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Five-Year Review ReportFive-Year Review Report

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Fourth Five-Year Review Report for theFourth Five-Year Review Report for the Oconomowoc Electroplating Company, Inc. Superfund SiteOconomowoc Electroplating Company, Inc. Superfund Site

Town of Ashippun, Dodge County, WisconsinTown of Ashippun, Dodge County, Wisconsin

July 2012July 2012

PREPARED BY:PREPARED BY:

United States Environmental Protection AgencyUnited States Environmental Protection Agency RegionRegion 55

Chicago, IllinoisChicago, Illinois

Date:Approved by:Approved by: Date:

~e/~ 7-//_/-z../2uu e i/^ •7 - / / . / 2 . Richard C. Karl, DirectorRichard C. Karl, Director Superfund DivisionDivisionSuperfund

Table of ContentsTable of Contents

List of Acronyms 111List of Acronyms iii

Executive Sumn1aryExecutive Summary vv

viiFive-Year Review Summary FormFive-Year Review Summary Form vii

I.I. IntroductionIntroduction 11

II. Site ChronologyII. Site Chronology 22

III. BackgroundIII. Background 33 Physical Characteristics 33Physical Characteristics Land and Resource Use 33Land and Resource Use History of ContaminationContamination 33History of Initial Response 33Initial Response Basis for Taking Action 44Basis for Taking Action

IV. Remedial ActionsIV. Remedial Actions 55 Remedy Selection Remedy Implementation 66 Remedy Selection 55 Relnedy IInplelnentation Institutional Controls 88Institutional Controls System and Maintenance (O&M) 10System Operations/OperationOperations/Operation and Maintenance (O&M) 10

V.V. Progress Since the Last Five-Year ReviewProgress Since the Last Five-Year Review 1111 Protectiveness Statement from the Last FYRProtectiveness Statement from the Last FYR 1111 Issues and StatusIssues and Status of Recommendations for Follow-up Actions from the Last reviewof Reconunendations for Follow-up Actions from the Last review 11ll DetailsDetails of the 2011 ROD Amendmentof the 2011 ROD Amendment.. 1515

VI.VI. Five-Year Review ProcessFive-Year Review Process 1919 Administrative ComponentsAdministrative Components 1919 Conununity Notification and InvolvementCommunity Notification and Involvement 2020 DOCUlnentDocument ReviewReview 2020 Data ReviewData Review 2020 Site InspectionSite Inspection 2121 InterviewsInterviews 2121

VII.VII. Technical AssessmentTechnical Assessment 2121 QuestionQuestion A: Is the remedy functioning as intended by the decision documents?A: Is the remedy functioning as intended by the decision documents? 2121 Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAGs) used at the timeaction objectives (RAOs) used at the time of the remedy selection still valid?of the remedy selection still valid? 22 Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial

22 Question C: HasHas any other infonnation come to light that could call into question the protectivenessthe protectiveness of the remedy?of the remedy? 23 Question C: any other infonnation come to light that could call into question

23 Technical Assessment SummaryTechnical Assessment Summary 2323

24VIII.VIII. IssuesIssues 24

24IX.IX. Recommendations and Follow-up ActionsRecommendations and Follow-up Actions 24

25X.X. ProtectivenessProtectiveness Statement(s)Statement(s) 25

XI. NextNext ReviewR,eview 26XI. , 26

TablesTables

Table 11 -- Chronology of Site Events 22Table Chronology of Site Events Table 22 -- IC Summary Table 99Table IC Summary Table Table 33 -- Action Taken Since Last Five-Year Review 1111 Table Surface Water Preliminary Remediation Goals 16 Table Action Taken Since Last Five-Year Review Table 44 -- Surface Water Preliminary Remediation Goals 16 TableTable 5.5 -- Groundwater Preliminary Remediation GoalsGroundwater Preliminary Remediation Goals 1717 Table Issues 24Table 66 -- Issues 24 Table 7 - Recommendations and Follow-Up Actions 24 Table 7 - Recommendations and Follow-Up Actions 24

Attachments Attachments

Attachment 1 - Site Map Attaclunent 1 - Site MapAttachment 2 - List of Documents Reviewed Attachment 3 -- Applicable or Relevant and Appropriate Requirements (ARARs)Attaclmient 2 List of Documents Reviewed Attachment 3 - Applicable or Relevant and Appropriate Requirements (ARARs)Attachment 4 - Public Notice Ad Attaclnnent 4 Public Notice AdAttachment 5 -- Private Well Risk Assessment Attacliment 5 Private Well Risk AssessmentAttachment 6 -- Vapor Intrusion Risk Assessment Attaclirnent 6 Vapor Intrusion Risk AssessmentAttachment 7 -- Trend analyses for select monitoring and private wells Attachment 7 - Trend analyses for select monitoring and private wells

11

ARARARAR

CERCLACERCLA

U.S. EPAu.s. EPA

CFRCFR

CVOCCVOC

ESES

ESDESD

FYRFYR

GACGAC

ICsICs

ICIAPICIAP

LIRALTRA

LTSLTS

MCLMCL

MCLGMCLG

MNAMNA

NCPNCP

NPLNPL

O&MO&M

OECIOECI

PAHPAH

List of AcronymsList of Acronvms

Applicable or Relevant and Appropriate RequirementApplicable or Relevant and Appropriate Requirement

Comprehensive Enviromnental Response, Compensation, and Liability ActComprehensive Enviromnental Response, Compensation, and Liability Act

United States Environmental Protection AgencyUnited States Enviromnental Protection Agency

Code of Federal RegulationsCode of Federal Regulations

Chlorinated Volatile Organic CompoundsChlorinated Volatile Organic Compounds

State of Wisconsin Groundwater Enforcement StandardState of Wisconsin Groundwater Enforcement Standard

Explanation of Significant DifferenceExplanation of Significant Difference

Five-Year ReviewFive-Year Review

Granular Activated CarbonGranular Activated Carbon

Institutional ControlsInstitutional Controls

Institutional Controls Implementation and Assurance PlanInstitutional Controls Implementation and Assurance Plan

Long-Term Remedial ActionLong-Term Remedial Action

Long-Term StewardshipLong-Term Stewardship

Maximum Contaminant LevelMaximum Contaminant Level

Maximum Contaminant Level GoalMaximum Contaminant Level Goal

Monitored NaturalNatural AttenuationMonitored Attenuation

National Contingency PlanNational Contingency Plan

National Priorities ListNational Priorities List

Operation and MaintenanceOperation and Maintenance

Oconomowoc Electroplating Company, Inc.Oconomowoc Electroplating Company, Inc.

Polynuclear Aromatic HydrocarbonPolynuclear Aromatic Hydrocarbon

IIIni

PALPAL

PCBPCB

PCORPCOR

PPBPPB

PRPPRP

RARA

RACRAC

RAORAO

RDRD

RI/FSRI/FS

RODROD

TBCTBC

VOCVOC

WDNRWDNR

WPDESWPDES

State of Wisconsin Groundwater Preventive Action LimitState of Wisconsin Groundwater Preventive Action Limit

Polychlorinated BiphenylPolychlorinated Biphenyl

Preliminary Close-Out RepOltPreliminary Close-Out Report

Parts per Bi:llionParts per Billion

Potentially Responsible PattyPotentially Responsible Party

Remedial ActionRemedial Action

Remedial Action ContractRemedial Action Contract

Remedial Action ObjectiveRemedial Action Objective

Remedial DesignRemedial Design

Remedial Investigation/Feasibility StudyRemedial Investigation/Feasibility Study

Record of DecisionRecord of Decision

To Be ConsideredTo Be Considered

Volatile Organic CompoundVolatile Organic Compound

Wisconsin Depm1ment of NaturalNatural ResourcesWisconsin Department of Resources

Wisconsin Pollutant Discharge Elimination SystemWisconsin Pollutant Discharge Elimination System

IVIV

Executive SummaryExecutive Summary

The 1990 Record of Decision (ROD) for the Oconomowoc Electroplating Company, Inc. (OECI)The 1990 Record of Decision (ROD) for the Oconomowoc Electroplating Company, Inc. (OECI) Superfund Site identified four Operable Units (OUs) requiring remedial action: OU-lcomprisesSuperfund Site identified four Operable Units (OUs) requiring remedial action: OU-1 comprises surface water, metal hydroxide sludge and contaminated soils associated with the two RCRAsurface water, metal hydroxide sludge and contaminated soils associated with the two RCRA Subtitle CC lagoons located behind the OECI facility, OU-2 comprisescomprises contaminated soil aroundSubtitle lagoons located behind the OECI facility, OU-2 contaminated soil around the OECI facility not associated with the RCRA lagoons, OU-3 contaminatedthe OECI facility not associated with the RCRA lagoons, OU-3 comprisescomprises contaminated groundwater associated with the Site, and OU-4 comprises the most highly contaminatedgroundwater associated with the Site, and OU-4 comprises the most highly contaminated sediments in Davy Creek and the wetlands area. 1991 Explanation of Significant Differencessediments in Davy Creek and the wetlands area. AA 1991 Explanation of Significant Differences (ESD) added operable unit, OU-5, to dismantie the abandoned facility and dispose of(ESD) added aa fifthfifth operable unit, OU-5, to dismantle the abandoned facility and dispose of associated debris, and aa 1994 ESD established finalfinal cleanup goals for the adjacent wetlands andassociated debris, and 1994 ESD established cleanup goals for the adjacent wetlands and Davy Creek.Davy Creek.

The remedial actions earned out under the 1990 ROD and two subsequent ESDs compriseThe remedial actions calTied out under the 1990 ROD and two subsequent ESDs comprise multiple initiatives to address contamination in each OU. Between 1990 and 1996 the followingmultiple initiatives to address contamination in each OU. Between 1990 and 1996 the following work completed:work waswas completed:

•• Excavation and disposal of lagoon sludge and surrounding soil (OU-1)Excavation and disposal of lagoon sludge and surrounding soil (OU-1)

•• Excavation and disposal of non-lagoon contaminated soil and debris from the Site (OU-2)Excavation and disposal of non-lagoon contaminated soil and debris from the Site (OU-2)

Construction of groundwater extraction and treatment system to restore subsurface•• Construction of aa groundwater extraction and treatment system to restore subsurface conditions to Wisconsin groundwater quality standards (OU-3)conditions to Wisconsin groundwater quality standards (OU-3)

Excavation and disposal of contaminated sediment from the and Davy Creek•• Excavation and disposal of contaminated sediment from the wetlandswetlands and Davy Creek (OU-4)(OU-4)

•• Dismantling and disposal of the abandoned electroplating facility and associated debrisDismantling and disposal of the abandoned electroplating facility and associated debris (OU-5)(OU-5)

The remedial actions for OUs 1,2,4, and 55 are now complete. OU-3 remains active, but theThe remedial actions for OUs 1,2,4, and are now complete. OU-3 remains active, but the groundwater extraction and treatment system was shut down after eight years of operationgroundwater extraction and treatment system was shut down after eight years of operation pursuant to system evaluations conducted in 2000 and 2004. The 2000 report concluded thatpursuant to system evaluations conducted in 2000 and 2004. The 2000 report concluded that metals had reached remedial standards and the 2004 report predicted that it would take 290-620metals had reached remedial standards and the 2004 repOli predicted that it would take 290-620 years for extraction and treatment to achieve remedial standards for Volatile Organicyears for extraction and treatment to achieve remedial standards for Volatile Organic Compounds (VOCs). The need for ROD Amendment to accommodate the shutdown andCompounds (VOCs). The need for aa ROD Amendment to accOlmnodate the shutdown and change the remedial action for OU-3 identified in the 2007 Five-Year Review (FYR).change the remedial action for OU-3 waswas identified in the 2007 Five-Year Review (FYR). AA ROD Amendment changing the selected remedy for OU-3 from groundwater extraction andROD Amendment changing the selected remedy for OU-3 from groundwater extraction and treatment to source area removal or in situ treatment and Monitored Natural Attenuation (MNA)treatment to source area removal or in situ treatment and Monitored Natural Attenuation (MNA)

signed May 16, 2011.waswas signed May 16, 2011.

The remedy is cUlTently protective of human health and the environment in the shOli tenn. TheThe remedy is cuiTcntly protective of human health and the enviromnent in the short tenn. The removal of lagoon sludge, contaminated soil, contaminated sediment, former facility, andremoval oflagoon sludge, contaminated soil, contaminated sediment, former facility, and associated debris has achieved the remedial action objectives of minimizing the migration ofassociated debris has achieved the remedial action objectives of minimizing the migration of contaminants to groundwater and surface water and preventing ingestion or direct contact withcontaminants to groundwater and surface water and preventing ingestion or direct contact with contaminated media.contaminated media.

The following actions are necessary for the remedy to remain protective in the long-tenn:The following actions are necessary for the remedy to remain protective in the long-tenn: removal or in situ treatment of residual source areas, completion of aa vapor intrusion analysis,removal or in situ treatment of residual source areas, completion of vapor intrusion analysis,

vV

continued groundwatergroundwater monitoring, and development and implementation of effectivecontinued monitoring, and development and implementation of effective institutional controls (ICs). The remedy will achieve completion when groundwater cleanupinstitutional controls (ICs). The remedy will achieve completion when groundwater cleanup standards are attained throughout the contaminant plume.standards are attained tluoiighout the contaminant plume.

VIVI

Five-Year Review Summary FormFive-Year Review Summary Form

SITE IDENTIFICATIONSITE IDENTIFICATION

Site Name:Site Name: Oconomowoc Electroplating Company, Inc.Oconomowoc Electroplating Company, Inc.

EPA ID:EPA 10: WID0061002755WID0061 002755

Region: 5 State: Wl City/County: Ashlppun/Dodge

NPL Status: FinalNPL Status: Final

Multiple OUs?Multiple OUs? Has the Site achieved construction completion?Has the Site achieved construction completion?

YesYes YesYes

REVIEW STATUS

Lead agency: EPALead agency: EPA

Author name (Federal or State Project Manager): William J. RyanAuthor name (Federal or State Project Manager): William J. Ryan

Author affiliation: U.S. EPA

Review period: September 2011 -- April 2012

Author affiliation: U.S. EPA

Review period: September 2011 April 2012

Date of Site Inspection: January 31, 2012Date of Site inspection: January 31, 2012

Type of review: StatutoryType of review: Statutory

Review number:Review number: 44

Triggering action date: July 11, 2007Triggering action date: July 11, 2007

Due date (five years after triggering action date): July 11, 2012Due date (five years after triggering action date): July 11, 2012

Vllvn

Five-Year Review Summary Form (continued)

Issues/Recommendations

OU(s) without Issues/Recommendations Identified in the Five-Year Review:OU(s) without Issues/Recommendations Identified in the Five-Year Review:

OUs 1, 2, 4, && 55OUs 1, 2, 4,

Issues and Recommendations Identified in the Five-Year Review:Issues and Recommendations Identified in the Five-Year Review:

Issue Category: MonitoringOU(s): 33OU(s): Issue Category: Monitoring

Issue: Low levels of vinyl chloride in nearby private water supplyIssue: Low levels of vinyl chloride in nearby private water supply wellswells

Recommendation: to monitor private water supply wellsRecommendation: ContinueContinue to monitor private water supply wells adjacent to the GECI Site for vinyl chloride and other volatileadjacent to the OECI Site for vinyl chloride and other volatile organic connpounds and implement contingency actions to limitorganic compounds and implement contingency actions to limit human exposure if contaminant concentrations exceed risk-basedhuman exposure if contaminant concentrations exceed risk-based standards.standards.

Implementing Oversight Milestone Party Date

Affect CurrentAffect Curmnt Affect FutureAffect Future implementing Oversight Milestone ProtectivenessProtectivem~ss ProtectivenessProtectiveness Party PartyParty Date

1-----------+----

NoNo YesYes EPAAA/DNR EPAlVVONREPA/WDNR 12/30/2012EPAlWONR 12/30/2012

OU(s): 33OU(s): Issue Category: MonitoringIssue Category: Monitoring

Issue: The potential for vapor intrusionintrusion1Issue: The potential for vapor ^

Recommendation: Collect deep soil gas samples to ensure that VIRecommendation: Collect deep soil gas samples to ensure that VI is not impacting residential properties near the Site. Sub-slab soilis not impacting residential properties near the Site. Sub-slab soil gas and indoor air sampling should be conducted ifgas and indoor air sampling should be conducted if trichloroethylene (TCE) is detected in deep soil gas at levels abovetrichloroethylene (TCE) is detected in deep soil gas at levels above the current VI screening level.the current VI screening level.

Affect CurrentAffect Curre,nt Affect Future Implementing Oversight MilestoneAffect Future Implementing Oversight Milestone ProtectivenessProtectivem~ss Protectiveness Party Party DateProtectiveness Party Party Date

1-----------1---- ---t----------+--.--.:...-----+--------I

NoNo Yes EPAlWONR EPAAA/DNR 12/30/2012Yes EPAAA/DNR EPAlVVONR 12/30/2012

vapor intrusion risk assessment was conducted in 2011 (and updated in 2012 for this FYR) to address concernsI AA vapor intrusion risk assessment was conducted in 20 II (and updated in 2012 for this FYR) to address concerns that VOCs in the groundwater beneath residential areas proximal to the site may have complete pathway for thethat VOCs in the groundwater beneath residential areas proximal to the site may have aa complete pathway for the migration of volatile compounds tlirough subsurface soils into the indoor air spaces of overlying buildings. The riskmigration of volatile compounds through subsurface soils into the indoor air spaces of overlying buildings. The risk assessment recommended that deep soil gas samples be collected and analyzed for volatile organic compounds. Ifassessment recommended that deep soil gas samples be collected and analyzed for volatile organic compounds. If TCE is detected in soil gas at levels above 4.3 \xg/m' then this should be followed by subslab soil gas and indoor airTCE is detected in soil gas at levels above 4.3 flg/m3 then this should be followed by subslab soil gas and indoor air sampling. However, if TCE levels in soil gas are found to be below 4.3 [ig/m' then the vapor intrusion pathway cansampling. However, ifTCE levels in soil gas are found to be below 4.3 flg/m3 then the vapor intrusion pathway can be ruled out. copy of the risk assessment is included as Attachment 6.be ruled out. AA copy of the risk assessm~nt is included as Attachment 6.

Vlllvni

1

OU(s):OU(s): 33 Issue Category: Institutional ControlsIssue Category: Institutional Controls

Issue: Institutional controlsIssue: Institutional controls

Recommendation: To ensure that the remedy continues to function as intended, prepare an Institutional Controls Implementation and Assurance Plan (ICIAP) which will include evaluation of existing ICs; the development and implementation of effective institutional controls (ICs) and long-term procedures to ensure that effective ICs are monitored, maintained and enforced. The State should also consider putting notice in the WDNR GIS Registry so that parties interested in using or purchasing the property will be aware of the conditions at the Site, restrictions on its use, and effects it may have on nearby properties.

Recommendation: To ensure that the remedy continues to function as intended, prepare an Institutional Controls Implementation and Assurance Plan (ICIAP) which will include evaluation of existing ICs; the development and implementation of effective institutional controls (ICs) and long-term procedures to ensure that effective ICs are monitored, maintained and enforced. The State should also consider putting aa notice in the WDNR GIS Registry so that parties interested in using or purchasing the property will be aware of the conditions at the Site, restrictions on its use, and effects it may have on nearby properties.

Affect Current Protectiveness Affect Current Protectiveness

Affect Future Protectiveness Affect Future Protectiveness

Implementing Party Implementing Party

Oversight Party Oversight Party

Milestone Date Milestone Date

1 NoNo YesYes EPAAA/DNREPAMlDNR EPAAA/DNREPAMlDNR 12/30/201212/30/2012

Sitewide Protectiveness Statement (if applicable)Sitewide Protectiveness Statement (if applicable)

Protectiveness Determination:Protectiveness Determination: Short-term ProtectiveShort-term Protective

Protectiveness Statement:Protectiveness Statement:

The remedy is currently protective of human health and the environment in the shortThe remedy is currently protective of human health and the environment in the short term. The removal of lagoon sludge, contaminated soil, contaminated sediment,term. The removal of lagoon sludge, contaminated soil, contaminated sediment, former facility, and associated debris has achieved the remedial action objectives offormer facility, and associated debris has achieved the remedial action objectives of minimizing the migration of contaminants to groundwater and surface water andminimizing the migration of contaminants to groundwater and surface water and preventing ingestion or direct contact with contaminated media.preventing ingestion or direct contact with contaminated media.

The following actions are necessary for the remedy to remain protective in the long­The following actions are necessary for the remedy to remain protective in the long­term: removal or in situ treatment of residual source areas, completion of aa vaporterm: removal or in situ treatment of residual source areas, completion of vapor intrusion analysis, continued groundwater monitoring, and development andintrusion analysis, continued groundwater monitoring, and development and implementation of effective institutional controls (ICs). The remedy will achieveimplementation of effective institutional controls (ICs). The remedy will achieve completion when groundwater cleanup standards are attained throughout thecompletion when groundwater cleanup standards are attained throughout the contaminant plume.contaminant plume.

IXIX

OCONOMOWOC ELECTROPLATING SUPERFUND SITEOCONOMOWOC ELECTROPLATING SUPERFUND SITE ASHIPPUN, WISCONSINASHIPPUN, WISCONSIN

THIRD FIVE-YEAR REVIEW REPORTTHIRD FIVE-YEAR REVIEW REPORT

I. INTRODUCTIONI. INTRODUCTION

The purpose of the five-year review is to determine whether the remedy at aa site is protective ofThe purpose of the five-year review is to determine whether the remedy at site is protective of human heahh and the environment. The methods, findings, and conclusions of reviews arehuman health and the environment. The methods, findings, and conclusions of reviews are documented in FYR reports. In addition, FYR reports identify issues found during the review, ifdocumented in FYR reports. In addition, FYR repOlis identify issues found during the review, if any, and provide recommendations to address them.any, and provide recommendations to address them.

U.S. EPA is preparing this FYR repoit pursuant to CERCLA §121 and the National ContingencyU. S. EPA is preparing this FYR repOli pursuant to CERCLA §121 and the National Contingency Plan (NCP). CERCLA §121 states:Plan (NCP). CERCLA §121 states:

Ifthe President selects aa remedial action that results in any hazardous substances,If the President selects remedial action that results in any hazardous substances, pollutants, or contaminants remaining at the site, the President shall review suchpollutants, or contaminants remaining at the site, the President shall review such remedial action no less often than each years after the initiation of such remedialremedial action no less often than each fivefive years after the initiation ofsuch remedial action to assure that human health and the environment are being protected by theaction to assure that human health and the environment are being protected by the remedial action being implemented. In addition, if upon such review it is the judgment ofremedial action being implemented. In addition, ifupon such review it is the judgment of the President that action is appropriate at such in accordance with section [104] orthe President that action is appropriate at such sitesite in accordance with section [104j or [106], the President shall take or require such action. The President shall report to the[106j, the President shall take or require such action. The President shall report to the Congress list of facilities for which such review is required, the results of all suchCongress aa list offacilities for which such review is required, the results ofall such reviews, and any actions taken as result of such reviews.reviews. and any aClions taken as aa result ofsuch reviews.

U.S. EPA interpreted this requirement further in the NCP; 40 CFR §300.430(f)(4)(ii) states:u.s. EPA interpreted this requirement further in the NCP; 40 CFR §300.430(f)(4)(ii) states:

If remedial action is selected that results in hazardous substances, pollutants, orIfaa remedial action i,s' selected that results in hazardous substances, pollutants, or contaminants remaining at the above levels that allowfor unlimited use andcontaminants remaining at the sitesite above levels that allow for unlimited use and unrestricted exposwe, the lead agency shall review such action no less often than everyunrestricted exposure, the lead agency shall review such action no less often than every five years after the initiation of the selected remedial action.jive years after the initiation ofthe selected remedial action.

Wisconsin Depmiment of NaturalNatural Resources (WDNR)(WDNR) and the United State EnvirOlilllentalWisconsin Department of Resources and the United State Enviroimiental Protection Agency (U.S. EPA), Region 55 conducted the current FYR of the remedy implementedProtection Agency (U.S. EPA), Region conducted the current FYR of the remedy implemented at the OECI Superfund Site in Ashippun, Wisconsin. This review was conducted by U.S. EPA'sat the OECI Superfund Site in Ashippun, Wisconsin. This review was conducted by U.S. EPA's Remedial Project Manager with support from the WDNR for the entire Site from SeptemberRemedial Project Manager with support from the WDNR for the entire Site from September 2011 to July 2012. This report documents the results of the review.2011 to July 2012. This repOli documents the results of the review.

This is the fourth FYR for the OECI Superfund Site. The firstfirst FYR was completed on SeptemberThis is the fourth FYR for the OECI Superfund Site. The FYR was completed on September 29, 1997, the second on July 12,2002, and the third FYR on July 11,2007. The triggering action29, 1997, the second on July 12, 2002, and the third FYR on July 11, 2007. The triggering action for this statutory review the signature date of the third FYR. This FYR is required becausefor this statutory review waswas the signature date of the third FYR. This FYR is required because hazardous substances, pollutants, or contaminants remain at the Site above levels that allow forhazardous substances, pollutants, or contaminants remain at the Site above levels that allow for unlimited use and um-estricted exposure.unlimited use and unrestricted exposure.

1

1

SITE CHRONOLOGYII.H. SITE CHRONOLOGY

T hiee Chrono ogy 0 ff S'tI Eyentssa 11 eeTabl -- Clironologv o Sit Event EVENTEVENT

OECI OperationsOECI Operations Proposed for inclusion on NPLProposed for inclusion on NPL Listed on NPLListed on NPL RI/FS (entire site)RIfFS (entire site) ROD (entire site)ROD (entire site) ESD for dismantling the abandoned facility1 ESD for dismantling the abandoned facility RDRD

1 Building ReinovalBuilding Removal Pre-Final Inspection of Building RemovalPre-Final Inspection of Building Removal

1 ESD addressing wetland cleanupESD addressing finalfinal wetland cleanup Remediation of Lagoons, Soils and SedimentsRemediation of Lagoons, Soils and Sediments Construction of Groundwater Pump TreatConstruction of Groundwater Pump && Treat SystemSystem Pre-Final Inspection of Lagoon, Soil andPre-Final Inspection of Lagoon, Soil and Sediment RemediationSediment Remediation Pre-Final Inspection of Groundwater Pump &&Pre-Final Inspection of Groundwater Pump Treat SystemTreat System PCORPCOR

1 Final Inspection of Entire SiteFinal Inspection of Entire Site First Five-Year ReviewFirst Five-Year Review Remediation System EvaluationRemediation System Evaluation Second Five-Year ReviewSecond Five-Year Review Optimization study entitled "Hydrogeologic1 Opfimization study entitled "Hydrogeologic Investigation and Groundwater ExtractionInvestigation and Groundwater Extraction System Evaluation" - RMT, Inc.System Evaluation" ~ RMT, Inc. Groundwater Extraction and TreatmentGroundwater Extraction and Treatment System shut downSystem shut down CH2MHill assumes responsibility forCH2MHill assumes responsibility for environmental monitoring under U.S.enviromnental monitoring under U.S. EPAcontractEPAcontract Third Five-Year ReviewThird Five-Year Review ROD AmendmentROD Amendment FOlih Five-Year Review inspectionForth Five-Year Review inspection

DATEDATE 1957-19901957 - 1990 Septembers, 1983September 8, 1983 September 21,1984September 21, 1984 April 1987-March 1990April 1987 - March 1990 September 20, 1990September 20, 1990 September 30, 1991September 30, 1991 September 26, 1990 June 30, 1993September 26, 1990 -- June 30, 1993 April 1991 -March 1992April 1991 - March 1992 March 21,1992March 21, 1992 March 8, 1994March 8, 1994 August 1994 - June 1995August 1994-June 1995

May 1995 - September 1996May 1995-September 1996

June 12, 1995June 12, 1995

September 25, 1996September 25, 1996

September 25, 1996September 25, 1996 October 10, 1996October 10, 1996 September 29, 1997September 29, 1997 August 2000August 2000 July 12,2002July 12, 2002

February 2004February 2004

July 2004July 2004

March 2005March 2005

July 11, 2007.Tuly 11,2007 May 16,2011May 16,2011 January 31,2012January 31, 2012

2

BACKGROUNDIII.III. BACKGROUND

Physical Characteristics -- The 10-acre OECI Site comprisescomprises 4-acres formerly occupied by thePliysical Characteristics The 10-acre OECI Site 4-acres formerly occupied by the OECI facility (bounded by Elm, Oak, and Eva Streets, and the Town of Ashippun's municipalmunicipalOECI facility (bounded by Elm, Oak, and Eva Streets, and the Town of Ashippun's garage), and 66 acres of adjacent wetland located to the south and west. Davy Creek flowsflowsgarage), and acres of adjacent wetland located to the south and west. Davy Creek tlirough the adjacent wetland approximately 500 feet south of the treatment facilitythrough the adjacent wetland approximately 500 feet south of the groundwatergroundwater treatment facility and is tributary to the Rock River. Several small businesses line Oak Street to the north andand is aa tributary to the Rock River. Several small businesses line Oak Street to the north and back up to the Chicago and North Western Railroad tracks. Residential areas lie west of Evaback up to the Chicago and Nmih Western Railroad tracks. Residential areas lie west of Eva Street and south of Elm. East of the municipal garage is baseball diamond and more residenfialStreet and south of Elm. East of the municipal garage is aa baseball diamond and more residential property. map of the OECI Site indicating the Site boundaries and the OUs is provided inpropeliy. AA map of the OECI Site indicating the Site boundaries and the OUs is provided in Attachment 1.Attachment 1.

Land and Resource Use -- The area immediately sUlTounding the OECI Site is aa mixture oflightLand and Resource Use The area immediately suiTounding the OECI Site is mixture of light industrial, commercial, municipal, and residential parcels. There is no public water supply andindustrial, commercial, municipal, and residential parcels. There is no public water supply and the Town relies on groundwater drawn from individual wells for business, municipal, andthe Town relies on groundwater drawn from individual wells for business, municipal, and residential use. Davy Creek is wann-water sport and there are two parks with facilitiesresidential use. Davy Creek is aa wann-water sport fisheryfishery and there are two parks with facilities for baseball, skeet shooting, and picnicking within quarter mile of the OECI Site.for baseball, skeet shooting, and picnicking within aa qumier mile of the OECI Site.

History of Contamination -- The OECr facility began operating in 1957. The plating processesHistory of Contamination The OECI facility began operating in 1957. The plating processes carried out there used nickel, chrome, zinc, copper, brass, cadmium, and tin. Contaminationcarried out there used nickel, chrome, zinc, copper, brass, cadmium, and tin. Contamination associated with the OECI Site came from spent process solutions, the transfer of material fromassociated with the OECI Site came from spent process solutions, the transfer of material from processing baths to rinses, accidental spills, leaks, plating tank systems, and sludge fromprocessing baths to rinses, accidental spills, leaks, plating tank filterfilter systems, and sludge from plating baths. Wastewater from the OECI facility contained cyanide compounds, cliromiumplating baths. Wastewater fi'om the OECI facility contained cyanide compounds, chromium compounds, and acid-alkaline solutions. In conjunction with electroplating, OECI also caiTiedcompounds, and acid-alkaline solutions. In conjunction with electroplating, OECI also calTied out degreasing operations that contributed to their waste stream. The volatile organic compoundsout degreasing operations that contributed to their waste stream. The volatile organic compounds (VOCs) used by OECI include chloroform, 1-1-dichloroethane, 1-2 dichloroethane, 1,1­(VOCs) used by OECI include chloroform, 1-1-dichloroethane, 1-2 dichloroethane, 1,1­dichloroethylene, tetrachloroethylene, 1,1,1-trichloroethane, and trichloroethylene.dichloroethylene, tetrachloroethylene, 1,1, I-trichloroethane, and trichloroethylene.

