iESiniipling ailudl Analysiiii Flan abiwa, 

The Qiiun* 1 shall ba oomts:L|»tatinit with thw rauciiuirinaants of the 

U.S., EPill Contract Lab Frograia (CLI=']i for laboratories proposaid 

outsida the CLP,. At a iiininm ., the QAFP shall includdit the 

following: 

o Statamnuant of Purpose 

o Pro j (Eiict Dascr ipt ion 

o Project Organization and IRasponsibility 

o Sunpling Procedures and Objectives 

o Sample custody and Doonient Control x / 

o Calibration Procaduraa amid Freguency 

o iyriAlytical Prooad'uinnts , Data Raduotion „ Validation , 

Asaessnan t ,, and Rairarting 

o Internal Quality Control Chacics and Frequency 

o Perf onotanca Systmt Charles and Frequency 

o Preventive Maintenance Procedures and Frequency 

o Datta Pr acision „ Accuracy and Coiinplet eness Assasmtant 

Procaduitrea 

o Corractiva Action 

o Quality Assurance Raporting 

:rhe Respondents shall prapare and subintit to the U.S. Q'A and the 

HOUR,, for approval Iby U.S.. EPilW in consultation with WOIR,, a 

Haterial Borriw Source Report which will identify potential soil 

material sources for cap construction. This report will 

identify any physical testing that has been performed on tha 

soils as veil as any potentiai problems associated with the use

o£ the borrow 

The Respondents shall prepare and submit to the U.S. EPA, and the 

WDNR, for approval by U.S. En,, in consultation with the m.,F 

draft and final construction pianist and specifications to 

implement the Remedial Actions for this Source Control Operable 

Unit at the Facility as required toy the 1OD aind SOW,, 

A. 

The BAspondant B isihall dinvelop clamr and coiiprehans ive dnuii ign 

plans and spacif Icationa vliidtn include but arm not linidteii to 

the £olloving: 

1 .. Discussion o:l! the desi«pn stratagY and tha design basis „ 

iBcluding; 

a. Coiwpliance with, all applicable or relevant and 

appropriate r '•quirownts as inotind her sin ;; airid 

b ., H iniai .zation of envi ronmental and public h IIMII Jl.tJ:i 

impacts,, 

2,. Discussion of the tachnical factors of iniportanca including: 

a, Uss of cinrantlY aocaptsd, «iirir:ILroimental control 

neasures and 

b,, The iinpliEuinentation of the design ; and 

c „ Usa of current ly acceptable coma truct ion pract icas 

and tachnlques,. 

3 ,. Description of assuMiEitions »Dtad.s and detailed justification of 

tlEitssa assuiiEtptions; 

4 ,, Discussion of tlui pitwsibla smitrcas of arror and ref arancss to 

possible oparat ion and ilnaiiciitananca probliEimn ;: 

5, Dstailad drawings of tlis pnafiosed design; 

6 ,, Tables listing eqniiipiiant and specif icat ions ,; 

7 „ Tables giving iiaterial balances ;; 

8 „ Appendices including ; 

a. Sample calculations (one encniiple presentaid and 

explained clearly for aignificinnt or unii:|[ue design 

17

calculations); 

b, Derivation of equations essential to understanding 

the design plans and specificatioiM? and 

c. Results of laboratory or field tests 

The Respondents shall maait :|regularly with U.S. EVA to discuss 

design issues,, The design and •pacifications shall be submitted 

to the U.S., EPA and the WDHR in phases as described below. 

I,. Preliminary Design 

The Respondents shall submit the Preliminary Design when 

the design effort is approximately 95% complete 

according to the schedule set forth in Sedation IV,, At |(l |, 

this stage,, the Respondents shall have field verified 

the existing conditions of the Site, The Preliiiinary 

Design sihali reflect a level of effort: sucn that tJInint 

technical xÊiicpiremsnts iiiLnd spmcif:!.cation 1-1 of than project 

have been adUiressed and out lined so that they nay be 

reviewed to deteriiine if the IPlnal Design will pravide 

an operable and usable Einwitdial Action,. supporting data 

and dconiinentation sball be prcnridmtd vith the daitsign 

documintnts defining the functional aspects of tine 

piragraiiBi. The pipiniiainaxy construct ion drmdngs 

siibnniitted by the Respondsnts shall r«ftflect organixation 

and: clarity. The Respondents shall include with their 

preliBinaxy suibnission, design calculations refleorting 

the suiiue percentage of coiipletioin as the designs they 

support., 

After review of the preliminary submission by U.S. EFilL, *-•'' 

the Respondents shall swiicute the reguired revisions and 

submit the final design (100% completion) with 

reproducible dnnwings and specif ications., 

The Prelimdnary Design subiniittal, shall, also consist of 

the Design Plans and Specifications„ operation and 

liaintenance Planr Capital alnd Operation and Maintenance 

cost Estimate,, Pro j eet Schedule, and Construct loin 

Quality AssniLraiice Flan. The guality of the dsasign 

documents should be much tha.t the iRAiiiipondents would be 

able to incJUnde theis in a bid package and invite 

contractors to submit bids for the construction project. 

:n:,. Final Design 

The Respondents shall submit the Final Design according 

to the scted'uile< under jSioiction :i:¥. The Final Dttsign 

submittal coniiiiists of the final Design Plans and 

Specifications (:i.00% ccnplets),, the Respondents' Final

construction Cost Estimate , the Final, operation and 

Maintenance Flan , Construction Quality Assurance Plan „ 

and Final Pro j act Sdtadule , 

Ill . Additional studies 

The Remedial. Action may require additional studies to 

supplement the liLvailabliii technical data. U.S. EPA Hay* 

at its discretion,, require any Bach additional studies. 

Included in these additional studies would .be a d.es:k|ra 

tor the "Feasibility Test 1 " 1 described in Section II .ill 

of this SOW, For any such stadias required,, the 

Easpondants shall :l! tinndab all saitrvicmts ,, including field 

work as required,, matusirials ,, supplies! plant,, later, 

equipment,, invastigations , studies and suparintandenee, 

\s ,/ If additicmal studiein ara raquirad,, there shall bait an 

initial maeting of all principal personnel involved in 

the devalopimant of the i-itudias to discuss objectives,, 

resources „ coMui:inicatio:n channels „ role of personnel 

involved and orientation of the site,, etc., 'ins :l!inal 

report generated toy tbe Respondents shall Include all 

data coileoted during the studies and a seminary of tbe 

results of the studies., 

Respondents shall prepare an Operation and llCoiinteiniance 

Plan to cover both i.mpleitanti!i.tion and long term inaintenance 

of the Raiiedial Action. An Initial Draft Operation and 

lintintenance Plan shall be sulbiiitted sinultaneouslY with the 

Preliminary Design Docuiment submission and the Final 

Operation and Haintenance Plan with the Final design 

docunients. The plan shall be composed of the following 

elements :: 

Description of normal operation and maintenance (OCIi) ; 

a. Description of tasks for opera t ion ;r 

b,, Description of tasks for maintenance; 

c ., Description of prescritosd treatment or operation 

conditions ; and 

d. Schedule shoving frequency of each OiScII task. 

Description of potential oparating problems; 

a. Description and analysis of potential, oparation 

problns j; 

to. Sources of information regarding problems; and 

19

c . ComoB and/or anticipat md raniindieiii .. 

d, Useful life analysis of sign 1:1! leant components and 

replaceniant costs, 

Description of routine monitoring and laboratory testing^ 

a,, Description of Boiriiitoring tasks;; 

b., Description of required laboratory taints and their 

int erpr e ta t ion ; 

c „ Required Data Collection, Quality Aeeurance Project Plan 

d. Sdtodule of moiniitoring fra>qiutamcY and date, if 

appropriat ,e, vrhan nomiitoring may cease j and 

Description of alternate OUIE; 

a. Sltould aystais fall,, alternate procedluxes to pratvsnt 

undue hazard and reLaaiiiies or threate of raleaaw of 

hazard.ous i-iubstancea ; amid 

corrective Action ,; 

a,. Oiascription of any potantial corractive action to be 

sltouldL any nym taint fail, ; and 

b, Sdbadule for implementing these conrectiva actions j 

Saf

8 ., Records and reporting mechanisms required; 

a,, Daily operating logs; 

lb „ Laboratory records ; 

c« Records for operating costs; 

d „ Mechanism for report Ing emergencies ? 

e. Personnel arid niaintraainice records; and 

f , Monthly '/annual reports to State agencies 

The Respondents shall develop for approval by U.S. EPA a 

Project Schedule for construction and. implementation o:l! the 

Remedial Actions., Respondents shall specif ically identify 

dates for conpletion of the project and major interim 

milestones .. An Initial Project Schedule shall be suiJtaitted 

simultaneously with, the Preliminary Design Docraisnt 

submission and the approved Project Schedule with, the Final 

Des ign Documents ., 

D «• ifiiffiuQiEM. .JiiL!i!i!iM!ît!EiL..l;!>!i!][i!!ill][[ Jii. 

Tbe Respondents shall sukHii.it the final reconnieindations of soil 

borrow sources to the U.S. E'PA and the NDNR, fox apiproval by 

U.S. EPA,, in consultation wltn the MDNR. 

Tbe Respondents shall. suLbmit as part of the preliminary design 

d(E9icuiient a draft Construction Quality Asiirarance Plan ., The 

Respondents shall finalize the Construortion Quality Assurance 

Flan (CQ]!|. Plan)i incorporaiting comtents r

officer and the necessary supporting i.napection staff. 

2. Construction Quality Insurance Personnel Qualifications 

The Respoirklsnts shall set forth the quail.:!!ications of 

the CQA Officer arid supporting inspection persomnel 

shall be presented in the CQ& Flam to deiiioiuiBtrate that 

they posses in the training and axparienca necessary to 

fulfill their identified racponaibllitiaa. 

3„ Inspection Activities 

Respondents shall suainouriise in the CQA Plan the 

observations and teints that will be used to monitor the 

construction and iristallation of the coiwponeinitiii of the 

Remedial Actions, The plan shall include the scope and \ . 

f requency of each type of iniU|iieii;:tioin. Inspeations shall 

verify compliance with all health axid safety procedures,, 

and the e:iTu r iroraiiental reiEpiLireigiuiiints „ 

4„ Sampling BequireiiBtents 

Tbe Respondents shall present in the CQJl Plaitu the 

sampling activities, saiinple s izB t sinineple locations,, 

siiuinple collect ion, methods „ f requeinoy of testing ir 

criteria for acceptance and rejectionrn, and plaints for 

correcting problems as addressed in the project 

specifications,. 

5,, Dociiuientation 

The Respondents shall descxibs in detail in the CQill> Flan 

the reporting reqairiiKiiiNiints for CQi, activities. This ...../ 

shall include such iteiins as daily summary reports,, 

inspection data shststsr problem identification and 

corrective raisiasures reports „ design acceptance reports,, 

and final docuiuEintation. All construction docimentation 

shAll netnitt the :!:iin!j|iiii;ILi!:i!i;[ii(iiinil:::i!; of ch. Ml't !51€ WJIC,, 

Firavisions for the final iiiitorage of all records shall be 

presented in the CQJk Plan.. 

The. Respondents shall construct and implement the Eennsdial 

Actions in accordance with the approved Work; Flan, design,, 

schedule and the CQA Plaiit. The EeApondents shall also implecinent 

the elements of the approved Gpsratiotn and itfointenance Flan and 

conduct the following' meetings and inspections:: 

22

A. EU!Cj!;tlQi^ 

The Respondents shal 1 conduct a precons traction inspect Ion end 

meeting to bin attended by U.S. EPA, the WDNR,, co ntr actor ( HI )„ 

subcontractor (s) , and other identified parties. The purpose of 

the meeting shall be to;: 

:i. „ Review methods for documenting and reporting inspection 

data y 

2 ,, Review methods for distributing and staring doemwntin 

and reports; 

:•) , Rev lew work area security and saf ety protocol ? 

^ , 4 „ Discuss any appropriate modif icatione of the CQ& Plan to 

ensure that sits-"specific considerations are addresntedir 

and 

5. Conduot a site walk-around to verify that the design 

criteria ,, plans , and speoiif icat Ions are understood and 

to review material and ecpipiiient storage loeat ions „ 

The preconiBttruoition inspection and meeting shall, be doomented 

by a designated person and minutes shall be tranenitted to all 

par ties present as well, as all Riespomdents ., 

Opon prelininary constiraction caiipletion,, the Eespondents shall 

notify U.S, EFA for the purposes of conducting a prefinal 

inspactioa. The prefinal inspection shall consist of a waU:through 

inspection of the entire project site. The inspection 

is to determine whether the construoition is complete and 

consistent with the oontraot: docunents and the U.S.. EPh approved 

Reimedi a ,1 Act ion .. Any outstanding , incoioiiple te ,, or 1 ncorrsict 

construction items discovered during the inspection shall be 

identified , noted and rectified by tltw Respc»nd,ents . 

Additionally, treatment equipment shall be operationally tested 

by the Respondents ,. The Respondents shall certify that the 

equipment has performed , and will function as designed, to meet 

the specif icat ions . The :Restpondents shall, correct any 

deficiencies and initiate retesting. The Respondents shall 

submit a Prefinal Inspection Reiport which shall document all 

outst and! ng „ incompleite (, or inoiorrect cons truction it ens , 

actions retguired to resolve iteinis, completion date for these 

items, and which shall set a date for final inspection. 

c. 

Upon completion of any outstanding construction i teniis , the 

Respondents shall notify EFA for the purposes of conducting a 

23

final inspect ion,. 'Tha f trail iiniiiifiNinction shall consist. of a walkthrough 

inspection o£ the project sit®.. Tha Prefinal inspection 

Report shall ba usiiid am a chl[MiL..iSitlilLl!iSlllJiilSitl!Liii'[i!l[]li!l' 

Tha Raspondants shall prapara plums „ spacif icatione (, and raports 

as sat forth in Tannks I through Tamk IV to docuiiant tha daaigitiir 

construct ion ,, oparation IP Biiiintiimance „ and iniooitoring of tJ:i,a 

Ranadial Action,. Other doHCUiientation liihall include,, but not ba 

limited to tha following : { , 

Tha Raspondapts shntll, at a ninirah, provlda tha U.S., EPA and 

the HD1HFR with signed, , monthly pn;»n|rass raports dunring tha 

dea ign and cons tract ion phasea amid sand -annual ]pri>ip:asa 

retpNCirts for operation and Biaintaraince activities containing: 

1 „ A description and astiinata of tha parcen taga of the 

RD / HA coimipiatad ; 

2.. Siiuinariaa of ijL|Lil,. findings; 

3. iiiiumnarias of jiiJLI changea made in tha RD/Wi, during the 

raporting period; 

i-iunnniarias of jyjL contacts with rapreaantat ivas of the 

local coiiwmity, public interast groupei or state 

goivarnmiant during the rapcnrting period ;: 

5 „ Suiimari ea of iJUL proiblamiii or potential problainuii 

encounterad diuiring the raporting period; 

4, 

6 , Actions baing taken to rectify problans ; 

7, Changas in personnel duiring the raporting period; 

til. Projected work; for the next raporting period;; and 

9. Copies of daily retports,, inspection raports,, 

laboratory /monitoring data,, etc. 

1 ., Within 60 days of the Final Inspact ion tha 

shall submiit a Draft Rantadial Action Iinplaiientation 

24

Ifleport to tha U.S. EPA and WD1R,, The Report shall 

document that the project is consistent with the design 

specifications ,, and that the Remedial. Action is 

perf orning adequately » The Report shall include , but 

not be limited to the following eLraents;: 

a., Synopsis of the Ranadial Action and 

certif ication of the design and constructioB ; 

b. Explanation of any nodificationiii to the plan 

and why thesa were neeaasaxy for the project; 

c, Listing of tJhe teclemical, raicpireniiEmts and 

apeci f icationa for j udging the functioning of 

the Remedial Action and also explaining any 

v , modification to thase technical :i:vEsquirietwmts 

and specif icatioiu ; 

d» Raaults of all site monitor ing ; and 

a.. Eacplanation of tha operation and :uintuanoe 

(inclwIiiiLg •onitoring) to l>i;i undertaltan at tha 

Site, 

Tha Respondent!;! shall suhoinit a Final Raiiniedial Action Report 

30 days aftar receiving U,S,, Eli'A and WDVR comments on the 

Draft Reiinadial Action :i::in|il«rai:iTl::ation Report,. The Fiinal 

R,enadial Action RapHiart jsball include a sttiiiomary of all 

constriuction activities , rapcirts IP nodif icat ions , and 

operation specifications neoesaary for 0 i M as deaoribaid 

v..y abova under the Notification of CoiiKpletion section,, 

IV. 

A suiiiDiiiary of the infonnaticn raporting requixwinents and 

deadlines for subniittals of plans and other docuiiants contained 

in the RD/RA SOW is presented below. Fo>r. each, reicpnired document 

or submission listed below,, the Rainpondenta stall subnidt 4 

copies t.o U .,!•!,. Eli'A,, and 2 copies to wraiR,. Additional 

requirements for document siibiniisaicns uy be identified by U .,!•!,. 

during the life of the project.. 