Prior to 1972 untreated wastewater was discharged directly into the wetland area south of thePrior to 1972 untreated wastewater was discharged directly into the wetland area south of the OECI property. In 1973 OECI installed wastewater treatment system and the WDNR issuedOECI propeliy. In 1973 OECI installed aa wastewater treatment system and the WDNR issued aa Wisconsin Pollution Discharge Elimination System (WPDES) permit for discharge to DavyWisconsin Pollution Discharge Elimination System (WPDES) permit for discharge to Davy Creek. OECI also constructed two unlined settling lagoons to supplement their wastewaterCreek. OECI also construct(~d two unlined settling lagoons to supplement their wastewater treatment system. Over the years, both lagoons accumulated large volumes of plating sludge andtreatment system. Over the years, both lagoons accumulated large volumes of plating sludge and supernatant, which overflowed the lagoons and accumulated in the wetlands between the OECIsupernatant, which overflowed the lagoons and accumulated in the wetlands between the OECI facility and Davy Creek. Contaminant spills from the wastewater treatment unit are wellfacility and Davy Creek. Contaminant spills from the wastewater treatment unit are well documented continued and in August 1978 WDNR revoked OECEs WPDES permit.documented continued and in August 1978 WDNR revoked OEeI's WPDES permit.

In 1979 the effects of the wastewater discharge and overflow were investigated by the SolidIn 1979 the effects of the wastewater discharge and overflow were investigated by the Solid Waste Management Division of the WDNR. Analytical results from sediment samples collectedWaste Management Division of the WDNR. Analytical results from sediment samples collected downstream of the OECI's discharge point to Davy Creek confinned high concentrations ofdownstream of the OECI's discharge point to Davy Creek confinned high concentrations of cadmium, cliromium, copper, and nickel. Aii analysis of surface soil samples collected fi'om thecadmium, chromium, copper, and nickel. An analysis of surface soil samples collected from the wetlands adjacent to the facility showed comparable concentrations of these metals.wetlands adjacent to the facility showed comparable concentrations of these metals.

Initial Response preliminary assessment was perfonned in May 1983 by U.S. EPA's FieldInitial Response -- AA preliminary assessment was perfOlmed in l\1ay 1983 by U.S. EPA's Field Investigation Team (FIT). The OECI Site (including the Davy Creek wetlands) receivedInvestigation Team (FIT). The OECI Site (including the Davy Creek wetlands) received aa

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Hazard Ranking Score (HRS) score of 31.86 and was placed on the National Priorities ListHazard Ranking Score (HRS) score of 31.86 and was placed on the National Priorities List (NPL) September 21, 1984.(NPL) September 21,1984.

In aa letter dated September 18, 1985 U.S. EPA notified OECl officials that they had beenIn letter dated September 18, 1985 U.S. EPA notified OECI officials that they had been identified as Potentially Responsible Party (PRP) under the Comprehensive Enviromnentalidentified as aa Potentially Responsible Patiy (PRP) under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) for the documented release or threatenedResponse, Compensation, and Liability Act (CERCLA) for the documented release or threatened release of hazardous substances. No other responsible parties have been named to date. Onrelease of hazardous substances. No other responsible patiies have been named to date. On October 9, 1985, OECI informed U.S. EPA that it did not have the resources to conductOctober 9, 1985, OECI informed U.S. EPA that it did not have the financialfinancial resources to conduct

Remedial Investigation/Feasibility Study (RI/FS) and formally declined to participate in theaa Remedial Investigation/Feasibility Study (RI/FS) and formally declined to patiicipate in the CERCLA process.CERCLA process.

Between 1983 and 1987 the WDNR sampled residential wells in the area on seven differentBetween 1983 and 1987 the WDNR sampled residential wells in the area on seven different occasions. In 1985 tliree shallow monhoring wells were installed by the Wisconsin Geologicaloccasions. In 1985 three shallow monitoring wells were installed by the Wisconsin Geological and History Survey (WGNHS). Two of these wells were located near the lagoons andand NaturalNatural History Survey (WGNHS). Two of these wells were located near the lagoons and one southeast of the OECI Site on the town garage property. Sampling demonstrated elevatedone southeast of the OECI Site on the town garage property. Sampling demonstrated elevated concentrations of cadmium, nickel, and zinc, in addition to the VOCs 1,1-dichloroethane, 1,1,1­concentrations of cadmium, nickel, and zinc, in addition to the VOCs 1, I-dichloroethane, 1,1,1­trichloroethane, and trichloroethylene.trichloroethane, and trichloroethylene.

In the summer of 1986 Technical Assistance Team (TAT), contractor to U.S. EPA'sIn the summer of 1986 aa Technical Assistance Team (TAT), aa contractor to U.S. EPA's Emergency Response Section conducted limited sediment sampling survey in the wetlands.Emergency Response Section conducted aa limited sediment sampling survey in the wetlands. The analytical results indicated high concentrations of metals and cyanide in the areaThe analytical results indicated high concentrations of metals and cyanide in the area immediately south of OECI. In March and April of 1987 the TAT conducted an extensiveimmediately south of OECl. In March and April of 1987 the TAT conducted an extensive sampling program that covered approximately 300 acres of the along Davy Creek. Thissampling program that covered approximately 300 acres of the wetlandswetlands along Davy Creek. This program also included sampling the OECI sludge lagoons and soil at the ballpark locatedprogram also included sampling the OECl sludge lagoons and soil at the ballpark located southeast of OECI. The analytical results indicated that the sludge and several acres of thesoutheast of OECl. The analytical results indicated that the sludge and several acres of the

adjacent to OECI were contaminated with cadmium, chromium, nickel, copper, zinc,wetlandswetlands adjacent to OECl were contaminated with cadmium, chromium, nickel, copper, zinc, (as high as 90,000 mg/kg in one area) and cyanide associated with the facility's electroplating(as high as 90,000 mg/kg in one area) and cyanide associated with the facility's electroplating process.process.

U.S. EPA used federal funds to perform the RI/FS after OECI declined to participate in theU.S. EPA used federal funds to perform the RIJFS after OECl declined to participate in the CERCLA process. U.S. EPA initiated the RI/FS in April 1987, and the report was completed inCERCLA process. U.S. EPA initiated the RI/FS in April 1987, and the repmi was completed in March 1990. Proposed Plan outlining U.S. EPA's cleanup strategy was presented to the publicMarch 1990. AA Proposed Plan outlining U.S. EPA's cleanup strategy was presented to the public on July 23, 1990.on July 23, 1990.

Basis for Taking Action -- Hazardous substances have been released at the Site. TheBasis for Taking Action Hazardous substances have been released at the Site. The contaminants found in each medium include:contaminants found in each medium include:

SoilSoil Lagoon Sludge/LiquidLagoon SludgelLiguid AcetoneAcetone AcetoneAcetone Ai senicArsenic Ai'senicArsenic CadmiumCadmium CadmiumCadmium Chi-omiumChromium Cln-omiumChromium CopperCopper CopperCopper CyanideCyanide CyanideCyanide 1,1 -Dichloroethane1,1-Dichloroethane 1,1 -Dichloroethane1,I-Dichloroethane

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SoilSoil 1,2-Dichloroethene (total)1,2-Dichloroethene (total) LeadLead Methylene ChlorideMethylene Chloride NickelNickel TetrachloroetheneTetrachloroethene TolueneToluene 1,1,I';Trichloroethane1,1,1 -Trichloroethane TrichloroethyleneTrichloroethylene XyleneXylene ZincZinc

GroundwaterGroundwater AcetoneAcetone CadmiumCadmium CyanideCyanide 1,1··Dichloroethane1,1 "Dichloroethane 1,2-Dichloroethane1,2-Dichloroethane 1,I-Dichloroethene1,1 -Dichloroethene 1,2··Dichloroethene (total)1,2-Dichloroethene (total) Melthylene ChlorideMethylene Chloride NickelNickel 1,1,1,1, I-Trichloroethane1 -Trichloroethane TrichloroethyleneTrichloroethylene Vinyl ChlorideVinyl Chloride

Lagoon Sludge/LiquidLagoon Sludge/Liquid EthylbenzeneEthylbenzene LeadLead Methylene ChlorideMethylene Chloride NickelNickel TetrachloroetheneTetrachloroethene TolueneToluene 1,1,1,1, I-Trichloroethane1 -Trichloroethane TrichloroethyleneTrichloroethylene XyleneXylene ZincZinc

Wetland SedimentWetland Sediment CadmiumCadmium ChromiumCln-omium CopperCopper CyanideCyanide LeadLead NickelNickel ZincZinc

Exposure to soil and groundwater contaminated with these compounds is associated withExposure to soil and groundwater contaminated with these compounds is associated with significant human health risks because they exceed U.S. EPA's risk management criteria.significant human health risks hecause they exceed U.S. EPA's risk management criteria. Contaminated groundwater presented the highest carcinogenic risk due to exposure by ingestion.Contaminated groundwater presented the highest carcinogenic risk due to exposure by ingestion. Soil contamina.ted with cadmium and lead posed the greatest non-carcinogenic risk to humanSoil contaminated with cadmium and lead posed the greatest non-carcinogenic risk to human health tluough demial contact and ingestion by children and people working at the OECI Site.health through del1nal contact and ingestion by children and people working at the GECI Site. Davy Creek and the wetlands area were contaminated with cadmium, chi'omium, nickel, copper,Davy Creek and the wetlands area were contaminated with cadmium, chromium, nickel, copper, lead, zinc and cyanide, and toxicity tests confirmed that these contaminants exceeded levelslead, zinc and cyanide, and toxicity tests confirmed that these contaminants exceeded levels known to be toxic to common aquatic species.known to be toxic to conUllon aquatic species.

IV.IV. REMEDIAL ACTIONSREMEDIAL ACTIONS

Remedy Selection ROD was signed for the OECI Site on September 20, 1990. TheRemedy Selection -- AA ROD was signed for the OECI Site on September 20, 1990. The Remedial Action Objectives (RAOs) were developed from data collected during the RI and theRemedial Action Objectives (RAOs) were developed from data collected during the RI and the selected remedy upon multiple removal activities to eliminate the sources of contaminationselected remedy reliedrelied upon multiple removal activities to eliminate the sources of contamination and restore contaminated groundwater. The RAOs sought to eliminate the principal threats byand restore contaminated groundwater. The RAOs sought to eliminate the principal threats by reducing the toxicity and mobility of the highly contaminated materials and reducing thereducing the toxicity and mobility of the highly contaminated materials and reducing the potential exposure to VOCs and metals.potential exposure to VOCs and metals.

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The ROD identified four OUs, and the selected remedy required the following remedial actions:The ROD identified four OUs, and the selected remedy required the following remedial actions:

•• Clean closure by excavation, treatment, and disposal at an off-site RCRA SubtitleClean closure by excavation, treatment, and disposal at an off-site RCRA Subtitle CC disposal facility for the impounded water, sludge and contaminated soils associated withdisposal facility for the impounded water, sludge and contaminated soils associated with the two RCRA Subtitle lagoons (OU-1)the two RCRA Subtitle CC lagoons (OU-1)

Treatment and disposal at an off-site RCRA Subtitle disposal facility for all other•• Treatment and disposal at an off-site RCRA Subtitle CC disposal facility for all other contaminated soil the OECI facility not associated with the RCRA lagoons orcontaminated soil aroundaround the OECI facility not associated with the RCRA lagoons or beneath the OECI buildings, including the area, the lowlands area, the drainagebeneath the OECI buildings, including the fillfill area, the lowlands area, the drainage ditches, and the parking lot (OU-2)ditches, and the parking lot (OU-2)

Construction and operation of groundwater extraction and treatment system to achieve•• Construction and operation of aa groundwater extraction and treatment system to achieve state groundwater quality standards for contaminated groundwater associated with thestate groundwater quality standards for contaminated groundwater associated with the Site, with treated water being discharged to Davy Creek in compliance with theSite, with treated water being discharged to Davy Creek in compliance with the substantive requirements of WPDES pennit (OU-3)substantive requirements of aa WPDES pennit (OU-3)

Excavation, treatment, and disposal at an off-site RCRA Subtitle disposal facility for•• Excavation, treatment, and disposal at an off-site RCRA Subtitle CC disposal facility for the most highly contaminated sediments in the Davy Creek wetlands area as an interimthe most highly contaminated sediments in the Davy Creek wetlands area as an interim action because cleanup goals had been established for contaminated sediment whenaction because cleanup goals had notnot been established for contaminated sediment when the ROD was signed, with additional monitoring of Davy Creek and the wetlandsthe ROD was signed, with additional monitoring of Davy Creek and the wetlands performed after the remediation to determine the effectiveness of the remedy (OU-4)performed after the remediation to determine the effectiveness of the remedy (OU-4)

1991 ESD added OU to authorize dismantling the abandoned facility and disposal ofAA 1991 ESD added aa fifthfifth OU to authorize dismantling the abandoned facility and disposal of associated debris, and aa 1994 ESD established the finalfinal cleanup goals for the adjacent wetlandsassociated debris, and 1994 ESD established the cleanup goals for the adjacent wetlands and Davy Creek.and Davy Creek.

Remedy Implementation -- On September 30, 1990, an Interagency Agreement was signed withRemedy Implementation On September 30, 1990, an Interagency Agreement was signed with the U.S. Army Corps of Engineers to perfonn Remedial Design (RD) for the Site. The RD wasthe U.S. Anny Corps of Engineers to perfonn aa Remedial Design (RD) for the Site. The RD was conducted in confonnance with the ROD as modified by the two ESDs. The RD was completedconducted in confonnance with the ROD as modified by the two ESDs. The RD was completed on June 30, 1993.on June 30, 1993.

Removal of the building and the hazardous chemicals began under remedial authorityRemoval of the building and the hazardous chemicals insideinside began under remedial authority April 27, 1991, and was completed March 31, 1992. The underlying soil also removed andApril 27, 1991, and was completed March 31,1992. The underlying soil waswas also removed and stockpiled because it posed significant thi-eat to surrounding residents. The hazardousstockpiled because it posed aa significant threat to surrounding residents. The hazardous chemicals and soil were subsequently hauled off for treatment at licensed hazardous wastechemicals and soil were subsequently hauled off for treatment at aa licensed hazardous waste treatment facility. U.S. EPA conducted pre-final inspection on March 21, 1992, and found notreatment facility. U.S. EPA conducted aa pre-final inspection on March 21, 1992, and found no outstanding construction items.outstanding construction items.

Remediation of the lagoons, stockpiled soil, and sediment in the and Davy Creek beganRemediation of the lagoons, stockpiled soil, and sediment in the wetlandswetlands and Davy Creek began in August 1994. The hazardous soil and sediment were removed for treatment and disposal at anin August 1994. The hazardous soil and sediment were removed for treatment and disposal at an approved hazardous waste treatment facility. U.S. EPA perfonned pre-final inspection inapproved hazardous waste treatment facility. U.S. EPA perfonned aa pre-final inspection in conjunction with the WDNR on June 12, 1995, and list of outstanding construction items wasconjunction with the WDNR on June 12, 1995, and aa list of outstanding construction items was subsequently addressed.subsequently addressed.

Construction of the groundwater extraction and treatment system began in May 1995. TheConstruction of the groundwater extraction and treatment system began in May 1995. The system became operational after U.S. EPA and WDNR conducted pre-final inspection insystem became operational after U. S. EPA and WDNR conducted aa pre-final inspection in

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September 1996 and determined that the had completed this portion of the remedy inSeptember 1996 and determined that the contractorcontractor had completed this portion of the remedy in accordance with the RD plans and specifications. The groundwater extraction and treatmentaccordance with the RD plans and specifications. The groundwater extraction and treatment system remained operational until its shutdown in July 2004.system remained operational until its shutdown in July 2004.

The entire Site achieved construction completion status when the Preliminary Close-Out ReportThe entire Site achieved construction completion status when the Preliminary Close-Out Report (PCOR) signed on September 25, 1996. The PCOR documents that U.S. EPA has completed(PCOR) waswas signed on September 25, 1996. The PCOR documents that u.S. EPA has completed all construction activities for the OECI Site in accordance with Procedures for Completion andall construction activities for the OECr Site in accordance with Procedures for Completion and Deletion of National Priorities List Sites and Update (OSWER Directive 9320.2-3C).Deletion of National Priorities List Sites and Update (OSWER Directive 9320.2-3C).

The remedial actions for OUs 1, 2, 4, and were completed between 1990 and 1996. At the timeThe remedial actions for OUs 1,2,4, and 55 were completed between 1990 and 1996. At the time of construction completion it expected that cleanup levels for all groundwater contaminantsof construction completion it waswas expected that cleanup levels for all groundwater contaminants (OU-3) would be reached within 30 years, as specified in the ROD. Nevertheless, WDNR(OU-3) would be reached within 30 years, as specified in the ROD. Nevertheless, WDNR retained an enviromnental consulting finn in the fall of to conduct comprehensiveretained an environmental consulting finTI in the fall of 20020011 to conduct aa comprehensive assessment of the groundwater e:<traction and treatment system. The study's repoitassessment of the groundwater extraction and treatment system. The study's finalfinal report identified the following conditions in February 2004:identified the following conditions in February 2004:

The high organic carbon content of the silty sand in the aquifer creates large•• The high organic carbon content of the silty sand in the aquifer creates aa large reservoirreservoir of TCE that is bound to the soil, limiting the migration of TCE away from the source areaofTCE that is bound to the soil, limiting the migration ofTCE away from the source area and the capacity of the groundwater extraction and treatment system to remediate theand the capacity of the groundwater extraction and treatment system to remediate the Site.Site.

•• The groundwater extraction and treatment system would need to operate for severalThe groundwater extraction and treatment system would need to operate for several hundred years to meet remedial standards under various pumping scenarios simulated byhundred years to meet remedial standards under various pumping scenarios simulated by groundwater contaminant fate and transport modeling.groundwater contaminant fate and transpOlt modeling.

•• Chemically reducing conditions in the aquifer are generally favorable to bacteria that canChemically reducing conditions in the aquifer are generally favorable to bacteria that can degrade chlorinated solvents tluough reductive dechlorination, and this degradationdegrade chlorinated solvents through reductive dechlorination, and this degradation process appears to be occurring based on observed distribution patterns of TCE, cis-1,2process. appears to be occurring based on observed distribution patterns of TCE, cis-1 ,2 DCE, and vinyl chloride.DCE, and vinyl chloride.

Based on these conclusions U.S. EPA authorized the shutdown of the treatment system in JulyBased on these conclusions U.S. EPA authorized the shutdown of the treatment system in July 2004 with the concun-ence of WDNR.2004 with the concurrence of WDNR.

The Remedial Action at the OECT Site has been federally because the only identifiedThe Remedial Action at the OEer Site has been federally financedfinanced because the only identified PRP foi-mally declined to participate in the CERCLA process. The NCP, 40 CFRPRP fOlmally declined to pmticipate in the CERCLA process. The NCP, 40 CFR §§ 300.435(f)(3), allows federally remedial actions to proceed for period up to ten years300.435(f)(3), allows federally financedfinanced remedial actions to proceed for aa period up to ten years after the remedy becomes Operational and Functional (O&F). U.S. EPA defines the ten yearafter the remedy becomes Operational and Functional (O&F). U.S. EPA defines the ten year period between the O&F determination and the start of Operation and Maintenance (O&M) asperiod between the O&F determ;ination and the stmt of Operation and Maintenance (O&M) as aa long-tenn response action (LTR.\). After the ten year LTRA, CERCLA, Section 104(c)(6),10ng-tenl1 response action (LTRA} After the ten year LTRA, CERCLA, Section 104(c)(6), provides the statutory basis for the transfer of federally ground water and surface waterprovides the statutory basis for the transfer of federally financedfinanced ground water and surface water restoration projects from U.S. EPA directed LTRA to State directed O&M program. Therestoration projects from aa U.S. EPA directed LTRA to aa State directed O&M program. The OECI Site was deemed O&F on May 7, 1999; the ten year LTR A. expired May 7, 2009.GECr Site was deemed O&F on May 7, 1999; the ten year LTRA expired May 7, 2009.

The transfer of the OECI Site to State led O&M program delayed by the shutdown of theThe transfer of the OECr Site to aa State led O&M program waswas delayed by the shutdown of the extraction and treatment system, which necessitated evaluating the potential ofgroundwatergroundwater extraction and treatment system, which necessitated evaluating the potential of

natural attenuaition (inlierent subsurface processes including volatilization, dispersion,natural attenuation (inherent subsurface processes including volatilization, dispersion, 77

adsorption, and biodegradation) to achieve remedial standards in aa reasonable period of timeadsorption, and biodegradation) to achieve remedial standards in reasonable period of time before fom1ally amending the ROD. After U.S. EPA determined that natural attenuation is aabefore fomially amending the ROD. After U.S. EPA determined that natural attenuation is viable altemative (see Section V, herein), the ROD was amended to change the selected remedyviable alternative (see Section V, herein), the ROD was amended to change the selected remedy for OD-3 from groundwater extraction and treatment to source area removal or in situ treatmentfor OU-3 from groundwater extraction and treatment to source area removal or in situ treatment and MNA, and monitoring program that will combine regular compliance monitoring with anand MNA, and aa monitoring program that will combine regular compliance monitoring with an ongoing analysis of natural attenuation parameters will be developed in cooperation with WDNRongoing analysis of natural attenuation parameters will be developed in cooperation with WDNR as part of the LTRA transfer.as pm1 of the LTRA transfer.

Institutional Controls -- Institutional Controls (ICs) are non-engineered instruments, such asInstitutional Controls Institutional Controls (ICs) are non-engineered instruments, such as administrative and/or legal controls, that help minimize the potential for exposure toadministrative and/or legal controls, that help minimize the potential for exposure to contamination and protect the integrity of the remedy. Compliance with ICs is required to ensurecontamination and protect the integrity of the remedy. Compliance with ICs is required to ensure long-tenn protectiveness for any areas that do not allow for unlimited use or um-estrictedlong-tenn protectiveness for any areas that do not allow for unlimited use or umestricted exposure (UU/UE).exposure (UU/UE).

Based on the RODs, cleanup goals for soil allow for and were based on commercial/ industrialBased on the RODs, cleanup goals for soil allow for and were based on commercial! industrial use; cleanup goals for groundwater were based on (eventual) unlimited use/unrestricted exposureuse; cleanup goals for groundwater were based on (eventual) unlimited use/umestricted exposure (UU/UE); cleanup goals for the wetlands were based on commercial/ industrial use; and cleanup(UD/DE); cleanup goals for the wetlands were based on conunercial! industrial use; and cleanup goals for the surface were the water quality standards and therefore no restrictions are required.goals for the surface were the water quality standards and therefore no restrictions are required. Table summarizes the ICs required for the OECI Site.Table 22 summarizes the ICs required for the OECI Site.

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Table 22 -- Institutional Controls Summarv T bla eeTable Institutional Controls Summary Tabl Media, Engineered , &&Media, Engineered ControlsControls Title of InstitutionalTitle of Institutional Areas that Do Not SupportAreas that Do Not Support IC ObjectiveIC Objective Control InstrumentControl Instrument UU/UE Based on CurrentUU/UE Based on Current ImplementedImplemented Conditions.Conditions. (note if planned)(note if planned)

Prohibit residential use;Prohibit residential use;

5*0/7- areas treated to industrial cleanup standards

alSoil- areas treated to industri cleanup standards

Prohibit interference except maintenance and protect integrity of the

Prohibit interference except maintenance and protect integrity of the

Under ReviewUnder Review

remedyremedy GroundwaterGroundwater -­ current area thattacurrent area th ProhibitProhibit groundwatergroundwater exceeds groundwater cleanupexceeds groundwater cleanup use until cleanupuse until cleanup Under ReviewUnder Review standardsstandards standards are achievedstandards are achieved

Prohibit residential use;Prohibit residential use; Prohibit interferenceProhibit interference

WetlandsWetlands except maintenance andexcept maintenance and Under ReviewUnder Review protect integrity of theprotect integrity of the remedyremedy

Surface Water (Davy Creek)-SllIface Water (Davy Creek)­cleaned up to water qualitycleaned up to water quality None requiredNone required Under ReviewUnder Review standardsstandards

Vapor PathwayVapor Pathway Pathway under investigation Pathway under investigation

Under ReviewUnder Review

Prohibit interferenceProhibit interference

Other Remedy ComponentsOther Remedy Components except maintenance and protect integrity of the except maintenance and protect integrity of the

Under ReviewUnder Review

~ remedyremedy

Maps which depict the current conditions of the Site and areas which do allow for UU/UEMaps which depict the current conditions of the Site and areas which do notnot allow for UUIUE will be developed as part of the GIS Registry or ICIAP or IC Plan discussed below.will be developed as part of the GIS Registry or ICIAP or IC Plan discussed below.

Status ofICs and Follow-up Actions: IC evaluation activities are in progress. TheseStatus of ICs and Follow-up Actions: IC evaluation activities are in progress. These activities include assessing Site ownership and detennining whether any prior-in-timeactivities include assessing Site ownership and detennining whether any prior-in-time encumbranees exist on the propeliies that require ICs to detennine if they would interfereencumbrances exist on the propeilies that require ICs to detennine if they would interfere with the ICs. Development of an ICIAP or IC Plan that incorporates the results of thewith the ICs. Development of an ICIAP or IC Plan that incorporates the results of the preliminary IC evaluation activities and plans for additional IC activities is needed, includingpreliminary IC evaluation activities and plans for additional IC activities is needed, including plmming for long-tenn stewardship and aa requirement for monitoring, maintaining andplanning for long-tenn stewardship and requirement for monitoring, maintaining and enforcing the ICs once implemented. In the meantime, consideration will be given to puttingenforcing the ICs once i]nplernented. In the meantime, consideration will be given to putting aa notice in the WDNR GIS Registry so that parties who may be interested in using ornotice in the WDNR GIS Registry so that parties who may be interested in using or purchasing the propeliy will be aware of the conditions at the Site, restrictions on its use, andpurchasing the property will be aware of the conditions at the Site, restrictions on its use, and any effects it may have on nearby properties.any effects it may have on nearby properties.

Current Compliance: Based on the Site inspection and interviews, no uses of the GECI SiteCurrent Compliance: Based on the Site inspection and interviews, no uses of the OECI Site were observed that are protective based upon the industrial use cleanup assumptions.were observed that are notnot protective based upon the industrial use cleanup assumptions. Furthennore, no one is using water that has contaminants above health-based standards (i.e..FU11hennorc, no one is using \vater that has contaminants above health-based standards (i.e.,

9

the federal Maximum Contaminant Level or the Wisconsin Enforcement Standard).the federal Maximum Contaminant Level or the Wisconsin Enforcement Standard).

Long Term Stewardship: Long-tem1 protectiveness at the Site requires compliance with theLong Term Stewardship: Long-term protectiveness at the Site requires compliance with the remedy and effective rcs to ensure that the remedy continues to function as intended. Toremedy and effective ICs to ensure that the remedy continues to fijnction as intended. To ensure proper maintenance, monitoring, and enforcement of effective rcs, long-termensure proper maintenance, monitoring, and enforcement of effective ICs, long-term stewardship (LTS) procedures will be reviewed and aa plan developed. The plan wouldstewardship (LTS) procedures will be reviewed and plan developed. The plan would include regular inspection of ICs at the Site and annual certification to U.S. EPA that ICs areincluderegular inspection ofICs at the Site and mmual certification to u.S. EPA that rcs are in place and effective. Additionally, use of communications plan and use of one-call systemin place and effective. Additionally, use of aa communications plan and use of one-call system should be explored for long term stewardship. In the meantime, as mentioned above,should be explored for long term stewardship. In the meantime, as mentioned above, consideration will be given to including the Site on the State's GIS Registry.consideration will be given to including the Site on the State's GIS Registry.

System Operations/Operation and MaintenanceSystem Operations/Operation and Maintenance -- The United States Army Corp of Engineers,The United States Army Corp of Engineers, on behalf of U.S. EPA, conducted the long-term groundwater monitoring and long-term responseon behalf of U.S. EPA, conducted the long-term groundwater monitoring and long-term response action for the groundwater extraction and treatment system under an interagency agreement fromaction for the groundwater extraction and treatment system under an interagency agreement from 1996 until the system was shut down in 2004. The primary activities associated with long-term1996 until the system was shut down in 2004. The primary activities associated with long-term response action for this period included:response action for this period included:

• Operation of the treatment plant 24 hours per day, seven days per week and treatingOperation of the treatment plant 24 hours per day, seven days per week and treating groundwater from all active groundwater extraction wellsgroundwater from all active groundwater extraction wells

• Periodic inspection and maintenance of groundwater extraction and monitoring wellsPeriodic inspection and maintenance of groundwater extraction and monitoring wells

• Inspection and maintenance of the treatment systemInspection and maintenance of the treatment system

• Weekly monitoring of treatment system influent and effluent to ensure compliance withWeekly monitoring of treatment system influent and effluent to ensure compliance with the substantial requirements of the WPDES pennitthe substantial requirements of the WPDES pennit

• Quarterly groundwater monitoringQuarterly groundwater monitoring

• Monthly reporting on treatment system monitoring and long-tenn response actionMonthly reporting on treatment system monitoring and long-tenn response action activities/problemsactivities/problems

U. s. EPA tasked its contractor to conduct environmental monitoring under the long-tennU.S. EPA tasked its contractor to conduct environmental monitoring under the long-tenn response action Groundwater Management Plan after the groundwater extraction and treatmentresponse action Groundwater Management Plan after the groundwater extraction and treatment system was shut down in 2004. The contractor prefomied the following activities:system was shut down in 2004. The contractor prefonned the following activities:

•• Quarterly compliance groundwater monitoringQuarterly compliance groundwater monitoring

•• Quarterly reports on the results of compliance groundwater monitoringQuarterly reports on the results of compliance groundwater monitoring

Site inspections•• Site inspections

Groundwater natural attenuation evaluation•• Groundwater natural attenuation evaluation

•• Treatment plant maintenanceTreatment plant maintenance

•• Grounds maintenanceGrounds maintenance

U.S. EPA conducted additionaladditional groundwatergroundwater sampling events in August 2010 and April 2011 atU.S. EPA conducted sampling events in August 2010 and April 2011 at 1010

private wells. u.s. EPA anticipates that routine compliance monitoring will resume once WDNRprivate wells. U.S. EPA anticipates that routine compliance monitoring will resume once WDNR assumes responsibility for O&M in September 2012.assumes responsibility for O&M in September 2012.

PROGRESS SINCE THE LAST FIVE-YEAR REVIEW (.July 11,2007)V.V. PROGRESS SINCE THE LAST FIVE-YEAR REVIEW (.luly I I , 2007)

Protectiveness statement from last review -- The remedy is currently protective ofhumanProtectiveness statement from last review The remedy is currently protective of human health and the environment in the short term. The removal of lagoon sludge, soils, debris andhealth and the environment in the short term. The rernoval oflagoon sludge, soils. debris and sediment to eliminate the source of contamination has achieved the remedial action objectives,sediment to eliminate the source ofcontamination has achieved the remedial action objectives. which were to minimize the migration of contaminants to gi'oundwater and surface water andwhich were to minimize the migration ofcontaminants to groundwater and sUlface water and prevent direct contact with, or ingestion of contaminated soils and sediments.prevent direct contact with, or ingestion of, contaminated soils and sediments.

However, in orderjor the reme(~v to be protective in the long-term, an assessment is necessary toHowever, in orderfor the remedy to be protective in the long-term, an assessment is necessary to determine thefuture effects ofshutting down the groundwater extraction and treatment system,determine the future effects of shutting down the groundwater extraction and treatment system, and institutional controls need to be implemented to ensure long-term protectiveness. The effectsand institutional controls need to be implemented to ensure long-term protectiveness. The effects ofshutting down the treatment system are currently being evaluated in conjimction with theofshutting down the treatment systern are currently being evaluated in conjunction with the efficacy of natural attenuation. Should VOC concentrations in nearby private wells approachefficacy ofnatural attenuation. Should VOC concentrations in nearby private wells approach risk-based standards, contingency actions will be implemented to reduce human exposure. Therisk-based standards, contingency actions will be implemented to reduce human exposure. The remedy will achieve long-term protectiveness when the groundwater cleanup standards areremedy will achieve long-term protectiveness ~vhen the groundH'ater cleanup standards are attained throughout the plume. Additionally, given that areas of Site do allow for unlimitedattained throughout the plume. Additionally, given that areas ofSite do notnot allow for unlimited use/unrestricted exposure, ICs will be needed to ensure protectiveness of the remedy.use/unrestricted exposure, Ies will be needed to ensure protectiveness ofthe remedy.