1. Draft KD/1E1A Work Plan — » 45 days after the date of the 

Adiniinistrative Order shall, include:: 

A.. Draft I :;;',']•! Pilot Test Work Plan 

B. Draft Health JSi Safety Plan 

C.. Draft Quality Assurance Project Plan 

i:> ,, Potent ial i:atar ial Borrow Sources Report

2,. Final Remedial Design work Flan — • 30 days after receipt of 

U,,s,. EPA'a comuimts on Draft RD/RA Work Plum 

A,, Final XSVE Pilot Test Work Plan 

B. Final Health i;Miiction —— 15 days after notification of 

construction cospletion 

7 .. Priii -final Inspection Rsport —— 1.5 days after Prm-f inal 

Inspection 

8 . Final. Inspection —— 15 days after Pre-f inal Inspectt ion 

Report: 

9 ,. Construction Compilation. Report —— 15 days after Final. 

I inspection 

10,, ISVE Pilot Scale Test 

a. Draft Pilot Scale Test Report for ISYE —— 45 days 

after completion of pilot scale test activities 

26

. Final Pilot Scale Test Report for ISVE —— 30 days 

after receipt of U.S.. EPA comments on Draft Pilot 

Scale Test Report 

:i.:i.,, ISVE Design Phase 

a. ISVE Draft Implementation Plan —— 60 days after 

U.S. EPA approval, of Final Pilot Scale Test Report 

for ISVE 

fo. ISVE Final Iiipileikentation Plan —— 30 days after 

U.S.. EPA contents on ISVE Preliminary Design 

1.2. Notification of completion of Remedial Action —— Upon 

achievement of Cleanup Standards for any of the components 

of the remedial action as specified in Section. II of this 

SOW 

13. Draft Remedial Action Report —— 60 days after Final 

Inspection 

1.4.. Final Remedial Act ion Report —•••• 30 days after receipt of 

U.S., EPA CQiimients on the Draft Remedial Action Report 

15.. I!:i¥E Feasibility Test Tecluiical Meinorandmn —— 6 months 

after initiating the fall-scale ISVE system 

1.6. Progress Reports for Tasks I through IV —— Monthly 

17.. Progress Reports During 0 % M —- Semi •••Annually 

27

ATTACHMENTS 

RECORD OF DECISION

Eiia MIIUIIMII lud L0«»tio«n:i: 

ID cnr 

iiiiunenio INIPIIIHIXIL JkBffHai!tx*B fen 

icfiom nimiiei ceiiinoL 'oraiaiu man 

mm :ni:i:iiiii]ii:intiiH:i aattaox 

Mttinkditgo Sanitary Landfill 

lltaiiiilcago ,, Wisconsin 

-„...„ liitmtniMiLt of Bin nils and varposss 

Ttols decision docuaant presents thai selected roaedial action for 

the Muskego Sanitary Landfill locatad in lAwkaô , wiaconsin. "ha 

dacision has bsinn da'wlopind in aceardanoa with tha- 

EnviroaMntal Rsiiipointsini! coppwwation, and Liability Act 

as HHiiBiiind by tllui Siiipncfiuunud jyiiMivdiiMiiinitiii and :R i;i!i!it::i(:)i:i:i Act 

(SARA), and 'in aceerdanea with tha National Oil and Bafcardoaa 

Stiitbiiitaiiiica contingmey Plan (MCI?) . Tlllmi daoiaion is baiiiad on tha 

Ad^niatrativa Racord for tills iiiltniu Tha attaehad indax idantlfia* 

tbint itmii that coiinpriiiiKiii tha AdainUtratiya Racord, upon whieh tha 

iiMiilniictiori of th.a raiMiidial action la Ibainad,, 

.lyiiaiiitsiininaint of ilMii eitaii . . 

Actual or thraatanad ralaaaaa of hacardoiw aubatancas fro* this 

sit a, if not addraaaad by iaplaMnting tha raaponsa action aalactad 

in thia Racord of Dacision (ROD) , nay pras

s t -in t in 

f«nc«»; 

cap installation ovinr the portions of the site damad 

naeasHiry in the EDO according to W iscons in Admini strativa 

Coda m 504 stuidardin j 

Installation or upgrada of landfill laacaata control syurbwiui 

a (:: the mite; 

Acrtivs iinmyilll, giiinii control anEil Boiiiitoring for the site; 

:i:n-Sltu,i;:i::n-p;i,iiiC(in| liioil V-mipour tuitraotion at portions of thin 

H'OTi-"[::i::»i[|[t.:l.'!i|ii]i(:!»i;Mii Fill ttwn o:l! ttnm sitia; 

Cirircrancll wintiikr iiM»itin:i!ntg of iiNiilincttiiiiil iniidLiniting monitoring and 

prlvatint vinils to te diiitinmndxMiuEil (Etariung thm rmadial dasigmi; amd 

amid ]lCnti]n±.«nainioa of all synitmiii .. 

Than staitin of WiiKconiniint comiouirnii with thm sialactad rmsdy, Tba 

latter of coaouiinrwnioai is attaohad to tJte Raoord of Decision (ROD) 

packagin.. 

isialtactind rmin«dY is p:rat

1:1:11- UIIOIIL uniiiraxriri iiii:iiiuo!io:]i 

jiiiuniii Linn'XLL nixn: 

OF 

i, SITE warn Mm LOCATION.. „...,,....,,,..................... i 

:i:x,, SITE HISTORY Km ENFORCEMENT ACTIVITIES. „.,,. „,,.,..,,,, 3 

XXI,, COMMUNITY PARTI dPATION, „ „ „ .. „.,... , ., . .. , , .,.,.., ,..... .... 5 

IV, SCOPE OF INTERIM ACTION SOURCE CONTROL 

•OFERMILE TOUT,.,.,. „ ,,,, „ „ , .., . „ , . „,. ,... . „,. . . ,. „ . . ..,. „ , - „ 6 

V, JEiiXTE CmRACTERISTIC!!!,.., „ , „ „ „ „. „ ,,, ,.. „ „,,,, ,,...,.,. „ „ . , , ,. 7 

VI,. !!ii:i]!«MI,Y OF SITE RISKS,, „ . ,. „ „ „,, „ „ „. ., „ „ , . ,,,, „.,, „ , . , , 15 

VII,, DEBCRXFTIOM OF ALTERNATIVES. . ,. ., . ,., . .. ,. -.. ,.... ••., . • . 17 

VXXI. SlimiAY OF €€iHEiy%J!kJTX¥E jyUJJYSXS OF ALTERNATIVES.,,. 25 

\,..J IX. TEE SELECTED REMEDY,,. .. . .. . .. . . ., . , ,, . . . . . , . . . . . . . ., . . ,. 31 

X. STM'UTORY DlilTniJ'IIMATICWS . ,,,, „ . ,, „ „ „ „. „ ,, „ „ . , „ „.., „ „ , „ , 33 

xx „ RESirararraiifESiSi IEIIIWPAY,. ., „ „.,. „ „,,.,,.,,.. „. „ „,..,., (Attached.;! 

XXX. MlilllXIEiTRM'X^l!! RECORD.. „.,, „,..,,. . .. „ , ,. ,.,,..,.,.,.,.,., Appendix A

FIGURE o 

FIGURE I 

FIGURE 2 

FIGURE 3 

FIGURE 4 

FIGURE 5 

FIGURE 6 

FIGURE 7 

FIGURE B 

FIGURE 9 

TMILE 1 

'IMBLE 2 

3 

TilkBLE 4 

IIKPIII11IEW i,;iuii;i:i:ii p :]i:]LLi mim 

SITE LOCATION Xiy» 

SITE HIP 

WASTE KMMiOilER OF WISCONSIN, INC, PROPERTY 

WATER TABLE MM' 1 

sj^raiiK LIXATIOHS 

JiiJklFLIlG LDCM'IOlJSt 

LOCM'IOHS 

LOCM'IOMS 

JUIPLIMG LOCATIONS (FlPtrATE WELLS) 

SEIIIIHEER SMIPLE LOClikTIONS 

'' 

:i(i'i]U!!i]ii:i!!i;K:i iiiinii uynonu, IKTE 

GROUP RESULTS. ROCI1DS 1 MID 2 

1IR 140 MID E1E"A KL EXCEEOMICES FOE 

4,:: CAPPING-, LANDFILL Gi'i.lii i LEIIiCI-llTE 

, AMD IM--IEIITU ntEMKeiMT OF THE NOil- 

CO1TIGUOUS FILL .MEM! 

COST SUIffittHY M,TERMM':i:¥E 4 FASIBILITY STCIDY

OF KUEDXIII juwnnnkTXVB BIUBCTXOH 

:i:inn:oii jtcrxav eointa!! covntoL opittBLE TOUT 

utmtXLL sxa 

lira sn i;io, 

:i:« BITE KIIJIOE xsm LOCXTXOV 

The Jlfuskego Sanitary Landfill Superfund site occupies approxiiialbiEily 

56 acres north; of State Highway 24 (Janesvilla Road), and east of 

Crowbar Road in tha City of Muskego, Waukesha County, Wisconsin,. 

The site is located in Southeastern Hiscdnsin approximately fifteen 

miles southwest of the City of Milwaukee (see Figure 0) , More 

specifically tha isite isi southweiiit of the urbanized portions of 

the City of Huskeqro by rouqhly three miles., 'Ilium Site includes 

three areas known as th'a '"Old Fill Area 11 ",; the "'Southeast Fill Anna" 

and the in Hon-">Co;iiitiguous Fill Arma 1 " (see Figure 1) „ The site also 

includes wastewater ponds associated with a former rendering plant 

complex: (the IM i!Urii«iina:iiE: plant 1 " 1 ), Those ponds are located east of the 

Nan -Con tiguous Fill. Area, Portions of the property associated with 

the jyiiamaiic plant are also included in the Old and Southeast Fill 

Area boundaries. Directly north of the site is the stoneridge 

Landfill,, a closed and covered solid waste lanidfill, that is not 

part of the Superfund site., Land use to the waet of the site is 

for aand and gravel excavation. To the south, east and north of 

the site, the land use is a combination of residential and 

agricultural,. The area surrounding the Site is mend.-rural, but is 

zoned to permit further development in the future, Sefveral hcnes 

and businesses are in the vicinity of the property, and many ware 

once served by individual private water supply wells.. In the later 

19 i-i cis,, city water mains Were extended into the araa anEll several 

homes and businesses were connected,. currently, two residences 

southeast of the site are not connected to public water, These 

residences are indicated in Figure 1. 

The Musilcego Sanitary Landfill 'Site is situated on unconsolidated 

deposits that are up to 300 feet thick and are generally conprised 

of glacial till, outwash|p and lacustrine deposits,. Site 

invastigative infonnation and private well boring logs shew layers

FIGURE 0 

SITE "iftr 

LOCATION ' * 

SITE LOCATION MAP 

SCALE IN MILES;; 

WhitiBfish Bay..-'' 

Shorewood 

SilTE .LOCATION 

8 16 north

Not Connected 

To Puibliic Walter 

Potential 

Expansion 

Fill Area 

OLD FILL 

AREA 

SOUTH 

EAST 

FILL 

AREA 

Figure 1 

l..oQ»lkm of former 

Plisurili 

t.a«ora 

INIon«Contiguous 

Fill Area 

Former 

Rendering Pliant [""] 

SiteMap 

Mluiskego> Sanitary Landfill 

IU1 ILII s Ike qo/Wise an si n

of fine-grained material (till and lacustrine deposits) south a:nd 

east of the site to depths of about 70 to 200 feet and coarse 

grained material (outwash) below the till to depths of about 200 to 

30Q feet below land surface. 

There are three principal sources of ground water in Waukesha 

County, In order of depth below the land surface they are; sand 

and gravel within the glacial drift,, Niagara dolomite, and an 

underlying sandstone. In the Muskego area,, a majority of the 

private wells are finished in the thick: sand and gravel deposits.. 

The water table for this shallow aquifer is approximately 20 to 40 

feet deep and has produced yields as high as 2,, 000 gal/min. The 

depth of the upper glacial drift is about 300 feet which 

corresponds to the aquifer thickness. The ground water 

classification for this aquifer is Class IIA (i.e. , is used for 

human consumption purposes and is not restricted). 

In the Huskego area, ground water flow in the water table shallow 

aquifer is generally in an easterly to southeasterly direction., 

This is similar to the ground water flow at the site,, which has two 

flow paths. The first is in a north to south direction under the 

eastern portion of the Old Fill Area where the basal clay unit 

separates the sand and gravel unit from the landfill.., The second 

flow path is generally to the southeast under the Southeast and 

Non-Contiguous Fill Areas., 

The site is located within the Fox River watershed,, just south of 

a local surface divide.. There are numerous wetlands in the area 

and the closest off site inteniittent stream is located about 

three-quarters of a mile to the southeast., None of the wetlands 

are located within the site boundaries, Surface drainage at the 

site is divided between flow to the wetlands and the interiiittent 

strewn to the southeast,, Surface water runoff from the Old Fill 

Area is to the ditch along Crowbar Road or to the southeast through 

a small swale., The western half of the Southeast Fill Area also 

drains to this swale which eventually discharges to a small, wetland 

north of an abandoned railroad right-of-way. Runoff from the 

neighboring Anaiiax property,, the Non-Contiguous Fill Area,, 

Stoneridge Landfill, and the eastern half of the Southeast Fill 

Area is toward the ditch along the service road to a small wetland 

southeast of the site and then through a culvert under Highway 24 

to a larger wetland. The site is located within the 100 year 

floodplain.

:i::x. isixn: HXMORY MID i!::i(i:i!'i:)i;!i:!:i!:iii:]!!:isi']i' ACCXVXTXES 

A. SifcftJlilfcfiQC 

The 3 8 -acre Old Fill Area accepted material from the 

niid-19!:iOs until. 1977., An unknown amount of waste oils, 

paint products!, and other wastes were deposited into the Old 

Fill Area during this time,, The Southeast Fill Area which 

covers about 16 acres ,, accepted only municipal wastes during 

its operation from 1977 to :i.98l, The Non-Contiguous Fill 

Area includes a drum trench, north and south reJE'use 

trenches,, and an L-shaped fill area, This Non-Contiguous 

Fill Area occupies approximately 4.2 acres northeast of the 

Old Fill Area,, Eased on information from workers employed 

during operation of the landfill! the L-shaped Fill Area is 

expected to contain waste similar to that in the Old Fill 

Area. 

In response to deteriorating water quality at on-site ground 

water monitoring wells,, sampling of off site private water 

supply wells was conducted in 191:12 and 191:14 by the site 

operator, Waste Management of Wisconsin,, Inc. (WMWI) , and 

Wisconsin Department of Matural Resources (TONE) ,. The 

results of these analyses indicated that several of the 

private wells may have been impacted by a source of 

contamination, which could have been the landfill and /or the 

Ansiiiax wastewater lagoons , The resu Its were based on 

elevated indicator parameters , The tea t f or indicator 

parameters is a preliminary test completed to show signs of 

ground water contamination. In 1986 public water was 

extended to this area and private wells in the area were 

connected to this supply,, The site was evaluated and ranked 

by the United States Eiwironmental. Protection Agency (U „ s . 

EPA) and placed on the National Priorities List (NPL) on 

S epteiiiiiiber 1 8 „ 1 Si 8 5 . 

In 1985,, a partial methane extraction system was installed 

by WMWI along the western portion of the Old Fill Area to 

alleviate methane gas migration that was noted at the site,, 

The extracted gas is destroyed through flaring. 

B * JEitJELISEJEUEitKlLiSbiiL 

During preparation of a portion of the Phase I Stoneridge 

Landfill area called Module III, which is due east of the 

]>l'o>n-

During the Remedial Investigation (HI) , a trench was 

discovered in a portion of the Non-Contiguous Fill .Area that 

contained, a large concentration of 55•••gallon drains., The 

boiundary of this Drum Trench area was furthsx' defined using 

a nagnetameter met el detector. Through a Unilateral 

Administrative Order issued on January 4, 1991, U.S. EPA 

ordered! Wl«l to rscimovsi the drums and su:i:xoi;inding 

contamiiiiated s oils, WlfWIT proceeded to conduct .this removal 

under U.S. EPA's supervision., Eiraavation of the drum trench 

began in April 1991 and was completed in May 1991. A total 

of 989 drams were excavated along with approximately 2,, 500 

cubic yards of surrounding contaminated soil. The Is oils 

were excavated down to a depth of approximately 25 feet 

below tile original surf ace elevation until ground water was 

encountered. 

The drum trench wain re-filled to a grade that allowed 

drainage away fron the area,. No final soil cleanup levels 

were established for this removal action since the 

excavation reached ground water.. Soil samples were taken in 

areas above the water table at the base of the trench, and 

contULination was found to be remaining,, This remaining 

contamination will be addressed in this Interim Action 

Source control Operable Unit (SCOU) Record of Decision 

(ROD), 

Below is a list of contaminants that were found from a 

representative sample of liquid collected from excavated 

drums on the staging pad on April 17,, 1991. The list below 

shows contaminants that were above detection limits., The 

detection limits for all contaminants were elevated due to 

sample concentrations. 

Benzene Chloroform Ethyl Benzene 

Toluene Trichloroethene Methylene Chloride 

Some of the other contaminants that were sampled for and 

found but not quantified because of elsrvatsd detection 

limits include;r vinyl chloride„ tettrachloroethene„ l,, 2dichloroethaner 

and 1IP1-dichloroethene. Contaninants found 

within the d:ranm trench are contaminants that are present in 

monitoring wells at the Site., 

The liquids; from the excavated druiui were separated, bulked,, 

and disposed of through either a fuels blending program or 

incineration, The soils were disposed of in a hazardous 

waste cell unit at the Calumet Indlustrial Design Landfill 

(CID) in Calumet City, XL, Solldiii; remaining in the drums 

were tested! bulked and accepted at a fuels blending 

facility in April of 1992 for repackaging., The solids 

totaled approximately 15 cubic yards and were then sent to a

£ ac'il ity in Texas for incineration ,. The disposal procedures 

occurred from October 1991 through April 1992. 

C. Baffillili^^ 

On September I?/ 1987 , wiiwi "signed an Administrative Order 

on Consent with U.S., EPA to conduct a Remedial 

Investigation/Peas Ibility Study (RX/FS ) £ or the site , The 

purposst of the RI is to idientif y sources of contamination 

and to characterize the contamination at the site. The RI 

is currently not finalized but ongoing results have been 

periodically suamarized in Technical Memoranda. The Final 

RI and Baseline Risk Assessment for the site have not been 

completed „ although site investigation work was completed in 

September 19!iil, Since the Baseline Risk Assessment has not 

been finalized, this Operable Unit will be considered an 

Interim Action Source Control Operable Unit. .A final remedy 

will be prepared for this Site that will include a Baseline 

Risk As sessment .. 

A Source Control Operable Unit FS was prepared in September 

1.991. The FS provides a detailed analysis of alternatives 

evaluated for this inter in action operable unit.. The 

alternatives developed in this FS are presented in the 

Description of Alternatives , Section VII » 

xxx. oaMMnmn vaaTxcxp*TX

equired until the final ground water operable unit ROD is 

completed. A response to all coinients received during the 

public comment period, in contained in the Responi-iivismess 

Summary,, which is attached to this the ROD, 

Other community relations activities were oionducted prior to 

thois a associated with the Proposed Plan and FS., A, comment 

period was held from August 2lit to* September 27,, 1987 

concerning the signing of the Rl/FS comment order, Press 

releases announcing this comment period were sent to local 

media., A couninity relations plan was finalized in early 

191:18, A "kidcoff" mam I:: log to discuss the initiation o£ the 

]R1 was held at the liuskego City Hall on Aug. 25,, 19BB. 

Advertisements and press releases were sent to local media, 

A fact sheet was developed and sent to everyone on the U.S. 

EFA"s niiailing list. In June 1991, a press release 

concerning tils,, EPA's drum removal project was issued and a 

fact sheet was developed and sent to everyone on the nailing \nj 

list, • .. 

IT,, BCOFB OF IimiltXM ACTIOM BOCIECE CO1RRO3L OPBOIJEtLE ItWXT 

As with many Super fund sites,, the problems at the Husk:ego 

Sanitary Landfill are complex., Early site characterization 

activities conducted as part oil! the ]RI identified souroes of 

oontasiiiimtion that could be addressed before full 

oharacteriiKation activities were consplete,, Therefore, to 

acoelerate the rmediation of the sources of contamination,, 

U.S.. EII'A,, in consultation with WIDHRir organiiiied the work into 

two oiperable units (Oils). These are as follows:: 

Interim Action Source Control 00 (SCOU): Control 

and remediation of the soiurces of oontaimination,, 

including landfill waste,, contuninated soils, leachate 

and landfill gas. 

Ground Water Oil (GilOU):: Control and reinediation of the 

contasdnation in the ground water aguifer„ 

The Interia A,ctioin SCOU F addresses contaiinination no>vene:nt 

into the groiund water aquifer and soils fron sown::es within 

the Old, Southeast, and M(Em-»Cointiguous Fill Areas, These 

areas pose a threat to human health and the environment 

lt»ecause of the risks froii possible ingestion of or dermal 

contaort with contamiinated soils looated there or possible 

ingestion of or denial contact with contaminated ground 

water at private residences domigredisnt of the Site., Based 

on. sascpiing by the II.S, EFA in August 19!iilir there are no 

current iioupaots o:l! Volatile Organic Compounds (¥OCs]i at 

private wells downgradient of the Site. Howefver,, the threat 

o»f future private well iimpacts exists since downgradient 

momItoring wells have shown contani natiom,. The first

purpose of this response is to prevent current or future 

exposure to the. cointaiiiinated soils and to reduce contaminant 

migration into the ground water that is a current source of 

drinking water for local residents ,. The second purpose of 

this response is to prevent current or future exposure to 

landfill gas containing explosive and potentially toxic 

contaminants and to reduce the migration of landfill gasses 

to adjacent soils and structures . 

The Ground Water Operable Unit (GWOtl) is at the FS stage 

with a ROD expected in 1993.. It is anticipated that the 

GWOU will be the final response action for this site and 

that it will, address on -site as well as off-site ground 

water cointamination concerns. The combination of these two 

OU« is intended to address the entire site with respect to 

the threats to human health identified,, and to be identified 

in the RI, FS, and site Baseline Risk Assessment.. 

¥„ SITE 

A. Geology and HydrogeolGigy 

The site is located in an area of thick: glacial drift 

overlying N iagara dolomite ., The drift thickness varies from 

approximately 300 feet on the east edge of the site to 50 

feet at a location about 2,, 000 feet south of the site, The 

site overlies a deep valley in the bedrock that is part of 

the Troy Valley which trends to the east with a steep 

bedrock slope rising to the south. 

The valley in the bedrock beneath the site is filled with 

sediments consisting of sand and gravel with a cover of 

glacial till. In general, fine-grained material (till and 

lacustrine deposits) south and east of the site extend to 

depths of approximately 70 to 200 feet. Below the till is 

coarse material (outwash) which extends to depths of about 

200 to 300 feet below land surface. 

At the northern portion of the site is the Upper New Berlin 

Formation which is a till deposit forming an east-west 

trending moraine.. The .New Berlin, Formation contains two 

pr incipal members , a lower sand and gravel unit and an upper 

till unit. The western portion of the site consists of the 

lower outwash sand and gravel unit that extends southwest 

from the site toward the Fox River, The upper unit is 

typically gravel, sand,, loam till that averages about 58 

percent sand,, 29 percent silt, and 13 percent clay, 

The sand and gravel deposits are present east of Crowbar 

Road and south of the land fill access road, beneath the 

western edge of the site, and extend east to the boundary of 

the basal clay under the Old Fill Area (Figure 2),

I:!: iiiilHlfll!!:)!:::« 

B0jiv iiy 

iji 

Lpuaii, iiuruiQ | 

1O !iilt|1LIJI| I •••! " 

--V-',-, i 

;\ ill : 

HWMd-|jyf 

|C/>

Above the Mew Berlin fooution is the Oak: Creek Formation 

which, consists of a much finer textured composition of finegrained 

till,, lacustrine clay,, silt, and sand,. This 

i:'o:nial::l.oni on an average consists of appropriately an 85 

percent clay-silt composition,. The western limit of the Oak 

Creek; Formation is the Valparaiso Moraine and ends within 

the Old Fill Area,, The western extent of the clay till and 

other low perBeability material is vertically and 

horizontally irregular,, AM a result,, its extent cannot be 

accurately defined., nor can an edge of low permeability 

material of constant thickness be mapped with an acceptable 

degree of certainty., The approximate Basal Layer Boundary 

is outlined in Figure 2,. 

The glacial sediments in the area are underlain by the 

Silurian-aged Niagara dolomite, at depths between 250 to 350 

feet below land surface. The Niagara dolomite is 

sequentially •underlain by Maguoketa shale, dolomites, 

sandstones t and i gneous and metamorphic rocks„ The 

Haquoilceta shale in the Site area is documented by private 

well logs which indicate there is about 200 feet of shale 

below the Niagara Dolomite,. 

The ground water flow in the site area varies in direction 

due to the complex geological, features. The general, ground 

water flow for the region is from the northeast to the 

southeast. Within unconsolidated areas located at the 

northern and western edges of the site,, the ground water 

moves in a southerly direction. However the geology by the 

Southeast and Old Fill Areas consists of consolidated clay 

layers. Therefore perched ground water conditions exist in 

these areas,, Ground water flows radially in all. directions 

from these areas as would be expected,. (Figure 3) Ground 

water from the northern portion of the site near the old 

rendering plant lagoons is split by a low ground water 

divide in the sand and gravel deposits., One flow path moves 

generally along a Southeast route that is directed beneath 

the Non-Contiguous Fill Area,, the Southeast Fill Area and 

the Anaimax plant.. The other flow path moves generally along 

a southern route that is directed under the Old Fill Area. 

The water table in the site area varies due to consolidated 

areas,, but in general is 20 to 40 feet deep., In areas where 

ground water is perched or leachats is held within the basal 

layer the water table is 20 to 3D feet deep., 

Presently, the main aquifer in the sand and gravel unit is 

currently used for private water supply downgradient of the 

site in only two private residences,, Public water was 

provided to the Site area in 19136 along Janes villa Road to 

the South and Hillendale Avenue to the east,, in 1986., The 

§

ifa: K 

NEHEOUU. »«eilia»IOUIFE^!IEILIIV SlUDr 

UUStLIEQD 5

municipal veil system is located -a few miles east of the 

site and is not near,, or is it affected, by the site. 

Hydraulic conductivity varies throughout the site dependincjf 

on the soil type.. Within the clay till,, the hydraulic 

conductivity ranges from 1.6 :»: 10"* centimeter is per second 

(cm/ ei) to 5.1 x 10~ 9 cm/ is., However,, the hydraulic 

conductivity of the sand and gravel deposits is much higher ,, 

ranging from 3.9 x l,0* i! cm/s to 1.2 x 10' 3 cm/s. 

The El sampling of ground water,, soil, sediment and leachate 

was predoiiinantly conducted at on- site locations , with the 

exception of ground water suipling at monitoring wells and 

pr ivate wells loca ted of f - s ite . Sampling was conducted for 

organ! c:s,, semi -volatile organics,, poiychlorinated biphenyls 

(PCBs) , and metals, 

1. Ground water 

Ground water is the main pathway of concern for contaminant 

migration at the site. As mentioned above , there are two 

iiiiai.il groiund water flow paths. The first one,, known as the 

Southern flow path,, runs from the northern section of the 

site under the Old Fill Area and continues to the south., 

The second or Southeast flow path., also nowes from the 

northern portion of the Site,, hut is diverted to the 

southeast and flows beneath the Southeast Fill Area,, the 

Non -Contiguous Fill Area and Ananoiax property .. In addition „ 

conditions exist where leachate accumulates in areas above 

these flow paths in perched or eleivated conditions,. (Figure 

3) 

^L!;!i!ilJ;;Jt]l!Sii][;]i:i...J!!JiL!;!ii!i:..J;!jS!«:l;J;ii •- The Southern Flow Path is potentially 

affected by the f ooier rendering plant lagoons „ and the Old 

and Non-Contiguous Fill. Areas., Two rounds of ground water 

sampling occurred at 12 downgradient wells at seven 

different locations, The results of the samples collected 

from these monitoring wells are summarized in Table l; 

locations of the monitoring wells are shown in Figure 4. 

Organic contanination located in the Southern Flow Path 

includes BETX (benzene „ ethylben;i:ene ,, toluene ,, xy lene ) ,, 

chlorinated ethene „ and chlorinated ethane groups „ 

Individual cheiiical concentrations and well locations are 

listed below. 

Benzene 1 ug/L :i.:i5A 

Toluene 3 ug/L 121B

i 

I, , 

o 

Q 

! I J ! S II ! I ! ! ! ! : i i ! s : 

: i i : : : : : i : i i : : : ! ! :;::::! 

::: ! " ::: !: : ::: iii :!: ? 

mi iii in tii mi t!i tn 

S , jS ? 9 9 9 9 9 i? ;:; 

i iiyi iiii iji tii MI ii 

i b o o !:i 1:1 !:S 

SE 

... i... (.., i 

X X X 

I '«'» «•• ! ! r» 'M « «"' ! ! i ! f •• t : I ! ! i ! ! i : m I ! 

i : ••• ;»> — ; : : : t : : i i i : : : : : i i t ••• l 

S t 

i o o o o 9 9 9 

1 W W W W < 

iii iii iii * 

I •••) I 

? 

i :

SAMPLE ID 

SRWRC::: Flow p 

=~~i 2 -Cjg"^j> 

ML-GWE93P-32 

MLGWE94-02 

MLGWE94P-C2 

ML G WE 134 02 

ML-GWEI14A-02 

MLGWF64C-02 

ML-GWTW62-02 

NcaîSiôa^FisiA^ 

Round : 

ML-GWE97F-3S 

ML GVrE-GGA -0: 

MLGWE:02AO: 

ML-GWEI04-€: 

ML G\£E-35 0- 

ML-GWTW74R-OI 

Roustd 2 

HL-OWE97P-02 

MLGWE!ODA-€2 

MLGWEI02A02 

MLGWEI04-02 

MLGWE-M02 

MLGWTW74R-02 

ML-OWEI7R4! 

MLGWE4I4I 

MLOWESSÎ 

ML-dWEi7-Oi 

MLOWE90î 

Round 2 

ML-GWEI7R-02 

MLGWE4I-02 

MLGWESf-02 

ML-GWEi7'02 

MLGWE50-D2 

Bscisro-ind Well: 

ML-GWEIO-S2 

ML-UW3W75-02 

MONITORING 

WELL 

E93P 

EN 

E94P 

EI34 

EI34A 

PMC 

r«?« 

s/Ar.s.T.ii Fsciiay 

E97F 

E-GSA 

EED2A , 

EIG4 

EL35 

TW74R 

E97? 

EI03A 

E:02A 

BI04 

EI36 

TW74R 

E17R 

E4I 

ESS 

ES7 

E90 

EI7R 

E4= 

ESS 

Ei? 

E90 

Eio 

TW73 

34 

3 

3:600 

503 

J 

36300 

TASLE I 

CHLORINATED CIUX)RINATED CHLORINATED 

ETHANES KETONES BENZENES PMENOI5 

13 

3 

7 

•9 

S 

7 

10 

3 

I? 

3 

10 

•o 3 

2403 

9 

2970 

i! 

2 

I2SO 

NT 

NT 

Psgs 2 os 3 

PAIIs PIITHALATES It'll. 

360 

NT 

NT 

NT 

NT 

NT 

NT 

NT 

NT 

NT 

NT 

NT 

NT 

NT 

NT 

NT 

NT 

NT 

NT 

NT 

NT 

NT 

NT 

NT 

NT

NOTES. 

1 , CGncen..s-io~! SR In sg/L. 

Table i (C 

2 Dallied rynAoU (-) indlcas es=paa»» »:» as scieaed in :Ke «mpk. Thg .ynsbsl (*) 

no- aaayasa is; Sa Shssa sa.TJJ.-i. 

3. NT i-!Jic=.« cc-spcund: wire nss sasiyzsd :cr i= :hi: unsple. 

4. This Tsble —5 origmsily T^fe 4-2 ffom ihs Sappkissem so Uchnka! tAi-i:-^.-.~ss No. 2. 

TIK/vu/ILV 

13527,33 

Psge 3 of 3

,Bcr,.. 

is!! 

!!..,. iilll 

i.. 11 

in i

EtJ:i.ylben;i:ene 

Xylene 

Tetrachloroethene 

Trichloroethene 

lr'2-Dichloroethene 

Clil.oroet.hane 

1,- 2 •••Dichlor oethane 

1.,, 1 -Dichloroethane 

3 uq/L 

1-13 ug/L 

1 uq/L 

1-3 uq/L 

1-8 uq/L 

2 ug/L 

2 uq/L 

1-5 ug/L 

123B 

123B, 96P 

12 3B 

123B, 135B, 138A 

135A-B, 137A-B, 96 

13 5A 

135A, 137A 

135A-B, 137A-B, 95Pr 96 

Semi •••volatile compounds and pesticides/PCBs were not 

detected in the Round I ground water samples collected from 

the Southern Flow Path., Therefore,, Round 2 samples were not 

analyzed for these parameter!!!, 

Ground water monitoring wells were also sampled for Target 

Analyte List (TAL) metals and cyanide, and general ground 

water quality indicators.. These analyses were used to 

assess chemical concentration, trends within the aquifer to 

aid in the determination of' ground water flow patterns, and 

contaminant fate and mi.gration.. 

There are seven TAL constituents that were detected in one 

or more monitoring well sample (s) along the Southern, or 

Southeastern Flow Paths at levels higher than those detected 

in the background wells E80 and TW75. All of these seven 

were detected along the Southern Flow Path at various wells.. 