Issues and staltus of recommendations for follow-up actions from the last reviewIssues and status of recommendations for follow-up actions from the last review

This is the fourth FYR for the OECI Site. U.S. EPA completed the third FYR in 2007. TableThis is the fourth FYR for the GECI Site. U.S. EPA completed the third FYR in 2007. Table 33 summarizes the issues and recommendations from the 2007 FYR.summarizes the issues and recommendations from the 2007 FYR.

Table Actions Taken Since the Last Five Year ReviewTable 33 -- Acti'ons Taken Since the Last Five Year Review IssueIssue RecomraendaecommendaR PartyParty Mile­Mile- ActionAction Date ofDate of

tions/Follow-IllslFollow­ti( ResponsibleResponsible stonestone TakenTaken ActionAction up actions.1 actions"1 DateDate

Vinyl chloride in privateVinyl chloride in private Continue tomtinue toCc U.S. EPAu.s. EPA Fall ofFall of MonitoringMonitoring OngoingOngoing water supply wellswater supply wells monitor privatemitor privateme 20072007

wells:llsw(

Effectiveness of MNAEffectiveness ofMNA Evaluate thealuate theEv U.S. EPAU.S. EPA Fall ofFall of InvestigationInvestigation July 2009July 2009 effectiveness offectiveness ofef 20072007 and analysisand analysis MNANAM

f-----------~

ROD Amendment or ESDROD Amendment or ESD Prepare ancpare anPr U.S. EPAU.S. EPA Fall ofFall of AmendedAmended May 16,May 16, 1 amendment tolendment toarr 20072007 RODROD 20112011 the existing: existingthe signaturesignature

I------------~ ROD)DRC

Institutional ControlsInstitutional Controls Develop an IC:velop an ICDc U.S. EPAU.S. EPA 12/12/0712/12/07 Title searchTitle search June 26,June 26, 1 plananI

---------'---'­20092009

The status of actions taken at the GECI Site pursuant to the recommendations contained in theThe status of actions taken at the OECI Site pursuant to the recommendations contained in the 2007 FYR is as follows:2007 FYR is as follows:

1111

•

•

•

•

•

•

Issue: Vinyl chloride detects in private water supply wellsIssue: Vinyl chloride detects in private water supply wells

Recommendation: Continue to monitor private water supply wells adjacent to the GEC!Recommendation: Continue to monitor private water supply wells adjacent to the OECI Site for vinyl chloride as well as other volatile organic compounds. Should vinyl chlorideSitefor vinyl chloride as well as other volatile organic compounds. Shoidd vinyl chloride concentrations exceed risk-based standards', implement contingency actions to limitconcentrations exceed risk-based standards, implement contingency actions to limit human exposure.Imman exposure.

Status: Quarterly sampling of private water supply wells continued until U.S. EPA'sStatus: Quarterly sampling of private water supply wells continued until U.S. EPA's RAC ended in 2009. Additional samples were collected in 2010 and 2011 to ensureRAC ended in 2009. Additional samples were collected in 2010 and 2011 to ensure protectiveness. Samples have never exceeded risk based standards for human exposure.protectiveness. Samples have never exceeded risk based standards for human exposure. U.S. EPA conducted risk assessment on the water well contamination in February 2010U.S. EPA conducted aa risk assessment on the water well contamination in February 2010 looking at historical concentrations of methylene chloride, trichloroethylene, and vinyllooking at historical concentrations of methylene chloride, trichloroethylene, and vinyl chloride in the private water supply wells. The risk assessment concluded that thechloride in the private water supply wells. The risk assessment concluded that the historical concentrations in the residential wells are significantly below non-cancer riskhistorical concentrations in the residential wells are significantly below non-cancer risk screening levels, and the lifetime cancer risk for these wells is either below or within thescreening levels, and the lifetime cancer risk for these wells is either below or within the US EPA's acceptable cancer risk range. Therefore, based upon the historical data, the lowUS EPA's acceptable cancer risk range. Therefore, based upon the historical data, the low levels VOCs found in these private wells should not contribute to any detrimental healthlevels VOCs found in these private wells should not contribute to any detrimental health effects of those citizens using these wells for drinking or bathing puiposes.effects of those citizens using these wells for drinking or bathing purposes. This assessment was updated for this FYR and copy is included as Attachment 5.This riskrisk assessment was updated for this FYR and aa copy is included as Attachment 5. Trend analyses for select monitoring and private wells are included as Attachment 7.Trend analyses for select monitoring and private wells are included as Attachment 7.

Issue: Effectiveness of MNA and need for anyfuture actionsIssue: E.ffectiveness ofMNA and needfor anyfuture actions

Recommendation: Evaluate the effectiveness of MNA andplanfor potentialRecommendation: Evaluate the efj(xtiveness ofMNA and plan for potential enhcmcements to the MNA remedy and/or the need to restart the Groundwater extractionenhancements to the MNA remedy and/or the need to restart the Groundwater extraction and treatment system.and treatment system.

Status: An evaluation of natural attenuation was completed in July 2009. MNA refers toStatus: An evaluation of natural attenuation was completed in July 2009. MNA refers to remedy based on natural processes to achieve remedial objectives through reductions inaa remedy based on natural processes to achieve remedial objectives through reductions in

the mass, toxicity, mobility, volume, and the concentration of contaminants within timethe mass, toxicity, mobility, volume, and the concentration of contaminants within aa time frame that is reasonable. Natural attenuation processes acting on contaminants canframe that is reasonable. Natural attenuation processes acting on contaminants can include dilution, adsorption, advection and dispersion, volatilization, geochemicalinclude dilution, adsorption, advection and dispersion, volatilization, geochemical dynamics and chemical or biological transformation. Any of these processes individuallydynamics and chemical or biological transformation. Any of these processes individually or collectively can be significant and may affect the nature and distribution of theor collectively can be significant and may affect the nature and distribution of the contaminants in the subsurface environment.contaminants in the subsurface environment.

The Office of Solid Waste and Emergency Response (OSWER) Directive 9200.4-17The Office of Solid Waste and Emergency Response (OSWER) Directive 9200.4-17 (1997) identifies tlu-ee lines of evidence that can be used to demonstrate the occunence of(1997) identifies three lines of evidence that can be used to demonstrate the occurrence of natural attenuation in chlorinated aliphatic hydrocarbons, including the following:natural attenuation in chlorinated aliphatic hydrocarbons, including the following:

•• Documented loss of contaminants at the fieldfield scaleDocumented loss of contaminants at the scale

•• Documented presence and distribution of geochemical and biochemical indicators ofDocumented presence and distribution of geochemical and biochemical indicators of natural attenuationnatural attenuation

•• Direct microbiological evidenceDirect microbiological evidence 1212

••

••

•

Sampling used at the OECI Site to investigate the two lines of evidence.Sampling waswas used at the OECI Site to investigate the firstfirst two lines of evidence. Analyses performed by U.S. EPA's contractor provided evidence of the naturalAnalyses performed by L.S. EPA's contractor provided evidence of the natural attenuation of chlorinated VOCs (CVOCs) at the Site. The indicators supporting naturalattenuation of chlorinated YOCs (CYOCs) at the Site. The indicators supporting natural attenuation include:attenuation include:

• Detections of etheiie and ethane, the end biodegradation products of TCE and 1,1,1-Detections of ethene and ethane, the end biodegradation products of TCE and 1,1,1­TCA, documenting the loss of contaminants and supporting the line of evidenceTCA, documenting the loss of contaminants and supporting the firstfirst line of evidence for MNAfor MNA

Dissolved oxygen concentrations less than mg/L in the area of highest CVOC• Dissolved oxygen concentrations less than 11 mg/L in the area of highest CYOC detections, indicating anaerobic conditions conducive to the biodegradation ofdetections, indicating anaerobic conditions conducive to the biodegradation of CVOCs and supporting the second line of evidence of MNACYOCs and supporting the second line of evidence of MNA

• Dissolved iron, dissolved manganese, methane above background concentrations, andDissolved iron, dissolved manganese, methane above background concentrations, and nitrate concentrations below mg/L in the area of highest CVOCs, indicating thenitrate concentrations below 11 mg/L in the area of highest CYOCs, indicating the presence of reducing conditions needed for biodegradation, and also supporting thepresence of reducing conditions needed for biodegradation, and also supporting the second line of evidence of MNAsecond line of evidence ofMNA

• Chloride concentrations three to four times higher than background in the area ofChloride concentrations three to four times higher than background in the area of highest CVOC further support the second line of evidence of NFNAhighest CYOC detectionsdetections further support the second line of evidence of I\1NA because chloride is released as by-product during each step of the reductivebecause chloride is released as aa by-product during each step of the reductive de­de­chlorination processchlorination process

Issue: ROD Amendment or ESDIssue: ROD Amendment or ESD

Recommendation: Prepare an amendment to the existing ROD or an ESD to documentRecommendation: Prepare an amendment to the existing ROD or an ESD to document the decisions made concerning the shutdown of the groundwater extraction system at thethe decisions made concerning the shutdown ofthe groundwater extraction system at the OECI Site as well as the need forfuture actions.OEC! Site as well as the need/hrfiiture actions.

Status: ROD Amendment changing the selected remedy for OU-3 fromStatus: AA ROD Amendment changing the selected remedy for OU-3 from groundwatergroundwater extraction and treatment to source area removal or in situ treatment and MNA waswas signedextraction and treatment to source area removal or in situ treatment and MNA signed May 16, 2011. Under the amended remedy residual source areas will firstfirst be delineated toMay 16, 2011. Under the amended remedy residual source areas will be delineated to characterize the vertical and horizontal extent of contamination in the southeast area ofcharacterize the vertical and horizontal extent of contamination in the southeast area of the Site. Following delineation U.S. EPA will decide whether to excavate the sourcethe Site. Following delineation U.S. EPA will decide whether to excavate the source material and dispose of it offsite, or treat it in place using chemical reduction. Thismaterial and dispose of it offsite, or treat it in place using chemical reduction. This decision will be based on teclmical feasibility and cost, and U.S. EPA will issuedecision will be based on technical feasibility and cost, and U.S. EPA will issue aa statement presenting its rationale for choosing either excavation or in situ treatment. Anstatement presenting its rationale for choosing either excavation or in situ treatment. An MNA program incorporating the ongoing analysis of natural attenuation parameters andMNA program incorporating the ongoing analysis of natural attenuation parameters and regular compliance monitoring will be implemented to ensure continued protectivenessregular compliance monitoring will be implemented to ensure continued protectiveness and progress toward attainment of the remedial objectives. This amended remedy will beand progress toward attainment of the remedial objectives. This amended remedy will be more cost effective ttian the remedy originally selected for OU-3 and will achievemore cost effective than the remedy originally selected for OU-3 and will achieve cleanup standards in a shorter length of time while being equally protective of humancleanup standards in a shorter length of time while being equally protective of human health and the environment.health and the environment.

1313

• Issue: Effective Institutional Controls must be implemented, maintained and monitored.Issue: Effective Institutional Controls must be implemented, maintained and monitored.

Recommendation: An IC plan will be developed by U.S. EPA within months of the• Recommendation: An IC plan will be developed by us. EPA within 66 months ofthe Five Year Review completion. The IC plan will incorporate the results of the evaluationFive Year Review completion. The IC plan will incorporate the results ofthe evaluation activities andplan for additional IC activities as needed, including planningfor long­activities and plan for additional IC activities as needed, including planning for long­term stewardship.term stewardship.

Status: The implementation of effective institutional controls requires detennination of• Status: The implementation of effective institutional controls requires aa detennination of property ownership. U.S. EPA commissioned title search in 2009, which concluded thatproperty ownership. U.S. EPA commissioned aa title search in 2009, which concluded that OECI was administratively dissolved on December 28, 1991, and Dodge County refusedGECl was administratively dissolved on December 28,1991, and Dodge County refused to assume title due to enviromnental contamination. Both the Dodge County Treasurerto assume title due to environmental contamination. Both the Dodge County Treasurer and the Town of Ashippun Assessor confirmed that their records still show OECI as theand the Town of Ashippun Assessor confirmed that their records still show GECl as the owner. U.S. EPA is also in the process of resolving the disposition of unused property atowner. U.S. EPA is also in the process of resolving the disposition of unused property at the OECI Site. This unused property includes the treatment plant building and associatedthe GECl Site. This unused propeliy includes the treatment plant building and associated remedial process equipment. U.S. EPA will develop ICs that ensure long-termremedial process equipment. U.S. EPA will develop lCs that ensure long-term protectiveness for any areas that do not allow for unlimited use or unrestricted exposureprotectiveness for any areas that do not allow tor unlimited use or unrestricted exposure once clear title has been established and the disposition of unused property is settled.once clear title has been established and the disposition of unused property is settled.

1414

Details of the 2011 ROD Amendment -- Based on the results of the natural attenuationDetails of the 2011 ROD Amendment Based on the results of the natural attenuation evaluation, U.S. EPA commissioned aa Focused Feasibility Study (FFS) in 2010 to support theevaluation, U.S. EPA commissioned Focused Feasibility Study (FFS) in 2010 to support the development of aa ROD Amendment. The general objectives of this FFS included the following:development of ROD Amendment. The general objectives of this FFS included the following:

•• Identify site-specific RAOsIdentify site-specific RAOs

•• Develop general response actionsDevelop general response actions

•• Identify and screen applicable remedial teclinologies for effectiveness, implementability,IdentifY and screen applicable remedial teclmologies for effectiveness, implementability, and costand cost

•• Develop remedial alternativesDevelop remedial alternatives

•• Analyze the alternatives in accordance with the nine NCP criteriaAnalyze the alternatives in accordance with the nine Ncr criteria

The RAOs identified in the FFS for the ROD Amendment are as follows:The RAOs identified in the FFS for the ROD Amendment are as follows:

•• Prevention of future residential exposure to groundwater that exceeds federal MCLs orPrevention of future residential exposure to groundwater that exceeds federal MCLs or Wisconsin State Enforcement StandardsWisconsin State Enforcement Standards

•• Restoration of groundwater exceeding federal MCLs and Wisconsin State EnforcementRestoration of groundwater exceeding federal MCLs and Wisconsin State Enforcement Standards in aa reasonable timeframe given the site-specific circumstancesStandards in reasonable timeframe given the site-specific circumstances

Preliminary Remediation Ooals (PROs), or site-specific, quantitative goals that define the extentPreliminary Remediation Goals (PRGs), or site-specific, quantitative goals that define the extent of cleanup required, were then developed to achieve the RAOs. The PROs developed for theof cleanup required, were then developed to achieve the RAOs. The PRGs developed for the OECI Site were based on the following considerations:GECI Site were based on the following considerations:

•• Chemical-specific Applicable or Relevant and Appropriate Requirements (ARARs)Chemical-specific Applicable or Relevant and Appropriate Requirements (ARARs) including federal MCLs and State of Wisconsin Enforcement Standards forincluding SDWSDWAA federal MCLs and State of Wisconsin Enforcement Standards for groundwater. The State of Wisconsin PALs for groundwater are used to indicategroundwater. The State of Wisconsin PALs for groundwater are used to indicate aa potential exceedance of an Enforcement Standard. Action is not necessarily required forpotential exceedance of an Enforcement Standard. Action is not necessarily required for aa PAL exceedance.PAL exceedance.

•• The State of Wisconsin fresh water aquatic life criteria are included for surface waterThe State of Wisconsin fresh water aquatic life criteria are included for surface water basedbased on potentialpotential future risks as discussed previously. The federal National Oceanic andon fiiture risks as discussed previously. The federal National Oceanic and Atmospheric Administration (NOAA) fresh water aquatic life criteria are included forAtmospheric Administration (NOAA) fresh water aquatic life criteria are included for surface water as TBC criteria.surface water as TBe criteria.

summary of the PRGs for surface water and groundwater exposure pathways at the Site areAA summary of the PROs for surface water and groundwater exposure pathways at the Site are included in Tables and 5, respectively.included in Tables 44 and 5, respectively.

1515

TABLETABLE 44 Surface Water Preliminary Remediation GoalsSurface Water Preliminary Remediation Goals

Contaminant*Contaminant*

1,1, i-Trichloroethane1,1,1-Trichloroethane

1,1-Dichloroethane1,1-Dlchloroethane

1,1-Dichloroethene1,1-Dichloroethene

cis-1,2-DCEcis-1,2-DCE

trans-1,2-DCEtrans-1,2-DCE

TCETCE

VCVC

Notes:Notes:

Freshwater Aquatic UfeaFreshwater Aquatic Life' (J.Ig/L)(ijg/L)

ChronicChronic

1,3351,335

NANA

137137

NANA

571571

646646

NANA

Federal Freshwater AquaticFederal Freshwater AquaticbUfeLife"* (|jg/L)*** (J.Ig/L)

AcuteAcute ChronicChronic

200200 1111

830830 4747

450450 2525

1,1001,100 590590

1,1001,100 590590

NANA 2121

NANA 930930

aSecondary chronic values calculated based on WAC NR 105.06(6).^Secondary chronic values calculated based on WAC NR 105.06(6). bSource: Buchman, M.F., 2008. NOAA Screening Quick Reference Tables, NOAA OR&R Report 08-1,"Source: Buchman, M.F., 2008. NOAA Screening Quick Reference Tables, NOAA OR&R Report 08-1, Seattle WA, Office of Response and Restoration Division, National Oceanic and AtmosphericSeattle WA, Office of Response and Restoration Division, National Oceanic and Atmospheric Administration, 34 pages. *Site-related chemicals previously detected in surface water or theirAdministration, 34 pages. *SJte-related chemicals previously detected in surface water or their degradation productsdegradation products **Federal values included as TBC criteria**Federal values included as TBC criteria NA == Not Available; Adequate toxicity data were not available to develop secondary chronic values.NA Not Available; Adequate toxicity data were not available to develop secondary chronic values. IJg/L == micrograms per literpg/L micrograms per liter

1616

TABLE 5TABLE 5 Groundwater Preliminary Remediation GoalsGroundwater Preliminary Remediation Goals

ConltaminantContaminant

Volatile organic compounds (VQCs)Volatile organic compounds (VOCs)

1,1,1-Trichloroethane1,1,1-TrichIoroethane

1,1-Dichloroethane1,1-Dichloroethane

1,1-Dichloroethene1,1-Dichloroethene

cis-1,2-DCEcis-1,2-DCE

trans-1,2-DCEtrans-1,2-DCE

TCETCE

VCVC

Notes:Notes:

Federal SDWA MClaFederal SDWA MCL' (lJg/l)(Mg/L)

200200

NA

77

NA

7070

100

55

22

100

WI State ESESbWl State "

(lJg/l)(fg/L)

200200

850

77

850

7070

100

55

100

0.20.2

WI State PAlb* (lJg/l)Wl State P A L " * (jjg/L)

4040

8585

0.7

77

0.7

2020

0.50.5

0.020.02

a Source: http://www.epa.gov/safewater/contaminants/index.html ' Source: http://wviAA/.epa.gov/saf6;water/contaminants/index.html b Source: WAC NH 140.10"Source: WAC NR 140.10 *PAl is used to indicate the potential fOI" exceedance of an ES. Action is not necessarily required for aa PAI_*PAL is used to indicate the potential for exceedance of an ES. Action is not necessarily required for PAL exceedance.exceedance. SDWA -- Safe Drinking Water Act MClMCL -- maximum contaminant level SDWA Safe Drinking Water Act

maximum contaminant level ESES -- Enforcement StandardEnforcement Standard PAL -- Preventive Action LimitPAL Preventive Action Limit NA -- Not AvailableNA Not Available pg/L-micrograms per literIJg/l-micrograms per liter

1717

Consistent with the RAOs and PRGs, remedial and process options were identifiedConsistent with the RAOs and PRGs, remedial technologiestechnologies and process options were identified and screened, and the options that remained following screening were assembled into aa range ofand screened, and the options that remained following screening were assembled into range of alternatives. These encompassed alternatives in which treatment is used to reduce the toxicity,alternatives. These encompassed alternatives in which treatment is used to reduce the toxicity, mobility, or volume or wastes, butbut vary in degree to which long-term management of residuals ormobility, or volume or wastes, vary in degree to which long-term management of residuals or untreated waste is required.untreated waste is required.

Based on the risks present at the Site and the remaining remedial technologies and processBased on the risks present at the Site and the remaining remedial technologies and process options available after completion of the screening, the following alternatives were assembledoptions available after completion of the screening, the following alternatives were assembled and then evaluated against the seven criteria identified in the NCP:and then evaluated against the seven criteria identified in the NCP:

•• Alternative 1— No Further ActionAlternative I-No FUliher Action

• Alternative 2—Monitored Natural Attenuation (MNA)Alternative 2-Monitored Natural Attenuation (MNA)•

• Alternative 3—Source Area Removal or In Situ Treatment and MNAAlternative 3-Source Area Removal or In Situ Treatment and MNA•

•• Alternative 4—Source Area Removal or In Situ Treatment, Pump and Treat, and MNAAlternative 4-Source Area Removal or In Situ Treatment, Pump and Treat, and MNA

•• Alternative 5—Source Area Removal or In Situ Treatment, Substrate Injection, andAlternative 5-Source Area Removal or In Situ Treatment, Substrate Injection, and MNAMNA

The remedy selected for the OECI ROD Amendment is Alternative 3: Source Area Reinoval orThe remedy selected for the OECI ROD Amendment is Alternative 3: Source Area Removal or In Situ Treatment and MNA. The source area removal or in situ treatment component of theIn Situ Treatment and MNA. The source area removal or in situ treatment component of the remedial action will target the residual source areas by delineating the vertical andremedial action will target the residual source areas by firstfirst delineating the vetiical and horizontal extent of contamination in the southeast area of the Site. The information gatheredhorizontal extent of contamination in the southeast area of the Site. The infomiation gathered during delineation will then be used to select either excavation or in situ treatment to address theduring delineation will then be used to select either excavation or in situ treatment to address the residual contamination.residual contamination.

Both removal and in situ treatment meet the statutory requirement for using pemianent solutions.Both removal and in situ treatment meet the statutory requirement for using penllanent solutions. The decision to remove contaminated media from the source area or treat it in situ will beThe decision to remove contaminated media from the source area or treat it in situ will be detemiined by cost. Source zone excavation and offsite disposal is fast and efficient and has highdetetmined by cost. Source zone excavation and offsite disposal is fast and efficient and has aa high probability of eliminating the residual contamination. This option will be selected if significant soilprobability of eliminating the residual contamination. This option will be selected if significant soil contamination is limited to clays in the upper 10 feet of soil, and relatively little material fails thecontamination is limited to clays in the upper 10 feet of soil, and relatively little material fails the Toxicity Characteristic Leacliing Procedure limit of 0.5 milligrams per liter for TCE. ExcavationToxicity Characteristic Leaching Procedure limit of 0.5 milligrams per liter for TCE. Excavation and offsite treatment costs, however, increase significantly for deeper soils or soils that requireand offsite treatment costs, however, increase significantly for deeper soils or soils that require extensive offsite treatment to meet Land Disposal Regulations (LDRs). In this case the most cost­extensive offsite treatment to meet Land Disposal Regulations (LDRs). In this case the most cost­effective treatment is in situ chemical reduction. When the remedial design is complete andeffective treatment is in situ chemical reduction. When the remedial design is complete and aa method is selected, EPA will issue an ESD providing the rationale for its decision.method is selected, EPA will issue an ESD providing the rationale for its decision.

If excavation is feasible, the source area will be removed with readily available constructionIf excavation is feasible, the source area will be removed with readily available construction equipment followed by offsite disposal of the excavated material. Based on historical soilequipment followed by offsite disposal of the excavated material. Based on historical soil concentrations of TCE in the residual source area, it is unlikely the contaminated soils would beconcentrations ofTCE in the residual source area, it is unlikely the contaminated soils would be characterized as hazardous waste. Nevertheless, if the soil is found to be characteristiccharacterized as aa hazardous waste. Nevertheless, if the soil is found to be characteristic hazardous waste, RCRA Land Disposal Regulations (LDRs) would apply, and treatment will behazardous waste, RCRA Land Disposal Regulations (LDRs) would apply, and treatment will be can-ied out in accordance with RCRA prior to disposal, including treatment of other underiyingcan'ied out in accordance with RCRA prior to disposal, including treatment of other underlying hazardous constituents as required by 40 CFR 268.9(a). If excavation is not feasible, the sourcehazardous constituents as required by 40 CFR 268.9(a). If excavation is not feasible, the source area will be treated in situ by using zero valent iron to promote abiotic reduction of thearea will be treated in situ by using zero valent iron to promote abiotic reduction of the remaining VOCs.remaining VOCs.

1818

The estimated target areas of residual contamination indicated in the FFS were derived from theThe estimated target areas of residual contamination indicated in the FFS were derived from the soil gas survey conducted during the remedial investigation. EPA will refine the delineation ofsoil gas survey conducted during the remedial investigation. EPA will refine the delineation of both vertical and horizontal contaminant distribution during the remedial design using qualitativeboth vertical and horizontal contaminant distribution during the remedial design using qualitative methods. These methods will include visual inspection for evidence of dense non-aqueous phasemethods. These methods will include visual inspection for evidence of dense non-aqueous phase liquid (DNAPL) in conjunction v ith infoi-mation from membrane interface probe and soilliquid (DNAPL) in conjunction \vith information from aa membrane interface probe and soil samples gathered using direct push teclinologies. The goal of source area removal or in situsamples gathered using direct push teclmologies. The goal of source area removal or in situ treatment is 90% reduction in the contaminant mass once the vertical and horizontaltreatment is aa 90% reduction in the contaminant mass once the vertical and horizontal contaminant diistribution has been adequately characterized. Recognizing the cuiTent level ofcontaminant distribution has been adequately characterized. Recognizing the cunent level of uncertainty prior to conducting remedial design investigation, EPA will determine the bestuncertainty prior to conducting aa remedial design investigation, EPA will determine the best course of action after completion of the pre-design studies.course of action after completion of the pre-design studies.

The MNA component of the remedial action will rely on natural attenuation for remediation ofThe MNA component of the remedial action will rely on natural attenuation for remediation of the rest of the groundwater plume along with regular compliance monitoring to ensure thatthe rest of the groundwater plume along with regular compliance monitoring to ensure that residential wells already affected by low-level contamination remain below health-basedresidential wells already affected by low-level contamination remain below health-based standards. Natural attenuaticDn is the process by which contaminant concentrations are reduced bystandards. Natural attenuation is the process by which contaminant concentrations are reduced by one or more inlierent subsurface processes including volatilization, dispersion, adsorption, andone or more inherent subsurface processes including volatilization, dispersion, adsorption, and biodegradation. The alternative includes the ongoing analysis of natural attenuationbiodegradation. The MNMNAA alternative includes the ongoing analysis of natural attenuation parameters to ensure that the anaerobic conditions conducive to biological reductiveparameters to ensure that the anaerobic conditions conducive to biological reductive dechlorination of the Site VOCs remain present in the aquifer, and assess the degree of naturaldechlorination of the Site VOCs remain present in the aquifer, and assess the degree of natural attenuation that is occumng.attenuation that is OCCUlTing.

Institutional controls will be designed for the OECI Site in coordination with the WDNR (e.g.,Institutional controls will be designed for the OECI Site in coordination with the WDNR (e.g., deed restrictions such as easements and covenants, deed notices, land use restrictions such asdeed restrictions such as easements and covenants, deed notices, land use restrictions such as zoning and local penl1itting, ground-water use restrictions, and public health advisories) tozoning and local pemiitting, ground-water use restrictions, and public heahh advisories) to ensure the long-term protectiveness of the remedy.ensure the long-term protectiveness of the remedy.

AA copy of the 2011 ROD Amendment can be found at:copy of the 2011 ROD Amendment can be found at: http://www.epa.gov/i-egion5/cleanup/oconoinowoc/pdfs/oeci-rod-aiiiendinent-201111 .pdfhttp://www.epa.gov/region5/cleanup/oconomo\voc/pdfs/oeci-rod-amendment-20 llll.pdf

VLVI. FIVE-YEAR REVIEW PROCESSFIVE-YEAR REVIE\" PROCESS

Administrativl~ Components _. U.S. EPA notified WDNR of the impending FYR with aa letterAdministrative Components - U.S. EPA notified WDNR of the impending FYR with letter dated September 20, 2011. The OECI FYR was conducted by Bill Ryan of U.S. EPA, Remedialdated September 20,2011. The OECI FYR was conducted by Bill Ryan oflJ.S. EPA, Remedial Project for the OECI Site, assisted by Resty Pelayo, Project Manager for theProject ManagerManager for the OECI Site, assisted by Resty Pelayo, Project Manager for the Remediation and Redevelopment Program at WDNR. The components of the review included:Remediation and Redevelopment Program at WDNR. The components of the review included:

•• Cominunity NotificationCommunity Notification

•• Document ReviewDocument Review

•• Data ReviewData Review

•• Site InspectionSite Inspection

•• Five-Year Review Report Development and ReviewFive-Year Review Report Development and Review

The effort extended tln-ough April 2012.The eff0l1 extended tlu'ough April 2012. 1919

U.S. EPA initiated activities to involve theCommunity Notification and InvolvementCommunity Notification and Involvement -- U.S. EPA initiated activities to involve the community in the FYR process in March 2012 with aa public notice ad published on March 14,cominunity in the FYR process in March 2012 with public notice ad published on March 14, 2012, in the local newspaper (Watertown Daily Times) that aa FYR was to be conducted. Since2012, in the local newspaper (Watertown Daily Times) that FYR was to be conducted. Since the notice was issued, no member of the community voiced any interest or opinion concerningthe notice was issued, no member of the community voiced any interest or opinion concerning the FYR process. copy of the Public Notice ad is included in Attachment 4.the FYR process. AA copy of the Public Notice ad is included in Attachment 4.

Document Review This FYR consisted ofThis FYR consisted ofaa review of relevant documents includingDocument Review -- review of relevant documents including evaluation reports and monitoring data (See Attachment 2). Applicable groundwater cleanupevaluation reports and monitoring data (See Attachment 2). Applicable groundwater cleanup standards,standards, as listed in the 1990 ROD, were also reviewed.as listed in the 1990 ROD, were also reviewed.

The data review for this FYR focused primarily on the information used toData ReviewData Review -- The data review for this FYR focused primarily on the information used to support the ROD Amendment. After the treatment plant was shut down in July 2004, U.S. EPA'ssupport the ROD Amendment. After the treatment plant was shut down in July 2004, U.S. EPA's contractor continued quatierly environmental monitoring from October 2004 through Januarycontractor continued quarterly enviromnental monitoring from October 2004 thi-ough January 2009. Groundwater samples analyzed for compliance with applicable groundwater cleanup2009. Groundwater samples analyzed for compliance with applicable groundwater cleanup standards were obtained from 26 monitoring wells and 111 private water supply wells, and naturalstandards were obtained from 26 monitoring wells and 1 private water supply wells, and natural attenuation parameters were obtained from 222 of the monitoring wells. Three surface waterattenuation parameters were obtained from 2 of the monitoring wells. Tliree surface water samples were also analyzed quatierly. Observations from the sampling program over thissamples were also analyzed quarterly. Observations from the sampling program over this timeframe include the following:timeframe include the following:

•• Chlorinated compounds, including TCE and vinyl chloride (VC), continue to be detectedChlorinated compounds, including TCE and vinyl chloride (YC), continue to be detected in groundwater from downgradient bedrock monitoring wells and private water supplyin groundwater from downgradient bedrock monitoring wells and private water supply wells. Although concentrations of VOCs in the private wells are all below thewells. Although concentrations of YOCs in the private wells are all below the Enforcement Standard (ES), and many below the Preventive Action Limit (PAL)^,Enforcement Standard (ES), and many below the Preventive Action Limit (PALi, detections have persisted since sampling the private wells began in July 2005.detections have persisted since sampling the private wells began in July 2005.

•• The extent of CVOC contamination does not appear to be migrating in the shallow andThe extent of CYOC contamination does not appear to be migrating in the shallow and deep unconsolidated units. Trends at the private wells with detections of CVOCs appeardeep unconsolidated units. Trends at the private wells with detections of CYOCs appear to show that parent compounds are generally absent or stable at low concentrations, withto show that parent compounds are generally absent or stable at low concentrations, with degradation products increasing.degradation products increasing.

•• Chlorinated compounds were found at two surface water sampling locations. OneChlorinated compounds were found at two surface water sampling locations. One location is in close contact with shallow unconsolidated groundwater and theselocation is in close contact with shallow unconsolidated groundwater and these compounds are potentially Site related. The other location is nearly 1,000 feetcompounds are potentially Site related. The other location is nearly 1,000 feet downstream, and the compounds detected there may not be Site related because theydownstream, and the compounds detected there may not be Site related because they would not come from upstream and persist in open water due to their volatility. Inwould not come from upstream and persist in open water due to their volatility. In addition, upgradient sentinel wells between this location and the source areas do notaddition, upgradient sentinel wells between this location and the source areas do not exhibit detections of VOCs.exhibit detections of YOCs.

22 These standards are found in Ch. NR 140, Wisconsin Administrative Code for Preventative Action Limits (PAL)These standards are found in Ch. NR 140, Wisconsin Administrative Code for Preventative Action Limits (PAL) and Enforcement Standard (ES) for respective compounds. The WDNR ES values typically coirespond to U.S.and Enforcement Standard (ES) for respective compounds. The WDNR ES values typically cOlTespond to U.S. EPA's Maximum Concentration Limits (MCLs). The preventive action limit represents lesser concentration of theEPA's Maximum Concentration Limits (MCLs). The preventive action limit represents aa lesser concentration of the substance than the enforcement standard. The PAL is set at 10%, 20%, or ) of the enforcement standard assubstance than the enforcement standard. The PAL is set at 10%,20%, or 50%50% of the enforcement standard as specified by staftate based on the health-related characteristics of the particular substance. Ten percent is used forspecified by statute based on the health-related characteristics of the particular substance. Ten percent is used for cancer-causing substances, ) for substances with other health effects and o for substances having aesthetic orcancer-causing substances, 20%20% for substances with other health effects and 50%50% for substances having aesthetic or other public-welfare concems.other public-welfare concems.

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The and second lines of evidence, as outlined in OSWER Directive 9200.4-17P•• The firstfirst and second lines of evidence, as outlined in OSWER Directive 9200A-17P (OSWER, 1999), indicate that natural attenuation is ongoing at the OECI Site. The firstfirst(OSWER, 1999), indicate that natural attenuation is ongoing at the OECI Site. The line of evidence is documented loss of primary contaminants at the scale: TCEline of evidence is aa documented loss of primary contaminants at the fieldfield scale: TCE concentrations are steady overall and degradation products such as cis-l,2-DCE andconcentrations are steady overall and degradation products such as cis-l ,2-DCE and VVCC are present in all three hydrogeologic units. The second line of evidence is theare present in all tlu"ee hydrogeologic units. The second line of evidence is the documented presence and distribution of geochemical and biochemical indicators ofdocumented presence and distribution of geochemical and biochemical indicators of natural attenuation including conventional parameters such as chloride, dissolved iron,natural attenuation including conventional parameters such as chloride, dissolved iron, methane, and parameters such as the Oxidation Reduction Potential, Dissolvedmethane, and fieldfield parameters such as the Oxidation Reduction Potential, Dissolved Oxygen, and pH.Oxygen, and pH.

•• Screening for evidence of anaerobic biodegradation processes based on the method ofScreening for evidence of anaerobic biodegradation processes based on the method of Wiederneier et al. (1998)' was perfonned for the OECI Site and the results indicate thatWiedemeier et al. (l998i was perfonned for the OECI Site and the results indicate that adequate evidence for natural attenuation by anaerobic biodegradation is present withinadequate evidence for natural attenuation by anaerobic biodegradation is present within all three hydrogeological units that comprise the impacted systemalltlu'ee hydrogeological units that comprise the impacted groundwatergroundwater flowflow system (shallow unconsolidated, deep unconsolidated, and bedrock units). Nevertheless,(shallow unconsolidated, deep unconsolidated, and bedrock units). Neveliheless, biodegradation capacities in these hydrogeological units appear to have been reduced onbiodegradation capacities in these hydrogeological units appear to have been reduced on

site-wide basis when compared to historical data.aa site-wide basis when compared to historical data.

SiteSite InspectionInspectioll-- Bill Ryan of U.S. EPA, and Resty Pelayo of the Remediation andBill Ryan of U.S. EPA, and Resty Pelayo of the Remediation and Redevelopment Program at WDNR conducted the FYR site inspection on January 31, 2012. U.S.Redevelopment Program at WDNR conducted the FYR site inspection on January 31, 2012. U.S. EPA's was on-site conducting the RD investigation for the new selected remedy. TheEPA's contractorcontractor was on-site conducting the RD investigation for the new selected remedy. The treatment plant building and idle process equipment were found in good condition, the fencingtreatment plant building and idle process equipment were found in good condition, the fencing was intact, and there no evidence of vandalism or destructive mischief.was intact, and there waswas no evidence of vandalism or destructive mischief.

InterviewsInterviews -- Interviews with individuals beyond the FYR project team were not conducted.Interviews wiIh individuals beyond the FYR project team were not conducted. Since the newspaper ad was placed, no community member or other individual voiced anySince the newspaper ad was placed, no community member or other individual voiced any interest in conducting an interview related to the FYR.interest in conducting an interview related to the FYR.

VII.VII. TECHNICAL ASSESSMENTTECHNICAL ASSESSMENT

Question A: Is the remedy ftinctioning as intended by the decision documents?Question A: Is the remedy functioning as intended by the decision documents?

Yes -- The review of documents, ARARs, risk assumptions, and the results of the site inspectionYes The review of documents, ARARs, risk assumptions, and the results of the site inspection indicate that the remedy has functioned as intended by the 1990 ROD, and as modified by theindicate that the remedy has functioned as intended by the 1990 ROD, and as modified by the 1991 and 1994 ESDs. The removal of lagoon contaminated soil, contaminated sediment,1991 and 1994 ESDs. The removal of lagoon sludge,sludge, contaminated soil, contaminated sediment, foiTner facility and associated debris has minimized the migration of contaminants toformer facility and associated debris has minimized the migration of contaminants to groundwater and surface water and prevented ingestion or direct contact with contaminatedgroundwater and surface water and prevented ingestion or direct contact with contaminated media. Operating the groundwater extraction and treatment system for eight years stabilized themedia. Operating the groundwater extraction and treatment system for eight years stabilized the contaminant plume, and implementing the selected remedy for OU-3 under the 2011 RODcontaminant plume, and implementing the selected remedy for OU-3 under the 2011 ROD Amendment should address the residual sources of contamination and allow natural attenuationAmendment should address the residual sources of contamination and allow natural attenuation to achieve cleanup goals in reasonable period offline while groundwater monitoring ensuresto achieve cleanup goals in aa reasonable period of time while groundwater monitoring ensures

Technical Protocol for Evaluating Natural Attenuation of Chlorinated Solvents in Groundwater: EPA/600/R­33 Technical Protocol for Evaluating Natural Attenuation of Chlorinated Solvents in Groundwater: EPA/600/R­98/12898/128

2121

that exposure to site-related contaminants remains below risk-based standards.that exposure to site-related contaminants remains below risk-based standards.

Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial actionOuestion B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy selection still valid?objectives (RAOs) used at the time of the remedy selection still valid?

Yes -- The exposure assumptions used to develop the baseline Human Health Risk AssessmentYes The exposure assumptions used to develop the baseline Human Health Risk Assessment for the 1990 ROD included both cun-ent exposures and potential future exposures. There havefor the 1990 ROD included both cun-ent exposures and potential future exposures. There have been no changes in the toxicity factors for the contaminants of concern used in the baseline riskbeen no changes in the toxicity factors for the contaminants of concern used in the baseline risk assessment that would affect the current Site remediation goals. These assumptions areassessment that would affect the cun-ent Site remediation goals. These assumptions are considered to be conservative and reasonable in evaluating risk and developing risk-basedconsidered to be conservative and reasonable in evaluating risk and developing risk-based cleanup levels. Nevertheless, there has been change in the toxicity value for TCE that wouldcleanup levels. Nevertheless, there has been aa change in the toxicity value for TCE that would impact the soil gas screening level for vapor intrusion. U.S. EPA's contractor conducted vaporimpact the soil gas screening level for vapor intrusion. U.S. EPA's contractor conducted aa vapor intrusion evaluation in 2005, prior to the change in the toxicity value, and drew the followingintrusion evaluation in 2005, prior to the change in the toxicity value, and drew the following conclusion:conclusion:

During the RI, aa soil gas survey was pCl10rmed, including off-site locations nearDuring the RI, soil gas survey was performed, including off-site locations near residential dwellings, and no organic vapors were detected at any off-siteresidential dwellings, and no organic vapors were detected at any off-site location. Since that time, source areas have been removed, VOC concentrationslocation. Since that time, source areas have been removed, VOC concentrations in groundwater have been significantly reduced, and VOCs within thein groundwater have been significantly reduced, and VOCs within the unsaturated zone have likely volatilized;volatilized; thus vapor intrusion into the residentialunsaturated zone have likely thus vapor intrusion into the residential dwellings in highly unlikely.dwellings in highly unlikely.

Given the findingsfindings from 2005, U.S. EPA has aa reasonable expectation that the exposure pathwayGiven the from 2005, U.S. EPA has reasonable expectation that the exposure pathway is incomplete. Nevertheless, because the toxicity value for TCE went from 30 ug/m3 to 10.7is incomplete. Nevertheless, because the toxicity value for TCE went from 30 ug/m3 to 10.7 ug/m3, aa vapor intrusion investigation is plmmed for summer 2012 to ensure continuedug/m3, vapor intrusion investigation is planned for summer 2012 to ensure continued protectiveness based on the new toxicity values. There have been no other changes to theprotectiveness based on the new toxicity values. There have been no other changes to the standardized risk assessment methodology that could affect the protectiveness of the remedy.standardized risk assessment methodology that could affect the protectiveness of the remedy.

Changes in Standards and To be ConsideredChanges in Standards and To be Considered

As the remedial 'York has been completed, most ARARs for sediment, soil and debrisAs the remedial work has been completed, most ARARs for sediment, soil and debris contamination cited in the ROD have been met. ARARs that still must be met at this time andcontamination cited in the ROD have been met. ARARs that still must be met at this time and that have been evaluated include: The Safe Drinking Water Act (SDWA)(40 CFR 141.11­that have been evaluated include: The Safe Drinking Water Act (SDWA)(40 CFR 141.11­141.16) and the state of Wisconsin groundwater quality standards (Ch. NR 140, WAC. Chapter141.16) and the state of Wisconsin groundwater quality standards (Ch. NR 140, WAC. Chapter 160, Wis. Stats.) from which many of the groundwater cleanup levels were derived -- [Maximum160, Wis. Stats.) from which many of the groundwater cleanup levels were derived [Maximum Contaminant Levels (MCLs), MCL Goals (MCLGs), and NR 140 Preventative Action LimitsContaminant Levels (MCLs), MCL Goals (MCLGs), and NR 140 Preventative Action Limits (PALs)]. ARARs are included in Attaclunent 3. There have been no changes in these ARARs(PALs)]. ARARs are included in Attaclmient 3. There have been no changes in these ARARs and no new standards or to be considered (TBCs) affecting the protectiveness of the remedy.and no new standards or to be considered (TBCs) affecting the protectiveness of the remedy.

Changes in Exposure Pathways, Toxicity, and Other Contaminant CharacteristicsChanges in Exposure Pathways, Toxicity, and Other Contaminant Characteristics

The exposure assumptions used to develop the Human Health RiskRisk Assessment includedThe exposure assumptions used to develop the Human Health Assessment included exposure to contaminated groundwater and soils from possible future ingestion pathway, andexposure to contaminated groundwater and soils from aa possible future ingestion pathway, and exposure to contaminated soils from aa possible future dermal contact pathway. The exposureexposure to contaminated soils from possible future dermal contact pathway. The exposure assumptions used to develop the ecological assessment for Davy Creek and the adjacentassumptions used to develop the ecological assessment for Davy Creek and the adjacent

2222

wetiands area included high toxicity to various aquatic species from high metal concentrations.wetlands area included high toxicity to various aquatic species from high metal concentrations. Toxicity tests confirmed these expectations.Toxicity tests confinned these expectations.

There have been no changes in the toxicity factors for the contaminants of concem used in theThere have been no changes in tiie toxicity factors for the contaminants of concern used in the baseline risk assessment that would affect remedial goals. These assumptions are considered tobaseline risk assessment that would affect remedial goals. These assumptions are considered to be conservative and reasonable in evaluating risk and developing risk-based cleanup levels. Nobe conservative and reasonable in evaluating risk and developing risk-based cleanup levels. No change to these assumptions or the cleanup levels developed from them is wairanted. Tliere haschange to these assumptions or the cleanup levels developed from them is walTanted. There has been no change to the standardized risk assessment methodology that could affect thebeen no change to the standardized risk assessment methodology that could affect the protectiveness of the remedy.protectiveness of the remedy.

Question C: Has any other infol111ation come to light that could call into question theOuestion C: Has any other infomiation come to light that could call into question the protectiveness of the remedy?protectiveness of the remedy1

NoNo -- The 2007 FYR noted that vinyl chloride was detected at low concentrations in nearbyThe 2007 FYR noted that vinyl chloride was detected at low concentrations in nearby private water supply wells in July 2005. It is possible that these low levels were present beforeprivate water supply wells in July 2005. It is possible that these low levels were present before 2005, but it change in the method detection limit for analyses conducted by new2005, but it waswas aa change in the method detection limit for analyses conducted by aa new contractor that brought these conditions to the attention of U.S. EPA. U.S. EPA conducted riskcontractor that brought these conditions to the attention of U.S. EPA. U.S. EPA conducted aa risk assessment on the water well contamination in February 2010 looking at historicalassessment on the water well contamination in February 2010 looking at historical concentrations of methylene chloride, trichloroethylene, and vinyl chloride in the private waterconcentrations of methylene chloride, trichloroethylene, and vinyl chloride in the private water supply wells. The risk assessment concluded that the historical concentrations in the residentialsupply wells. The risk assessment concluded that the historical concentrations in the residential wells are significantly below non-cancer risk screening levels and the lifetime cancer risk forwells are significantly below non-cancer risk screening levels and the lifetime cancer risk for these wells is either below or within the US EPA's acceptable cancer risk range. Therefore,these wells is either below or within the US EPA's acceptable cancer risk range. Therefore, based upon the historical data, the low levels VOCs found in these private wells should notbased upon the historical data, the low levels VOCs found in these private wells should not contribute to any detrimental health effects of those citizens using these wells for drinking orcontribute to any detrimental health effects of those citizens using these wells for drinking or bathing pui-poses. This risk assessment was updated for this FYR and copy is included asbathing purpos,~s. This risk assessment was updated for this FYR and aa copy is included as Attachment 5.Attachment 5.

Technical Assessment SummaryTechnical Assessment Summary

According to the data reviewed and the Site inspections, the remedy has functioned as intendedAccording to the data reviewed and the Site inspections, the remedy has ftinctioned as intended by the ROD, as modified by the ESDs. There have been no changes in the physical conditions ofby the ROD, as modified b}' the ESDs. There have been no changes in the physical conditions of the Site that would affect the protectiveness of the remedy. Most ARARs for soil contaminationthe Site that would affect the protectiveness of the remedy. Most ARARs for soil contamination cited in the ROD have been met. Nevertheless, there has been aa change in the toxicity value forcited in the ROD have been met. Nevertheless, there has been change in the toxicity value for TCE that would impact the soil gas screening level for vapor intrusion. The value for TeE wentTCE that would impact the soil gas screening level for vapor intrusion. The value for TC'E went from 30 ug/m3 to 10.7 ug/m3. AA vapor intrusion investigation is planned for summer 2012 to seefrom 30 ug/m3 to 10.7 ug/ni3. vapor intrusion investigation is planned for summer 2012 to see whether unacceptable risks are present at the nearby residences due to site-related. There is nowhether unacceptable risks are present at the nearby residences due to site-related. There is no other infonnation that calls into question the protectiveness of the remedy.other infOlmation that calls into question the protectiveness of the remedy.

2323

ISSUESVIII.VIII. ISSUES

Table 66 - IssuesTable - Issues

CurrentlyCurrently Affects FutureAffects Future

AffectsAffectsIssue ProtectivenessIssue Protectiveness

ProtectivenessProtectiveness (Y/N)(YIN)

(YIN)(YIN)

Low levels of vinyl chloride in nearby private water supplyLow levels of vinyl chloride in nearby private water supply NN Yy

wells

The potential for vapor intrusion NN Yy

wells

The potential for vapor intrusion

yInstitutional ControlsInstitutional Controls NN Y

RECOMMENDATIONS AND FOLLOW-UP ACTIONS

T a a IOns anan Follow-Up Actions

IX.IX. RECOMMENDATIONS AND FOLLOW-UP ACTIONS

Tablbiee 77 -- RecommendationsRecommend f dd F0 IIow-UJp AcfIOns

AffectsAffects

IssueIssue Recommendations/ Follow-up Actions Recommendations/ Follow-up Actions

Party Responsible

Party Responsible

Oversight Agency

Oversight Agency

Milestone Date

Milestone Date

Protectiveness? (Y/N)

Protectiveness? (YIN)

CurrentCurrent FutureFutUl'e

Continue to monitorContinue to monitor private water supplyprivate water supply wells adjacent to thewells adjacent to the OECI Site for vinylOECI Site for vinyl

Low levels of vinyl chloride in nearby private water supply wells

Low levels of vinyl chloride in nearby private water supply wells

chloride and other volatile organic compounds and implement contingency actions to limit human

chloride and other volatile organic compounds and implement contingency actions to limit human

U.S.EPA WDNR U.S.EPA // WDNR

U.S.EPA/ WDNR

U.S. EPA/ WDNR 12/30/201212/30/2012 NN Yy

exposure if vinylexposure ifvinyl chloridechloride concentrationsconcentrations exceed risk-basedexceed risk-based standards.standards.

Collect deep soil gasCollect deep soil gas

The potendalThe potential samples to ensure that VI is not samples to ensure that VI is not

for vapor intrusion for vapor intrusion

impacting residential properties near the impacting residential properties near the

U.S.EPA/ WDNR

U.S.EPA/ WDNR

U.S. EPA WDNR

U.S. EPA // WDNR 12/30/201212/30/2012 NN Yy

Site. Sub-slab soilSite. Sub-slab soil gas and indoor airgas and indoor air sampling should besampling should be

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AffectsAffects

IssueIssue Recommendations/ Follow-up Actions

lsi ns

datiOl Actio

Recommen Follow-up _

Party Responsible

Party Responsible

Oversight Agency

Oversight Agency

Milestone Date

Milestone Date

Protectiveness? (Y/N)

Protectiveness? (YIN)

CurrentCurrent FutureFuture

conducted if TCE isliSTCEconducted if detected in deep soilIiIeep scdetected in d gas at levels aboveabovegas at levels the cuirent IIthe cunent VV screening level.el.screening lev

To ensure that theIt theTo ensure th: remedy continues o0nues ttremedy conti function as intended,d,ltenelefunction as il prepare an IC'IAP'lAPprepare an Ie which will includeeluelewhich will in evaluation of existingngexistlevaluation of ICs; the development:ntlopmcICs; the deve and implementationnltatioand implemeJ of effectiveof effective institutional controlsIsantrainstitutional c (ICs) and long-termIg-tem(ICs) and Ion procedures to ensure"eensUlprocedures to that effective ICs arereICs athat effective

Institutional controls Institutional controls

monitored, maintained and enforced. The State

lei

State

monitored, maintained at

enforced. The U.S.EPA/

WDNR U.S.EPA/

WDNR U.S.EPA/

WDNR U.S. EPA/

WDNR 12/30/201212/30/2012 NN YY

should also consider putting a notice in the WDNR GIS

rmside :e in IS

should also c( putting a noti. the WDNRG Registi-y so that parties interested in using or purcliasing the propei-ty will be aware of the

at ted in lasing viII be

Registry so til parties interes using or purcl the propelty \ aware of the conditions at the Site, restrictions on its

:e,he Sil its

conditions at J:

restrictions on use, and effects it may have on nearby properties.

!

ts it learb)

use, and effec may have on I propel1ies.

X.x. Protectiveness StatementProtectiveness Statement

The remedy is currently protective of human health and the enviromnent in the short tenn. TheThe remedy is currently protective of human health and the envirorunent in the short teml. The reinoval of lagoon sludge, contaminated soil, contaminated sediment, former facility, andremoval of lagoon sludge, contaminated soil, contaminated sediment, former facility, and associated debris has achieved the remedial action objectives of minimizing the migration ofassociated debris has achieved the remedial action objectives of minimizing the migration of contaminants to groundwater and surface water and preventing ingestion or direct contact withcontaminants to groundwater and surface water and preventing ingestion or direct contact with contaminated media.contaminated media.

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The following actions are needed for the remedy to remain protective in the long-term: removalThe following actions are needed for the remedy to remain protective in the long-term: removal or in situ treatment of residual source areas, completion of aa vapor intrusion analysis, continuedor in situ treatment of residual source areas, completion of vapor intrusion analysis, continued groundwatergroundwater monitoring, and development and implementation of effective institutional controlsmonitoring, and development and implementation of effective institutional controls (ICs). The remedy will achieve completion when groundwater cleanup standards are attained(ICs). The remedy will achieve completion when groundwater cleanup standards are attained throughout the contaminant plume.throughout the contaminant plume.

Next ReviewXl.XI. Next Review

The next FYR for the OECI Site is required within years of the signature date of this review.The next FYR for the GECI Site is required within fivefive years of the signature date of this review.

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Attachment Site MapAttachment 11 -- Site Map

~ Former

Manufacturing Building

....,...,f---- Existing Groundwater Pump and Treat Facility

Operable Units (GUs) and /------ DECI Site Response Actions

Boundary (approximate)

O au 1: Wastewater Lagoons Sludge and So~ Removal

o au 2: Contaminated So~s

Excavation and Removal

o ou 3: Cround WaterOU 3: Ground Water

Pump and Treat SystemPump and Treat System

o au 4: Davy Creek and WetlandsOU 4: Davy Crook and Wotlands

Sediment RemovalSediment Removal

D OU 5: Manufacturing BuildingsOU 5: Manufacturing Buildings

Demolition and RemovalDemolilioii and Reinoval

OECI,.-•-••, OECI

SlJe Boundary la".a""l»•*--'4 Sile Boundary (apprcKimais)

liHHiiiliii

Data Table: OEC Site - Operable UnitsData Table: DECII Site· Operable Units

au Name Contaminants of Concern (COCs)Contaminants of Concern (COCs) au StatusOU Name Remedial ApproachRemedial Approach OU Status Institutional ControlsInstitutional Controls

OUau 11 WastewaterWastewater lagoonsl-agoons Inorganics: As, Cd, Cr, Cu, Pb, Ni. 2n. Cyanide; Organics: Remedial work completed -1996Remedial work oompJeled - 1996 Need is TBDNeedisTBOlnat!lanics: As, Cd. Cr. Cu, Pb. Ni. In. Cyanide: Organics: Sludga and Soil RemovalSludge and Sail R<lmO\IllI Acetone, Metfiyiene Chloride. 1,l-DJch!oroeIfiane. 1,1,1Aaltone. Methylene CI\Iocide. 1,1-0ichloroethane. 1,1.1

Trichloroethane, Trichloroethene. Tetrachloroethene, Toluene,Trichloroethane, Trichloroethane, Teltachloroethene, Toluene, Ethylbenzene, XyleneEthylbenzene, Xylene

aU2 Remed"l work completed -- 1996 Excavation and RemovalE!<cavalion and Removal Oidiloroelhane, Trichloroethane, Trichloroethene, Toluene

OU2 Contaminated SoilsContaminated SOils Inorganics: As. Cd, Cr. Cu. Pb. NI, Zn. Cyanide; Organics:lnorganics: As. Cd, Cr, Cu. Pb. N1. In, Cyanide: Organics: Remedial work completed 1996 Need Is TBDNeedlsTBO Didlloroethalle, Trichloroethane. Trichloroelhene, Toluene

OU3aU3 Ground Water Inorganics: Cd. Ni. Cyanide; Organics: l.l-Dichloroethene, Remedial work ongoingRemed"l WO<1< ongoing Need isTBOGround Water lnorganks: Cd. Ni. Cyanide; Otvanics: 1.1-Dlchloroethene, Pump and Treat SystemPump and Treat System 1,1- Dichloroethane, 1.2-DichIoroethane. 1,1,1 Trichloroethane,1.1- OichloroelhaM, 1.2-DichIoroethane, 1,1,1 Trichloroethane.

TrichloroetheneTrichloroelhene

OU4 Davy Creek and WetlandsDavy Creek and Welland. fnorganics: Cyanide, Nt, Cu NeedisTBDOU4 Inorganics: Cyanide, NI, Cu Remedial work completed 1996Remecf"" wor1< completed -- 1996 f^^ed is TBD Sediment RemovalSediment Removal

Demolition debris Need is TBDOUSOU5 Manufacturing BuHdlr^sManufacturing Buildings Demolition debris Remedial work completed -1992Remedial wor1< completed - 1992 NeedisTBO Demolition and RemovalDe.mofilion and Removal

2727

Attachment 22 -- List of Documents ReviewedAttachment List of Documents Reviewed

1990 Record of Decision, U.S. EPA1990 Record of Decision, U.S. EPA

1991 Explanation of Significant Difference, U.S. EPA1991 Explanation of Significant Difference, U.S. EPA

1994 Explanation of Significant Difference, U.S. EPA1994 Explanation of Significant Difference, U.S. EPA

1997 Five-Year Review, U.S. EPA1997 Five-Year Review, US. EPA

2002 Five-Year Review, U.S. EPA2002 Five-Year Review, U.S. EPA

2007 Five-Year Review, U.S. EPA2007 Five-Year Review, US. EPA

2000 Remediation System Evaluation, US. EPA2000 Remediation System Evaluation, U.S. EPA

2004 Hydrogeologic Investigation and Groundwater Extraction System2004 Hydrogeologic Investigation and Groundwater Extraction System Evaluation, RMT, Inc.Evaluation, RMT, Inc.

2004 Groundwater Treatment Facility Shutdown Plan, CH2MHill2004 Groundwater Treatment Facility Shutdown Plan, CH2MHill

2005 Soil Gas Survey Historical Results, CH2MHill2005 Soil Gas Survey Historical Results, CH2MHill

2009 Annual Groundwater Report, CH2MHill2009 Annual Groundwater Report, CH2MHill

2010 Private Water Supply Contamination Risk Assessment, U.S. EPA2010 Private Water Supply Contamination Risk Assessment, U.S. EPA

2010 Focused Feasibility Study, CH2MHill2010 Focused Feasibility Study, CH2MHill

2011 ROD Amendment, U.S. EPA2011 ROD Amendment, U.S. EPA

2011 Vapor Intrusion Risk Assessment, U.S. EPA2011 Vapor Intrusion Risk Assessment, U.S. EPA

2828

Attachment 33 -- Applicable or Relevant and Appropriate RequirementsAttaciiment Applicable or Relevant and Appropriate Requirements (ARARs)(ARARs)

Evaluation of ARARs and requirements To He Considered (TBC)Evaluation of ARAFls and requirements To Be Considered (TBC) GEC! Focused Feasibility Study ReportOECI Focused Feasibility Study Report

Regulation Requireme ARARRegulation ] Requirementnt ARAR

IStatusStatus

Chemical-Specific ARARsChemical-Specific ARARs

CERCLA GuidanceCERCLA Guidance Establishes appropriate considerations inriate considerations inappropEstablishes TBCTBC onon Land Use in tlieLand Use in the defining future lan use.dd use.ure Iandefining fut CERCLA RemedyCERCLA Remedy Selection ProcessSelection Process

40 CFR 260 through40 CFR 260 through Regulates the generation, transport, storage,ration, transport, storage,Ie geneRegulates tl ARARARAR 264, Subtitle264, Subtitle CC treatment, and disposal of hazardous wastesosal of hazardous wastesnd disptreatment, a

generated in the course of remedial action.urse ofaa remedial action.the cogenerated in Regulates the construction, design,truction, design,Ie consRegulates tI monitoring, operation, and closure ofion, and closure ofoperatmonitoring, hazardous waste facilities.cilities.laste fahazardous \'

40 CFR 261- Identifies th

Identification and asas hazardouhazardouss wastes. 40 CFR 261- ose wa:ites subject to regulation ARARIdentities those wastes subject to regulation ARAR Identification and wastes. Listing of HazardousListing of Hazardous WasteWaste

hnical and procedural closure G-Closure and Post- for hazardous waste facilities.zardous waste facilities. ARAR

4040 CFR 264,CFR 264, SubpanSubpan; Provides tecProvides technical and procedural closure NotNot anan G-Closure and Post- requirementrequirementss for ha ARAR ClosureClosure Requires the: facilitfacilit mannerRequires tht / be closed in

that controls minimizes or eliminates to the :I be closed in aa manner

that control~:,, mininlizes or eliminates to the extent necessary to protect human health andextent necessary to protect human health and the environment, post-closure escape ofthe environrnent, post-closure escape of hazardous waste, h:izardous constituents,hazardous waste, hazardous constituents, leachate, contaminated runoff, or hazardousleachate, COlHaminated runoff, or hazardous waste decomposition products to the groundwaste deconIpositic'n products to the ground or surface water or to the atmosphere.or surface IVater or to the atmosohere.

40 CFR 268 Subpart Materials coMaterials containingg ReRA hazardous waste ARAR40 CFR 268 Subpart ntainin RCRA hazardous waste ARAR 0-D-TreatmentTreatment subject to land disposal restrictions. Somend dispsubject to la osal restrictions. Some StandardsStandards hfizardous wastes restricted from landastes rhazardous \\ estricted from land

disposal in SubpartSubpart may be land-disposeddisposal in • CC may be land-disposed providing they attain levels achievable byproviding theyaltain levels achievable by best demonstrated available technologiesbest demons trated available technologies (BOAT) for each hazardous constituent for(BOAT) for each hazardous constituent for each listed v.'aste.each listed \',aste.

NRNR720-Soil CleanupnO-Soil Cleanup Establishes the soil cleanup standardshe soil cleanup standards Not anEstablishes I Not an Standards (residual COl ent levels, RCLs) for the ARARStandards (residual contaminant levels, RCLs) for theHamil1£, ARAR

remediation of soil contamination.remediation of soil contamination.

GroundwaterGroundwater

Federal Water TheThe proposepropose nn must be consistent with ARARARARFederal Water dd actioactio must be consistent with Pollution Control ActPollution Control Act regional water quality management plans aser qual ity management plans asregional lVat as amended by the developed under Section 208 of Clean Wateras amended by the developed under Section 208 of Clean Water CleanClean Water Act ofWater Act of Act.Act. 1977, Section 208(b)1977, Section 208(b)

2929

AnalysisAnalysis

IProvides guidance to in selectingProvides guidance to USEPUSEPAA in selecting land use for remedy selection purposes.land use for remedy selection purposes.