The constituents were as follows: 

.Arsenic 

Barium 

Chromium 

"• Lead 

* Manganese 

* Nickel 

* Sine 

J;!js;!13i:!;Jl!iL!!ij!ii:!;;!iL][;;i:i...Ji;],.:S!LJI:li!!J;;l3i ••• The Southeastern Flow Path which 

diverts from the Southern Flow Path in the northern area of 

the site,, was character ized using 11 monitor ing wells at six 

locations. The sampling from these wells are summarised in 

Table 1; locations of the monitoring wells are shown in 

Figure 5., 

There are four organic contaminant groups that were detected 

on-site along the Southeastern Flow Path. These groups are 

BETXs , chlorinated ethenes,, chlor inated ethanes,, and 

phthalates. Individual concentrations and well locations 

are listed below, One organic contaminant„ vinyl, chloride,, 

was fouridl off-site,, at levels in exceedance of Federal 

Max! munii Contaminant Levels (HCLs) and WDNR Bnf or cement 

Standards (ESs) shown in Table 2. The vinyl chloride 

contamination was found during ground water monitoring 

southeast of the Site at Well'p64C.. 

Benzene 1 ug/L 

10

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mnil> i jwn ilium ii uuiiLiniuMunnil yUAIVTV'iy "^~* »...«, 31. '—..«. -f(l- 

———————— ...- —————————————— ... ——— .. BI wf ifj (.UC|j_|| p wM _ 1N( |N | M (i „ .„ jr.p , j . ,,,. 

MllSKII CUl SAMUMT 1 AM 11 III 

WWSlt UWWMG*WtN1l 0* : WISCONSIN MC . ' ——— """ ——————————— ----. 

mnt OF s£Cio« us i w.«»« . „.. . ....... „„......._......._„...._....„—-——.— 

CHY l> MUSKI'V) WMML-SIIA CCXffllV. IMSCCI4SM - «•" ««,.,, r...,,« «.^.....-.,

Xylene 1 ug/L 92P 

Trichloroethene 2-3 ug/L 92A 

1,2-Dichloroethene 2-3 ug/L 92A 

Vinyl Chloride 5-7 ug/L 64C 

1,2-Dichloroethane 2! ug/L 92A 

1.1-Dichloroethane 6-7 ug/L 92A 

Additional organic compounds detected in this area include 

1.2-dichloropropane from monitor ing well E92A at a 

concentration of 2 ug/L (Rounds :i. and 2) ; and methylene 

chloride (a common/probable laboratory contaminant) , TW62 at 

a concentration of 2 ug/L (Round 1 only) ., 

Phthalates were detected, in one ground water sample from 

this area during Round 1 (E92-3 ug/L) , and two samples from 

Round 2 (E94-4 ug/L, and TW62•••:•) ug/L) . Constituent 

compounds detected were di-n-octyl phthalate and bis; (2ethy 

Ihexy 1) phthalate,. 

As with the Southern Flow Path, pi-isticides/PCBi-i were not 

detected in Round 1 ground water samples collected from this 

area. Therefore,, Round 2 sample!:! were not analyzed for 

these parameters., 

There are five TA'L constituents that were detected in one or 

more monitoring well sample (a) along the Southeastern Flow 

Path at levels higher than those detected in the background 

wells ElitO and TW7S.. These constituent!:! are as follows:: 

* Arsenic * Zinc 

* Barium * Manganese 

* Nickel 

£>:>;J:Mis;i::....i;LJ[;.!i!.i!i;!i> - The Southern and Southeastern Flow Paths 

described above affect well locations primarily downgradient 

froun the site as) shown in Figures 4 and 5., 

Monitoring wells are also located in the Non-Contiguoui-i Fill 

and Ananiax plant areas as well as along the northern extent 

of the Old Fill Area (Figures 6 and 7) '. The highest 

concentration of organic contamination for the site was 

found at wells in the Non-Contiguous Fill Area. 

Specifically, monitoring well Ei::h:i, located in the Noncontiguous 

Fill Area, was contaminated with several VOCs at 

levels in exceedance of HCLs and WDNR Enforcement Standards 

(ESs), 

Contaminant groups that were detected within the Non- 

Contiguous Fill, Ananiax plant and northern boundary areas 

include BETXs,, chlorinated ethenes, chlorinated ethanes, 

ketones,, phenols, and polycyclic aromatic hydrocarbons 

(PAHs)., Some of the individual concentrations and well 

locations are listed below, 

11

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Benzene 1-21 Ug/L 10 OA, 102A, 104 

97P, TW74R, 87 

Toluene 8-12,000 ug/L la;;:A,, :.::i6 

Ethylbenzene 270-7,300 ug/L 102A, 136 

Xylene 5-39,000 ug/L 102A, 136 

TetrachloroetJ:i ene 3 uq'/ L 17R 

Trichloroethene 1-7 ug/L 87, 100A, 104, TW74R 

1,2-Dichloroethene 1-12 ug/L 100A, 102A, 1.04 

TW74R, 87 

1,2-Oichloroethane 3-9 ug/L 102A, 87 

-1,1-Dichloroethane 3-8 ug/L 100A, 102A, 1.04 

87, 971? 

Chloroethane B ug/L 97P 

2 -Butanona 9 ••••;

2. Soil/Sediment 

Soil samples were conducted at locations in the Old Fill 

.Area,, Southeast Fill Area, North and South Refuse Trenches 

and the Drum Trench of the Non-Contiguous Fill Area (Figure 

9) .. These samples were taken at the apparent base of fill 

material in these areas to determine the effect of 

contaminant movement in the soils under the waste., The soil 

samples varied in depth from 20 to 40 feet below surface 

level, The saiiples in the Old and Southeast Fill Areas were 

collected at leachate head well locations LII14 , LHlifi , LH12 ,, 

and LH17. The six Refuse and three Drum Trench samples were 

completed after excavation to the soil beneath the waste in 

these areas , 

BETX and ketones were the predominant organic compound 

groups detected in the basal soil samples from the leachate 

head well borings. The primary constituents and their 

concentration!-! are listed below,. 

Benzene 160-13 , 000 ug/kg 

Toluene 12 0-13 0,000 ug/kg 

Ethylbeneze 40-24 ,, 000 ug/kg 

Xylenei 2-100, 000 ug/kg 

Acetone 13 -7 , 1.00 ug/kg 

;;!-butanone 3-13 , 000 ug/kg 

4-methyl-2-pentanone 180-29 , 000 ug/kg 

Jsophorone 59-3 , 600 ug/kg 

Other volatile organics found in soil samples included: 

trichloroethene (790 ug/kg) in the Drum Trench, 

tetrahydrofuran (1,900 ug/kg) in the Drum Trench and (2:1. 

ug/kg ) in the Refuse Trench, and chloroform (520 ug/kg and 

1.50,000 ug/kg) in the Dnum Trench. 

Total phenols and PAEls were the precllominant semi -volatile 

organics in the Drum and Refuse Trench Areas., In addition,, 

phthalates were also detected in these areas. The primary 

coinsti.tu.ents and their respective concentrations are listed 

below, 

50-3,2oug/kg 

2 -Hethy Iphenol 4 3 0 ug/kg 

4«ethylphenol 210-550 ug/kg 

Eenisoic acid 170 ug/kg' 

Napihthalene 100-5 ,, 6C)6 ug/kg 

2-Methylnaphthalene 72-1,300 ug/kg 

Phenanthrene :i.:i.o ug/kg 

Pyrene 82 ug/kg 

Chrysene 81 ug/kg 

31.3

Ben::: o (a) pyrene 

Indeno (1,, 2,3 -cd) pyrene 

D ibeniKO (a, h) anthracene 

Benw o (g , h,, i) perylene 

Butylbenzyl phthalate 

0lathyIphthalate 

Di-n-butYl phthalate 

Bis (2 eth;y Ihexy 1} phtJhal ate 

110-140 ug/kq 

210 ug/kq 

230 ug/kg 

190 ug/kg 

42-1,000'uq/kg 

98-150 ug/kq 

86-310 ug/kq 

300-440 ug/kg 

PCBs were detected In one sail sample each from the Drum 

Trench and North and South Refuse Trenches,. Pegiticides were 

also detected in one or more samples from the North and 

South Refuse Trenches. The constituents and their 

conceiTtxat ions are 1isted below. 

Arochlor 1242 

Arochlor 1248 

Arochlor 1260 

4„4'-DOT 

4,4"-DDE 

4,4•-DDE 

42-170 ug/kg 

200 ug/kg 

62 ug/kg 

22 ug/kg 

9.2-30 ug/kq 

8.2-33 ug/kg 

The only trace elements that were not within the common 

regional range for natural, soils based on U.S., EPA 

other publications were, magnesium and cadmium. 

Magnesium was found in exceedance of the conion range in the 

Southeast, Drum,, and Refuse Trench areas. Cadmium was found 

in exceedance of the .common range in the Old,, Drum,, and 

Refuse Trench areas. Nine TAL metals; aluminum, arsenic, 

cobalt,, copper, iron, lead, mercury, sodium ,, and zinc 

exceeded the regional background soil levels at one or more 

basal soil sample locations . 

In addition ,, a sediment investigation was conducted to 

assess the effects of surface water runoff from the fill 

areas and the Ananoiax property., Sampling was conducted at 

various locations on and off the site. However, 

concentrated efforts were conducted along a drainage swale 

on the east side of the Old Fill and Southeast Fill Areas 

(Figure 9) . Below is a list of the constituents identified 

along wi .th concentrations and locations . 

CiSllEM! 1 !Ee ililrliLiiiJllr 

Acetone 

1„1-0 ichloroethane 

2-Butanone 

Toluene 

Phenol 

4-MethyIphenol 

- 1BO ug/kg 

11 ug/kg 

53 ug/kg 

2-190 ug/kg 

790 ug/kq 

570-960 ug/kg 

141 

SD4 

SD4 

SD4 

SDI , SDS 

SD4 

SOI , SD4

O •4 

in 

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!b III 

Cl III 

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iff f I 

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Benzole Acid 230 ug/kg 804 

Naphthalene 210 ug/kg SD4 

2Hiethyl.naphthalene 96- 200 ug/kg SDl, SD4 

Fyrene 110 ug/kg SD3 

bis(2-Ethylhexyl)phthalate 600-680 ug/kg SDl, SDiil 

Di-u-butyl-phthalate 170 ug/kg SD8 

3. Air 

Ambient air, leadhate head well,, and gas vent vapor sample® 

were taken, at the site during the El,, However, the result!;! 

were found to be invalid due to the exceedance of 

recoimended sample holding times.. S inc.®, the investigation 

of the site began,, the operator„ WMNI, has agreed to 

implement the Nisconsin raquirsment, NR 506., 08 

J!k

assessment determines whether contamination at the land fill 

could pose an unacceptable health risk or environmenta1 risk 

in the absence of any remedial action. Potential threats to 

public health are estimated by making assumption!-! about the 

manner,, frequency and length of tine a per son could be 

exposed to site-related contaminants., However, for this 

interim action operable unit the baseline risk assessment 

has not been completed since the EX has not been finalized,. 

For the proposed SCOII, a qualitative risk assessment was 

prepared consistent with U.S. EPA. policy, '"Hole of the 

Baseline Risk Assessment in Superfund Remedy Selection 

Decisions/ 1 " dated April 22,, 1991. The qualitative risk 

assessment examined contaminants detected in ground water, 

leachate, and soils during the field investigation phase of 

the RI, These contaminants were evaluated, with respect to 

their carcinogenIcity, toxicity, and possible exposure 

pathways from and at the site.. 

The following is a representative list of contaminants 

detected, in ground water, leachate,, sediment,, and soil at 

and near the site:: 

Bern: ene Acetone Mercury 

Ethylbenzene 2-Butanone Butylbenzylphthalate 

Toluene 2-Hexanone Diethylphthalate 

Xylenes Tetrahydrofuran dl-n-octylphthaiate 

Chl oroethane :i.,, 4 ••• D ich lore benz ene PCBs 

1,, 1-Dichloroethane 2-Methylphenol Arsenic 

1,2-Dichloroethene 4-Methylphenol Barium 

Stvrene Pentachlorophenol Cadmium 

Dichloropropane Phenol Chromium 

Trlchloroethene Benzole Acid Copper 

Vinyl Chloride Cyanide 

Bis (2 - e thylhexy 1) phthala :te Lead 

Nickel 

Zinc 

The sand and gravel aquifer in the immediate area of the 

landfill is contaminated, The potential exists for this 

contamination to move with ground water flow toward private 

residences. 

Exposure to landfill gas,, through either methane migration 

in the soils or VQC migration in the air,, is a concern at 

the Site., Inhalation of landfill gas is of concern due to 

the potential presence of unacceptable levels of VOCs that 

may cause a health risk,. A potential health risk: would 

exist until landfill gas controls are installed and 

operating to adequately manage potential exposure. wmi has 

14!

comitted to managing landfill gas at the site in accordance 

with Wisconsin Administrativa Coda NR 506,08(6) ,. 

Direct exposure to contaiiinated soil or waste is currently 

not a concern at the site,, All fill areas are covered by at 

least one foot of soil to limit the exposure potential,. 

However, future exposure nay be a concern if the cover is 

not adequately improved and maintained, 

Continued Isachate generation and the resulting additional 

ground water contamination is another potential concern at 

the site, Private wells to the Southeast and South of the 

Site ware sampled, by U.S. EPA for VOCs in August 1991, but 

no contaminat ion was detected.. Although most potential 

receptors of contaminated ground water are now on public 

drinking water supp 1 ies, some downgr ad lent res ident s are 

still using private wells that may become impacted by siterelated 

ground water com taminat i on.. E leva ted 1 eacha te 

levels in the Old, Southeast and Non-Contiguous Fill Area® 

will result in continued ground water contamination until 

leachate generation is adequately controlled or most of the 

contaminants have been leached from the waste., 

Of the chemicals in ground water, those with exceedances of 

Safe Drinking Hater Act or WDNR NR 140 WAG ground water 

drinking standards are shown in Table 2„ This Table 

compares the maximum ground water concentrations in the 

immediate landfill area with the MCLs, ESs and WDNR ME 1.40 

Frevsntative Action Limits (FALs) ,, 

Based on toxi c:ological studies „ benzene and viny 1 chloride 

are classified as U.S., EPA Group A •••• human carcinogens; 

while trichloroethene, tetraohloroethene and 

pentachlorophenol are classified as Group B2 - probable 

human carcinogens. Pending completion of the complete 

baseline risk: assessment, exiceeduices of drinking water 

standards alone justify the interim action operable unit 

remedial action. Actual or threatened releases of hazardous 

substances from this site,, if not addressed by implementing 

the respomse action selected in this ROD, may present an 

imminent and substantia.! endianganiiient to public health,, 

welfare,, or the env ironnient., 

« DEeotiPTioi OF 

A,, Remedial Action Obj ectives 

Upon completion of the first phases of investigation work at, 

the site, remedial action objectives were developed that 

address the source areas while considering the long-term 

goals of protecting human health and the environment and. 

17

Chemical 

Compounds 

VOCs 

vinyl 

1,2 DichlGroethane 

Trichloroethene 

Benzene 

Tetraehleroetnene 

Toluene 

Ethylbensene 

(total) 

Tetrahydrofuran 

Chloroform 

Table 2 

! 

KR 140 and EPA MCL FOR GROUND 

UG/L (unless otherwise noted) 

Maximum i 

Concentration 

7, 00 | 

9,00 

7,00 

21*00 

1,00 

12000,00 

7300»00 

39000.00 

41 = 00 

1,00 

NR 140 

Enforcement 

Standard 

5 

5 

5 

1 

343 

136Q 

620 

50 

6 

.2 

NR 140 

Preventive 

Action 

Limit 

2720 

,0015 

,05 

,18 

,067 

= 1 

68,6 ! 

124 

10 

.6 

t 

40 CFR 

Part 141 

MCL 

1000 

2 

5 

5 

5 

5 

700 

10000 

! 