Requirements under these regulations mayRequirements under these regulations may be relevant and appropriate to storage ofbe relevant and appropriate to st,Jrage of certain non-hazardous wastes or treatmentcertain non-hazardous wastes or treatment system residuals if the risk they present aresystem residuals if the risk they present are similar to those associated with hazardoussimilar to those associated with hazardous wastes. The criteria and limitations used to\vastes. The criteria and limitatiC'ns used to identity wastes as being hazardous or non­identitY wastes as being hazardous or non­hazardous are applicable to groundwaterhazardous are applicable to groundwater treatment residuals.treatment residuals. The criteria and limitations used to identify'The criteria and limitations used to identitY wastes as being hazardous or nonhazardouswastes as being hazardous or nonhazardous in 40 CFR 261 are relevant and appropriatein 40 CFR 26\ are relevant and appropriate to all proposed cleanup actions at theto all proposed cleanup actions at the Oconomowoc Site. Determining whetherOconomowoc Site. Determining \vhether wastes qualify' as hazardous will oftenwastes qualitY as hazardous will often establish the applicabilit\' of otherestablish the applicability of othlT regulations.regulations. No remedial alternative includesNo remedial alternative includes consolidation.consolidation.

Movement of excavated materials to newMovement of excavated materials to new location and placement in or on land willlocation and placement in or on land will trigger land disposal restrictions for thetrigger land disposal restrictions for the excavated waste or closure requirements forexcavated waste or closure requirements for the unit in which the waste is being placed.the unit in which the waste is being placed. No alternatives propose moving soil withinNo alternatives propose moving soil within the area of contamination.the area of contamination.

Applies to detennining the effectiveness ofApplies to detennining the effectiveness of soil remedial alternatives. Do not apply tosoil remedial alternatives. Do nOI: apply to remediation of groundwater.remediation of groundwater.

Substantive requirements adopted by theSubstantive requirements adopted by the state pursuant to Section 208 of the Cleanstate pursuant to Section 208 of the Clean Water Act would be applicable to directWater Act would be applicable to direct discharge of treatment system efjluent ordischarge of treatment system eflluent or other discharges to surface water.other discharges to surface water.

RegulationRegulation

Federal WaterFederal Water Pollution Control ActPollution Control Act as amended by theas amended by the Clean Water Act ofClean Water Act of 1977, Section 3041977, Section 304

40 CFR 122.44(a)­40 CFR 122.44(a)­Technology-BasedTechnology-Based Effluent LimitationsEffluent Limitations and Standardsand Standards

40 CFR 122.44(e)­40 CFR 122.44(e)­Technology-BasedTechnology-Based Controls for ToxicControls for Toxic PollutantsPollutants

40 CFR 131-Water40CFRI31-Water Quality StandardsQuality Standards

40 CFR 141-National40 CFR 141-National Primary DrinkingPrimary Drinking Water RegulationsWater Regulations

Safe Drinking WaterSafe Drinking Water Act (SDWA)-Act (SDWA)— MaximumMaximum Contaminant LevelsContaminant Levels (MCLs)(MCLs) 40 CFR 141.6140 CFR 141.61 (organic chemicals)(organic chemicals) 40 CFR 141.6240 CFR 141.62 (inorganic chemicals)(inorganic chemicals) SDWA-MaximumSDWA—Maximum Contaminant LevelContaminant Level Goals (MCLGs)Goals (MCLGs) 40 CFR 141.5040 CFR 141.50 (organic chemicals)(organic chemicals) 40 CFR 141.5140 CFR 141.51 (inorganic chemicals)(inorganic chemicals) 40 CFR 143­40 CFR 143­SDWA-SecondarySDWA—Secondary MCLs (SMCLs)MCLs (SMCLs)

Oft1ce of DrinkingOffice of Drinking Water. Drinking waterWater. Drinking water health advisories.health advisories.

RequirementRequirement

Establishes water quality criteria for specificEstablishes water quality criteria for specific pollutants for the protection of human healthpollutants for the protection of human health and for the protection of aquatic life. Theseand for the protection of aquatic life. These federal water quality criteria are non­federal water quality criteria are non­enforceable guidelines used by the state toenforceable guidelines used by the state to set water quality standards for surface water.set water quality standards for surface water. Requires the use of the Best AvailableRequires the use of the Best Available Technology (BAT) for toxic andTechnology (BAT) for toxic and nonconventional wastewaters or the Bestnonconventional wastewaters or the Best Conventional Technology (BCT) forConventional Technology (BCT) for conventional pollutants. The nature of theconventional pollutants. The nature of the wastewater and the technology-basedwastewater and the technology-based limitations will be determined by the state onlimitations will be determined by the state on aa case-by-case basis.case-by-case basis. Discharge limits must be established atDischarge limits must be established at concentrations exceeding levels achievableconcentrations exceeding levels achievable by the technology-based (BAT/BCT)by the technology-based (BAT/BCT) standards. The discharge limitations wouldstandards. The discharge limitations would be evaluated on case-by-case basisbe evaluated on aa case-by-case basis depending on the proposed treatment systemdepending on the proposed treatment system and the receiving water.and the receiving water. States are granted enforcement jurisdictionStates are granted enforcement jurisdiction over direct discharges and may adoptover direct discharges and may adopt reasonable standards to protect or enhancereasonable standards to protect or enhance the uses and qualities of surface water bodiesthe uses and qualities of surface water bodies in the state.in the state.

Establishes maximum contaminant levelsEstablishes maximum contaminant levels (MCLs) and maximum contaminant level(MCLs) and maximum contaminant level goals (MCLGs) for specific chemicals togoals (MCLGs) for specific chemicals to protect drinking water quality.protect drinking water quality.

CERCLA 121 (d) states that aa remedialCERCLA 121(d) states that remedial action will attain aa level under the SDWA.action will attain level under the SDWA. MCLs are enforceable maximum permissibleMCLs are enforceable maximum permissible level of contaminant which is delivered tolevel of aa contaminant which is delivered to any user of public water system.any user of aa public water system.

CERCLA 12 1(d)(2)(A) states that aa remedialCERCLA 121(d)(2)(A) states that remedial action attain MCLGs where relevant andaction attain MCLGs where relevant and appropriate. MCLGs are non-enforceableappropriate. MCLGs are non-enforceable health goals under the SDWA.health goals under the SDWA.

Non-enforceable limits intended asNon-enforceable limits intended as guidelines for use by states in regulatingguidelines for use by states in regulating water supplies. Secondary MCLs are relatedwater supplies. Secondary MCLs are related to aesthetic concems (e.g. taste and odor)to aesthetic concerns (e.g. taste and odor) and are not health-related.and are not health-related. Guidance levels for drinking water issued byGuidance levels for drinking water issued by Office of Drinking Water.Office of Drinking Water.

30

ARARARAR StatusStatus

TBCTBC

ARARARAR

ARAR/VRAR

ARARARAR

ARARARAR

ARARARAR

ARARARAR

Not anNot an ARARARAR

TBCTBC

AnalysisAnalysis

Water quality criteria may be relevant andWater quality criteria may be relevant and appropriate to groundwater or treatmentappropriate to groundwater or treatment system effluent or other discharges tosystem effluent or other discharges to surface water.surface water.

Substantive requirement is used by WDNRSubstantive requirement is used by WDNR in setting discharge limits for onsitein setting discharge limits for onsite groundwater treatment.groundwater treatment.

Substantive requirement is used by WDNRSubstantive requirement is used by WDNR in setting discharge limits for onsitein setting discharge limits for onsite groundwater treatment.groundwater treatment.

Applicable to direct discharge of treatmentApplicable to direct discharge of treatment system effluent or other process waters.system effluent or other process waters. Such discharge would activate theSuch aa discharge would activate the administrative requirements of this ruleadministrative requirements of this rule because it would affect offsite surfacebecause it would affect offsite surface waters.waters. MCLs and nonzero MCLGs are relevantMCLs and nonzero tvlCLGs are relevant and appropriate because groundwater isand appropriate because groundwater is used as drinking water supply.used as drinking water supply.

MCLs are relevant and appropriate forMCLs are relevant and appropriate for potential drinking water sources per thepotential drinking water sources per the NCP. Remedies may not have toNCr. Remedies may not have to demonstrate compliance with an ARAR thatdemonstrate compliance with an ARAR that is technically impracticable (see NCP), suchis technically impracticable (see NCP), such as areas of DNAPL.as areas ofDNAPL.

Non-zero MCLGs may be relevant andNon-zero MCLGs may be relevant and appropriate. MCLGs equal to zero are notappropriate. MCLGs equal to zero are not appropriate for cleanup of groundwater orappropriate for cleanup of groundwater or surface water at CERCLA sites bysurface water at CERCLA sites by USEPUSEPAA policy (see NCP).policy (see NCP).

Chemicals with SMCLs have beenChemicals with SMCLs have notnot been identified as chemicals of concern at thisidentified as chemicals of concern at this site.site.

May be used for chemicals without MCLs ifMay be used for chemicals without MCLs if gi'oundwater is to meet drinking watergroundwater is to meet drinking water quality.quality.

RegulationRegulation

NR 140-GroundwaterNR 140-Groundwater Quality (EnforcementQuality (Enforcement Standards)Standards)

NR 140-GroundwaterNR l40-Groundwater QualityQuality (Preventative Action(Preventative Action

Limits)Limits)

NR 809-SafeNR809-Safe Drinking WaterDrinking Water

Surface WaterSurface Water

Federal WaterFederal Water Pollution Control ActPollution Control Act as amended by theas amended by the Clean Water Act ofClean Water Act of 1977, Section 208(b)1977, Section 208(b)

NR 102-WaterNR I02-Water Quality Standards forQuality Standards for Wisconsin SurfaceWisconsin Surface WaterWater NR 103-WaterNR I03-Water Quality Standards forQuality Standards for WetlandsWetlands

NR 104-UsesandNR I04-Uses and Designated StandardsDesignated Standards and Secondary Valuesand Secondary Values NR 105-SurfaceNR lOS-Surface Water Quality CriteriaWater Quality Criteria for Toxic Substancesfor Toxic Substano~s

NR 106-ProceduresNR I06-Procedures for Calculating Waterfor Calculating Water Quality BasedQuality Based Effluent LimitationsEmuent Limitations for Toxic andfor Toxic and OrganolepticOrganoleptic SubstancesSubstances Discharged to SurfaceDischarged to Surface WatersWaters

Requirem entRequirement

Establishes the remediation goals forEstablishe:,the remediation goals for groundwater WhI·ch are to achieve thegroundwater which are to achieve the Enforcement Standards (ESs) at the Site.Enforcement Standards (ESs) at the Site. .Also specifies actions required shouldAlso speci fies actions required should aa groundwater standard be exceeded at thegroundwater standard be exceeded at the point of standard application.point of sl;Illdardss application. Establishe:,the Preventive Action LimitsEstablishes the Preventive Action Limits (PALs) at the Site. Also specifies actions(PALs) at the Site. Also specifies actions required sliould groundwater standard berequired s1lould aa groundwater standard be exceeded a the point of standardsexceeded ittt the point of standards applicationapplication.

Establishes drinking water standards forEstabJishe:', drinking water standards for water supplies, including federal MCLs.water supplies, induding federal MCLs. .Also specifies sampling and analysisAlso speci fies sarnpling and analysis requirements.requirements.

Establishes water quality criteria for specificEstablishe:; water quality criteria for specific pollutants for the protection of human healthpollutants tor the protection of human health and aquati'"life. 1·hese federal water qualityand aquatic life. These federal water quality criteria are non-enforceable guidelines usedcriteria are non-enforceable guidelines used by the state to set water quality standards forby the state to set water quality standards for surface water.surface water. Describes the designated use categories andDescribes the des ignated use categories and water quality crit(Tia to support uses.water quality criteria to support uses.

Establishes w ater quality standards forEstablishe3 water quality standards for weflands and implementation procedures forwetlands and imp lementation procedures for application of the wetland water qualityapplication of the wetland water quality standards.standards.

Establishes surfacsurfac water classifications andEstablishes ee water classifications and specifies e[fluent limitations for intrastatespecifies effluent limitations for intrastate waters.waters. Establishes water quality criteria and methods r developing criteria andrdeve Establishes water quality criteria and methods fofo loping criteria and secondary values for toxic and organolepticsecondar)' values for toxic and organoleptic substances for the protection of humansubstance~: for tht": protection of human health and welfiire, and propagation offish,health and welt:rr,~, and propagation of fish, aquatic lite and wildlife. Also requires thataquatic lik and \\ ildlife. Also requires that contaminated sediment be remediated tocontaminated sed iment be remediated to meet sediment quality criteria that aremeet sediment qlmlity criteria that are protective of surface water quality standards.protective of surf;ace water quality standards. Specifies 11le pro(:edures to calculate effluentSpecifies the procedures to calculate effluent limits for 1oxic arld organoleptic substanceslimits for toxic and organoleptic substances andifand howthese limits will be includedand if and how these limits will be included in WllDES penni ts.in WPDES permits.

ARARARAR StatusStatus

ARARARAR

ARARARAR

ARARARAR

TBCTBC

ARARARAR

ARARARAR

ARARARAR

ARARARAR

ARARARAR

AnalysisAnalysis

Relevant to determine effectiveness ofRelevant to determine effectiveness of remedial altematives considered.remedial alternatives considered.

Relevant to determine effectiveness ofRelevant to determine effectiveness of remedial altematives considered.remedial alternatives considered.

MCLs are relevant and appropriate forMCLs are relevant and appropriate for potential drinking water sources per thepotential drinking water sources per the NCP. Remedies may have loNCP. Remedies may notnot have to demonstrate compliance with an ARAR thatdemonstrate compliance with an ARAR that is technically impracticable (see NCP), suchis technically impracticable (see NCP), such as areas of DNAPL.as areas ofDNAPL.

Water quality criteria are TBCs used inWater quality criteria are TBC" used in setting standards for discharges to surfacesetting standards for discharge~ to surface water from treatment system.water from aa treatment system.

Surface water standards are applicable toSurface water standards are applicable to Davy Creek. Also treated groundwater mustDavy Creek. Also treated groundwater must meet water quality standards.meet water quality standards.

Relevant to treated discharge fromRelevant to treated discharge from groundwater source control. Also relevantgroundwater source control. Also relevant for soil excavation and groundwaterfor soil excavation and groundwater withdrawal activities that have the potentialwithdrawal activities that have the potential to impact wetlands.to impact wetlands. Actions involving treated discharge mustActions involving treated discharge must meet water qualit}' standards.mcet water quality standards.

Water quality criteria are used by WDNR inWater quality criteria are used by WDNR in setting WPDES discharge limit for toxicssetting WPDES discharge limit for toxics and developing sediment quality criteria.and developing sediment quality criteria.

Water quality criteria are used by WDNR inWater quality criteria are used by WDNR in setting WPDES discharge limit for toxicssetting WPDES discharge limit for toxics and developing sediment quality criteria.and developing sediment qualil)' criteria. Surface water standards are applicable toSurface water standards are applicable to Davy Creek.Davy Creek.

31

RegulationRegulation

AirAir Clean Air ActClean Air Act

40 CFR 50-National40 CFR 50-National Primary andPrimary and Secondary AmbientSecondary Ambient Air Quality StandardsAir Quality Standards

40 CFR 6 I-National40CFR61-Nafional Emission StandardsEmission Standards for Hazardous Wastefor Hazardous Waste PollutantsPollutants

40 CFR 264.AA-Air40 CFR 264.AA-Air Emission StandardsEmission Standards for Process Ventsfor Process Vents

NR 404-Ambient AirNR 404-Ambient Air QualityQuality

NR 405 - ProtectionNR 405 - Protection of Signiticantof Significant DeteriorationDeterioration

NR 407 - OperationNR 407 - Operation PermitsPermits

NR 415-Control ofNR415-Controlof Particulate EmissionsParticulate Emissions

NR 419-Control ofNR419-Controlof Organic CompoundOrganic Compound EmissionsEmissions

RequirementRequirement

Calls for development and implementationCalls for development and implementation of regional air pollution control programs.of regional air pollution control programs.

Establishes Ambient Air Quality Standards.Establishes Ambient Air Quality Standards.

Requires limits on the discharges of toxicRequires limits on the discharges of toxic substances to the atmosphere.substances to the atmosphere.

Requires total organic emissions from airRequires total organic emissions from air strippers or steam strippers to be reducedstrippers or steam strippers to be reduced below 1.4 kg/hr and 2.8 Mg/yr or that totalbelow 1.4 kg/hr and 2.8 Mg/yr or that total organic emissions be reduced by 95 percentorganic emissions be reduced by 95 percent by weight.by weight.

Establishes ambient air quality standards forEstablishes ambient air quality standards for particulate matter and specifies measurementparticulate matter and specifies measurement methods.methods. Establishes the requirements and proceduresEstablishes the requirements and procedures for reviewing and issuing air pollutionfor reviewing and issuing air pollution control construction pelll1its to any ncwcontrol construction pemiits to any new major stationary source.major stationary source. Required for all direct stationary sourcesRequired for all direct stationaiy sources requiring aa pennit.requiring pennit.

Establishes standards for fugitive dustEstablishes standards for fugitive dust emissions and specifies that precautionsemissions and specifies that precautions should be taken to prevent paliiculate mattershould be taken to prevent particulate matter from becomin!l air borne.from becoming air borne. Describes the notification and approvalDescribes the notification and approval requirements and emission limitations torrequirements and emission limitations for remediation of soil or water contaminatedremediation of soil or water contaminated organic compounds.organic compounds.

3232

ARARARAR StatusStatus

ARARARAR

ARARARAR

ARARARAR

ARARARAR

ARARARAR

ARARARAR

ARARARAR

ARARARAR

ARARARAR

AnalysisAnalysis

Section 101 of the Clean Air Act delegatesSection 101 of the Clean Air Act delegates primary responsibility for regional airprimary responsibility for regional air quality management to the states. The rulesquality management to the states. The rules for implementation of regional air qualityfor implementation of regional air quality plans are contained in 40 CFR 52.plans are contained in 40 CFR 52. Regulations promulgated under the CleanRegulations promulgated under the Clean Air Act may apply to possible actions at theAir Act may apply to possible actions at the Site that generate air emissions, but areSite that generate air emissions, but are most applicable to stationary sources.most applicable to stationary sources. Applicable to discharges of toxic substancesApplicable to discharges oftoxic substances to the atmosphere during waste handling orto the atmosphere during waste handling or treatment. The existing groundwatertreatment. The existing groundwater treatment system did not require airtreatment system did not require air emission controls so it is unlikely re-startingemission controls so it is unlikely re-starting the treatment system with lower VOCthe treatment system with lower VOC concentrations will require air emissionconcentrations will require air emission controls. The substantive requirements of ancontrols. The substantive requirements of an air pennit will need to be re-evaluated.air pennit will need to be re-evaluated. Applicable to discharges of toxic substancesApplicable to discharges of toxic substances to the atmosphere during waste handling orto the atmosphere during waste handling or treatment. The existing groundwatertreatment. The existing groundwater treatment system did not require airtreatment system did not require air emission controls so it is unlikely re-startingemission controls so it is unlikely re-starting the treatment system with lower VOCthe treatment system with lower VOC concentrations will require air emissionconcentrations will require air emission controls. The substantive requirements of ancontrols. The substantive requirements of an air pennit will need to be re-evaluated.air pennit will need to be re-evaluated. Applicable to discharges of toxic substancesApplicable to discharges of toxic substances to the atmosphere during waste handling orto the atmosphere during waste handling or treatment. The existing groundwatertreatment. The existing groundwater treatment system did not require airtreatment system did not require air emission controls so it is unlikely re-stai1ingemission controls so it is unlikely re-struiing the treatment system with lower VOCthe treatment system with lower VOC concentrations will require air emissionconcentrations will require air emission controls. The substantive requirements of ancontrols. The substantive requirements of an air permit will need to be re-evaluated.air permit will need to be re-evaluated. Relevant to excavation of soil forRelevant to excavation of soil for remediation.remediation.

Relevant to air emissions associated withRelevant to air emissions associated with restarting the existing groundwaterrestarting the existing groundwater treatment system.treatment system.

Relevant if the size of the pump and treat airRelevant if the size of the pump and treat air emission system falls within the size andemission system falls within the size and type limits requiring an operation permit.type limits requiring an operation vermit. Relevant to excavation of soil forRelevant to excavation of soil for remediation.remediation.

Applicable to discharges of toxic substancesApplicable to discharges of toxic substances to the atmosphere during waste handling orto the atmosphere during waste handling or treatment. The existing groundwatertreatment. The existing groundwater treatment system did not require airtreatment system did not requirc air emission controls so it is unlikely re-startingemission controls so it is unlikely re-staIiing the treatment system with lower VOCthe treatment system with lower VOC concentrations will require air emissionconcentrations will require air emission

Requirement AnalysisRegulationRegulation Requirement 1 ARARARAR 1 Analysis StatusStatus

controls. The substantive requirements of ancontrols. The substantive requirements of an air pennit will need to be re-evaluated.air permit will need to be re-evaluated.

NR43I -Control ofNR 431 - Control of This applies to all air contaminant sourcesair contaminant sourcesto aJIThis applies ARARARAR 1 No owner or operator of direct or portableNo owner or operator of aa direcl or portable Visible EmissionsVisible Emissions and is used o categorize air contaminantgorize air contaminantocateand is used tt source may cause or allow emissions ofsource may cause or allow emissions of

sources and to establish visible emissionblish visible emissionto estasources and shade or density great than number of theshade or density great than number 22 of the limitations for thes sources to protect airee sources to protect airor thcslimitations ~ Ringlemann chart or 40% opacity. This canRinglemann chart or 40% opacity. This can quality.quality. affect operation of the groundwateraffect operation of the groundwater

treatment system emissions.treatment system emissions. NR 439 Reporting ofNR 439 -- Reporting of This establishes general reporting,neral reporting,hes geThis establis ARARARAR requirements apply to theSubstantiveSubstantive requirements apply to the Record Keeping,Record Keeping, recordkeeping, testing, inspection andting, inspection andIg, tcsrecordkeepir groundwater pump and treat system airgroundwater pump and treat system air Testing, Inspection,Testing, Inspection, of compliance requirementsompliance requirementsnn ofcdeterminatiodeterminatio emission unit.emission unit. and Detennination ofand Determination of for all air emission sources.sources.lissionfor all air en ComplianceCompliance NR 440 Standards ofNR 440 -- Standards ,)f This enables to implement andRR to implement andWDNWDNThis enables ARARARAR Applies to the groundwater treatmentApplies to the groundwater treatment 1 Performance for NewPerfOimancc for New enforce standards of perfonnance for new,f perf0l111anCe for newdards (en force stan system emissions.system emissions. Stationary SourcesStationary Sources stationary sources promulgated by thepromulgated by theurcesstationary so

USEPA under the Clean Air Act.Clean Air Act.er theUSEPA und NR 445-Control ofNR 445-Control of Specifies emission limits and controllimits and controlissionSpecifies em ARARARAR Emissions for actions that may emit airEmissions for actions that may emit air Hazardous PollutantsHazardous Pollutant:; for air contaminant sourcesir contaminant sourcesss for arequirementrequirement pollutants must meet NR 445 requirements.pollutants must meet NR 445 requirements.

emitting hai-.ardous_pollutants.J2ollutants.ardousemitting haz NR 445.04-EmissionNR 445.04-Emission Specifies air concentrations not to bentrations not to beconceSpecifies air ARARARAR Emissions for actions that may emit airEmissions for actions that may emit air Limits for New orLimits for New or exceeded in tenns of 24-hour and 1-hourof 24-hour and I-hourtel111Sexceeded in pollutants must meet NR 445 requirements.pollutants must meet NR 445 requirements. Modified SourcesModified Sources averages. Requires lowest achievablelowest achievablequiresaverages. Rc

emission rates and best available technologybest available technologyes andemission rat for air contaminants without acceptablets without acceptableminanfor air conta ambient concentrations.ions.centratambient con

NR 449 Control ofNR 449 -- Control of Establishes emissio limitations andnn limitations and~missioEstablishes, ARARARAR Applies to the groundwater treatmentApplies to the groundwater treatment Vinyl ChlorideVinyl Chloride sampling testing procedures for vinyl19 procedures for vinyldd testiIsampling anan system emissions.system emissions. EmissionsEmissions chloride air contaminan sources.1inantt sources.contanchloride air Location-Specific ARARsLocation-Specific ARARs

50 CFR 402­50 CFR 402- Requires Federal agencies ensure thatlal agencies ensure thattt FedeRequires thatha ARARARAR Potential risks to threatened and jndangeredPotential risks to threatened and ~ndangered

InteragencyInteragency any action authorized, funded, or carried out,~d, funded, or carried oututhorizany action a species were not identified previously atspecies were not identified previously at CooperationCoopcration -- by the is not likely to jeopardize thet likely to jeopardize theyy is noby the agencagenc Site.Site. Endangered SpeciesEndangered Species continued existence of any threatened orc: of any threatened oristenccontinued ex Actof 1973Act of 1973 -­

endangered species or destroy or adverselyor destroy or adversely;;pecksendangered . 16 u s e §1531 etseq.16 USC § I53 I et seq. modify critical habitat.ita!.'al habmodify critil.

50 CFR 20050 CFR 200

50 CFR 402­50 CFR 402~ remedial agency to consult withagency to consult withnedialRequiresRequires rer NotNot Potential risks to endangered species orPotential risks to endangered species or InteragencyInteragency Fish and Wildlife Sei-vice if action mayervice if action maydlife SFish and Wit likelylikely critical habitat were not identifie<lcritical habitat were not identified Cooperation—Cooperation­ affect endangered species or critical habitat.pecies or critical habitat.gered saffect endan ARARARAR previously at Site.previously at Site.

Endangered SpeciesEndangered Species Actof 1973, asAct of 1973, as amendedamended National HistoricalNational Historical Establishes jirocedures to provide for preser­ures to provide for preser-JrocedEstablishes I NotNot May be ARAR during the remedialMay be ARAR during the remedial

Preservation ActPreservation Act vation of scientific historical, and,, historical, andentificvation of sci likelylikely activities if scientific, historic, oractivities if scientific, historic, or

16 u s e §661 etseq.16 USC §661 et seq. archaeological data that might be destroyedthat might be destroyedal dataarchaeologic ARARARAR archaeological artifacts are identified duringarchaeological artifacts are identified during through alteration o terrain as result offf terrain as aa result of aaation 0through alter implementation of the remedy.implementation of the remedy.

36 CFR Part 6536 CFR Part 65 federal construction project or federally licensed activity or program. If scientific,

Ii project or aa federally program. If scientific,

ructio vity or

federal canst Ii censed acti historical, or archaeological artifacts areeological artifacts arearch ahistorical, or discovered the Site, work in the area of thediscovered aatt the Site, work in the area of the Site affected by discover)' will beSite affccted by sucsuchh discovery will be halted pending the completion of any datahalted pendi ng the completion of any data

3333

RegulationRegulation RequirementRequirement ARARARAR AnalysisAnalysis StatusStatus

recovery and preservation activities requiredrecovery and preservation activities required pursuant to the act and its implementingpursuant to the act and its implementing regulations.regulations.

Fish and WildlifeFish and Wildlife The Act provides protection and consultationThe Act provides protection and consultation ARARARAR The Act is considered an ARAR forThe Act is considered an ARAR for

Coordination Act

(16 u s e 661 etseq.)

Coordination Act

(16 USC 661 et seq.)

with the U.S. Fish and Wildlife Service and state counterpart for actions that would affect streams, wetlands, other water bodies,

with the U.S. Fish and Wildlife Service and state counterpart for actions that would affect streams, wetlands, other water bodies,

construction activities performed during the implementation of remedies that may affect the and Davy Creek.

construction activities performed during the implementation of remedies that may affect the wetlandswetlands and Davy Creek.

or protected habitats. Action taken shouldor protected habitats. Action taken should protect or wildlife, and measures shouldprotect fishfish or wildlife, and measures should be developed to prevent, mitigate, orbe developed to prevent, mitigate, or compensate for project-related losses tocompensate for project-related losses to fishfish and wildlife.and wildlife.

Protection ofProtection of Requires actions to minimize theRequires actions to minimize the ARARARAR Wetlands are present onsite.Wetlands are present onsite. Wetlands—ExecutiveWetlands-Executive destruction, loss, or degradation of wetlandsdestruction, loss, or degradation of wetlands Order 11990Order 11990 and to preserve and enhance the natural andand to preserve and enhance the natural and 40 CFR 6, Subpart40 CFR 6, Subpart AA beneficial values of wetlands. Appendix Abeneficial values of wetlands. Appendix i\

50 CFR Part 6,50 CFR Palt 6, requires that no remedial alternativesrequires that no remedial alternatives AppendixAppendix AA adversely affect wetland if anotheradversely affect aa wetland if another

practicable alternative is If none ispracticable alternative is available.available. If none is available, effects from implementing theavailable, effects from implementing the chosen alternative must be mitigated. Publicchosen alternative must be mitigated. Public notice and review of activities involvingnotice and review of activities involving wetlands is required.wetlands is required.

Executive OrderExecutive Order Requires actions to reduce the risk of floodRequires actions to reduce the risk of t100d TBCTBC Site is withinSite is within aa floodplain.floodplain. 1198811988 loss; to minimize the impact of floods onloss; to minimize the impact of t100ds on

50 CFR Part 6,50 CFR Part 6, human safety, health, and welfare; and tohuman safety, health, and welfare; and to

AppendixAppendix AA restore and preserve the natural andrestore and preserve the natural and beneficial values served by floodplains.beneficial values served by t1oodplains.

Rivers and HarborsRivers and Harbors permit is required for work in or affectingAA permit is required for work in or affecting NotNot Remedial actions are not likely to affectRemedial actions are not likely to affect Act. 3 CFR Part 332,Act. 333 CFR Part 332, navigable waters of the U.S. This includesnavigable waters of the U.S. This includes likelylikely Davy Creek.Davy Creek. Section 10.Section 10. dredging, disposal of fill material, ordredging, disposal offill material, fillingfilling or ARARARAR

modification of said waters below themodification of said waters below the ordinary high water level (OHWL).ordinary high water level (Ol-!WL).

Action-Specific ARARs/TBCAction-Specific ARARs/TBC

Executive OrdersExecutive Orders Requires federal agencies to avoid wheneverRequires federal agencies to avoid whenevCl" TBCTBC Applicable to wetlands and Davy Creek.Applicable to wetlands and Davy Creek. 11988 and 1199011988 and 11990 possible, adversely affecting plains orpossible, adversely affecting floodflood plains or 40 CFR 6, Subpart40 CFR 6, Subpart AA wetlands and to evaluate potential effects ofwetlands and to evaluate potential effects of

actions in these designated areas.actions in these designated areas.

Occupational SafetyOccupational Safety The Occupational Safety and Health Act wasThe Occupational Safety and Health Act was ARARARAR The Act is considered an ARAR forThe Act is considered an ARAR for and Health Actand Health Act passed in 1970 to ensure worker safety onpassed in 1970 to ensure worker safety on construction acfivities performed during theconstruction activities performed during the

(29U.S.C. 61 etseq.)(29 U.S.c. 61 et seq.) the job. The U.S. Department of Labor oversees the Act. Worker safety at hazardous the job. The U.S. Department of Labor oversees the Act. Worker safety at hazardous

implementation of remedies.implementation of remedies.

waste sites is specifically addressed under 29waste sites is specifically addressed under 29 CFR 1910.120: Hazardous Waste OperationsCFR 1910.120: Hazardous Waste Operations and Emergency Response; general workerand Emergency Response; general worker safety is covered elsewhere within the law.safety is covered elsewhere within the law.