= = =

Chemical 

Compounds 

SVOCs 

Arsenic 

Barium 

Cadmium 

Chromimum , tots 1 

Iron 

Lead 

Manganese 

Selenium 

Silver 

1 

Table 2 

NR 140 and EPA MCL FOR 

UG/L (unless 

Maximum 

Concentr at ion 

4 = 00 

25,90 

11*70 

133,00 

,7 os mg/1 

50300,00 sg/1 

5 = 20 

4560.00 

34 = 00 

SMCL - Contaminant Level 

41 

NR 140 

Enforcement 

Standard 

300 

50 

1,0 mg/1 

10 

50 

50 

50 

10 

50 

,30 sg/1 

NR 140 

Preventive 

Action 

Limit 

30 

5 

,2 mg/1 

1,0 

5 

25 

1 

10 

,15 sg/1 

5 

40 CFR 

Part 141 

MCL 

50 

1 

2,0 mg/1 

5 

100 

.3 sg/1 aCL 

15 SMCL 

50 

50 

100

meeting applicable or relevant and appropriate requirement!-; 

(MtARi-iji, Site-specific goals of limit ing the potential for 

the release of contaminants to the ambient air,, sub-waste 

soils, and ground water include the following:; 

«> Minimize the migration of chemical constituents from 

soil/refuse transported by leachate to ground water 

that would contribute to ground water concentrations in 

excess of MCLs, ESs; and PALs beyond the waste boundary; 

«> Control the seepage, migration and concentration of 

landfill, gas generated by the refuse in the Old, 

Southeast, and Non-Contiguous Fill Areas, and in the 

soils or air at or beyond the property boundary; 

«> Minimize hazardous air contaminants that may be emitted 

from the Old,, Southeast and Non-Contiguous, Fill Areas,, 

and comply with applicable air pollution control 

standards; and 

w Minimize the potential, for human exposure to waste and 

contaminated soils and for release of contamination to 

the environment, 

Since this interim action operable unit addresses source 

control., site-specif ic cleanup standards for soils and 

ground water Mill not be necessary for the Old and Southeast 

Fill Areas,, where containment provides the primary source 

control.. However,- a per f ormiance-based cleanup standard,, 

which account!!! for and incorporates ground water standards 

will be established for soils in a portion of the Non 

Contiguous Fill Area,, where the source area will be treated 

as wail as contained,. A cleanup standard would be 

established because of the more concentrated nature of the 

hazardous materials located in this specific area.. 

The performance-based cleanup standard would be applied to 

the area, covered by the in-situ vapor extraction (ISVE) 

system., The cleanup standard Mill, be based on residual 

soil-gas concentrations that are low enough to assure 

compliance with ground water cleanup standards, which will 

be specified in more detail (including compound specific 

standards) in the ROD for the GWOU for the Site. The 

relationship between soil-gas VOC concentrations and ground 

water VOC concentrations would be modeled to determine the 

concentration of VOCs in the waste/subsoil that must be 

achieved, in order to assure that,, even if the remaining VOCs 

leach into ground water, the level, of VOCs in the ground 

water will not exceed levels that are protective o:i: human 

health and the environment. The model will incorporate data 

collected during a pilot-scale test, and the first two-year 

period of full-scale ISVE operation, as well as previous 

US

sampling and monitoring data coll acted at the Site., In 

accordance with the national. Contingency Plan (NCP) 

§300.430(f) (5)i(iii)i (A), if waste is left in place at the 

conclusion of a response action,, the (specified ground water 

clean-up standards should be attained at the points of 

compliance identified in the GNOU HOD. 

The XSVE system will operate until the concentration of VOCs 

in the waste/subsoil calculated by the model is achieved. 

This methodology would be superior to setting numerical 

reduction rates,, based upon the percentage of VOC removal 

from thak soil, because it directly corresponds to achieving 

groujid water cleanup lev els. 

B. Developniiient of Alternativeiii 

Alternatives developed in the FS for the SCOU considered the 

Old,, Southeast, and Non-Contiguous fill areas.. As stated 

above,, the remedial action objectives involve controlling 

landfill leachate and gas,, limiting the potential for 

exposure to contaminants via inhalation, ingestion, and 

denial absorption pathways, and nininizing impacts to ground 

water. 

In developing alternatives, the FS takes into consideration 

previous removal work: that has occurred, The remedial 

alternatives were assembled from applicable remedial 

technology options., The alternatives surviving the initial 

screening were evaluated and compared with respect to the 

nine criteria required by the NCP., In addition to the 

remedial action alternatives,, the NCP requires that a noaction 

alternative also be considered for the site. The noaction 

alternative serves primarily as a point of comparison 

for other alternatives„ 

Two general strategies have been utilized, to accomplish the 

remedial action objectives four the source control portion of 

this site. The first strategy is to control the production 

of gas and leachate while minimizing potential exposure to 

waste or conta,ininated soil. 'Ilium second is to manage gam and 

leaoihate after production,. These strategies are evident 

within the forthcoming alternative descriptions. 

€., Alternatives 

Under Alternative 1 no additional corrective action would be 

taken at the site to address sources or potential sources of 

ground water contamination or direct contact threats. The 

limited removal of leachate by WMWFI from the Southeast Fill 

If

Area would! continue utilizing the current method of pumping 

from a portion of the existing collection system directly to 

the sanitary sewer. 

Under a no-action scenario,, contannination from the source 

areas in leachate or soils would not be prevented from 

reaching the ground water aquifer, This would result in 

continued off •••site migration of contaniiinants in the ground 

water.. Also,, gas and air con .tarni nation would continue to 

migrate through soils off-site and/or into the atmosphere ., 

Finally, the current cover over the source areas would 

degrade due to freezing and thawing, This would result in. 

greater percolation of rainwater and more likelihood of 

contaminant transfer into the ground water „ 

A no-action remedy would allow the site to remain as it 

exists today with an incomplete fencing structure around the 

site., Therefore, direct contact to soils would be a greater 

likelihood for workers at the Stoneridge Recycling facility 

and trespassers.. There would be no capital or operational 

costs assoc dated with this alternative .. 

The LiBitiiid-Action Alternative involves jjinplsmenting 

measures to restrict access to the site and monitor gas 

migration, Site controls include a fence extension and deed 

restrictions for the site. Fencing would be extended across 

into the Anamax property to complete the enclosure of all 

fill areas and the wairotewater ponds. Landfill gas 

monitoring would also be a component of this alternative to 

deteonine compliance with solid waste regulations., 

As in the No-Action Alternative, this remedy would not 

prevent contamination currently in leachate or soils from, 

reaching the ground water eguifer through percolation or 

direct leaking,. This alternative also does not address the 

prevention of gas migration through soils nor does it 

prstvent the current cover degradation through freeze-thaw 

cycles., 

The limited-action scenario would deter direct contact to 

contaainated soils with the installation of a fence., In 

addition this action would hinder premature destruction or 

disturbance of the current cover., The current cover does 

not contain any freeze-thaw protection layer of soil on top 

of the clay. This allows the clay layer to expand and 

contract from freezing conditions, 

Capital cost for this alternatvie would be seventeen 

thousand four hundred dollars ($17,400),, There would be no 

operational or maintenance costs.

AlteouLtiva 3 consists of sswan major coiniponants . Thin first 

threa : deaidi restrictions (, f mem s:u:tans ion , and landf 1 .1 .1 gas 

nitonitoriinig and control ara thin mum am Alternative 2. Tha 

add! tional four components arm :: 

«> Cup installation over tha Old and Sirathaast Fill Araas 

in accordamica with NE 5041 MAC; 

«> landfill leachata control in the Old Fill Araa; 

«> XaprovoiMnt of thin unxisting leachatin control system In 

thm Southeast Fill Arsaj: and 

Alternative 3 would increase the effactivariess of laachate 

extraction by increased or naxiDixed use of the current 

system and installation of additional extraction vails 

using the sane procedure as in the Old Fill Area, 

Collection walls would ba installed to the base of the 

refuse and spaced appropriately to influence and collect 

leachata from all areas where laachate can collect or build 

up (:i.,,e. , create a head of leachate} , The exact design and 

spacing will be detainined in the remedial design. The. 

datannlniation of the final configuration of walls would ba 

madia by U.S. EPA, in consultation with WD1NIR,, during the 

remedial design activities.. 

The leadbiate extraction systems would be operated to 

maximize the amount of leachata withdrawn and Minimize to 

the extent practicable,- the a»no>unt of leachat e accunulated 

on the base of both fill areas, 

Laachate and gas systemi condensate will likely ba discharged 

to .the sanitary sewer,, provided pre treatment standards are 

mat, It may be necessary to pretreat leachate bafora sewer 

discharge to meet pretxeatiment standards „ Leachata may be 

treated along with, groundvater as part of the subsequent 

GWOU. Effluent limits for possible discharge of treated 

ground water/leachate to surface and/or ground water will be 

deteoiinetd for that action, if necessary•'. Sludlge/'residual 

from tixMiiaiîiiJiiUTt/ipiiiel:::!: 1 *!^!!!:::!!!!!!!]:!!!:: may have to ba managed as a 

hazardous waste if sltown to be a Toxicity ctiaracteristic 

Leaching Procedlure (TCLP) characteristic hazardous waste, 

Wastes excavated or generated by the installation of 

airtxaction systems (i.e.,, drill spoils) „ may have to be 

managed as a haiBardous waste if shown to be a TCLP 

characteristic hazardous waste. Sludge/residuals and/or 

other excavatad/genarated wastes, if shown to be a nonhazardous 

waste, may be managed at a solid waste landfill. 

The Land Disposal Restrictions (LDKs) would apply to any 

TCLP hazardous wasta that is to be disposed of'(i.e.„ 

placement of the waste occurs) on or off site, Certain nonliquid 

ax:ca¥ated/generated wastes nay ba re-buried at the 

site, in an appropriate location selected during the RD 

(likely at the Southeast. Fill Area), under the new cover 

system whan it is constructed. This would include some of 

the :ij[rineiiirl:;igation--deri¥ed wastes now being stored in 

containers at the Site. U.,!•!,. Elf'A has detariiined that such 

re-burial would not. constitute placement„ and would not 

trigger the LDEs., U.S., EPA has also dateriiDiined that the 

substantive analysis required under the Wisconsin policy 

"Interim Policy (Guidelines) For Promoting :i:n-State and On- 

Site Nanaganient of Hazardous Wasta in the' State of 

Wisconsin" 1 should be performed for the management of any 

hazardous wastes from the Site, It may be possible to treat

TCLP liazardowii waste so it no longer shows the 

characteriatic and maiuge it as a non-"hazardous waste, 

The final, additional segment of Alternative 3 is an active 

landfill gam control system in the Old and Southeast Fill 

Areas. This system would, work in con j unction with the 

leaehate collection system to extract landfill gases in the 

Fill Areas. The e:dtxactad landfill gam would be destroyed 

by a ground flare consistent with Wisconsin NR 445 WAC 

requireiiiuiintiii. 

-Alternative 3 is composed of several sagments that address 

actual or potential contaminant migration from the Old and 

Southeast Fill Arses . Alt ernat iv« 3 aiddrnitsees (, tbroiuigh 

contairunwnt and trditatnant, tha rn of contamination 

and the prevention of huinian (raposure to coimtaninants,, 

The NR 504 MAC cap will raduca tltnuit percolation of rain water 

through conitaminatnitd waste iiatarial and into the ground 

water by providing an iigtipennaitabla layer above the waste 

material ,, This decreasmtd periinabilitY w ill- contain 

contaminatioin within tha Fill Ireae and help prevant . 

migration off •••site. Thun cap will also provide added 

protection from direct oaintact by adding additional cover 

material., ifiddsd cover will alao be installed to protect the 

cap integrity from freeze- thaw cycles comsietent with the 

reg ion " a weathar . 

The installation of a gas extraction system would directly 

reduce and treat, through thenal destruction ir landfill gas 

contaminants., The gas extraction synitsiin will also reduce 

the chance of cap cracking caused by internal presaura front 

gas formation, 

Alternativs 3 addresses contamination probleitm in t:he old 

and Southeast Fill Areae but iloiiuii not addrass contamination 

in the Non-Contiguous Fill Iraa excatpt to the extent that 

area is included in the fencing and dead rastrictions.. 

Tha capital coat for this altarnativa is estimated to be 

seven itillion dollars (!ii7jrOOOir00D]| „ The operation and 

maintenance costs for Altarnativa 3 are one million seven 

hundred thousand dollars ( $1 „ 700 „ 000) ,. 

:JSU^ 

J!l^^ 

Alternative 4 consists of ail of the components contained in 

Alternative 3 with the addition of the following:: 

23

•» iBStallation of a Wisconsin MR 504 cap over the Noncontiguous 

Fill Area; and 

«> In-Situ Vapor Extraction (ISVIE!) in the Non-Contiguous 

Fill Area 

Modified Alternative 4 (the selected remedy) is the same as 

Alternative 4r with the addition of:: 

•» A ground water monitoring program conducted at 

selected existing Monitoring and private well® approved 

by U.S., Ell'A,, In consultation with. WDNR, during Remedial 

Design (RD]| and after iMplementat ion. 

Alternative 4 is coiipoaed of several segments that address 

actual or potential contaminant migration from the Old,. 

Southeast„ and Non-Contiguous Fill source areas, 

Alternative 4 addresses„ through containment and treatment,, 

the reduction of contamination and the prevention of human 

exposure. 

The NR. 504 AC c

Tne selected reBedy includes ground water Boinltoring to be 

completed at locations spine if led during the KD by U.S. EPAr 

in coiwultation with the WDNR. Tills ground water Monitoring 

will bin performed to contribute to the def inition of the 

contamination plum and to Bsarare the •ffectivanass of the 

implementation of the inter in renedial measures .. The 

program will include ,, ait a iinininnm, seiii-uiLnual monitor ing 

f or Chapter MR 5013 WAC indicator paraBeters and VOCs at low 

detection limits in selected monitoring wells along the 

liioiuith and souitheanit port ions of tJnii Sita, in a salected 

baokgroiuind monitoring vell|p and in i»elanoted privata walls. 

The iionitoring and privata wiklls would ba sslaoted baa ad on 

veil location IP dapith ,, past Bonitoiring raiiiiiiiltisi „ construction IP 

ate,, This alternativa is tlte nnost connprahanaive cleanup 

of all of the alternatives, 

Coats for .iFk.lta:nniati¥a 4 or tha salaoted reiiniiidy would ba 

approxiBataily thai sanw with alight varianca in comparison to 

the capital and operational counts, Titus capital costs for 

jy.teniatiw 4 or the aalaoted reniMiidY ara eigbt nil lion 

dollars ($1:1 , i:iOO(lai:iCi)i „ Tltta opinratioin and Bainteiniance costs 

are one Billion nine hundred thouaand dollars . 

¥ixi ., einniiiuoE' ow conmuua-nm mLisie our 

1.1 ,,S., ElfMlL has estiiLbliiiiLhad nimis oritaria that balance haalth|p 

technical. ,, and cost considerat ions to determine the most 

appropriats alternative,, I'lfinn criteria analyiee the salectad 

reBady so that the rauiiedy is px^tactivs of human health and 

the eiwirominieiiiit ,, attains MtMLs IP is cost effactiva,, and 

utilises psnnanant solutions and treatiiiient tecltMmologies to 

the iniuclBun extant practicable,, The raiedial alternativas 

devaloped in the FS have heen evaluated amu:li coBpinriiitd using 

the nine criteria set forth in the MCP. The nine criteria 

are set fourth by i.LS. EFA under MCP 30i;i,,430(e) (9) (ill) . 

These nine criteria are syBnsrixed as follows ;i 

moncTioii OF 

addresses wihetber a rsBedy provides ade«pna1ba protection of 

bUBan health, and the enviromsnt and describes how risks are 

posed tnrough each exposure pathvay are eliminated ,, reduced , 

or controlled througfh traatnunt ,, eng:iLneeri:ng controls ,, or 

institutiona .1 controls « 

eOMFLIllCE 1IT1 IJE'FLXOJIIIUI! Ol». ElUriOUR MSB 

:ni:i!!i;;ti[i:i::i;i:i!:ill[]!!;iim!i CUUlilsli addresses wlhethaMi: a rasedy will Beet 

all othiDtr Federal and State anvironBental statutes and/or 

provides grounds for invoking a waiver. 

2S

LOBO-Tim BFFlCTXVnnsa ili-lsm FinilOkJinCE refer::! to the ability 

of a remedy to maintain reliable protection of human health 

and the envir onnnent over time , once cleanup standards have 

been net. 

OF eoirruixiiiyiiT TQXXCXTY, MOBILITY, OR TOLDMB 

through treatment is the anticipated perforimance of the 

treatment technologieiii a remedy may employ. 

Jill-1 DJii'lI'-TIi:]!!.!!!; BVFBCTIYBBBM addresses the period of tine needed 

to achieve protection^ and any adverse impacts on human 

health and the eiwixonment that may be posed during the 

construction and implementation peri od „ unit: 11 cleanup 

standards are achieved., 

IMnEMEmBILITY is the technical and adainistrative 

feasibility of a remedy, including the availability of 

materials and services needed to implement a particular 

option. 

COST' incl tides estimated initial capital. ,, operation and 

maintenance (OlilM) costs, and net present worth costs, 

MiOiX'TlKiE indicates whether, basetd on its review of 

the RI/F!:i and Proposed Plan,, the State concurs with, 

opposes, or has inio comniient on the preferred alternative at 

the present time ., 

COMICCIMIR JkCli^nnJIC]!: is based on cominents received from the 

public during the public conment period, These comments are 

assessed in the responsiveness sumnary attached to this ROD, 

B. EjE!i:n)i!ii!

pot Hint ia 1 exposure to waste and contuniiriants and continued 

ground vat mr contasdna t :i. on , 

AltsniuEitive 3 is more protective of human health and the 

env:ixonsiant than Mternetives 1 III 2 .. The cainibination of 

ins t Itut ional controls , capping and leachate/ landf i 11 gam 

controls effectively protect potsntial receptors from 

landfill contaminants as long as these systems are 

Baintained. l-toweiver,, Alternative 3 is not vary effective in 

controlling the sources of contamination in the Won- 

Contiguous Fill Anna,, where high levels of soil and ground 

• water contamination are known to sadist ., Under alternative 

3 1 this Area would continue! to be a source oil! soils and 

groundwater contunination., 

Alternative 4 provides additioiriial protection by u,pE3irai:lii:ng 

the cap and providing :ES¥E extractio:n for the INfon-'-Contiguoas 

Fill Areas.. These additional measures will reduce the 

future potential for further soil and ground water 

contanikiBation in, and arising fronn,, this area.. 

The selected alternative adds a final elennent of 

protectiveitMss teyond what JlLltsirnative 4 provides by 

routinely supling residential and inoindtoring wells nioi-it 

likely to be affectmtd by contasiination at the Site.. 

to,, cniPLUkKii iiTi lypFLXCiiiBu: OE liisumyra 1 mi .]'i:i; | :p]!i:i:!>]!':i;t;i:;ii, 1 i:i!! 

The Site was never an operating Resource Coiuiervation and 

RecovaMcy Act (RCIflA) facility., Site records do not 

conclusively desioostrate that the materials disposed of at 

the Site during its operation Mere listed RCRA hazardous 

wastes, Th«refOKrelp RGKIl closure rsquireiinents would not be 

applicable at this site. RC1A Land Disposal Restrictions 

(Ulls) are none the less applicable to the isanageniient of 

treatinisflt residues end/or any other wastes nnanaged as part 

of reimsdy iiniplesMiintation that are found to be charact eristic 

ltita»:ardous wastes and are disposed of through placement of 

the waste on or in the land,, on or off site, 

Alt ernative 1 and 2 do not meet current State and Federal 

landfill closure requirements ,- which are applicable to this 

site. 

Under NR 50(5, .08 (06) lM!r laBdfills containing over 500,000 

cubic yards of vasts that accepted nnunicipal solid waste 

must have an active landfill gas recovery system to 

effectively control, emissions of haiBardous air contaminants 

to the air. Alternatives 3 and 4 include active landfill 

gas control systems that comply with those xMMiuirensnts for 

ill?

controlling methane migration and controlling emission!:; of 

hazardous landfill gas constituent!:!, 

The improved cap and additional leachate collection system 

in Alternatives 3 and 4 comply vita Wisconsin solid waste 

closure (NR 506.08 WAC) t ground-water quality requirements 

(NR 140 WAC), and landfill cover system design criteria (NR 

504,.07 WAC) ., Under Section ME 506.08(03) MAC,, a site with 

chapter M!R 140 WAC ground water standard exceedances; is 

required to install a cover system meeting the standards in 

section MR 504,07, if such a system is necessary to abate 

such exceedances. The ISVE system in Alternative 4 will 

likewise be designed to meet AHAEs.. The ISVE cleanup 

standards vi.ll be developed in conjunction with the 

identification and compliance with ground water ARARs as 

part of the GWOU remedy „ 

2. Primary Balancing Criteria 

Five primary balancing criteria are used to identify major 

trade-offs between the remedial alternatives which satisfy 

the two threshold criteria,. These trade-offs are ultimately 

balanced to identify the preferred alternative and to select 

the final remedy. JQiecause Alternatives 1 and 2 do not 

satisfy the threshold criteria,, they will not be evaluated 

by the primary balancing criteria. 

a, LOW-TEW EFFECTXVEHEM Mill FlEiUAMDCE 

Alternatives 3 and 4 and the selected remedy provide 

controls for a permanent and effective source control 

reimedy.. 

Alternative 4 and the selected remedy provide good control, 

of potential, exposure to waste contaminants or continued 

leaching of waste contaminants by treating soils in the Non- 

Contiguous Fill Area, capping all identified source areas,, 

and providing leachate and landfill gas controls in the 

landfill areas., The selected remedy provides additional 

assurance of long-term effectiveness by monitoring nearby 

wells,. Capping and leachate/landfill, gas controls in. 

Alternative 3 provides adequate controls for the areas 

addressed„ but may provide less long-ti-srm effectiveness than 

Alternative 4 because it does not address the Non-Contiguous 

Fill Area.. Institutional Controls and O&M further reduce 

the risks from direct contact under all alternatives. 

!!!§

. UDUCTXOM XM TOXXCXTY, MOBILITY, OR VOLUME TRROUOE 

TRBATMBMT 

Due to moist conditions in a portion of the Old and 

Southeast Fill Areas,, the waste is being reduce:! in volume 

through biodegradation. However,, biodegradation would not 

significantly reduce contannination and the time frame and 

uncertainties for such reductions would be much greater than 

for implementing a remedy . 

Alternatives 3 and 4 and the selected remedy will reduce the 

toxicity, nobility! and volume of methane and other VOCs in 

the subsurface through actively extracting and treating 

landfill gas. 

Alternatives 3 and 4 will reduce the mobility and volume of 

Isachate in the Old and Southeast Fill Areas by extracting 

leachate through a series of wells and constructing a 

low-peinneability cap, The described cap option would allow 

some, infiltration to enter the landfill,, which will aid the 

natural biodegradation occurring within the landfill and 

reduce the time until the refuse is stabilized. The 

collected leachate Mill receive appropriate! treatment and be 

proper 1 y disposed« 

In addition, Alternative 4 and the selected remedy would 

also reduce the mobility and volume of VOCs at the 

Noncontiguous Fill Areas using ISVE. VOCs in the waste and 

surrounding soils would be extracted through wells screened 

in the unsaturated a:one and treated,, if necessary, above 

ground.. 

C,, SHORT-TERM EmCTXVEHESS 

None of the alternatives would pose a substantial risk to 

the community t workersf and environment during remedial 

actions, Precautionary actions, through the ramadiaI action 

health and safety plan,, would address risks to on-i-iite 

workers and potential off-site risks„ 

Capping, installation of a landfill leachate and gas 

extraction system,, and installation of an II-IVE system can be 

acconnplished in one construction season.. The risks of 

construction activities for Alternatives 3 and 4 and the 

seleeted remedy are adequately managed through dust 

suppression and the use of personal protective equipment for 

construction workers. The need for lea chat e extract ion nay 

decrease since the improved caps should result in reduced 

leachate generation.

d. ZMFLniEHTABXLXTY 

Iiiplementation for any of the alternatives should not be 

difficult,. Capping with an NR 504 WAG cap,, a component of 

Alternatives 3 and 4 , would be the most extent i ve remedial 

measure but still, not difficult to implement, because this 

type of cap is common at Super fund and landfill sites., 

A leachats extraction system,, combined with an active 

landfill gas collection system! a component of Alternatives 

3 and 4, is common at landfills,. Implementation should not 

be difficult. 

ISVE is also becoming a common cleanup technology at various 

Superf und sites and implementation would be technically 

practical. Although ISVE is a relatively new technology 

when spec i. f i ca 1 ly be ing imp lenient sd in a non-homogene ous 

landfill mass,, this should not impede the implementation 

since a similar technology is being applied at the Hag en 

Farm Superf und site in Wisconsin., 

Iniplementability of institutional, controls should not be 

difficult because no significant off -site controls should be 

necessary, 

HI,, COSTS 

The estimated costs of the four FS alternatives are listed 

below,, The first column list, the capital, or construction 

costs for the project. The second column are the costs to 

operate the remedial, system once it is constructed., The 

final column is the sum of the first two columns,. 

:i.,. o o o 

2. $17,400 0 $17,400 

31, $7,.0 mil $1. 7 -2 .6 Illlil $8.7-9.6 nil 

4. SGLO mil $1.9 -2, .8 nil $9. 9 -10. 8 mil 

The selected remedy adds monitoring costs of appropriately 

$20, 000 to Alternative 4, but is in every other way 

identical. A range is given in the Total Cost figures to 

account for a 51 and 10% discount rate, The higher cost 

figure corresponds to the lower discount rate. The 

operation and maintenance for these alternatives is :K) 

years., In addition, Capital Cost figures are based on 

construction beginning iiimed late ly . The vast ma j or ity of 

these cost will not actually be incurred until after 

Remedial Design is completed, A more detailed description 

of the costs for Alternative 4 is provided in Table 3 1

YEAR 

0 

1 

2 

3 

4 

5 

6 

7 

a 

s 

veil 

12 

13 

14 

15 

16 

17 

IS 

IS 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

CAPITAL 

COSTS 

7.984.000 

! 

OSM 

COSTS 

309,500 

309,500 

309.500 

309,500 

309,500 

134,200 

134.200 

134,200 

134.200 

134,200 

134.200 

134J200 

134,200 

134.200 

134,200 

134,200 

134.200 

1 34,200 

134.200 

134,200 

134,200 

134.200 

134,200 

134.200 

134,200 

134,200 

134.200 

134,200 

134,200 

134.200 

MUSKEGO LANDFILL 

ALTERNATIVE 4: GAS & LEACHATE CONTROL, 

AND TREATMENT OF THE FILL 

TOTAL 

ANNUAL 

COSTS 

7,984,000 

309,500 

309,500 

309.500 

309,500 

309,500 

134.200 

134.200 

134,200 

134,200 

134,200 

134.200 

134.200 

134,200 

134,200 

134,200 

134,200 

134.200 

134,200 

134,200 

134.200 

134,200 

134.200 

134.200 

134,200 

134,200 

134.200 

134,200 

134,200 

134,200 

134.200 

DISCOUNT 

RATE: NET 

10% 

P/W FACTOR 

7,934.000 

281,364 

0,751315 

0.683013 

192,175 

0.564474 75,752 

0,513158 

04S6507 

0.424098 56.914 

51,740 

0350494 47,036 

0.31B631 

0.280864 

0.217629 

0,197645 

24,137 

21,943 

0.148644 19,948 

0,135131 16,135 

0,122646 

0.111678 14,987 

0.101526 

11,260 

0.076278 10,236 

DISCOUNT 

*: NET 

5% 

p/W FACTOR WORTH 

1,000000 7,984,000 

0,952361 

0.863838 

0,783526 

0.746215 100,142 

0.710681 95.373 

0,644609 

0,613913 

0.584679 78,464 

74.728 

0.530321 71,169 

0,505068 

0,481017 

0.458112 61,479 

58.551 

0.415521 

0,395734 53.107 

0,376889 

0.358942 48,170 

0.341S50 45.876 

0,325571 

0,310068 41,611 

0.295303 

0.281241 37.743 

34,234 

Q.057309 7,8910.231377 

31,051 

TOTAL: $9,91 4,000 TOTAL*: 

VARIANCE; -8== VARIANCE: 0* 

NOTE: ' Suparfund program RI/FS racernmsnds iha! a discount rats of 5% before taxes and alter inflation tot 

assumed, as in the column, Ths PRPs ussd 10% In the FS Report, as she—- in the first €-of«mn. 

rotate are te the nearest $1 .000. 

Table 3 

DISCOUNT 

RATE: . NET 

3% 

«>/W WORTH 

7,984,000 

291,733 

0.915142 

0.888487 274.987 

112,390 

0,613092 109,117 

0,789409 

0.766417 

0.744094 

0.722421 

0.701380 

91.384 

0.661118 

0.623167 

0,605016 81,193 

74,303 

0,537549 72,139 

0,521893 

0.506692 

0.4S1934 86,018 

0.477606 

0,463695 

0.450189 80.415 

0.437077 

0,424346 56,947 

0.411987 

TOTAL: $11,417,000 

VARIANCE: 6%

3,. Modifying Criteria 

in,, STM'E ACCIFTMCB 

The WDNR has bean the support agency for the RI/FS and has 

reviewed this ROD. The WDNR concurs with the selected 

remedial action,. In addition!, the WDNE does not feel that 

Alternatives 1 through 3 are protective or would attain 

ARARs; therefore,, these alternatives are not acceptable to 

the State,. 

b „ CQMKOVXTY ACCEPTIVCE 

Comments have been submitted by the community,, local 

governnent officials, and potentially responsible parties 

(PRPs). In general, issues presented in the comments were 

directed toward the inclusion of ground water monitoring for 

the final remedy, and a delay in the capping of the 

Southeast Fill Area, Comments and responses to those 

comments are described in greater detail in the 

Respons iveness Summary attached to this :ROD, 

c. Summary 

Based on a comparison of the nine criteria, Alternatives 1 

and 2 do not provide protection from all of the potential 

risks at the site and do not comply with ARAEs. They 

therefore do not meet the threshold test for selection of a 

remedy alternative at the site. Alternative 3 would be 

protective for a portion of the source areas of the Site, 

but would not provide protection from all of the potential 

risks at the site either,, Alternati.ve 4 would be protective 

of human health and the environment with respect to all 

source areas and would attain ARARs. The selected remedy 

adds a final, element of protect.:!.veness by periodically 

monitoring those existing wells more likely to provide 

potential 1 representation of ground water cbnt.amination. 

Alternative 4 and the selected remedy provide the greatest 

degree of long-term effectiveness and permanence because 

they provide the greatest, degree of remediation and 

containment of the contaminants„ The selected remedy adds a 

monitoring program to help provide assurance of long-term 

effectiveness,. Alternatives 3, 4 and the selected remedy 

provide reduction of toxicity through destruction and 

treatment of contaminants „ but Alt ernat ive 4, and the 

selected remedy encompass all source areas and utilize ISVE. 

Implementation for any of the alternatives is not expected 

to pose any technical problems since similar remedies have 

been selected and constructed at other Superfund sites, 

31

Alternatives 3 and 4 are more costly due to the sco>pe of the 

work: perfoou-id under each. Alternative 4 and the selected 

remedy are the most costly because they enconiipass capping 

and ISVE at the Non-ContigiULous Fill Area. The incremental 

cost of this significant additional remedial activities(, 

however„ is rather small in comparison to the environmental 

benefit obtained. 

The WDNR concurs with the selected remedy for the site, and 

does not consider Alternatives l. through 3 to be protective 

or in compliance with ARARs,, and therefore would not accept 

any of these alternati ves. The community „ local government 

officials,, and PRPe that submitted public comments agree 

with capping the Fill Areas, although a question was raised 

as to the need for immediate capping of the Southeast Fill. 

Area,, These groups also concur that the leachate collection 

and ISVE portions of this interim action operable unit are 

necessary, valuable, and consistent with the final remedy. 

II,, TEE SELECTED EEMIEDT 

Based on the evaluations of the alternatives,, U.S., EPA and 

the State of Wisconsin believe that the selected remedy 

(Alternative 4 plus ground water monitoring of existing 

well!-!) will be protective of huiun health and the 

environmentt comply with AEiy;t.sr be cost effective,, and will, 

utilise permanent solutions to the maximum extent 

practicable.. 

The selected remedy for the SCOU entails:: 

4i Ground water monitoring of selected existing monitoring 

and private wells to be determined during remedial 

design; and 

ii Operation and Maintenance of all systems,. 

Site controls, including the extension of the fence to 

encompass the waste disposal portion of the Anamax property 

currently outside the fenced area,, will minimize 

non-authorized access to contaminated areas, and deed 

restrictions will ensure that the land is not used for 

residential purposes in the future., Installation of a new 

cover system over the Old Fill,, Southeast Fill and 

Non-Contiguous Fill Areas will remove the potential for 

people to come in contact with the landfill waste, through 

direct contact or inhalation of airborne particles,, and will 

reduce the amount of leachate produced in those areas.. 

Implementing leachate controls in the Old Fill and Southeast 

Fill Areas will prevent further ground water contamination 

by removal and disposal of contaminants prior to reaching 

the ground water. Landfill gas controls in the Old Fill, and 

Southeast Fill Areas will minimize releases of hazardous 

landfill gas constituents to the air. The use of an ISVE 

system will provide additional, protection by removing vocs 

before they can be leached into soil or ground water or 

emitted to the air. 

The remedial action objectives and cleanup goals for this 

interim action, operable unit remedy are presented in Section 

VII of this ROD, The remedial action objectives include:: 

«' Minimize the migration of chemical constituents from 

soil/refuse transported by leachate to ground water 

that would contribute to ground water concentrations in 

excess of MCLs, ESs and PALs; 

in Control, the seepage„ migration and concentration of 

landfill gas generated by the refuse in the Old,, 

Southeast, and Non-Contiguous Fill Areas, to the soils 

or air at or beyond the property boundary; 

«' Minimize hazardous air contaminants that may be emitted 

from the Old, Southeast and Non-Contiguous Fill Areas, 

and comply with applicable air pollution control. 

standards; and 

ii' Minimize the potential for human exposure to waste or 

contaminated soiIs,. 

Table 4 lists a detailed cost summary for the selected 

remedy, U.S. EPA and the HDNR believe that, the selected 

remedy will achieve the remedial action objectives for this 

operable unit remedy of the site.

.CAPrTALCOSTS 

SiteTenong 

Capping 

a. Old and Southeast Fill Areas 

b., Non-Contiguous Fill Areas 

Gas Control 

Leachate • Control 

In-Situ Vapor Extraction 

SUBTOTAL 

Adnunistration (5%) 

Engineering (20%) 

Contingency (20%) 

TOTAL 

ap vo nnng an V!:i:::::! 