40 CFR 50-9940 CFR 50-99 The Clean Air Act amendments of 1990The Clean Air Act amendments of 1990 ARARARAR The existing groundwater treatment systemThe existing groundwater treatment system greatly expanded the role of Nationalgreatly expanded the role of National did not require air emission controls so it isdid not require air emission controls so it is Emission Standards for Hazardous AirEmission Standards for Hazardous Air unlikely re-starting the treatment systemunlikely re-starting the treatment system Pollutants by designating 179 new hazardousPollutants by designating 179 new hazardous with lower VOC concentrations will requirewith lower VOC concentrations will require air pollutants and directed USEPA to attainair pollutants and directed USEPA to attain air emission controls. The substantiveair emission controls. The substantive maximum achievable control technologymaximum achievable control technology requirements of an air permit will need to berequirements of an air permit will need to be standards for emission sources. Suchstandards for emission sources. Such re-evaluated.re-evaluated. emission standards are potential ARARs ifemission standards are potential ARARs if

3434

--

--

RegulationRegulation

40 CFR 122.21­40 CFR 122.21-Application for PellnitApplication for Pennit

40 CFR 122.44­40 CFR 122.44-EstablishingEstablishing Limitations,Limitations, Standards, and OtherStandards, and Other Permit ConditionsPermit Conditions

40 CFR 122.44(i)-40CFRI22.44(i)-MonitoringMonitoring RequirementsRequirements

40 CFR 125-USEPAA40CFR125-USEP Regulations onRegulations on Criteria and StandardsCriteria and Standards fortheNPDESfor the NPDES 40 CFR 136­40 CFR 136-GuidelinesGuidelines Establishing TestEstablishing Test Procedures for theProcedures for the Analysis of [Water]Analysis of [Water] PollutantsPollutants 40 CFR 144­40 CFR 144-UndergroundUnderground Injection ControlInjection Control ProgramProgram

40 CFR 146­40 CFR 146-UndergroundUnderground Injection ControlInjection Control Program: Criteria andProgram: Criteria and StandardsStandards 40 CFR 147­40 CFR 147-Regulations on StateRegulations on State UlC ProgramsUIC Programs (Subpart YY)(Subpart YY) ResourceResource Conservation andConservation and Recovery ActRecovery Act (RCRA), (42 U.S.C.(RCRA), (42 U.S.c. 321 etseq.)321 etseq.)

RequirementRequirement

remedial technologies (such as incineratorsremedial technologies (such as incinerators or air strippers) produce air emissions ofor air strippers) produce air emissions of regulated hazardous air pollutants. Specifiesregulated hazardors air pollutants. Specifies requiremems for air emissions such asrequirements for air emissions such as particulates, sulfur dioxide, VOCs,particulates, sulfijr dioxide, VOCs, hazardous air pollutants, and asbestos.hazardous air pollutants, and asbestos.

Permit application must include detailedPermit application must include aa detailed description of the proposed action, includingdescription of the proposed action, including

listing of all required environmentalaa listing of all required environmental permits.permits. Federally approved state water qualityFederally approved state water quality standards. These miay be in addition to orstandards. These may be in addition to or more stringent than federal water qualitymore stringent than federal water quality standards under Ihe CW/\.standards under the CWA.

Requires mDnitoring of discharges to ensureRequires monitoring of discharges to ensure compliance. Monitoring programs shallcompliance. Monitoring programs shall include data on the mass, volume, andinclude data on the mass, volume, and frequency of all discharge events.frequency of all discharge events. The Site operator shall develop be.stThe Site operator shall develop aa best management practice (BVtP) program andmanagement practice (Sl'vIP) program and shall incorporate it into the operations planshall incorporate it into the operations plan or theNPDES permit application if required.or the NPDES permit application ifrequired. These sections require adherence to sampleThese sections require adherence to sample preservation procedures including containerpreservation procedures including container materials and sample holding times.materials and sample holding times.

Establishes the requirements forEstablishes the requirements for underground injection wells and forunderground injection wells and for discharge of wastewaters and hazardousdischarge of wastewaters and hazardous wastes. Reinjection is prohibited except forwastes. Reinjcction is prohibited except for reinjection of contaminated groundwater intoreinjection of contaminated groundwater into the same formation from which it wasthe same formation from which it was withdrawn pursuant to CERCLA activities.withdrawn pursuant to CERCLA activities. Establishes the technical criteria for the UICEstablishes the technical criteria for the UlC program, including the construction,program, including the construction, operating, monitoring and reportingoperating, monitoring and reporting requirements.requirements.

The proposed action is required to be inThe proposed action is required to be in compliance with State underground injectioncompliance with State underground injection requirements.requirements.

RCRA was passed in 1976. It amended theRCRA was passed in 1976. It amended the Solid Waste Disposal Act by includingSolid Wast,~ Disposal Act by including provisions for hazardous waste management.provisions for hazardous waste management.

AR.^RAR-\R StatusStatus

Not anNot an ARARARAR

Not anNot an ARARARAR

ARARARAR

ARARARAR

ARARARAR

ARARARAR

ARARARAR

ARARARAR

PossiblePossible ARARARAR

AnalysisAnalysis

Administrative requirement applicable onlyAdministrative requirement apph'cable only for discharges to offsite surface water.for discharges to offsite surface water.

All substantive requirements under the citedAll substantive requirements under the cited sections of 40 CFR 122 would be applicablesections of 40 CFR 122 would be applicable to the direct discharge of effluent to anto the direct discharge of effluent to an onsite or offsite surface water body.onsite or offsite surface water body.

Substantive requirement is used by WT)NRSubstantive requirement is used by WDNR in setting discharge limits for onsitein setting discharge limits for onsite groundwater treatment.groundwater treatment.

Substantive and administrative requirementsSubstantive and administrative requirements of 40 CFR 125 would be applicable to theof 40 CFR 125 would be applic8.ble to the direct discharge of treatment systemdirect discharge of treatment system effluent to offsite surface water body.effluent to offsite surface water body. Applicable to direct discharge of treatmentApplicable to direct discharge of treatment system effluent.system effluent.

Applicable to injection activities forApplicable to injection activitie, for remediation of the groundwater or soil.remediation of the groundwater or soil.

Applicable to injection activities forApplicable to injection activitie~~ for remediation of the groundwater or soil.remediation of the groundwater or soil.

Applicable to injection activities forApplicable to injection activities for remediation of the groundwater or soil.remediation of the groundwater or soil.

There is no documented evidence ofThere is no documented evidence of disposal of listed hazardous waste at thedisposal of listed hazardous waste at the Site. Soil excavated for offsite ex situSite. Soil excavated for offsite cx situ treatment or offsite disposal may howevertreatment or offsite disposal may however be characteristic hazardous waste.be characteristic hazardous waste.

3535

RegulationRegulation

40 CFR 268 Subpart40 CFR 268 Subpart C-Prohibitions onC-Prohibitions on Land DisposalLand Disposal

40 CFR 268 Land40 CFR 268 Land Disposal RestrictionsDisposal Restrictions

Hazardous MaterialsHazardous Materials Transportation Act; 49Transportation Act; 49 CFR 100-109erR 100-109 Transportation ofTransportation of hazardous materials.hazardous materials. 40 CFR 262 and 26340 CFR 262 and 263

NR 140.28(5}~CriteriaNR 140.28(5)-Criteria for Grantingfor Granting aa Temporary ExemptionTemporary Exemption Where Infiltration orWhere Infiltration or Injection is UtilizedInjection is Utilized for aa Remedial Actionfor Remedial Action NR 141-GroundwaterNR 141-Groundwater Monitoring WellMonitoring Well RcquirementsRequirements NR 200-ApplicationNR 200-Application for Discharge Permitfor Discharge Permit

NR 207-WaterNR 207-Water QualityQuality AntidegradationAntidegradation PolicyPolicy NR 214-LandNR214-Land Treatment ofTreatment of Industrial LiquidIndustrial Liquid Wastes. By-ProductWastes. By-Product Solids and SludgesSolids and Sludges

NR 217 - EftlllentNR 217-Effluent Standards andStandards and

RequirementRequirement

The land disposal restriction under thisThe land disposal restriction under this subpart prohibits land-based disposal ofsubpm1 prohibits land-based disposal of certain solvent-containing wastes, dioxin­certain solvent-containing wastes, dioxin­containing wastes, and listed wastes.containing wastes, and listed wastes.

The land disposal restrictions requireThe land disposal restrictions require treatment before land disposal for aa widetreatment before land disposal for wide range of hazardous wastes.range of hazardous wastes.

Specific DOT requirements for labeling,Specific DOT requirements for labeling, packaging, shipping papers, and transport bypackaging, shipping papers, and transport by rail, aircraft, vessel, and highway.rail, aircraft, vessel, and highway.

Establishes responsibilities for transportersEstablishes responsibilities for transporters of hazardous waste in handling,handling,of hazardous waste in transportation, and management of thetransportation, and management of the waste. Sets requirements for manifesting,waste. Sets requirements for manifesting, recordkeeping, and emergency responserecordkeeping, and emergency response action in case of spill.action in case of aa spill. Describes the criteria for requesting anDescribes the criteria for requesting an exemption from WDNR to exceed the PALsexemption from WDNR to exceed the PALs or ES at point of standard application foror ES at aa point of standard application for aa remedial action including the infiltration orremedial action including the infiltration or injection of contaminated groundwater.injection of contaminated groundwater.

Establishes minimum standards for theEstablishes minimum standards for the installation, construction and abandonmentinstallation, construction and abandonment of monitoring wells.of monitoring wells. Specifies requirements for applying forSpecifies requirements for applying for permit for discharges to surface water and 10permit for discharges to surface water and to land areas where watcr may percolate orland areas where water may percolate or seep to groundwater.seep to groundwater. Establishes implementation procedures forEstablishes implementation procedures for the antidegradation policy in NR 102.the antidegradation policy in NR 102.

Establishes the design for all land treatmentEstablishes the design for all land treatment systems that receive wastewater and requiresystems that receive wastewater and require approval of plans and specifications byapproval of plans and specifications by WDNR. Effluent limits, discharge permitsWDNR. Effluent limits, discharge permits and groundwater monitoring requirementsand groundwater monitoring requirements are also specified. Use of injection wells ofare also specified. Use of injection wells of any sort is prohibited unless approved byany sort is prohibited unless approved by WDNR.WDNR. Establishes eftluent standards andEstablishes effluent standards and limitations for pollutants in eftluentlimitations for pollutants in effluent

3636

ARARARAR StatusStatus

ARARARAR

PossiblePossible ARARARAR

PossiblePossible ARARARAR

PossiblePossible ARARARAR

PossiblePossible ARARARAR

ARARARAR

ARARARAR

ARARARAR

Not anNot an ARy\RARAR

ARARARAR

AnalysisAnalysis

The rules in 40 CFR 268 restrict landThe rules in 40 CFR 268 restrict land disposal of several types of hazardousdisposal of several types of hazardous wastes and as such, may affect thewastes and as such, may atfect the implementation of several potential actions,implementation of several potential actions, including actions involving disposal ofincluding actions involving disposal of contaminated soils. The land disposal bancontaminated soils. The land disposal ban may be applicable or relevant andmay be applicable or relevant and appropriate to the proposed cleanup becauseappropriate to the proposed cleanup because qualifying hazardous wastes might bequalifying hazardous wastes might be present in onsite soils. The LDRs delegatepresent in onsite soils. The LDRs delegate primary responsibility to the states except toprimary responsibility to the states except to the extent that promulgated federalthe extent that promulgated federal regulations are not yet incorporated.regulations are not yet incorporated. ARAR for disposal of hazardous waste.ARAR for disposal of hazardous waste. Applicable to soils that are aa characteristicApplicable to soils that are characteristic hazardous waste or that contain listedhazardous waste or that contain aa listed waste. Contaminated soils must meet thewaste. Contaminated soils must meet the higher of 10 x the universal treatmenthigher of lOx the universal treatment standard or 90% reduction of thestandard or aa 90% reduction of the contaminant concentration.contaminant concentration. Off-site shipment of hazardous waste mayOff-site shipment of hazardous waste may occur.occur.

Applicability depends on wasteApplicability depends on waste classification of groundwater treatmentclassification of groundwater treatment residuals and excavated soil.residuals and excavated soil.

Contaminant concentrations in the effluentContaminant concentrations in the effluent may require variance to discharge themay require variance to discharge the treated groundwater and this standard maytreated groundwater and this standard may be applied to remedial tluid injection.be applied to remedial fluid injection.

Construction and abandonment ofConstruction and abandonment of monitoring wells must conform to standardsmonitoring wells must confoml to standards specified.specified. \VPDES permit may be required forWPDES permit may be required for discharge to Davy Creek but not requireddischarge to Davy Creek but not required for onsite discharges. All the substantivefor onsite discharges. All the substantive requirements, however, must be met.requirements, however, must be met. Applicable for discharges to Davy Creek.Applicable for discharges to Davy Creek. Establishes procedure to follow whenEstablishes procedure to follow when proposing new or increased discharges toproposing new or increased discharges to aa surface water body.surface water body. Land treatment is not included in remedialLand treatment is not included in remedial alternatiYes.alternatives.

Applicable for groundwater treatmentApplicable for groundwater treatment system discharge to Davy Creek.system discharge to Davy Creek.

RegulationRegulation

LimitationsLimitations

NR 219-AnalyticalNR219-Analytical Test Methods andTest Methods and ProceduresProcedures

NR 220-CategoriesNR 220-Categories and Classes of Pointand Classes of Point Sources and EftluentSources and Effluent LimitsLimits

NR 600 to NR 685-NR600toNR685-Hazardous WasteHazardous Waste ManagementManagement RequirementsRequirements NR 60S-HazardousNR 605-Hazardous Waste ClassificationWaste Classification

NR 610 to NR 615-NR610toNR615-Small and LargeSmall and Large Quantity GeneratorQuantity Generator StandardsStandards

NR 670-NR 670-Miscellaneous UnitMiscellaneous Unit StandardsStandards

NR 675~LandNR 675-Land Disposal RestrictionRestriction ssDisposal

NR 7IB-ManagementNR 718-Management of Solid Wastesof Solid Wastes Excavated DuringExcavated During Response ActionsResponse Actions

NR 722-Standards forNR 722-Standards for Selecting RemedialSelecting Remedial ActionsActions NR 724-RemedialNR 724-Remedial and Interim Actionand Interim Action Design,Design, Implementation,Implementation, Operation,Operation, Maintenance, andMaintenance, and MonitoringMonitoring RequirementsRequirements

RequiremcntRequirement

discharged to surface waters.discharged to surface waters.

Establishes analyt ical test methods,Establishes analslical test methods, n procedures, requirements forpreservatiopreservatio I1 procedures, requirements for

laboratories, and procedures applicable tolaboratorie~;, and procedures applicable to effluent limits for discharges to surfaceeffluent lim its for discharges to surfacc waters.waters. Required V-fDNR to establish effluent limitsRequired V/DNR to establish effluent limits for uncategorized point sources (i.e., not included in NR 22NR22 to 299 inclusive) and to for uncategorized point sources (i.e., not included in 11 to 299 inclusive) and to base those j imits on best practicable controlbase those limits on best practicable control technology currently available or besttechnology currelnly available or best available control technology economicallyavailable control technology economically achievable. Specifies minimuinimu requirements for storage achievable. Specifies rn mm requirements for storage or tt ofhaof hazardous wastes.or treatmentreatmen zardous wastes.

Establishes critericriteri for the classification ofEstablishes aa for the classification of hazardous waste.hazardous'vaste.

Specifies transpoI1 ation standards forSpecifies transportation standards for hazardous '.vaste based on ReRA standards.hazardous waste based on RCRA standards.

Establishes standards for environmentalEstablishes standards for environmental performancperformanc of miscellaneous treatmentee ofmiscellaneous treatment units.units.

Identifies hazardous wastes that areIdentifies hazardous wastes that are restricted from land disposal and definesrestricted from lalld disposal and defines exceptions.exceptions.

Describes requirements for temporaryDescribes require!nents for temporary storage, treatment, transportation, andstorage, treatment. transportation, and disposal of contanlinated soil and other non­disposal of contaminated soil and other non­hazardous solid wastes resulting fromhazardous solid wastes resulting from cleanup activities.cleanup activities. Describes requirelnents for identifying andDescribes requirements for identifying and evaluating remedi al action options andevaluating remedial action options and selecting reInedial actions. Specifies ee requrequirements for the design, selecting remedial actions. Specifies thth irements for the design, implementation,operation, maintenance andimplementation, operation, maintenance and monitoring of remedial actions.monitoring ofremedial actions.

37

ARARARAR StatusStatus

ARARARAR

ARARARAR

ARARARAR

ARARARAR

ARARARAR

ARARARAR

ARARARAR

ARARARAR

ARARARAR

ARARARAR

AnalysisAnalysis

Procedures applicable to effluent limitationsProcedures applicable to eftluent limitations for discharges from point sources under 144for discharges from point sources under 144 and 147 stats.and 147 stats.

The substantive requirements of obtaining aaThe substantive requirements of obtaining WPDES permit would be necessary.WPDES permit would be necessary.

Applies to actions involving excavation andApplies to actions involving excavation and disposal of contaminated soil exceedingdisposal of contaminated soil exceeding TCLP limits.TCLP limits.

Contaminated soil may exceed TCLPContaminated soil may exceed TCLP toxicity characteristic levels ancl betoxicity characteristic levels and be considered aa hazardous waste if recoveredconsidered hazardous waste if recovered from ground.from ground. Relevant and appropriate for oflsiteRelevant and appropriate for ofisite management of hazardous substances.management of hazardous substances. Would also apply to any treatment residualsWould also apply to any treatment residuals from water treatment units, including spentfrom water treatment units, including spent activated carbon.activated carbon. Placement of treated or untreated soil that isPlacement of treated or untreated soil that is classified as hazardous waste may make NRclassified as hazardous waste nny make NR 660 applicable, unless exemption under NR660 applicable, unless exemption under NR 680.04 is granted.680.04 is granted. Soils and debris exceeding TCLP level orSoils and debris exceeding TCLP level or considered to contain listed waste-typeconsidered to contain listed waste-type contamination may not be disposed incontamination may not be disposed in aa landfill without treatment. After treatment,landfill without treatment. After treatment, characteristic waste-type soils and debrischaracteristic waste-type soils and debris may be disposed of in Subtitle D landfill.may bc disposed of in aa Subtitle 0 landfill. Soils and debris with listed waste-typeSoils and debris with listed waste-type contamination after treatment must becontamination after treatment must be disposed of in Subtitle landfill.disposed of in aa Subtitle CC landfill. Applicable if excavated soil are notApplicable if excavated soil are not hazardous and relevant and appropriate forhazardous and relevant and appropriate for hazardous wastes (as defined by NRhazardous wastes (as defined by NR fiOO.03).600.03).

Requirements specified are consist whhRequirements specified are consist with remedy selection in FS process.remedy selection in FS process.

Design and implementation will confonn toDesign and implementation will confonn to requirements specified.requirements specified.

RegulationRegulation RequirementRequirement ARARARAR AnalysisAnalysis StatusStatus

NR 812-WellNR 812-Well Establishes the standards and methods forEstablishes the standards and methods for ARARARAR Construction of extraction wells willConstruction of extraction wells will Construction andConstruction and construction of new extraction wells andconstruction of new extraction wells and confomi to standards specified.confonn to standards specified. Pump InstallationPump Installation requirements for new pump installations.requirements for new pump installations. NR812.05-DisposalNR 812.0S-Disposal Specifies that injection of any waste toSpecifies that injection of any waste to ARARARAR Injection of treated groundwater will requireInjection oftreated groundwater will require ofPollutants;of Pollutants; surface or subsurface water is allowed ifsurface or subsurface water is allowed if approval from WDNR.approval from WDNR. Injection ProhibitionInjection Prohibition approved by WDNR.approved by WDNR. NR812.37-WaterNR 812.37-Water Describes the requirements for installation ofDescribes the requirements for installation of NotNot Point-of-use or in-house water treatmentPoint-of-use or in-house water treatment TreatmentTreatment point of use or in-house water treatmentpoint of use or in-house water treatment ARARARAR devices are not included in remedialdevices are not included in remedial

systems and establishes the need for WDNRsystems and establishes the need for WDNR alternatives.alternatives. approval.approval.

Chapter 147 Statutes-Chapter 147 Statutes- Requires point source discharges to obtainRequires point source discharges to obtain aa ARARARAR Substantive requirements in obtainingSubstantive requirements in obtaining aa Pollution DischargePollution Discharge permit from WDNR.permit from WDNR. pennit would have to be met for dischargespennit would have to be met for discharges EliminationElimination to Davy Creek.to Davy Creek. Note: Federal ARARs are included above however where the State of Wisconsin has authorization for the program the State ofNote: Federal AI?ARs are included above however where the State of Wisconsin has authorization for the program the State of Wisconsin ARARs apply.Wisconsin ARARs apply.

3838

Attachment 44 -- Public Notice AdvertisementAttachment Public Notice Advertisement Published in the Watertown Daily Times Wednesday,Wednesday, March 4,2012Published in the Watertown Daily Times March 4, 2012

EPA Begins ReviewEPA Begins Review of Oconomowoc Electroplating Inc.of Oconomowoc Electroplating Inc.

Superfund SiteSuperfund Site Ashippun, WisconsinAshippun, Wisconsin

u.s. EnvirolIDlental Protection Agency is conducting aa five-year review of the OconomowocU.S. Environmental Protection Agency is conducting five-year review of the Oconomowoc Electroplating, Inc. Superfund Site, W2573 Oak St., Ashippun, Dodge County, Wis. TheElectroplating, Inc. Superfund Site, W2573 Oak St., Ashippun, Dodge County, Wis. The Superfund law requires regular checkups of sites that have been cleaned up—with wasteSuperfund law requires regular checkups of sites that have been cleaned up-with waste managed on-site—to make sure the cleanup continues to protect people and the environment.managed on-site-to make sure the cleanup continues to protect people and the environment. This is the fourth review of the Site.This is the fourth five-yearfive-year review of the Site.

In 1990, EPA's cleanup plan included aa ground-water extraction system that had been pumpingIn 1990, EPA's cleanup plan included ground-water extraction system that had been pumping and treating contaminated ground water since 1996. That system waswas shut down in 2004 after anand treating contaminated ground water since 1996. That system shut down in 2004 after an EPA study determined it ineffective. 2011 amendment to the cleanup plan includedEPA study determined it waswas ineffective. AA 2011 amendment to the cleanup plan included natural processes to treat ground water contaminants and aa study of source areas to determine thenatural processes to treat ground water contaminants and study of source areas to determine the extent of contamination. This information will be used to select either excavation or in-j)laceextent of contamination. This information will be used to select either excavation or in-place chemical treatment to enhance source-area biological activity and further remove contaminants.chemical treatment to enhance source-area biological activity and further remove contaminants.

More information is available at the Ashippun Town Hall, W1266 Highway O, Oconomowoc,More information is available at the Ashippun Town Hall, W1266 Highway 0, Oconomowoc, and at www.epa.gov/region5/cleanup/oconomowoc. The review should be completed by July.and at www.epa.gov/region5/cleanup/oconomowoc. The review should be completed by July.

The five-yearfive-year review is an opportunity for you to tell EPA about Site conditions and anyThe review is an opportunity for you to tell EPA about Site conditions and any concerns you have. Contact:concerns you have. Contact:

Susan PastorSusan Pastor Bill RyanBill Ryan Community Involvement CoordinatorCommunity Involvement Coordinator Remedial Project ManagerRemedial Project Manager (312)353-1325(312) 353-1325 (312)353-4374(312) 353-4374 pastor.susan@epa.govpastor.susan@epa.gov ryan.williamj@epa.govryan.williamj@epa.gov

You may also call Region 55 toll-free at 800-621-8431, 8:30 a.m. -- 4:30 p.m., weekdays.You may also call Region toll-free at 800-621-8431, 8:30 a.m. 4:30 p.m., weekdays.

3939

Attachment Private Well Risk AssessmentAttachment 55 -- Private Well Risk Assessment

^^v to sr,,^^ UNITED STATES ENVIRONMENTAL PROTECTION AGENCYUNITED STATES ENVIRONMENTAL PROTECTION AGENCY ^ A \ SREGIONREGION 5 i ^ ^ 2 I 9311 GROH ROAD9311 GROH ROAD V ^ ^ I ^ P GROSSEILE, MI 4813 8GROSSE ILE, MI 48138

MEMORANDUMMEMORANDUM

SUBJECT: Well water contamination from Oconomowoc Electroplating, Ashippun, WISUBJECT: Well water contamination from Oconomowoc Electroplating, Ashippun, Wl

FROM: Keith Fusinski, Toxicologist US EPAFROM: Keith Fusinski, PhDPhD Toxicologist US EPA Superfund Division, Remedial Response Branch #1, Remedial Response Section #1Superfund Division, Remedial Response Branch #1, Remedial Response Section #1

TO: William Ryan, Remedial Project Manager, US EPATO: William Ryan, Remedial Project Manager, US EPA Superfund Division, Remedial Response Branch #2, Remedial Response Section #7Superfund Division, Remedial Response Branch #2, Remedial Response Section #7

DATE: 4/2/2012DATE: 4/2/2012

BACKGROUNDBACKGROUND

The Oconomowoc Electroplating Company Inc. (OECI) remedial Site (hereafter referred to asThe Oconomowoc Electroplating Company Inc. (OECI) remedial Site (hereafter referred to as the Site), comprises 10 acres ofland which includes the fmmer 44 acre OECI facility and 66 acresthe Site), comprises 10 acres of land which includes the foimer acre OECI facility and acres adjacent to the propeliy. The Site is located at 2573 Oak Street in Ashippun, WI.adjacent to the property. The Site is located at 2573 Oak Street in Ashippun, WL

Fonner operations at the Site included metal cleaning and electroplating which used chlorinatedFonner operations at the Site included metal cleaning and electroplating which used chlorinated solvents, cyanide and various metals. Operations ceased in 1990 and the buildings on Site weresolvents, cyanide and various metals. Operations ceased in 1990 and the buildings on Site were demolished in 1992. Historical groundwater contamination noted and remediated from 1994demolished in 1992. Historical groundwater contamination waswas noted and remediated from 1994 through 2004 for various metals and chlorinated solvents.tln-ough 2004 for various metals and chlorinated solvents.

STATEMENT OF THE ISSUESSTATEMENT OF THE ISSUES

RPM William Ryan requested an evaluation of human health risks be performed on dataRPM William Ryan requested an evaluation of human health risks be performed on data collected from various private wells from the Site. These wells have shown historicalcollected from various private wells from the Site. These wells have shown historical exceedances of the Wisconsin Administrative Code (WAC) NR 140 Preventive Action Limitexceedances of the Wisconsin Administrative Code (WAC) NR 140 Preventive Action Limit (PAL) of volatile organic compounds (VOC).(PAL) of volatile organic compounds (VOC).

CHEMICALS OF CONCERNCHEMICALS OF CONCERN

Vinyl ChlorideVinyl Chloride

Vinyl chloride is aa colorless, manufactured gas which does not occur naturally (ATSDR 2006). ItVinyl chloride is colorless, manufactured gas which does not occur naturally (ATSDR 2006). It bums easily and it is notnot stable at high temperatures. It can be formed when other substancesbums easily and it is stable at high temperatures. It can be formed when other substances such as trichloroethane, trichloroethylene, and tetrachloroethylene are broken down.such as trichloroethane, trichloroethylene, and tetrachloroethylene are broken down.

4040

Breathing high levels of vinyl chloride can cause dizziness and unconsciousness. BreathingBreathing high levels of vinyl chloride can cause dizziness and unconsciousness. Breathing extremely high levels can cause death. Structural changes of the liver have been associated withextremely high levels can cause death. Structural changes of the liver have been associated with prolonged breathing of vinyl chloride for several years. Some people who work with vinylprolonged breathing of vinyl chloride for several years. Some people who work with vinyl chloride have nerve damage and develop immune reactions. The lowest levels that produce liverchloride have nerve damage and develop illlinune reactions. The lowest levels that produce liver changes, nerve damage, and immune reaction in people are not known. The effects of drinkingchanges, nerve damage, and illlinune reaction in people are not known. The effects of drinking high levels of vinyl chloride are unknown.high levels of vinyl chloride are unknown. Touching vinyll chloride may cause numbness, redness, and blisters. Animal studies have shownTouching vinyl chloride may cause numbness, redness, and blisters. Animal studies have shown that long-term exposure to vinyl chloride can damage the sperm and testes.that long-term exposure to vinyl chloride can damage the spemi and testes.

The U.S. Depm1ment of Health and Human Services has determined that vinyl chloride is aaThe U.S. Department of Health and Human Services has detemiined that vinyl chloride is known carcinogen. Studies in workers who have breathed vinyl chloride over many yearsknown carcinogen. Studies in workers who have breathed vinyl chloride over many years showed an increased risk of liver, brain, lung cancer, and some cancers of the blood have alsoshowed an increased risk ofliver, brain, lung cancer, and some cancers of the blood have also been observed.been observed.

Methylene ChlorideMethylene Chloride

Methylene chloride is aa colorless liquid which does not occur naturally in the enviromnentMethylene chloride is colorless liquid which does not occur naturally in the environment (ATSDR-2000). It is used as an industrial solvent and as aa paint stripper. It may also be found in(ATSDR-2000). It is used as an industrial solvent and as paint stripper. It may also be found in some aerosol and pesticide products and is used in the manufacture of photographic film.film.some aerosol and pesticide products and is used in the manufacture of photographic

Inhalation of small amounts of methylene chloride may effect attention and accuracy in tasksInlialation of small amounts of methylene chloride may effect attention and accuracy in tasks requiring hand-eye coordination. Inhalation of large amounts of methylene chloride may causerequiring hand··eye coordination. Inhalation of large amounts of methylene chloride may cause dizziness, nausea and aa tingling or numbness of fingerfinger and toes. Skin contact with methylenedizziness, nausea and tingling or numbness of and toes. Skin contact with methylene chloride causes buming and redness of the skin.chloride causes burning and redness of the skin.

It is not known if methylene chloride can cause cancer in humans. An increased cancer risk wasIt is not known if methylene chloride can cause cancer in humans. An increased cancer risk was seen in mice breathing large amounts of methylene chloride for aa long time. The World HealthHealthseen in mice breathing large amounts of methylene chloride for long time. The World Organization (WHO) has determined that methylene chloride may cause cancer in humans. TheOrganization (WHO) has determined that methylene chloride may cause cancer in humans. The Department of Health and fluman Services (DHHS) has determined that methylene chloride canDepat1ment of Health and Human Services (DHHS) has determined that methylene chloride can be reasonably anticipated to be cancer-causing chemical. The EPA has determined thatbe reasonably anticipated to be aa cancer-causing chemical. The EPA has determined that methylene chloride is probable cancer-causing agent in humans.methylene chloride is aa probable cancer-causing agent in humans.

Trichloroethylene (TCE)Trichloroethylene (TCE)

Trichloroethylene (TCE) is aa nonflammable, colorless liquid (ATSDR-1997). It is used mainly asTrichloroethylene (TCE) is nonflammable, colorless liquid (ATSDR-1997). It is used mainly as aa solvent to remove grease fi'om metal parts, but it is also an ingredient in adhesives, paintsolvent to remove grease from metal parts, but it is also an ingredient in adhesives, paint removers, typewriter con-ection fluids, and spot removers. Trichloroethylene is not thought toremovers, typewriter conection fluids, and spot removers. Trichloroethylene is not thought to occur naturally in the environment. However, it has been found in underground water sourcesoccur naturally in the envirOlill1ent. However, it has been found in underground water sources and many surface waters as aa result of the manufacture, use, and disposal of the chemical. TCE isand many surface waters as result of the manufacture, use, and disposal of the chemical. TCE is known to be only slightly soluble in water, but there is ample evidence that dissolved TCE canknown to be only slightly soluble in water, but there is ample evidence that dissolved TCE can remain in groundwater for long time. The primary of degradation of TCE inremain in groundwater for aa long time. The primary meansmeans of degradation of TCE in

is by bacteria, but breakdown product by this means is vinyl chloride, taowngroundwatergroundwater is by bacteria, but aa breakdown product by this means is vinyl chloride, aa known human carcinogen and likely more of aa health concel11 than TCE. When TCE is released into thehuman carcinogen and likely more of health concern than TCE. When TCE is released into the air, it reacts relatively quickly in the presence of sunlight and oxygen, with about half of itair, it reacts relatively quickly in the presence of sunlight and oxygen, with about half of it

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breaking down to simpler compounds in about aa week. (ATSDR-1997.)breaking down to simpler compounds in about week. (ATSDR-1997.)