Landfill . Gaa/Leachate Control 

Leachate Treatment 

(years 1992 to 1997) 

(years 1998 to 2022) 

In-Situ Vapor Extraction 

(years 1992 to 1997) 

SUBTOTAL 

(years 1992 to 1997) 

(years 1998 to 2022) 

Contingency (15%) 

fye'anl9$2to'l997) 

(years 1998 to 2022) 

TOTAL 

(yean 1992 to 1997) 

(years 1998 to 2022) 

PRESENT NET WORTH 

(IO%IRicounTKate) 

MAL/vlr/JEM/KEB 

[iriiiad«4(I) 

13,3:27.41 

Table 4 

FcMftfllly Study 

1 Luudlllll 

$ 12.000 

S 3,641,000 

S 426,000 

$ 300.000 

S 884.000 

$ 243Lggo 

S 5,506,000 

S 275,300 

S 1,101,200 

$ yoyoo 

S 7,984,000 

S 

$ 

$ 

S 

S 

S 

39,700 

29,000 

164,000 

48,000 

36.400 

269,100 

116,700 

401,400 

S 309^00 

$ 134*200 

S 9.914.000

I. STATUTORY DiraXXMATXOMS 

^^ 

The selected remedy provides adequate protection of human 

health and the eiwixonment through ISVE to treat waste and 

contaminated soil in portions of the Non-Contiguous Fill 

Area; capping to contain wastes and contaminated soils, 

al levi at ing threats from direct contact and niniaiz ing 

leachats generation ; collection , control and appropr late 

treatmient of oontaniinants in landfill leachate ; cent inued 

extraction of landfill, gas to prevent migration,, buildup 

and/ or explosion ; ground water monitoring to ident If y 

potential impacts of contamination on existing wells; and 

land use restrictions and fencing to limit direct exposure 

to contamination., 

Any short term risks associated with excavation of trenches 

for ISVE will be minimized through good construction 

practices.. 

Wetlands are located southeast of the Site directly east of 

the Anamax facility entrance road, An intermittent creek 

flows over the Site and discharges into the wetlands area., 

Sediment samples taken in the intermittent creek area, 

specifically 504 f show contamination in this area., The 

levels were below surface water criteria levels for the 

contaminants with listed values in U. S. EPA water quality 

criteria (QuAlity_$a^£ejâ__fjzt_Ha£sr_1222.) . In addition,, 

the cap portion of the SCOU will prevent contamination in 

soils from cont acting surface water runoff ,. Therefore 

wetland affects from the Site will be mitigated. 

The source control measures under the selected remedy „ in 

combination with the ground water operable unit,, will 

attempt to restore ground water to the State ESs and PALs 

and to Federal MCLs,. 

The selected remedy will be designed to meet all applicable, 

or relevant and appropriate requirements (AEARs) under 

federal ,, and more stringent state environnental. laws ., A 

list of MIARs for the site is contained in the alternative 

arrays section of the FS. The primary AKARs that will be 

achieved by the selected alternative are::

water *ot of 1977, aim amended [33 U.B.C. iii 1317] 

40 CFR 40 3 - Pretreatnent Standards . Require that waste 

waters to be discharged into a Publicly Owned Treatment 

Works ( POTH) satisfy both general and specif ic requirements 

to protect against damage to PO'IWisi. Any waste to be 

discharged to a POTW must, if necessary, be treated to 

satisfy these standards prior to discharge.. These 

pretreatnment requirenents are administered under NR 2 l :i. and 

IDS., The substantive requirements of these regulations will 

apply to collected leachate to be discharged., 

Eesottiroe conservation and R«oov«ry l!i.ot(, am attended |[4ilt 

U.BoC.1 § if Ml et iiiaq. ]; WiiiioomniiiB Eiiiiwiroitmeiinta:!. FroteotioB 

lElaiKardous Waste Hanag«i,sBt lot [Wis« Btat,, § :i.44«(EiO'-74l] 

Host RCRA requirenents are administered under the State of 

Wisconsin " s i:niplenenting regulations ., U. S . EPi'i, does not 

have sufficient evidence to deinkonstrate that listed 'RCEA 

wastes were disposed of at the site. RCRA requirenments are 

therefore not applicable to One site,, except to the extent 

that new haiKardous wastes (such as treatBent residuals) are 

generated during the course of the remedy.. Several other 

RCRA regulations ,, al though no>t ap>pl icable „ address probl einis 

or circuiuitances very similar to those encountered at this 

site and are therefore relevant and appropriate., However, 

the reiiedy will coiiply with the following applicable 

requirements:: 

Mis. Admin.. Code MR 60!:i; 40 CFR 261 - Identification of 

Haieardous Hastes.. Provide reguireiients for deteniining when 

a waste is hazardous ,. The substant i ,ve requirements of these 

regulations will apply to TCLP testing of treatment 

reeiiduals and waste excavated at the site which niiiiy be 

di sposed of of f -sit e „ 

Wii-i. Admin,. Code NR 1:115; 40> CFR 262 - Standards Applicable 

to Generators of Haieardous Waste ,. Provides requirements foxthe 

ship>;iniexit of wastes to treaibment,, storage or disposal 

facilities .. These requirements may app ly to of f -site 

shipiment of treatment reeiiduals and other wastes. 

Mis., Admin. Code NR 620; Department of Transportation 

Hazardous llCeterials Transportation, Act. [49 U..S,C,, § :UIO:i.]; 

40 CFR 263 ••• Standardei Applicable to Transporters of 

BaziiLrdous Waste ., Requires record keeping „ reporting and 

iwnif acting of waste shipments „ These requirements may 

apply to of f -site shipment o:l: treatment residuals and other 

wastes..

W IB,. Admin. Code MR 6:3 0. .10-17; 40 CFR 264,, Subpart B - 

General Faci 1 ity Requirements ., Est ablishes s utost ant i . ve 

requir einienti-i for s ecuri ,ty t inspection , personnel training , 

and materials handling which are relevant and appropriate to 

on -sit e act! vities involving excavat ions and handl ing of 

hazardous soils and materials . 

Wis, Admin. Code ME 630.21-22; 40 CFR 26'!,, Subpart D - 

Contingency Plan and Emergency Procedures., Establishes 

substantive reguirenents for emergency planning which are 

relevant and appropriate for on -site activities involving 

excava tion and handling of hazardous s ubst a rices . 

His., Admin. Code NR 675; 40 CFR 268 - Land Disposal 

Rest r ict ions ., Requires that hax ardous wastes cannot be land 

disposed unless they satisfy specified treatment standards 

and imposes record keeping requirements on such wastes ., 

These requirements apply to off -site disposal, of any 

treatment residues or other hazardous wastes .. 

Wii!ii::o:iii!!iln EiiririroBiiaiEtal ProtinctioB Law,, eubeltmptiiiir ril'HEloliiill 

Waste [Wis. Stint,, lii :I.44,43-

into the ambient air and procedures for measuring specific 

air pollutants . Landf 1 ,11 gas end ss ions , handling of 

contaminated soils during excavation,, and cap construction, 

could cause air emissions of VOCs, particulates, fugitive 

dust or other contaminants which could adversely effect 

human health and the environment ., The design of the remedy 

will reduce such emissions to acceptable levels or provide 

for treatment to satisfy these standards, 

Safe Drinking Water Lot [40 U.8.C. § ::iOO et nmiq; . ] 

40 CFR 141,, His. Adiuiin,. Code ME. 109 - Maximum Contaminant 

Levels (MCLi:!) ,. MCLs establish drinking water standard!;! for 

potential and actual, drinking water sources. MCLs have been 

exceeded at the site in the shallow aquifer, which is 

classified as a potential drinking water source., The ISVE 

component of the ntiLSidy,, in combination with the upcoming 

ground water operable unit, will achieve compliance with 

MCLs and non-zero Maximum Contaminant Level. Goals. 

Wis. Admin., Code NR 1.40 ••• Grouiindwater Quality Standards. 

Provides for groundwater quality standards including 

Preventive Action Limi , t .is ( PALs ) , Enforcement Standards 

(ESs) „ and (Wisconsin) Alternative Concentration Limits 

(WACLs) . The IS¥E coHponent of the remedy « in combination 

with the upcoming ground water operable unit, will, achieve 

compliance with any applicable substantive groundwater 

quality standards. 

WiscoBiiiiniL EiwixoniiiLemtal Froteotioin. :i:>in,imIP eubchaiiter XI -Water 

and Sewage [Wini, stint.. § :i.d 11 , oil -;i!7;| 

Wis. Admin, Code NR 102 and 105 - Surface water quality 

standards. NR 102 creates an antidegradation policy for all 

waters of the state and prohibits toxic substances in 

surface waters at concentrations which adversely affect 

public health or welfare, present or prospective water 

supply uses, or protection of aniital life. The ISVE 

component of the remedy «. in combination with the upcoming 

ground water operable unit, will achieve compliance any 

substantive requirements o£ these regulations that 

const it: u te iftEARs . 

Clean water l,ot of l!!i?T, am uneigideiili |[3:ii iL.iii.c., § Ui'il

coivtaminated runoff is channeled directly to .a surface water 

bodyt. however, that runoff must comply with any applicable 

concentration limits. 

3 • 

Claami Water Act of 1977, am emeBdeiil 133 u.B.C. iii IMU] 

Executive Order 11990 and 40 CFR 6 - Protection of Wetlands,. 

These requirements -provide for protection against loss or 

degradation of wetlands . Contanination in surface waiter 

runoff will be controlled so that it does not have an 

adverse impact on nearby wetlands . 

c. 

The selected remedy provides overall cost-effectiveness., 

ISVE adds a significant degree of permanence,, as does the 

extraotioin of contaminants in leachate and landfill gasses ,. 

The substantial additional, protection and psoianence 

provided by the upgraded cap and ISVE under the selected 

alternative is achieved with only a minor (roughly 9%) 

increase in cost over the only other protective alternative., 

Moreover , by ef f ect ively addressing sources of ground water 

contamination , the sel ected inter im action operabl e unit 

remedy may also reduce the cost of the ground water operable 

-unit. 

The selected alternative represents the best balance of 

alternatives with respect to the nine evaluation criteria 

described in Section VIII . An innovative treatment 

technology , :i:S¥E, is used to permanent ly address the most 

highly concentrated source area of contamination . The 

selected alternative treats the principal source of ongoing 

ground water contaiiination and direct contact threats. The 

cap further retards the movement of residual contaminants to 

ground water by reducing the generation of leachate. The 

upgraded leachate collection system captures for treatment 

the leachate that is produced,, Collected leachate will also 

be treated and disposed of., The land use restrictions will 

further assure protection to the public health and the 

environment . 

E, PoiUÊiTiiiJice for Treatfflsnt As A PrinclDal 

3191

By treating the BOS t highly concentrated conta:i»iinat ed so:i. 1 

and leadhata as reguired,, the selected remedy satisfies the 

statutory preference for remedial* that employ treatment of 

the principal threat to peinnanently and significantly reduce 

toxicity, mobility,, or volume of hazardous substance!-!,, 

The selected remedy reduces the likelihood that the i-iource 

areas will continue to be a significant source of ground 

water contaaination by use of XS¥Eir collection and 

appropriate treatment of leachateir and capping to reduce 

infi 1 tration„ The reiinaining existing contajiiination in 

ground water will be addreased thlrough the second operable 

unit at tlie site, The cap,, combined with institutional 

controls will also act to prevent exposure through direct 

contact..

This Eesponsiveness Summary has been prepared to meet the 

requirementiEi of Sections 113 (k) (2)i (B) (ivj and 117 (b) of the 

Conpreheinsive Environmental Response,, Compensation,, and Liability 

Act (CERCLA) of 19130,, as amended by the Superfund Amendments and 

Reauthorization Act (SARA) of 1986, which requires U.S.. EPA to 

respond ".. .to each of the written or oral presentations 111 on a 

Proposed Flan for remedial action.. This Responsiveness Summary 

summarizes comments and concerns expressed by the public and 

other interested parties in written and oral form received by 

U., S. EPA, on the recommended remedy. 

On November 18 1991,, U.S.. EPA made available to the public for 

review and content the FS and Proposed Plan for source areas at 

the Husksgoi Sanitary Landfill., 

U.,S. EPA received comments at the public meeting on December 12, 

1991, at the Muskego City Hall.. Additional written comments were 

also submitted during the comment period. 

Comments received during the public comment period are summarized 

in this section. The comment period was held from November 18 to 

December 18, 1991. Some of the comments have been paraphrased in 

order to effectively summarize them in this document. The reader 

is referred to the public meeting transcript and copies of 

written comments submitted during the comment period. All are 

contained in the Administrative Record and are available for 

review at the information repositories., 

ComiitBt: One commenter believed that U.S, EP'A should add a 

gr oiund water monitor ing pr ogr am at s e lee ted mon it or i ng a nd 

private wells to the remedy. The suggestion was made to include 

semi-annual monitoring for MR 508 MAC indicator parameters and 

VOCs at low detection limits in monitoring wells along the south 

and southeast portions of the site, as well as in a selected 

background monitoring well and in selected private wells. These 

wells should be selected based on their location,, depth, past 

monitoring result s,, and construction. The comnienter suggested 

that this monitoring program begin in Spring 1992, if possible. 

U.S. :i;:il!'l, Response:! U.S.. EP'A agrees with, the commenter., Such, a 

monitoring program will be included in the selected remedy and 

outlined in the ROD, The implementation time frame for this work 

will be finalized in the Remedial Design phase of the project.. 

U.S. EPA will plan to Implement all portions of the remedy in an 

expeditious and effective manner. 

Cc»:imiiiBt;c In the first of four separate comments,, one commenter 

pointed out a cost discrepancy between the Proposed Plan and FS.

i:i,,B« EPA, Eeinponssx U.S.. EPA agrees that, different present net 

worth costs for Alternative!:! 3 and 4 appeared in the two 

documents., The lower costs of $8,. 7 million and $9.9 million,, 

respectively,, have been noted as the most recent figures for 

Alternatives 3 and 4 and will be reflected in the ROD,. 

The second comment pertained to the effectiveness of 

U.S.. EFA"s list of source control remedial alternatives., The 

coiuonenter stated that while capping,, landfill gas, ISVE, and 

leachate extraction should have a substantial effect on limit ing 

ground water contamination and the release of site contaminant si, 

natural processes ( sorpt ion , dispersion ,, and biodegradat ion) can 

also reduce the observed concentrations in dowxigradient ground 

water to acceptable levels. The commenter viewed natural 

processes as being a major component to the final, remedy. 

U.S., EF1. liinspoBsiiiii While U.S.. EPA agrees that natural processes 

can reduce the observed concentra tions , concen tr at ions are high 

enough that the time and likelihood for these processes to be 

effective to protect human health, and the environment would be 

unknown. Additional information on this subject will be provided 

in the next operable unit which will focus on ground water, The 

source control remedy selected is not inconsistent with utilizing 

natural, degradation processes to reduce ground water 

contamination levels.. 

Comment:: The third comment stated that cap construction of the 

southeast fill area could be postponed while the effects of the 

proposed upgraded leachate and landfill gas extraction system!:; 

are monitored. 

U.S. EPA lesponsiiiii: U.S. EPA disagrees,. First, leachate 

collection mechanisms ,, including new extraction wells ,, nay not 

effectively reduce leachate levels over the entire bottom area of 

fill, therefore allowing the possibility of leachate to leak: from 

this area during the evaluation period , Additional percolation 

through the old, weathered cover would add to the amount, of 

leachate that could leak: out „ 

Second,, the current, cover ..allows the potential for air intrusion 

at a significantly greater rate than a new MR 504 cover. This 

condition reduces the effectiveness and efficiency of gas 

collection in this area.. 

Third,, according to the intent, of NR 50 4.07(1.;) WAC and NR 

506., 08 (3) MAC,, the construction of a cap should be accomplished 

in the most effective and quickest manner possible (i.e. , it 

should be implemented as quickly as possible ) to minimize the 

amount of percolation into a fill area over time., 

Conmiuiti: The commenter " s final comment pertained to the 

effectiveness of the ISVE system., The commenter offered a method 

for measuring that effectiveness., The method wold use a soil -gas

medium to determine the clean-up Etandards for .the system. The 

clean-up standard would be based on soil-gas concentrations that 

correspond to ground water cleanup levels,, which will be 

developed later during the Groundvatar Operable Unit Feasibi1ity 

Study. A model evaluating the relationship between soil-gas VOC 

concentrations and groundwater VOC concentrations would be used 

to determine the waste/subsoil concentrations necessary to 

achieve the protective level of VOC's in groundwater. This 

method would provide sufficient fli-sxibility to allow cleanup to 

occur without premature imposition of unrealistic clean up goals 

or performance standards. 

O.B» EF1 RiiHiipoMiin U.S. EPA generally agrees with this comment 

and has included language on clean up standards in the ROD that 

addresses this concern, 

Conoiment:: Two comments were received concern!ng ground water 

migration. 