Inhalation of small amounts may cause headaches, lung ilTitation, dizziness, poor coordination,Inlialation of small amounts may cause headaches, lung iiTitation, dizziness, poor coordination, and difficulty concentrating. Inhalation of large amounts of TCE may cause impaired hemiand difficulty concentrating. Inhalation of large amounts of TCE may cause impaired heart function, unconsciousness, and death. Nerve, kidney, and liver damage may result fromfuncfion, unconsciousness, and death. Neiwe, kidney, and liver damage may result from prolonged inhalation of TCE.prolonged inhalation of TCE.

Consumption of small amounts of trichloroethylene for long periods may cause liver and kidneyConsumption of small amounts of trichloroethylene for long periods may cause liver and kidney damage, impaired immune system function, and impaired fetal development in pregnant women,damage, impaired immune system function, and impaired fetal development in pregnant women, although the extent of some of these effects is not yet clear. Drinking large amounts may causealthough the extent of some of these effects is not yet clear. Drinking large amounts may cause nausea, liver damage, unconsciousness, impaired heati function, or death. Skin rashes may occurnausea, liver damage, unconsciousness, impaired heart function, or death. Skin rashes may occur after short periods of contact with TCE.after short periods of contact with TCE.

Some studies with mice and rats have suggested that high levels of trichloroethylene may causeSome studies with mice and rats have suggested that high levels of trichloroethylene may cause liver, kidney, or lung cancer. Some studies of people exposed over long periods to high levels ofliver, kidney, or lung cancer. Some studies of people exposed over long periods to high levels of trichloroethylene in drinking water or in workplace air have found evidence of increased cancer.trichloroethylene in drinking water or in workplace air have found evidence of increased cancer. Although, there are some concerns about the studies of people who were exposed toAlthough, there are some concerns about the studies of people who were exposed to trichloroethylene, some of the effects found in people were similar to effects in animals.trichloroethylene, some of the effects found in people were similar to effects in animals.

EXPOSURE ASSESSMENT AND ASSUMPTIONSEXPOSURE ASSESSMENT AND ASSUMPTIONS

To be conservative in this assessment, the highest historical concentration detected, of eachTo be conservative in this assessment, the highest historical concentration detected, of each individual VOC, in each well used to determine both cancer and non-cancer risks. Ingestionindividual VOC, in each well waswas used to determine both cancer and non-cancer risks. Ingestion of well water and inlialation of volatilized VOCs during daily showering of the residents wereof well water and inhalation of volatilized VOCs during daily showering of the residents were both evaluated in this assessment. It is assumed that the residents shower for 30 minutes everyboth evaluated in this assessment. It is assumed that the residents shower for 30 minutes every day.day.

CONCLUSIONSCONCLUSIONS

The US EPA deteiTnines probability of non-cancer detrimental health effect to occur byThe US EPA detennines probability of aa non-cancer detrimental health effect to occur by calculating hazard index (HI). The HI is ratio of single substance exposure level overcalculating aa hazard index (HI). The HI is aa ratio of aa single substance exposure level over aa specified period of time to reference dose of the same substance derived from similarspecified period of time to aa reference dose of the same substance derived from aa similar exposure period. It is recommended that the HI of an exposure to chemical of concern be belowexposure period. It is recommended that the HI of an exposure to aa chemical of concern be below or equal to 1 which is the level at which no adverse human health effects are expected to occur.or equal to I which is the level at which no adverse human health effects are expected to occur. For cancer risk, the U.S. EPA recommends screening level that would equate to one inFor cancer risk, the U.S. EPA reconm1ends aa screening level that would equate to aa one in aa million (1x10' ) or greater lifetime risk of developing cancer from exposure to contaminatedmillion (I x10-6

) or greater lifetime risk of developing cancer from exposure to aa contaminated site. However, rates up to in 10,000 (1x10"" ) can be considered acceptable.site. However, rates up to 11 in 10,000 (lx10-4

) can be considered acceptable.

Of the ten private wells evaluated, only eight had exceedances of the Wisconsin AdministrafiveOf the ten private wells evaluated, only eight had exceedances of the Wisconsin Administrative Code (WAC) NR 140 Preventive Action Limit (PAL). Wells PW-04, PW-05, PW-07, PW-08,Code (WAC) NR 140 Preventive Action Limit (PAL). Wells PW-04, PW-05, PW-07, PW-08, PW-09, PW-11 all had multiple historical exceedances of vinyl chloride. Well PW-03 hadPW-09, PW-ll all had multiple historical exceedances of vinyl chloride. Well PW-03 had multiple historical exceedances of trichloroethylene. Well PW-Ol had single exceedance ofmultiple historical exceedances of trichloroethylene. Well PW-0 I had aa single exceedat1ce of methylene chloride in April of 2007.methylene chloride in April of2007.

As demonstrated in the chart below, all of the historical exceedances of the public wells are wellAs demonstrated in the chart below, all of the historical exceedances of the public wells are well

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below non-cancer risk screening levels. The lifetime cancer risk for these wells is either below or below non-cancer risk screening levels. The lifetime cancer risk for these wells is either below or within the US EPA's acceptable cancer risk range. Therefore, based upon the historical data, the within the US EPA's acceptable cancer risk range. Therefore, based upon the historical data, the low levels VOCs found in these private wells should not contribute to any detrimental health low levels VOCs found in these private wells should not contribute to any detrimental health effects of those citizens using these wells for drinking or bathing purposes. effects of those citizens using these wells for drinking or bathing purposes.

HighestHighest Non-Non- LifetimeLifetime WellWell Chemical of )f Historical Cancer CancerCancer Historical Cancer Non-Cancer Chemical ( Non-Cancer IDID Concern Concentration Child (HI) Child (HI) Adult (HI) Risk Concern Concentration Adult (HI) Risk PW-01 Methylene Chi Methylene Chloride 3.5 ug/L 3.7E-033.7E-03 1.3E-031.3E-03 3.9E-07PW-01 oride 3.5 ug/L 3.9E-07 PW-02PW-02 No Exceedances No Exceedances PW-03 TrichloroethyleTrichloroethylene 0.65 ug/L 8.6E-02 3.1 E-02 4.4E-07 PW-03 ne 0.65 ug/L 8.6E-02 3.1E-02 4.4E-07 PW-04PW-04 Vinvl Chloride Vinyl Chloride 0.069 ug/L 1.5E-031.5E-03 5.0E-04 1.5E-061.5E-06 0.069 ug/L 5.0E-04

Vinvl Chloride 0.042 ug/L 3.1E-04 PW-05PW-05 Vinyl Chloride 0.042 ug/L 8.9E-048.9E-04 3.1E-04 9.4E-079.4E-07 PW-07 PW-07 Vinyl Chloride 0.080 ug/L 1.7E-03 5.8E-04 1.8E-06Vinyl Chloride 0.080 ug/L 1.7E-03 5.8E-04 1.8E-06 PW-08PW-08 Vinyl Chloride 0.070 ug/L 1.5E-03 1.6E-061.6E-06 Vinvl Chloride 0.070 ug/L 1.5E-03 5.1E-045.1E-04 PW-09PW-09 Vinyl Chloride 1.6E-031.6E-03 5.3E-04 1.6E-06 0.073 ug/L 5.3E-04 1.6E-06Vinvl Chloride 0.073 ug/L PW-10 No Exceedances No ExceedancesPW-10 I PW-11 Vinyl Chloride ] 0.039 ug/L 0.039 ug/L I 8.3E-04 I 2.8E-04 8.7E-07 1PW-11 Vinyl Chloride 8.3E-04 2.8E-04 ~7E-07

* No reference dose available * No reference dose available

REFERENCESR E F E R E N C E S

ATSDR. 1997. Toxicological Profile for Trichloroethylene. U.S. DHHS, Atlanta ATSDR. 1997. Toxicological Profile for Trichloroethylene. U.S. DHLIS, Atlanta

ATSDR. 2000. Toxicological Profile for Methylene Chloride. U.S. DHHS, Atlanta ATSDR. 2000. Toxicological Profile for Methylene Chloride. U.S. DHHS, Atlanta

ATSDR. 2006. Toxicological Profile for Vinyl Chloride. U.S. DHHS, Atlanta ATSDR. 2006. Toxicological Profile for Vinyl Chloride. U.S. DHHS, Atianta

43 43

Appendix AAAppendix

The equations used to determine health risk for local residentsresidents drinking and bathing in waterThe equations used to determine health risk for local drinking and bathing in water from private wells on the Oconomowoc Electroplating Site are described below along withfrom private wells on the Oconomowoc Electroplating Site are described below along with examples as to how these equations were used.examples as to how these equations were used.

AT == Averaging timeAT Averaging time (cancer == 365 days/year xx 70 years == 25550 days)(cancer 365 days/year 70 years 25550 days) (non-cancer child == 365 days/year xx 66 years == 2190 days)(non-cancer child 365 days/year years 2190 days) (non-cancer adult == 365 days/year xx 24 years == 8760 days)(non-cancer adult 365 days/year 24 years 8760 days)

Averaging time in Shower scenarioATATss == Averaging time in Shower scenario (cancer == 24 hours/day xx 365 days/year xx 70 years == 613200 hours)(cancer 24 hours/day 365 days/year 70 years 613200 hours) (non-cancer child == 24 hours/day 365 days/year xx 66 years == 52560 hours) (non-cancer adult = 24 hours/day x365 days/year(non-cancer adult = 24 years = 262800 hours) (non-cancer child 24 hours/day 365 days/year years 52560 hours)

24 hours/day x365 days/year xx 24 years = 262800 hours)

BWBWc == Body Weight for Child (l5kg)c Body Weight for Child (15kg)

BWBWa = Body Weight for Adult (70kg)a = Body Weight for Adult (70kg)

CF == Conversion factor (1 x1003 ug/lmg)CF Conversion factor (1x1 ug/1 mg)

Conc = Measured Concentration (mg/kg)Cone = Measured Concentration (mg/kg)

ETs = Exposure Time in shower scenario (0.5 hours/day)

EDEDcc = Exposure Duration Child (6 years)

ETs = Exposure Time in shower scenario (0.5 hours/day)

= Exposure Duration Child (6 years)

EDEDaa == Exposure Duration Adult (24 years for cancer; 30 years for non-cancer)Exposure Duration Adult (24 years for cancer; 30 years for non-cancer)

EF Exposure Frequency (1 hour/day)EF == Exposure Frequency (l hour/day)

HI = Hazard Index (recommended to be less than 1)HI = Hazard Index (recommended to be less than 1)

HQ = Hazard Quotient (recommended to be less than 1)HQ = Hazard Quotient (recommended to be less than 1)

Water Ingestion Rate for Child (lL/day)IngInge =c = Water Ingestion Rate for Child (IL/day)

Water Ingestion Rate for Adult (2L/day)IngInga =a = Water Ingestion Rate for Adult (2L/day)

IUR = Inhalation Unit Risk ()lg/m3)lUR = Inhalation Unit Risk ([ig/m^)

KK == Volatilization factor (0.5 -Volatilization factor (0.5 - RAGS B)RAGS B)

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Rido == Oral reference dose from IRIS or applicable tables (mg/kg-day)Rfdo Oral reference dose from IRIS or applicable tables (mg/kg-day)

RiCj == Inhalation Reference Com.:entration from IRIS or applicable tables (mgim3)RfCj Inhalation Reference Concentration from IRIS or applicable tables (mg/in" )

St~ == Cancer Slope factor from IRIS or applicable tables (mg/kg-dayr1Sfo Cancer Slope factor from IRIS or applicable tables (mg/kg-day)"'

Ingestion of Soil

Daily Ingestion Rate for ChildDaily Ingestion Rate for Child -== Cone e EF ED /(BWc AT)

Ingestion of Soil

Cone xx IngIngc xx EF xx ED /(BWc xx AT)

Daily Ingestion Rate for Adult= Cone xx IngIngDaily Ingestion Rate for Adult= Cone aa xx EF xx ED /(BWa xx AT)ED /(BWaEF AT)

HI = Daily Ingestion RateHI == Daily Ingestion Rate /Rfd/Rfdoo

Lifetime cancer risk Daily Average Dose SfoLifetime cancer risk == Daily Average Dose xx St~

Inhalation of volatiles in shower scenarioInhalation of volatiles in showelr scenario

Daily Average Dose == Conc xx KK xx ET xx EF xx ED // ATATsDaily Average Dose Cone ET EF ED s

HI Daily Average Dose/(RfCi CF)HI == Daily Average Dose/(RfCi xx CF)

Lifetime cancer risk == Daily Average Dose xx IURLifetime cancer risk Daily Average Dose lUR

Total RiskTotal Risk

HQ ZHI from each scenarioHQ == :LHI from each scenario

Total Lifetime Cancer Risk = :LCancer RiskICancer RiskTotal Lifetime Cancer Risk =

ExampleExample

The maximum vinyl chloride concentration found in well PW-07 0.080 ug/L. Health risksThe maximum vinyl chloride concentration found in well PW-07 waswas 0.080 ug/L. Health risks from this concentration are demonstrated below.from this concentration are demonstrated below.

Non-Cancer -childNon-Cancer -child

Ingestion of well water from PW-09Ingestion of well water from PW-09 (8.0 xlO"' mg/L x 1 L/day 350 days/year years) (15 kg 2190 days)(8.0 xl0-5 mg/L xl L/day xx 350 days/year xx 66 years) // (15 kg xx 2190 days)

This results in daily dose of 5.1x10''^mg vinyl chloride/kg-day formg vinyl chloride/kg-day for aa child.This results in aa daily dose of 5.1 x 10-6 child.

This value is then divided by Rfd„ to determine total non-cancer risk.This value is then divided by Rido to determine total non-cancer risk.

4545

5.1xl 0-6 mg vinyl chloride/kg-day // 3xlO-3 mg vinyl chloride/kg-day =5.1x10 mg vinyl chloride/kg-day 3x10 mg vinyl chloride/kg-day = aa hazard indexhazard index ofof1.7x10"1.7x10-3

by well water ingestionby well water ingestion

Inhalation of volatile compounds during shower/bathing scenarioInlialation of volatile compounds during shower/bathing scenario (8.0 x10-5 ~lg/m3 x 0.5 x 0.5 hours/day x 350 days/year x 6 years) / (52560 days)(8.0 xlO"^ i-ig/m^ X 0.5 x 0.5 hours/day x 350 days/year x 6 years) / (52560 days)

This results in aa daily dose of7.9xlO-7 ~g vinyl chloride per cubic meter of air throughThis results in daily dose of 7.9x10"^ ^g vinyl chloride per cubic meter of air through volatilization for aa child.volatilization for child.

This value is then divided by the inlialation reference concentration multiplied by the conversionThis value is then divided by the inhalation reference concentration multiplied by the conversion factor to convert |ig to mg. 7.9x10"^ |ig vinyl chloride per cubic meter/factor to conve11 ~g to mg. 7.9xlO-7 ~g vinyl chloride per cubic meter! (l.Oxi 0-1 mg/m3xl 000 ~g/mg). This results in aa hazard index of 7.9x10-9 by volatile(1.0x10"' nig/m^ xlOOO |ig/mg). This results in hazard index of 7.9x10"^ by volatile inhalation. When the His of both exposure pathways are added together, the result is totalinhalation. When the HIs of both exposure pathways are added together, the result is aa total hazard index of 1.7x10-3 for aa child.hazard index of 1.7x10"' for child.

NOIl-Callcer -adultNon-Cancer -adult

The same equations can be used to calculate non-cancer risks for an adult exposed to.The same equations can be used to calculate non-cancer risks for an adult exposed to. 0.080 ug/L of vinyl chloride with aa consumption rate of2 liters per day.0.080 ug/L of vinyl chloride with consumption rate of 2 liters per day.

IngestionIngestion

(8.0 xlO-5 mg/L x 2 L/day x 350 days/year x 24 years) / (70 kg x 10950 days)(8.0 xlO"' mg/L X 2 L/day x 350 days/year x 24 years) / (70 kg x 10950 days)

This results in aa daily dose of 1.8x10-6 mg of vinyl chloride/kg-day for an adult throughThis results in daily dose of 1.8x10" mg of vinyl chloride/kg-day for an adult through ingestion.ingestion.

This value is then divided by RfdRfdo to determine the HI. l.8xI0-6 mg of vinyl chloride /kg-dayThis value is then divided by o to determine the HI. 1.8x10'*' mg of vinyl chloride /kg-day /3xI0-3 mg vinyl chloride/kg-day == aa HI of 5.8x10-4 by ingestion/3xlO"^ mg vinyl chloride/kg-day HI of 5.8x10"'* by ingestion

Inhalation of volatile compounds during shower/bathing scenarioInhalation of volatile compounds during shower/bathing scenario (8.0 xl 0-

5 ~g/m3 xx 0.5 xx 0.5 hours/day xx 350 days/year xx 24 years) // (262800 hours)(8.0 xlO"' |ig/m^ 0.5 0.5 hours/day 350 days/year 24 years) (262800 hours)

This results in daily dose of 6.4x10"'' |ig vinyl chloride per cubic meter of air throughThis results in aa daily dose of 6.4x I0-7 ~g vinyl chloride per cubic meter of air through volatilization for an adult.volatilization for an adult.

This value is then divided by the inhalation reference concentration multiplied by the conversionThis value is then divided by the inlialation reference concentration multiplied by the conversion factor to convert ~g to mg. 6.4xl 0-7 ~g vinyl chloride per cubic meter/ (1.0x10"' mg/ni^ xlOOO |ig/iiig). This results inmg/m hazard index of 6.4x10"'by volatile factor to convert \ig to mg. 6.4x10"^ |ig vinyl chloride per cubic meter/ (l.OxlO-

1 3x 1000 ~g/mg). This results in aa hazard index of6.4xlO-9 by volatile

inhalation. When the His of both exposure pathways are added together, the result is totalinhalation. When the HIs of both exposure pathways are added together, the result is aa total hazard index of 5.8x10"^ for an adult.hazard index of 5.8x10-4 for an adult.

Cancer -childCancer -child

Cancer Risk is assessed by the same method except the averaging time of 25550 days is used toCancer Risk is assessed by the same method except the averaging time of 25550 days is used to

4646

determine cancer over lifetime.determine cancer riskrisk over aa lifetime.

IngestionIngestion (8.0 xlO-5 mg/L x 1 L/day x 350 days/year x 6 years) / (15 kg x 25550 days)(8.0 xlO"' mg/L X 1 L/day x 350 days/year x 6 years) / (15 kg x 25550 days) This results in an averageaverage daily dose of 4.4x 10-7 mg vinyl chloride/kg-day for aa child. This valueThis results in an daily dose of 4.4x10"^mg vinyl chloride/kg-day for child. This value multiplied by the Sfo to determine cancer risk by ingestion.multiplied by the Sf~ to determine cancer risk by ingestion.

4.4xI0-4.4x10"''mg vinyl chloride/kg-day for7 mg vinyl chloride/kg-day for aa child xx 1.5xlOo (mg/kg-dayrchild 1 = 6.6xlO-7 cancer risk for1.5x10° (mg/kg-day)"' = 6.6x10"^ cancer risk for

child due to ingestion.aa child due to ingestion.

Inhalation of volatile compounds during shower/bathing scenarioInhalation of volatile compounds during shower/bathing scenario (8.0 xlO"^ |ig/iii^ X 0.5 X 0.5 hours/day x 350 days/year x 6 years) / (613200 hours)(8.0 xlO-5 /lg/m3 x 0.5 x 0.5 hours/day x 350 days/year x 6 years) / (613200 hours)

This results in daily dose of 6.8x10" ^ )ag vinyl chloride per cubic meter of air throughThis results in aa daily dose of 6.8x 10-8 /lg vinyl chloride per cubic meter of air through volatilization for child.volatilization fix aa child.

This value is then multiplied by the inhalation unit risk. 6.8x10-8 /lg vinyl chloride per cubic meter xx 8.8xI0-meter 8.8x10"^ Hg/m^6 ~lg/m3. This resultsThis results inin aa cancer risk of 6.0xlO-13' by volatile inhalation. This value is then multiplied by the inhalation unit risk. 6.8x10"^ )ag vinyl chloride per cubic

cancer risk of 6.0x10 ^ by volatile inhalation.

Cancer -adultCancer -adult

IngestionIngestion (8.0 xlO"' mg/L X 2 L/day x 350 days/year x 24 years) / (70 kg x 25550 days)(8.0 xlO-5 mg/L x 2 L/day x 350 days/year x 24 years) / (70 kg x 25550 days)

This results in an average daily dose of 7.5x10-7 mg vinyl chloride/kg-day for an adult. ThisThis results in an average daily dose of 7.5x10" mg vinyl chloride/kg-day for an adult. This value multiplied by the o to determine cancer risk by ingestion.value multiplied by the SfSfo to determine cancer risk by ingestion.

7.5x10"^ mg vinyl chloride/kg-day 1.5x10° (mg/kg-day)"' == 1.1xlO-6 cancer risk for an adult due to ingestion. 7.5xlO-7 mg vinyl chloride/kg-day xx 1.5xlO° (mg/kg-dayr 1 1.1x10' cancer risk for an adult due to ingestion.

Inhalation of volatile compounds during shower/bathing scenarioInhalation of volatile compounds during shower/bathing scenario (8.0 xl0-5 /lg/m3 xx 0.5 xx 0.5 hours/day xx 350 days/year xx 24 years) // (613200 hours)(8.0 xlO"^ lag/ni" 0.5 0.5 hours/day 350 days/year 24 years) (613200 hours)

This results in aa daily dose of2.7xl 0-7 /lg vinyl chloride per cubic meter of air throughThis resuhs in daily dose of 2.7x10"'' |ig vinyl chloride per cubic meter of air thi'ough volatilization for an adult.volatilization fcx an adult.

This value is then multiplied by the inhalation unit risk. 2.7xl 0-7 /lg vinyl chloride per cubicThis value is then multiplied by the inhalation unit risk. 2.7x10'^ |ig vinyl chloride per cubic

cancer risk of 2.4x10 ^ by volatile inhalation.metermeter xx 8.8xlO-8.8x10 6 /lg/m)ig/ni^ This results in3• This results in aa cancer risk of 2.4xlO-12' by volatile inhalation.

Total lifetime cancer risk for vinyl chloride exposure can be detemiined by adding each cancerTotal lifetime cancer risk for vinyl chloride exposure can be detelmined by adding each cancer for each exposure pathway for both children and adults resulting in total lifetime cancerriskrisk for each exposure pathway fC)r both children and adults resulting in aa total lifetime cancer

risk of 1.8xlO-6 from exposure to well water at the Oconomowoc Electroplating Site.risk of 1.8x10"^ from exposure to well water at the Oconomowoc Electroplating Site.

4747

Attachment Vapor Intrusion Risk AssessmentAttachment 66 -- Vapor Intrusion Risk Assessment

,.tt) sr,;. ^ UNITED STATES ENVIRONMENTAL PROTECTION AGENCYUNITED STATES ENVIRONMENTAL PROTECTION AGENCY ^ '-h REGIONREGION 55

i ^ ^ I 9311 GROH ROAD9311 GROH ROAD \'^^*'^J GROSSE ILE, MI 48138GROSSE ILE, MI 48138

MEMORANDUMMEMORANDUM

SUBJECT: Review of Potential Vapor Intrusion Issue for Oconomowoc Electroplating.SUBJECT: Review ofPotential Vapor Intrusion Issue for Oconomowoc Electroplating.

FROM: Keith Fusinski, PhD Toxicologist US EPAFROM: Keith Fusinski, PhD Toxicologist US EPA Superfund Division, Remedial Response Branch #1, Remedial Response Section #1Superfund Division, Remedial Response Branch #1, Remedial Response Section #1

TO: William Ryan, Remedial Project Manager, US EPA Superfund Division, Remedial Response Branch #2, Remedial Response Section #7

TO: William Ryan, Remedial Project Manager, US EPA

Superfund Division, Remedial Response Branch #2, Remedial Response Section #7

DATE: 4/2/2012 DATE: 4/2/2012

BACKGROUND BACKGROUND The Oconomowoc Electroplating Company Inc. remedial Site (the Site), comprises 10 acres ofThe Oconomowoc Electroplating Company Inc. remedial Site (the Site), comprises 10 acres of land which includes the fonner 44 acre facility and 66 acres adjacent to the property. The Site island which includes the fornier acre facility and acres adjacent to the property. The Site is located at 2573 Oak Street in Ashippun, WI.located at 2573 Oak Street in Ashippun, Wl.

Fonner operations at the Site included metal cleaning and electroplating which used chlorinatedFomier operations at the Site included metal cleaning and electroplating which used chlorinated solvents, cyanide and various metals. Operations ceased in 1990 and the buildings on site weresolvents, cyanide and various metals. Operations ceased in 1990 and the buildings on site were demolished in 1992. Historical groundwater contamination was noted and remediated from 1994demolished in 1992. Historical groundwater contamination was noted and remediated from 1994 tln-ough 2004 for various metals and chlorinated solvents.through 2004 for various metals and chlorinated solvents.

STATEMENT OF THE ISSUESSTATEMENT OF THE ISSUES

Vapor intrusion is the migration of volatile chemicals from the subsurface into overlying buildings.Vapor intrusion is the migration of volatile chemicals from the subsurface into overlying buildings. Volatile chemicals in contaminated groundwater can emit vapors that may migrate throughVolatile chemicals in contaminated groundwater can emit vapors that may migrate through subsurface soils and into indoor air spaces of overlying buildings. In extreme cases, the vapors maysubsurface soils and into indoor air spaces of overlying buildings. In extreme cases, the vapors may accumulate in dwellings or occupied buildings to levels that may pose near-tenn safety hazards (e.g.,accumulate in dwellings or occupied buildings to levels that may pose near-tenn safety hazards (e.g., explosion), acute health effects, or aesthetic problems (e.g., odors).explosion), acute health effects, or aesthetic problems (e.g., odors).

The vapor intrusion pathway is considered complete when the vapors move from the source (orThe vapor intrusion pathway is considered complete when the vapors move from the source (or contamination) tln-ough the deep soil and subsurface soil gas, and into structure.groundwatergroundwater contamination) through the deep soil and subsurface soil gas, and into aa structure.

Each of these components must exist in order for the pathway to be considered complete. It isEach of these components must exist in order for the pathway to be considered complete. It is possible for volatile compounds to impact deep and subsurface soil gas but still not impactpossible for volatile compounds to impact deep and subsurface soil gas but still not impact indoor air. In this case the pathway would not be considered complete and no mitigation wouldindoor air. In this case the pathway would not be considered complete and no mitigation would be required.be required.

4848

RPM Bill Ryan was advised by the Wisconsin Depm1ment of NaturalNatural Resources (WDNR)(WDNR) ofRPM Bill Ryan was advised by the Wisconsin Department of Resources of concems for possible vapor intrusion issue at the residential neighborhood to theconcerns for aa possible vapor intrusion issue at the residential neighborhood to the west/southwest of the Site. These concerns are upon elevated trichloroethylene (TCE) inwest/southwest of the Site. These concerns are basedbased upon elevated trichloroethylene (TCE) in the shallow and deep monitoring wells which are proximal to the residential neighborhood. Mr.the shallow and deep monitoring wells which are proximal to the residential neighborhood. Mr. Ryan requested an analysis of historical groundwater data to determine if these concems areRyan requested an analysis of historical groundwater data to determine if these concerns are valid.valid.

CHEMICALS OF CONCERNCHEMICALS OF CONCERN

Trichloroethylene (TCE)Trichloroethylene (TCE)

Trichloroethylene (TCE) is aa nonflammable, colorless liquid (ATSDR-1997). It is used mainly asTrichloroethylene (TCE) is nonflammable, colorless liquid (ATSDR-1997). ft is used mainly as solvent to remove grease from metal parts, but it is also an ingredient in adhesives, paintaa solvent to remove grease from metal parts, but it is also an ingredient in adhesives, paint

removers, typewriter con-ection fluids, and spot removers. Trichloroethylene is not thought toremovers, typewriter conection fluids, and spot removers. Trichloroethylene is not thought to occur naturally in the enviromnent. Hov^ever, it has been found in underground water sourcesoccur naturally in the environment. Hmvever, it has been found in underground water sources and many surface waters as result of the manufacture, use, and disposal of the chemical. TCE isand many surf~lce waters as aa result of the manufacture, use, and disposal of the chemical. TCE is known to be only slightly soluble in water, but there is ample evidence that dissolved TCE canknown to be only slightly soluble in water, but there is ample evidence that dissolved TCE can remain in groundwater for long time. When TCE is released into the air, it reacts relativelyremain in groundwater for aa long time. When TCE is released into the air, it reacts relatively quickly in the presence of sunlight and oxygen, with about half of it breaking down to simplerquickly in the presence of sunlight and oxygen, with about half of it breaking down to simpler compounds in about week (ATSDR 1997).compounds in about aa week (ATSDR 1997).

Inhalation of small amounts of 'ICE may cause headaches, lung irritation, dizziness, poorInhalation of small amounts of TCE may cause headaches, lung irritation, dizziness, poor coordination, and difficulty concentrating. Inhalation of large amounts of TCE may causecoordination, and difficulty concentrating. Inhalation of large amounts of TCE may cause impaired heart function, unconsciousness, and death. Nerve, kidney, and liver damage may resultimpaired hem1 function, unconsciousness, and death. Nerve, kidney, and liver damage may result from prolonged inhalation of TCE.from prolonged inhalation ofTCE.

Some studies vv'ith mice and rats have suggested that high levels of trichloroethylene may causeSome studies with mice and rats have suggested that high levels of trichloroethylene may cause liver, kidney, or lung cancer. Some studies of people exposed over long periods to high levels ofliver, kidney, or lung cancer. Some studies of people exposed over long periods to high levels of trichloroethylene in drinking water or in workplace air have found evidence of increased cancer.trichloroethylene in drinking water or in workplace air have found evidence of increased cancer. Although, there are some concerns about the studies of people who were exposed toAlthough, there are some concerns about the studies of people who were exposed to trichloroethylene, some of the effects found in people were similar to effects in animals,trichloroethylene, some of the etTects found in people were similar to effects in animals,

VAPOR INTRUSION AND GROUNDWATER ASSESSMENTVAPOR INTRUSION AND GROUNDWATER ASSESSMENT

The US EPA detemiines probabihty of non-cancer detrimental health effect to occur byThe US EPA detennines probabil-ity of aa non-cancer detrimental health effect to occur by calculating hazard index (HI). The HI is ratio of single substance exposure level overcalculating aa hazard index (HI). The HI is aa ratio of aa single substance exposure level over aa specified period of time to reference dose of the same substance derived from similarspecified period of time to aa reference dose of the same substance derived from aa similar exposure period. It is recommended that the HI of an exposure to chemical of concern be belowexposure period. It is recommended that the HI of an exposure to aa chemical of concem be below or equal to 1, which is the level at which no adverse human health effects are expected to occur.or equal to 1, which is the level at which no adverse human health effects are expected to occur. For cancer risk, the US EPA recommends screening level that would equate to one inFor cancer risk, the US EPA reconunends aa screening level that would equate to aa one in aa millionmillion (1x10" '(1 x 10-6 or greater lifetime of developing cancer from exposure to contaminated)) or greater lifetime riskrisk of developing cancer from exposure to aa contaminated site. US EPA Office of Solid Waste and Emergency Response (OSWER) recommends removalsite. US EPA Oflice of Solid Waste and Emergency Response (OSWER) reconunends aa removal action if exposure to contamination may result in non-cancer (HI) greater than 3, oraction if exposure to contamination may result in aa non-cancer riskrisk (HI) greater than 3, or aa lifetime cancer greater than 1 in 10,000. US EPA's residential indoor air screening levels arelifetime cancer riskrisk greater than I in 10,000. US EPA's residential indoor air screening levels are

4949

based upon an HI of 1 or an excess lifetime excess cancer risk of in 1,000,000.based upon an HI of loran excess lifetime excess cancer risk of 11 in 1,000,000.