U.S., EPA EaiiiipoiiiisiiM! Ground water migration will be addressed in 

the next operable unit for the Site! That operable unit will 

deal solely with ground water issues. Ground water monitoring 

will be required for this source control operable unit in order 

to measure the effect on ground water by the remedy., This 

monitoring will also provide additional information on the ground 

water contaminant migration to be used for the final remedy. 

Comment! Two commenters stressed that the most complete cleanup 

possible be done at the Site. 

U.B., EPA Response!: U.S. EPA agrees, The most complete cleanup 

considered for the source areas at the Site is being selected., 

In addition to the original recommendation as outlined in the 

Proposed Plan,, the Agency is planning to add a ground water 

monitoring program to the source control operable unit action., 

This is outlined in the ROD. 

Comment:: One commenter requested that all..private and monitoring 

well, results of all tests taken on her property be sent to her. 

U«e« EFA Essponsiiiii U.S. EPA sent all information on January 8, 

1992., Additional infornation regarding test results is available 

at the information repositories located at the Muskago City Hall 

and the IMtuskego Public Library., 

Comment it One commenter provided U.S. EPA with sampling 

information provided to him by the WDNR. He also included his 

telephone number if the Agency needs more information. 

U.S., EPA Response)! u.8. EPA thanks the comment sir for this 

information. If more information is needed, the Agency will 

certainly contact him.,

Paoe MO. 

03/12/52 

niCttE'/IF MM! PAGES Oil 7 IE 

AONINIITMTIVE u-oara nn>« 

MUtKECO UNITARY LANDFILL SITE 

i, WltOMIN 

TITLE AUTHOR RECIPIENT DOOM-HIT TYPE OCOIIJK 

2 89/05/05 l.'iMt'MM- ri: InwiiriiiiKiK lEdflimtiriiri,)!,. •• Stitt G(fford,N. 

Unntw Mimiviunirii: Report »1F y

Pacio NO.. 2 

03n2/92 

ADMINISTRATIVE RI-OOIW INDEX 

HUSKEGO stimuli LANDFii.i. $ i re 

MUBKIEKI,, WI'iOCIMillM 

FICHE/FRAHE PACES DATE TITLE AUTMHI RECIPIENT DOCUMENT TYPE OOCNUMB' 

Prapwiiindi SiMiplirvgi iiinel 

AnmiliyiMiii OMiKMte tin IHI 

ueindl far rifiiiiripUnw at 

i:lni( iLiiiidninitiii HiniEl 

iiritl lEiiin Viiiitii mi: 

13 91/01/Oft Ultirich.!)., * U,!i, IEPA ,,/!,. •• wniitii 

lor iMuNtcnwBi Lwidtl 1,1 

kilhtlhi in Uittiir 

iliiriiitiiry l.iincll'lll 

Couiricy, 

UlMieirmiiri 

1)1 PILimri 

itinniitinry l.iwlif 11II 

yniAmilM Conn'ty,, 

Wliiicoiuiiiri Vail. 3 of !S 

ui/nr/oo ciunil.l!ty Aiiiiuirinriciii 

iPngiJnci: Plnni 

iliiiriliiiniry liinnHHIU 

206 68/00/00 Piriwiouii 

I. music (I HI 

Jtiimi tniry 

W, llmiiartn on 

llinrilhtinry 

llll'llHP 111. IK|lLMlli;i»n«i, 

V«>H.. 2 

Wiirir»iri IEi>»iiiiiihnr iir»o, line.. Miurmiiiiimimi: K!«|»B>rtt/itiEiLidil imi 1 i! 

Unr«>iri 

iB9/W>/00 Rinimalini InviuniinirtI»n Miirxyn 

/IF muni li 11 Ihcy Ittudy line.. 

Hun>l(i»oa Itiiivitiiiry l.ii«HFIII. 

SHEW irnchnilicnll 

HO.. 1 V'CllUNIK i! (I1F Ji 

lEIruiirimif *ni|i iliMitn II ii1»rl !i/!l Mull hm 

Uimyni IEiri||iliPMMiir>ing,Inc. UiinlK 15 

Uutu 

EnglnMfing, lliiiirn Rl>|WtCII/!ilElJKlllllnll 17 

10 

11 

14

Pa Ha. 3 

0:5/12/92 

F1CHE/FSAME PAGES DATE 

ADMINISTRATIVE IHECCHJCl INDEX 

jiAiinriwv ILMIDIFII.I. SITE 

, WISCONSIN 

TITLE AUTHOR RECIPIENT DOCUMENT TYPE OOCNUH 

/Feasibility Study Inc. 

HuMiknwE) Sanitary Landfill 

Site Siuppl,imnt To 

Teehnii en I Mnic.cluiii Ha.1l 

!!

Psen- Mo.. 4 

03/12/92 

FICHC/fRAHE IP'AGI-Si DATE TITLE 

() 90/06/00 

ion 

thill 

Rl/FS 

Altvrmtlvm Army 

DaffiiLiinnrttt ilmrein Control 

Opwratoln IJlirilMt IRomiKliiiil 

I iwinit i nii'l: I oiV NIIIII < l> 11II ty 

dim Kuiilcmgiti I.iiiri(i-Ml.ll 

IIII/F9 

ADMINISTRATIVE KOMI INDEX 

MKIUilifll SANI TART UIIOMI.I. Si I TIE: 

AUTHOR 

1!) l.«l:icnir cawiir'iirig tho fliicidnji:, 

KaiLirull ill SmiisiH mil lloirl: 

Plhnrn MitoKluiii Jab Mo. 

IMilT.1,1!, 

1l!i 911 /111 1/00 Attaint: 

Drum lliiMinwnl Iliiintciii 

if'l.nn 

HiiiniMriiiirHiljm 

), UlliSiOOinill 

1IIEC1IPII lEIIir 

DOCUMENT TYPE OQOIIW 

EngtnMrfng HOE:., llwitn NliHmwimnnit Kii«iM)>iri:«/!!ittiJiEl

PEitpl! INK). 5 

03 /"I2 in 

ADMINISTRAT tve IIIECOIUDI INDEX 

UNITARY LANDFILL sure 

HIJIICKIEQO,, 

nCHf/FRAHE PAGES 0ATIE TITLE AUTKHI ir'IPI: OOOIUHIr 

91/0()/«0 IMiinnBMiiil Uinrxyn, Ire.. 

91/10/00 . U.K. 

ItninJ i:«nr 

I.1MWKFIIU, Sltll 

SLi|9|Eiiiimnm I: 

mull lirwlyiiiii 

of Iliihiiildiiirivliil Wnl.II 

liilinn 

1!S>6 91/11/00 iFniKitiibilllty JEtudy 

0|Miiinitolii UHrilht 

MunulMHiKi Smriiitiiiry 

LfllPlltfltl IKl/IFii 

Ijiiintiii Himmiwiwmcm Rcpcirtn/'StiLiiiiittn 

Jorws.V. • U.I. EWl KtU«y,J.,HMJbold,U. IMpcur i:n/«udl 1111 

trninyn I inc.. 

ilnli in l'lnn

2 9 IW2 

Mir., Valdas ¥. Adamkus, Administrator 

U.S. EPA Region V 

BO S. Dearborn St., 

Chicago, Fill 601504 

SItate of Wisconsin \ DEPARTMENT OF NATOIEAIL RESOURCES 

11011 iionitli Wrilmliiir JtaiElt 

|[|

Mr., Vail das V. Adii.mlo.i«;,, Acini nlstrator 2 

" Biased on 30 years of operation and narinteinaince (O&M) 

The Department concurs with the! selection of this remedy, as described above 

and in the Record of Decision for the situ, 

Me understand that if the potentially responsible parties; (PRP's) do not agree 

to fund the remedy, the State of Wisconsin will] contribute ILK of the remedial 

action costs; associated with the action and 10% of the GUI costs for the first 

year ami provide for all OJiiM after that. Me provide this assurance on the 

assumption that. ILL S. II PA will pursue all appropriate enforcement action!; with 

the PRP's prior to expending the Fund at the site. 

Me understand that if the Fund is expended to conduct the remedy and If 

hazardous waste meedlmg disposal Is required to be managed off-site as part of 

the remedy, that the State of Wisconsin Mi'11 be required to provide tlhe 

assurances for haziirdous wigiste managCTiismt in |40 CI : R 300., !ilO(d) amid (e) of the 

Haiti oiriall Continigeincy Plain. The assurances are that a compliant hai.iirdoi.is 

waste facilMity is a v a ill able,, and that facillity's use is coins; istent with our 

approved Capacity Assurance Plan., Haiardous waste residuails naiy be generated 

by the future pretreatineirit of leachate and liindfil'l gas coiridensiitte prior to 

discharge to the sanitary sewer., However, it Is expected that leachate nay be 

discharged to the sanitary sewer without pretreatnent In the near tern, 

tie also understand that our staff will continue to work in close consultation 

with your staff during the pre-desigin, design and construction phases of the 

remedy,. 

Thank you for your support and cooperation in addressing tlhe contairii nation 

problem at the IMuskego Landfill site., Should you have any questions regarding 

this matter, please contact Mr. Paul D1d1er, Director of the Bureau of Solid l!i 

Hazardous Vlasfe Manaicieneint , at 1608) I! l:>6 • 1327 , 

Sincerely,, 

€, D. 

Secretary 

i::DB::GAI: 

cc: Lynan Hyble ••• AD/5 

Linda Heyer - LC/5 

Paul Didler - SH/3 

Frank Sclnultz/Jin Schmidt •• SEO 

Ul-ill Haubold - U.,S,. EPA Region. V, HSRU-6J 

Mark G1esfeldt/6ary Ede 1 stein - SW/3

ATTACHMENT 4 

LIST OF RESPONDENTS

ATTACHMENT 4 

LIST OF RESPONDENTS 

UNILATERAL ORDER FOR SOURCE CONTROL OPERABLE UNIT 

MUSKEGO SANITARY LANDFILL SITE 

1. Carl Wauer 

2.. Waste Management of Wisconsin,, Inc. 

3.. Acme Galvanizing, inc.. 

4.. Aldrich Chemical Company, Inc. 

5.. Alien-Bradley Company, Inc. 

6.. Allied Signal Corporation 

7.. American Motors Corporation 

8.. American Can Company 

9.. Ampco Metal Inc. 

10. Amron Corporation 

11.. Beatrice Company 

12. Beazer East, Inc. 

v_; 13. Browning Ferris Industries of Wisconsin, inc. 

14. Brunswick Corporation 

15.. Caterpi 1 lax, Inc, 

16. Cudahy Tanning Co., Inc. 

17. Dings Company, Magnetic Group 

18. E.Z. Paintr Company 

19. Envirex Inc. 

20. General Electric Company 

21. Harnischfeger 

22.. Hydrite Chemical Company 

23. Inryco Corporation 

24.. Laidlaw Waste Systems, Inc., 

25. Law Tanning Co. r 

26. Louis Alien Division of Magnetix, Inc. 

27. Master Lock. Company 

28.. Metals Transport Company, Inc.. 

29.. Midwest Tanning Company 

W 30. PPG Industries 

31.. Pressed Steel Tank Co,,, Inc. 

32.. Prestige Foods 

33.. PVL Limited Partnership 

34.. Jack Quigley 

3 5., RAPCO Leather Company 

36.. Rexnord Incorporated 

37. St. Luke's Hospital 

38. Star Line Trucking Company 

39.. Teledyne Wisconsin Motors 

40.. Trinity Hospital 

41.. Vulcan Materials Company 

42. W.A. Krueger Company 

43. Wayne Chemical Corporation 

44. Wisconsin Bell Telephone Company 

45. Wisconsin Electric Power Company 

46. Zummach-Peerless Chemical Coating Co.

INDEX OF LIABILITY DOCUMENTS 

09 / 2 5 / B 6 Waste Hanagement,, U., S, EP'A 

Inc, 

02/24/87 Waste Management, U.S. EPA 

Inc, 


Inc,. 


Inc, 

:i. 1 /13 / 92 Was t e Management , U., S,. EPA 

Inc. 

09/09/86 Carl Wauer U.S. EPA 

06/01/87 Acne Galvanizing,, U.S. EPA 

Inc. 

11/02/92 Acme Galvanizing,, U.S. EPA 

Inc, 

12/19/86 Aldrich Chemical U.S. EPA 

Company 

10/10/92 Aldrich Chemical U.S. EPA 

Company 

12/18/86 Alien Bradley Co. U.S. EPA 

11/03/92 Alien Bradley Co. U.S. EPA 



Supplemental 



(including 12 driver 

affidavits) 

Supplemental 



Supplemental 



(attaching site-related 

r 'ecor ds) 

Supplemental 



(attach ing 1iquid 

waste report 

summaries) 





Supplenoiental 




Inforiiation Request 

Supplemental 





Supplemental 


Information Request

12/22/86 American Motors U.S. EPA 

Corp., 

11/12/92 Anpco Metal Co. U.S. EPA. 

04/24/87 Anron Corporation U.S. EPA 

11/06/92 Anron Corporation U.S. EPA 

11/04/92 Beatrice Company U.S. EPA 

11/2 5/92 Beatrice Company U.S. EPA 

07/06/87 Bostrom Seating U.S. EPA 

Inc.. 

11 /1:2 / 9 2 Bostrom Seat ing U., S. EPA 

Inc., 

11/24/92 Browning Ferris U.S. EPA 

Industries 

06/04/87 Caterpillar Tractor U.S. EPA 

Company 

11/12/92 Caterpillar Tractor U.S. EPA 

Company 

12 / 0 4 / 8 6 Cudahy Tanning Co. U. S,. EPA 

11/12/92 Cudahy Tanning Co. U.S. EPA 

11/20/92 Cudahy Tanning Co. U.S. EPA 

Title. 






Infornation Reques t 

Supplemental 




I nf o nna t i o n Reque s t 

Supplementa1 





Supplemental. 







Supplemental 




Information Requemt 

Supplemental 


Informati on Requemt 

Supplemental 


Infonnation Request

o (S / 3 o / 8 7 Dings company 

1 0 / 2 6 / 9 2 D ings Company 

06/15/87 E.Z. Paintr Co, 

10/29/92 Envirex, Inc. 

ll/l8/92 Envirex, Inc» 

12/12/86 Harnischfeger 

10/20/9:;! Harnischfeger 

U.S. EPA 

U.S. EPA 

U.S. EPA 

11/06/92 E.Z. Paintr Co, U.S. EPA 

U.S. EPA 

U.S.. EPA 

05/05/87 General Electric U.S. EPA 

Company 

U.S. EPA 

U.S. EPA 

11 / o 2 / 9 2 Hydr it e Chenica 1 U,. S. EPA 

Company 

09/24/06 Laidlav Waste U.S., EPA 

Systems, I nc „ 

11/12/921 Law Tanning Co. U.S., EPA 

12/23/86 Louis Allis U.S. EPA 

08/05/87 Master Lode Co. U.S, EPA 

11/05/92 Master Lode Co, U.S. EPA 



Supplemental 

Rei-sponse to EP'A 


Reeponse to EPA 


SuppleBiental 


][n:l!oniiation Request 



Supplemental 




Infornation Request 



Supplemental 

Response to ERA 



I nf o mat i on Request 





Respomse to EPA 




Supplemental 


Information Request

11/12/92 Master Lock Co, 

Ri-jg ;L]RJ;

v.../ 

11/17/92 Star Line 

Tracking Co. 

u.s. EPA 

05/21/87 Teledyne Wisconsin U.S., EPA 

Motors 

11 / 06/92 Teledyne Wisconsin U,. S., EPA 

Motors 

0(5/29/87 Theiii Corporation/ U.S. EPA 

Koippers Company 

11/12/92 Bea:ser East., Inc. U.S., EPA 

11/05/92 Trinity Hospital U.S. EPA 

11/13/92 Vulcan Materials U.S. EPA 

Company 

11/25/9;;! Vulcan Materials U.S., EPA 

Company 

12/17/86 W.A. Krueger U.S. EPA. 

06/10/87 Wayne Chemical U.S. EPA 

Corp. 

10/26/92 Wayne Chemical U.S. EPA 

Corp. 

11 /10 / 9 2 Wayne Cheaica 1. U., S, EPA 

Corp., 

06/13/87 Wisconsin Bell U.S. EPA 

1 Ci / 23192 Misconsin Bell. U.S. EPA 

12/17/86 Wisconsin Electric U.S. EPA 

Power Co, 

Supplemental 





Supplemental 





Supplemental 







Supplemental 






In £ormat, ion Request. 

Supplemental 

Response to EPA. 

Inforiiation JRequest 

Supplemental 


Informati on Request 


Information JRequest 

Supplemental 


Inf orraat i on Request 


Information Request

Date 

Qr 

lb"/27 " /92 Wisconsin Electric U. S. EPA 

Power Co ., 

11/05/92 Wisconsin Electric U.S. EPA 

' ' pow(ar Co

Unilateral Administrative Order - Muskego Sanitary Landfill ...

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