WDNR has expressed concems regarding possible vapor intrusion issues based upon TCEWDNR has expressed concerns regarding possible vapor intrusion issues based upon TCE exceedances of Wisconsin Preventative Action Limits (PALs). PALSs are determined by WDNRexceedances of Wisconsin Preventative Action Limits (PALs). PALSs are determined by WDNR to be protective of human health (WDNR 2010). US EPA Region Vapor Intrusion Guidanceto be protective of human health (WDNR -- 2010). US EPA Region 55 Vapor Intrusion Guidance recommends the vapor intrusion mitigation be based upon indoor air concentrations shown to berecommends the vapor intrusion mitigation be based upon indoor air concentrations shown to be from subsurface source, such as contaminated groundwater plume 2010).from aa subsurface source, such as aa contaminated groundwater plume (USEP(USEPAA -- 2010). AA complete vapor intrusion pathway should be established prior to remedial action taking place.complete vapor intrusion pathway should be established prior to aa remedial action taking place.

The Region Vapor Intrusion Guidance describes calculation to detennine the attenuationThe Region 55 Vapor Intrusion Guidance describes aa calculation to detennine the attenuation factor (AF) between groundwater and indoor air (USEPA 2010).factor (AF) between groundwater and indoor air (USEPA -- 2010).

A F — Cindoor/(CgroLind\vater X H X C F )AF = Cindoor/(Cgroundwater x H x CF)

Where;Where; AF attenuation factorAF == attenuation factor

Concentration indoor AirCindoorCindoor == Concentration indoor Air Cgroundwater = Concentration groundwaterCgroundwater = Concentration groundwater

Henry's law constant (unitless)HH == Henry's law constant (unitless) CF Conversion factor (O.OOlm /L)CF == Conversion factor (0.00Im3/L)

The Region Vapor Intrusion Guidance states that the default AF from groundwater to indoor isThe Region 55 Vapor Intrusion Guidance states that the default AF from groundwater to indoor is 0.001. Therefore, the default AF from indoor air to groundwater is 1000. The above equation can0.001. Therefore, the default AF from indoor air to groundwater is 1000. The above equation can be used to derive groundwater screening levels using the above default parameters. The regionalbe used to derive groundwater screening levels using the above default parameters. The regional screening level for indoor air based upon in 1,000,000 excess lifetime cancer risks is 0.43screening level for indoor air based upon aa 11 in 1,000,000 excess lifetime cancer risks is 0.43 pg/m" . The Region Vapor Intrusion Guidance suggest that because of temporal and seasonalIlg/m3. The Region 55 Vapor Intrusion Guidance suggest that because of temporal and seasonal variations, indoor air levels exceeding in 100,000 (1x10"^) lifetime cancer risk level generallyvariations, indoor air levels exceeding aa 11 in 100,000 (lxlO-5

) lifetime cancer risk level generally trigger actions to reduce indoor air levels under the Remedial Program. Therefore, an indoor airtrigger actions to reduce indoor air levels under the Remedial Program. Therefore, an indoor air screening level of 4.3 pg/ni would be used to protect against lifetime excess cancer risk ofscreening level of 4.3 ~lg/m3 would be used to protect against aa lifetime excess cancer risk of 11 inin 100,000. However, the indoor air screening level of 2.1 |ig/ni'' is protective against potential non­100,000. However, the indoor air screening level of 2.1 Ilg/m3 is protective against potential non­cancer health effects and should be used to calculate groundwater screening concentrations sincecancer health effects and should be used to calculate groundwater screening concentrations since it is more protective number. The Henry's law constant of TCE is 0.4.it is aa more protective number. The Henry's law constant ofTCE is 0.4.

Cgroundwater = Ciiidoor ( C F X X A F )Cgroundwater = Cindoor // (CF x HH x AF)

Using the above factors;Using the above factors; Cgroundwater^ 2 .1 pg /n i^ / (O.OOllll^/L X 0.4 X 1000)Cgroundwater= 2.1 Ilg/m3 / (0.00hn3/L x 0.4 x 1000)

This results in screening level of 5.25 )ig/This results in aa groundwatergroundwater screening level of 5.25 Ilg/LL

Ground water is to the southwest of the Site with discharge to Davy Creek (CH2M HillGround water flowflow is to the southwest of the Site with discharge to Davy Creek (CH2M Hill 2009). Historically there were four monitoring wells of interest to the southwest of the Site MW­2009). Historically there were four monitoring wells of interest to the southwest of the Site MW­6, MW-15S, MW-15D, and MW-102D (Figure 1).6, MW-I5S, MW-I5D, and MW-I02D (Figure 1).

5050

•• MW- 66 was abandoned ill 2003. However in 1989 it had TCE concentrations of 130MW- was abandoned in 2003. How-ever in 1989 ft had TCE concentrations of 130 Ilg/L.pg/L. MW-15S one detection ofTCE in March 2006 01'25 ~tg/L.•• MW-15S one detection of TCE in March 2006 of 25 |Lig/L. MW-15D thitieen detections of TCE during sampling events which took place between•• MW-15D thirteen detections of TCE during sampling events which took place between 2004 and 2009. TCE concentrations ranged from 10 Ilg/L to 41 Ilg/L. The most recent2004 and 2009. TCE concentrations ranged from 10 pg/L to 41 pg/L. The most recent detection in 2009 was 18 ~lg/L.detection in 2009 was 18 pg/L. MW-I02D eleven detections ofTCE during sampling events which took place between•• MW-102D eleven detections of TCE during sampling events which took place between 2004 and 2009. TCE concentrations ranged from 0.63 Ilg/L to 3.7 Ilg/L. The most recent2004 and 2009. TCE concentrations ranged from 0.63 pg/L to 3.7 pg/L. The most recent detection waswas 11 Ilg/L.detection pg/L.

The concentration ofTCE fi'om one sampling event of MW-6 and fivefive from MW-15D were at orThe concentration of TCE from one sampling event of MW-6 and from MW-15D were at or above the calculated protective vapor intrusion groundwater screening criteria of 5.25 Ilg/L.above the calculated protective vapor intrusion groundwater screening criteria of 5.25 pg/L.

CONCLUSIONSCONCLUSIONS

As stated previously, exceedance of the groundwater screening level does notnot automaticallyAs stated previously, exceedance of the groundwater screening level does automatically trigger aa vapor intrusion mediation. The vapor intrusion pathway requires multiple lines oftrigger vapor intrusion mediation. The vapor intrusion pathway requires multiple lines of evidence to detennine if volatilization of groundwatergroundwater contamination leads to deep soil gasevidence to detennine if volatilization of contamination leads to deep soil gas contamination. This in tum must impact subslab soil gas underneath buildings. The contaminatedcontamination. This in tum must impact subslab soil gas undemeath buildings. The contaminated subslab soil gas then impacts indoor air tlirough cracks in the foundation, and so forth. Each ofsubslab soil gas then impacts indoor air through cracks in the foundation, and so f01ih. Each of these is required for complete vapor intrusion pathway.these is required for aa complete vapor intrusion pathway.

number of monitoring wells located on the Site property consistently show high levels of TCEAA number of monitoring wells located on the Site property consistently show high levels of TCE in the groundwater (CH2M Hill 2009). Based upon this, and the above discussion of monitoringin the groundwater (CH2M Hill 2009). Based upon this, and the above discussion of monitoring wells in the residential area, it can be concluded that there is potential for the existence ofwells in the residential area, it can be concluded that there is aa potential for the existence ofaa groundwater plume of volatile organic compounds under the residential structures southwest ofgroundwater plume of volatile organic compounds under the residential structures southwest of the former Oconomowoc Electroplating facility.the former Oconomowoc Electroplating facility.

RECOMMENDATIONSRECOMMENDATIONS

It is the mission of US EPA to protect human health and the environment. The health effects ofIt is the mission of US EPA to protect human health and the enviromnent. The health effects of prolonged inhalation of TCE from vapor intrusion can be detrimental to human health. In orderprolonged inhalation of TCE from vapor intrusion can be detrimental to human health. In order to ensure that vapor intrusion is not an issue at this Site, it is recommended that deep soil gasto ensure that vapor intrusion is not an issue at this Site, it is recommended that deep soil gas samples be collected and analyzed for volatile organic compounds. If TCE is detected in soil gassamples be collected and analyzed for volatile organic compounds. If TCE is detected in soil gas at levels above 2.1 pg/m^ then this should be followed by subslab soil gas and indoor airat levels above 2.1 Ilg/m3 then this should be followed by subslab soil gas and indoor air sampling. However, if TCE in soil gas are found to be below 2.1 pg/m'' then the vaporsampling. However, if TCE levellevelss in soil gas are found to be below 2.1 Ilg/m3 then the vapor intrusion pathv/ay can be mled out.intrusion pathway can be ruled out.

In addition to TCE, other volatile organic compounds may also play a role in the vapor intrusionIn addition to rCE, other volatile organic compounds may also playa role in the vapor intrusion pathway. The table below shows indoor air screening levels based upon in 100,000 excesspathway. The table below shows indoor air screening levels based upon aa 11 in 100,000 excess lifetime cancer risk or HI of I for other potential chemicals of concern at the Oconomowoclifetime cancer risk or aa HI of 1 for other potential chemicals of concem at the Oconomowoc Electroplating Site, along with calculated groundwater screening levels. Once again, anElectroplating Site, along with calculated groundwater screening levels. Once again, an exceedance of the groundwater screening level does necessarily equate to an exceedance inexceedance of the groundwater screening level does notnot necessarily equate to an exceedance in the indoor air tlirough the vapor intrusion pathway.the indoor air through the vapor intrusion pathway.

5151

Soil-gasSoil-gas Groundwater Groundwater ScreeningScreening Screening Screening

Volatile Organic Compounds Level LevelLevel Volatile Organic Compounds Level

(VOCs) (ug/m3)(ug/m3) (ug/l) Basis (nc=nonca ncer; ca=cancer) (VOCs) (ug/l) Basis (nc=noncancer,- ca=cancer)

Trichloroethane, 1,1,1-Trichloroethane, 1,1,1- 5,2005,200 7,400 nc 7,400 nc (HI=l)(Hl=l)

Dichloroethane,l,l-Dichioroethane, 1,1- 1515 65 ca 65 ca (CR=le-OS)(CR=le-05)

Dichloroethylene, 1,1- 210 197 nc (HI=l)Dichloroethylene, 1,1- 210 197 nc (Hl=l)

378 (HI=l)(Hl=l) Dichloroethylene,Dichloroethylene, l,2-trans- 1,2-trans- 6363 378 ncnc

TrichloroethyleneTrichloroethylene 2.12.1 5.2 ncnc (HI=l)

Vinyl Chloride 1.61.6 1.41.4 caca (CR=le-05)

5.2 (Hi=l)

Vinyl Chloride (CR=le-OS)

REFERENCESREFERENCES

ATSDR 1997. Toxicological Profile for Trichloroethylene. u.s. DHHS, Atlanta ATSDR 1997. Toxicological Profile for Trichloroethylene. U.S. DHHS, Atlanta

CH2M Hill 2009. ANNUAL GROUNDWATER REPORT. Oconomowoc Electroplating CH2M Hill 2009. ANNUAL GROUNDWATER REPORT. Oconomowoc Electroplating Company, Inc. Site. Oconomowoc , Wisconsin. WANo. 003-LRLR-05M8/ContractNo. EP-S5-Company, Inc. Site. Oconomowoc, Wisconsin. WA No. 003-LRLR-05M8/Contract No. EP-S5­06-01 06-01

US EPA 2010. United States Environmental Protection Agency. Region 5-Superfund Division. US EPA 2010. United States Environmental Protection Agency. Region 5-Superfijiid Division. Vapor Intrusion Guidebook. Vapor Intrusion Guidebook.

WDNR 2010. NR 140.05 Groundwater Criteria. http://legis.wisconsin.gov/rsb/code/nr/ WDNR 2010. NR 140.05 Groundwater Criteria. littp://legis.wisconsin.gov/rsb/code/nr/ nrl40.pdfnrl40.pdf

5252

FIGURE 11FIGURE

MW-102D 3.7 pg/L MAX

Figure 1. Area map showing the former Oconomowoc Electroplating facility and local residences.Figure 1. Area map showing the former Oconomowoc Electroplating facility and local residences. Groundwater is to the southwest. Shallow and deep groundwater monitoring wells are shown withGroundwater flowflow is to the southwest. Shallow and deep groundwater monitoring wells are shown with maximum detected TCE concentrations. Green dots are active monitoring wells. Red dot ismaximum detected TeE concentrations. Green dots are active monitoring wells. Red dot is aa decommissioned monitoring well. The location of wells is approximated.decommissioned monitoring well. The location ofwells is approximated.

5353

Attachment 77 -- Trend Analyses for Select Monitoring and PrivateAttachment Trend Analyses for Select Monitoring and Private WellsWells

5454

••

TCE Levels Observed f rom PW-03TCE Levels Observed from PW-03VOC Trends fromVOC Trends from PW Name 1 Well tvoel DateDate 1 DatelDatel 1 DatB2 1I VC 1I VinvlchloridelVinylchlaide I TCTCEE I Trichloroethene ILPw Name) Well typel I I Date2 VC 1 TrichloroethenePrivate Well Data r »W-03 PWPW Jul-OS 0711112005 Jul-05 0.018 0.018U 0.42 0.42PW-03 Jul-05 07/11/2005 Jul-05 0.018 0.018U 0.42 0.42Private Well Data PW-03 PWPW Jan-06 0110912006 Jan-06 0.018 0.018UJ 0.360.36JPW-03 JanoC6 01/09/2006 JanoC6 0.018 0.018UJ 0.36 0.36_J PW-n3PW-03 iPW Mar-06MaroC6 03/09/2006 Mar-06MaroC6 0.018 0.018UJ0.018UJ 0.37 0.37J ,PW ' 03/0912006 0.018 0.370.37J PW-03PW-03 'PWPW JanoC7 01/15/20070111512007 0.0180.018 0.018U0.018U 0,50.5 0.5 PW-03 PW AproC7 04/02/2007 AproC7 0.018 0.018UJ 0,49Q-aaJ

Jan-07 Jan-07JanoC7 0.5 PW-03 PW Apr-07 04/0212007 Apr-07 0.018 0.018UJ____ PW-03PW-03 PW JunoC7 06/25/2007 JunoC7 0.013 O . O I j g f O . e S - * , ! / HighestPW Jun-07 06/2512007 Jun-07 0.013 0.65O.Ole ~.:~~ 0.65 Highest

PW 09/2412007 TeE levelPW-03 SepoC7 SeO-C7 0.013 0.013U . "-Q.53 TCE level -- . .PW-03PW-03 PW JanoC8 01/07/2008 JanoC8 0.013 0.013UJ 0.58 0.58J -':••• , detectedPW Jan-08 0110712008 Jan.«8 0.013 0.013UJ 0.580.58J ' detected PY"-03 PW /^ r -08 04/1412008 Apr-08 0.013 0.013U ^jSasf.JY.Sl{PW-03 PW AproC8 04/14/2008 AproC8 0.013 0.D1~ _ 0.540.54 from'ran allal/The most-recent water-supply well samples from MarchThe most-recent water-supply well samplesfrom March PW-03 JuloC8PW-03 PWPW Jul-OBJuloC8 07/14/200807/1412008 Jul-08 0.0130.013 0.013U 0.46 - y - < ' ' 0.46 PWs0.013(::::" PW-03PW-03 PWPW Oct-OBOctoC8 10/10/200810/1012008 Oct-08 0.0130.013 0.013O.O^wCT 0 . 6 5 * ' 7 ]> 0.65OctoC8 PWs2011 showed Private well PW-03 as the only one being2011 showed Private well PW~03 as the only one being i::;c':5' ~:::

Jar>-09 0.59 PW-03 PWPW Mar-11 03/15/201103/15/2011 Mar-11 0,0080.008 0.008J 0,57 0.57

JanoC9 0.013U0.013U 0.59PW-03PW-03 PWPW Jan-09 01/05/200901/05/2009 Jan-09 0.0130.013 ^ 0.59. - "PW-03 Mar-ll Mar-ll 0.008J 0.57 0,57routinely monitored with TCE that exceeds 0.5 ug/l or theroutinely monitored with TCE that exceeds 0.5 ug/l or the

Wisconsin DNR groundwater preventive action limitWisconsin DNR groundwater preventive action limit (PAL)(PAL) PW-03PW-03 y = 5E-05e°™"2)<y = 5E.Q5e°.OOO2x

for TCE. R2R2 == 0.44490.4449for TCE.

0.9

_ 0 . 80.8 0;:­g> 0.772 0.

0.9

•• •• _ _ _ - - ^ I

| o . 6~ 0.6 l ­ • --:--' •••• — 1 - * - ""^ ----­0.50.5 ­

, — — " • • -•VC (Vinyl Chloride) Levels Observed from PW-07VC (Vinyl Chloride) Levels Observed from PW-07 0.40.4 ­ * * Year11 Year

0.3 I PW Date I Datel I Date2 VC I Trichloroelhenel Date 04,05 04/06 04/07 04/08 04/09 04/10 05/11NameNamel1Well typeWell tvpelI Date 1 Datel 1 Date2 1I vc 1I VinylchlorideVinvlchlorid B\I TCETCE 1 Trichloroethene Date 1Q,(,410104 04105 ,0,0510105 04106 10/0610106 04107 1010710/07 04/08 10/0810108 04109 1010910/09 04110 10/1010/10 05/11 11/1111/11IPW 1

_ J,!-1-05 Jul-05 0.042J PW-07 PW Jan-06 01/09/2006 JanoC6 0.056 0.056J 0.041 0.041J

PW-07PW-07 PWPW Jul-05 07/11/200507l11g005 Jul-05 0.04~ 0.03 0.03U0.042 0.042J 0.03 ~03U

PW-07 PW JanoC6 01/0912006 Jan-06 0.056 0.056J 0.0410.041J PW-07 PW MaroC6 03/09/2006 MaroC6 0.056 0.056J 0,031 0.031 JPW-07 PW Mar-06 03/0912006 Mar-06 0.056 0.056J 0.031 0.031J PW-07PW-07 PW JanoC7 01/16/2007 JanoC7 0.046 0.046J 0.076 0.076J PW-03PW Jan-07 01/1512007 Jan-07 0.046 0.046J 0.076 0.076J ; ^ I MW-14DMW-14D VPW-07PW-07 PWPW Apr-07AproC7 04/02/200704/0212007 Apr-07AproC7 0.05 0.05J 0.054 0.054J ,0.05 0.05J 0.054 0.054J

PW Jun-07 06/25/2007 JunoC7 0.013 0.013U 0.05 0.05U . _ . H . ' " 9'"' , PW-02PW-07PW-07 PW JunoC7 06/2512007 Jun-07 0.013 0.013U PW-040.050.05U PV/-04 .. PN-02 PW-07 . PW Sep-07 09/2412007 0.0720.072 0.05 0.05U0.05 0.05UPW-07 PW SepoC7 09/24/2007 SeO-C7Sep-07 0.0720.072 Highest level.Highest level. ,PW-07 PWPW Apr-08AproC8 04/141200804/14/2008 Apr-08AproC8 0.0650.065 0.065 0.0550.055.1._----0.055 0 . 0 5 5 4 . . - - — '••PW-07 0.065

~ MW-4DPW Jul-08 07/1412008 Jul-08 0.056 0.056 [l..Llitt O.t>56J PW-07 PW OcloC8 ""'.tIROriJia_ • .P.c1511------ 0.050.05U PW-09PW-09 , PW-07PW-07 PW Jul-08 07/14/2008 JuloC8 0.056 0.056 _QJ3Se-0.T)56J PW-07 PW Oct-08 10/1012008 n n59 ­PW-07 PW JanoC9 09 Jan-09 0.08 0.05 0.05U0.05 0.05U

10/10/2008 _UJJ59 0 . 0 5 9 - - ' ' - ' 0.05 0.05U r.tW-101B PW-07 PW Jan-09 01105 JanoC9 0.08^2^ 0.080.08 MW-4S,MW-101S -PW Mar-11 03/15/20 - 0.50.5UPW-07PW-07 PW Mar-ll 0 3 / 1 5 / 2 0 V T 0.056 0.5 0.5U ,, _ EW-01

PW-07PW-07 ^ PW-07 ,3E.Q5e°.OOO2x yy-== SE-OSe"""^ I ,R2 = 0.0524R2 = 0.0524 _^ W PW-06 I

0.09 ,0 09 ­ :3f v MW-15D MW-3D•• \ • MW.15S ,I \

0.070.07 •- • MIV-ISB•• - , \ MW-3S

m • m • m2. 0.05

•• • •5. 0.05 ~ PW-08PW-080

> .. • • ^ _ EW·02 :1t MW-2D

0.030.03

, _^ NOND-1Year_• ^ - 1 Yea • , MW'12D0.01 • l MW-12DMW-12S

0 01 Date / .Date ,0 MW-12S10/05 10106 04Kl7 04108 041101010404 0410504/05 10105 O4Kl6 10107 04/08 04109 04/10 05/1104/06 10/06 04/07 10/07 10/0810Kl8 04/09 10Kl910/09 1011010/10 05/11 1111/1111 ,

MW-13DMW-130 ,K: MW-13SIWW-13S MW-12BMW-12BPrivate well PW-07 is cased down to aa depth of45ft. This cas­ P-03

MW-5

,Private well PW-07 is cased down to depth of 45ft. This cas­

MW­" « p.02

ing depth is deeper than the screen for nearby piezometer MW­ing depth is deeper than the screenfor nearby piezometer MW­ ; MW-5D , EW03EW-03 MW-ia4S^ -- MW-1D4S15D (set at 32 to 42ft depth) where TCE has been detected, but15D (set at 32 to 42ft depth) where TCE has been detected, but MW1040•- MW-104D

VC hasn't been detected since 2004.VC hasn 't been detected since 2004.

M W _ N O T « 1 WBl_typB| Dal< | DaWI t Date2 | VC fvk^CtertSid^l TCE | Trichtoro^h«ng| G W _ B « |WW N W" DOle' DIIe2 ve 101B 6R A p t ^ 3 04/1BC003 Apr-03 0.1' 0.18U 0.48 o.4au 844.36

MW-101B BR JuMS 07/11/2005 JuK)5 0.01' D~0i8U 0i)3 MW-101B O4I,liI2OO3� AfK./J3 0.18 0.181.1 OAi O.C8U B44.36

D7111l2OO5 ......� 0.b3U 843.94101B BR� 0.018 D.018U 0.D3 0.D3U 843.94TeE Trends fromTCE Trends from 0'_Jan-06 01/093006 Jan-06 0.O46 OMBJ 844.47101B BR 0.038 0.036J 0.018 0.D46J ,,"._7MW-101B BR Jan./J6 0.036 0.036J

M d l B BR 04^12/2007 Apf-07 0.018 0.01 BU a4 0.4 847.58101B BR Apr.07 O4IC2J2OOT AfKq, 0.018 o.oUIU 0.4 0.4 847.51

~-'o,. SR Ju^07 06/25/2007 Jun./JT 0.0550.055 145.33MW- ia iB BR O6I25I2OOT Jun-07 0.0130.013 0.013UO.01SU Oi)55J0.D55J 845.33 ~101B Sep.07 O!li2IQOOT 0.013U 0.3409/24CO07 Sep-07 848.48MW-IOIB BRBR Sepq, 0.0130.013 o.o"U 0.34 a34 146.41Monitoring Well DataMonitoring Well Data Jan-08MVV-101B BR Jan-OS O1/O7/ZO08D1M7Q008 0.013 OJJi; I J 847.87~'o,. SR 0.0'3 O.Dl~l.9W.fi1 ~'o,.MW-IOIB BRSR ApfJ18 04/14/20080411412008 Apr-08'"""" 0.0130.013 0.0131O.Dl~3 t J - - ..0.15 - ^ 0.15JQ.l5J 848.07AfK'" ".07 MW-IOTB BR JuI<l' 0.Q13 0.013Uo.013U 0.08 ret: a.olu 847.3e8473607/14/2008 Ju!-08 Shallow water-table monitoring wells (MW-Shallow water-table monitoring wells (MW­~\1W-'O'B 5R Jukis 07/1412009 0.013 0.08 ao8JrCt level

0.013U 845.1)'ffl-101eMW-101B BR oci-oe io/io«ooa10110i2008� Od-08Od./J8 0.0130.013 0.013U D.ll! Q.16J ~5.1BR t!

~lnlR ni«>5C009n,fQ5I2OO9 jBn-09 0.013 0.013U 1 H6.72RR Jen./J9 0.013 0.013U 1.1 1.8' I46.n 105S, -12S) indicate increasing TCE trends,lOSS, -12S) indicate increasing TCE trends,BEDROCK Monitoring WellMonitoring Well r z z t z z i with the most-recent datafrom MW-105S

BEDROCK with the most-recent data from MW-105S

GW__ l W.. I 0_ VC Von� (MW-l0lB)MWMWNNan »| We»_^typwr Pita I Dalai 0 ^ 2 | ve | V i n y f c N a i t l B l — I C t 4 - I t l ^ r o « * h e n e j GW_Eteyl ----Y-.-2£-_3-2.-....~·---------l

MW-ISD 1(V06/2004 OcWJ4 0.074 ., ., "".. ,� (MW-IOIB)MW-l P _56� (2,400 ug/l) being the highest level observeda 0.1997oa-04 • 143."� R2 (2,400 ug/V being the highest level observedMW-15DMw.,5O PZ .u<l5 07/11/2D0501M112OO5 JuI<>5 0.09 0.09U R^= 0.1997

MW-15D PZ 0Cl.()5JuM)5 JuWS 0.09 30 143."

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MW-150MW-1SO PZ AfKq, 04/02/20070<102I2007 Apr-07AfK./J7 0.018 a.OlaV 30 847.37 MW-15D P2 0&25/2007 Jun./JT 0.065 O.065U ......0.01'� 30 B47.37Apr-07MW-l50 Jun./J7� 844.95Jtjn-07 """"'007 Jur>.07 0.065 20 20 ~ ~ MW-15D PZ 09/24/2007 ....,l7 0.013U B46.D5 •MW-l50 _7 OlII2<12OO7 0.013� •

S B P « 7 0.013 ....05'0 '0/OT/2008IOTI2OO8 Jon<>a 0.0650 23 S46.97 •DEEP 114/2008 Apr-08 0.0650,065 0.065U 847.fl2�

Jan-OS 0.0650.065 23 841.81� T O T - •DEEP 714/2008 ,. ~ 0.' 0.'AfK./J.� B47.B2 0.1' •/14/2008/1412008 Jul-OBJuI·08 0.0650.065 0.0650 2." 2. B47.06841.06 .a .� .• O.OB fJeeper piezometers (MW-105D, -103D, -15Dl--::===----"""=:=:~==~~===~:=::::=::=--~ Peeper piezometers (MW-105D, -103D, -15D

0.08/10/2008 Ocl-08 0.0650.065 0.065Ua065UPiezometerPiezometer 11012008 "".08 844.95......� 0.055'3 '3� 0.046 0.055/05/20Og 1Jan./JO 0,(:165 o.065U

0.01 -l----~==:..:'-y.:,.·..:-..===~I'-- ---_---~---_< "'and -12D) indicate decreasing TCE trends.Monitoring Well 105f2OO9 Jan-09 0.065 a065U ,. ,. S46.43841.43 " * ,Y=a r and -12D) indicate decreasing TCE trends.Monitoring Well « _

.....Oat. 1Q105 lliWI O4«lt ,~'"

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844.81WT 01/09/2006 Jan-06 3.2 18 844.1'MW-12S WT AfK./JT 04I02flW7 AfK./JT� MW~'05SMW-10SS WT -Jan-06 0'_ ....... 3.2 3.2 ,. 1.�MW-12S 1 -- 04/02/2007 Apf-07 '.3 1.3 /Wh•• TC~10 845.18 WT M Mar-OG 3.3 33 33MW·l05SMW-105S WT Mar-06..... 03/09/200603100I2OO8� M.... 3.3 « i 33 33

Jan-07 e MW-12&'MW~12S WT Juri47 0812512007 0... 98Jun./J7 06/250007 Jun./JT 0." ,..., 844.s2

_T ,., MW-l05S WT .Jan./JT� Jan./JT 11 290•• MW-IOSS WT Jan^7 01/15/20070111512007 11 M 200 ...290 145.82845.62 3/24/2007 Sep-07 110 845..11 MW-l05S wrW t Af/f.(J7 04I02J2007 Apf-07 •.8 'tis 570 570 846.24~ ' Ap r ^7

WATER-TABLEWATER-TABLE 1/07/2008~=~ ,.. 1.1~"' 130 -_ ..• .. • -- -B/25C007 Jijn-07 560 8 MW-105S 04/02/2007 ""'./JT I .• ....2.

Jan./J8 1.4 130� --- -8I2512OOT 560Jan-OB _ 845..99� - I IJ 144.55844.55Jun-01 11 11J Sep-07 845.42"WZOO8t/14/2008 Apr-OB 1.2 '20 846.07� WATER-TABLE lII24flOOT Sep./J7 8.8 8.86.6 "'"ClIO "'" 845.42,.2� lIOO Jan-08 846.39Shallow ""'...� WATER-TABLE ^"^•' ",4J2OOISr/14/2008 Ju>08Jid-Oe 0.88 0.88 110 110 845.76� 110712008 Jen<l. '.3 1.'U1.3U 1300 '300 14l!.39

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V1Q/20D8 CCV080<>08 u ,.. 110 110 844.84 P-03 Shallow� "'-412008 ,U HighestJul-OB Hi~.st 845.981500 1SO0J 145.98Monitoring Well :::::� r/14/2008TI1412OO11 ....... '.8 .g.B.. 1500 l500J TCE levelMonitoring Well 1/05/2009 J8rv09J.....,. '.2 1.2 '20 '20 84S.s7 PIN-S Shallow ' ' ''"3/10/2008 Ocl-08

11 TCE/~ 845.15845.15detBdedJart-09 dfi1hlct~ 84S.79O.DOO1.DtlCIl3A(MW-12S)� Monitoring Well "".08Monitoring Well ~= y a� 1/05/2009 J..... 6.56.5J 845.79(MW-12S)

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0*2 I .'!f I~GW~,l '0108I2OO4 PZ Jan-06 01tmQQ06 ,. '5 25� MW-105D """" """" ,., 1.1MW-l20MW-12D PZ ....... 01/09/2006 JarvOG 15 15 2525 25 844.66844.66 PZ 07l1112OD5 JuI<>5�MW·l050 PZ JuI<>5 130 JlYfJI 30 84339

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2.' 2.' 846.09 MW-103DMW-103D PZPZ 0d./J5 ,llI03I2OO5 0d./J5 MW-l050 P2 JeMlll 0'_ 21 2100 2'00 P2 AfK./JT 0.5 MW-103D PZ� MW-105D P2 ll3IOW2OOtI M 0." 0."" 180

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P2 Jun./JT 1.6 844.83644.S3 PZPZ 1.IU MW-l050� P2 Jan./JT 01l15rlOO7 Jan./JT .2 '2 846.02 MW-l030MW-103D PZPZ ......7 Dll15Q007 au 1100 1100 846.51•0/24/2fJC17 Sepq, OA&J 845.82� MW-105D P2 ...q, 33 114702W24/2O07 0.48 1_31.3J 845.82 Mw-,05D PZ AfKq, O4IC2J2OOT 0.e5 0.85 33DEEP� MW~103D PZ ,lIlOMW-1D3D PZ 04IC2J2007 ""'''T ,.. '.IU ,lIlO llTA647.4

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Piezometer 4/'4120084/14,'2008 Apr-08 0.380.38 0.38 1.3 1.31.3 847.14 DEEP SlP./JT 0.11 846.35 Jn412OO7 _7 0.63 0.63 27 27 845.81....... 0.38 t 1-3 847.14 DEEP lII24/2fJC17 0.11 150 150 848.35 DEEP�Piezometer 7/1412008 0.49 0.49� 846.761 '.3 1.3 846.T6 JIn.O<l 1.3 910 IJ07QOOI

Oct-DB 1.5 O.H D.B6J 4/WZOO8 840 7/14/2D08 Ju>08Jul-08 0.49 0.49 1.3 1.3� 1/0712008 1.3U 940 847.48847.46 DEEP

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