US EPA RECORDS CENTER REGION 5
1111111111111111111111111111111111111111 408387
Five-Year Review Report
Fourth Five-Year Review
-.../'... Hagen Farm Superfund Site Town of Dunkirk, Wisconsin
July2011
Prepared By:
u.s. Environmental Protection Agency, Region 5 In conjunction with Wisconsin Depaliment ofNatural Resources
7-:~ 7-/1
Richard C. Karl, Approved Date Director, Superfund Division U.S. EPA, Region 5 [This page intentionally left blank.]
2 Five-Year Review Report Table of Contents
List of Acronyms ...... 5
Executive Summary ...... 7
Five-Year Review Summary Form ...... 9
I. Introduction ...... 11
II. Site Chronology ...... 12
III. Background...... : ...... 14 Physical Characteristics ...... 14 Land and Resource Use ...... 14 History of Contamination ...... 15 Initial Response ...... 16 Basis for Taking Action ...... 16
IV. Remedial Actions ...... 18 Remedy Selection ...... 18 Remedy Implementation ...... 20 Institutional Controls ...... 25 System Operations/Operation and Maintenance ...... 30
V. Progress Since the Last Five-Year Review ...... 34
VI. Five-Year Review Process ...... 36 Administrative Components ...... 36 Community Involvement...... 37 Document Review ...... 37 Data Review ...... 37 Site Inspection ...... 43
VII. Technical Assessment ...... 43 Question A: Is the remedy functioning as intended by the decision documents? ...... 43 Question B: Are the exposure assumptions, toxicity data, cleanup levels, and RAOs used at the time of the remedy selection valid? ...... 45 Question C: Has any other information come to light that could question the protectiveness of the remedy? ...... 45 Technical Assessment Summary ...... 45
VIII. Issues...... 46
IX. Recommendations and Follow-up Actions ...... 46
X. Protectiveness Statement(s) ...... 47
XI. Next Review ...... 48
3 Tables
Table I - Chronology of Site Events ...... 12 Table 2 - Hagen Farm Groundwater Cleanup Standards and Maximum Concentrations ...... 22 Detected Since 2006 Table 3 - Assessment of Access and Institutional Controls ...... 26 Table 4 - Current Monitoring Schedule ...... Attachment 8 Table 5 - Proposed Future Monitoring Schedule .... :...... Attachment 8 Table 6 - Oxidation Reduction Classification and Processes ...... Attachment 8 Table 7 - Dissolved Oxygen Monitoring Data ...... Attachment 8 Table 8 - Issues ...... 46 Table 9 - Recommendations and Follow-up Actions ...... 46
Figures
Figure 1 - Site Location Overview Map Figure 2 - Stoughton Jurisdictional Boundary Map Figure 3 - Site Features Map Figure 4 - Site Map Showing Institutional Controls and Monitored Private Well Locations Figure 5 - Soil Vapor Extraction Wells and Gas Probe Locations Figure 6 - Site Map Showing Groundwater Monitoring Well Locations Figure 7 - Site Map Showing Low Flow Air Sparge Point Locations
Attachments
Attachment 1 - U.S. EPA Notification of Five-Year Review Start Attachment 2 - PRP Certification of Current IC Status Attachment 3 - Groundwater Data Trend Plots for Key Wells Attachment 4 - Newspaper Notice Announcing Start of Five-Year Review Attachment 5 - Documents Used to Prepare Five-Year Review Attachment 6 - Five-Year Review Site Inspection Checklist for Hagen Farm Attachment 7 - Photography Log from April 27, 2011 Five-Year Review Inspection Attachment 8 - Additional Tables
Appendix
Appendix 1 - Institutional Controls Investigation of May 2006 Performed by Waste Management
4 List of Acronyms
ACL Alternate Concentration Limit AOC Administrative Order on Consent ARAR Applicable or Relevant and Appropriate Requirement CD Consent Decree CERCLA Comprehensive Environmental Response, Compensation, and Liability Act DCE 1,2-Dichloroethy lene ES Enforcement Standard (state of Wisconsin) ESD Explanation of Significant Differences EW Extraction Well GCOU Groundwater Control Operable Unit IC Institutional Controls ISVE In-Situ Vapor Extraction LFAS Low Flow Air Sparge LOD Level of Detection LOQ Level of Quantification MCL Maximum Contaminant Level MCLG Maximum Contaminant Level Goal MW Monitoring Well NCP National Contingency Plan NPL National Priorities List O&M Operation and Maintenance OU Operable Unit PAL Preventive Action Limits (State of Wisconsin) PPB Patis-per-billion or micrograms per liter (ug/L) PC OR Preliminary Close Out RepOli PRP or Potentially Responsible Patiy RP RA Remedial Action
5 RD Remedial Design RIfFS Remedial InvestigationiF easibility Study ROD Record of Decision SCOU Source Control Operable Unit TCE Trichloroethylene THF T etrahydro furan UAO Unilateral Administrative Order U.S. EPA United States Environmental Protection Agency VC Vinyl Chloride VOC Volatile Organic Compound WAC Wisconsin Administrative Code WDNR Wisconsin Department of Natural Resources WMWI Waste Management Wisconsin, Inc.
6 Executive Summary
The United States Environmental Protection Agency (U.S. EPA) is conducting this fourth Five Year Review of the remedy at the Hagen Farm Superfund Site in Dunkirk, Wisconsin with the assistance of the Wisconsin Department ofNatural Resources under a cooperative agreement grant with Region 5. The triggering action for this statutory review is the completion of the last review on September 21, 2006. The Five-Year Review is mandated by Section 121 ( c) of CERCLA, and amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA).
The 28-acre Hagen Farm Site property is located one mile east of the city of Stoughton, Wisconsin (Figure 1). Within the property boundary is a 10-acre disposal area. The Site was operated as a sand and gravel pit prior to the late 1950s. The gravel pit was then used for waste disposal from the late 1950s to the mid-1960s. Waste solvents, various organic materials and municipal wastes were disposed of at the Site.
The major contaminants of concern were tetrahydrofuran and vinyl chloride. Two operable units were defined for the Site. The Source Control Operable Unit (OUl) addresses waste refuse and sub waste soils and involved capping the Site and installing an active soil venting system. The Groundwater Control Operable Unit (OU2) addresses the contaminated on- and off-property groundwater and included a groundwater extraction and treatment (pump-and-treat) system that was anticipated to operate for about 30 years before achieving groundwater cleanup goals.
In August 2000, a low flow air sparge system (LF AS) was proposed to replace the pump-and treat system in order to achieve cleanup goals more efficiently. Under a pilot study, U.S. EPA approved the use of the LF AS, allowing the temporary shutdown of the pump-and-treat system. Permanent replacement ofthe pump-and-treat system by the LF AS is contingent upon demonstrating that groundwater contaminant levels meet the defined cleanup goals at the waste boundary. The LFAS system was upgraded in 2005 and 2007 and shows improved capability. This review indicates that the system reduces some of the contaminant levels but will require enhancements to demonstrate it can achieve cleanup goals throughout the aquifer before a decision document can be prepared to memorialize the replacement of the pump-and-treat system.
Operable Unit 1 protects human health and the environment in both the short and long term. The source of contamination is not accessible to humans as it was consolidated and capped. Access and ICs, including fencing and deed restrictions, respectively, have been implemented to prevent current and future exposures to onsite groundwater and prevent residential/commercial activities for the onsite property.
Operable Unit 2 protects human health and the environment in the short term. Access and ICs, including fencing, deed restrictions, and governmental controls have been implemented to prevent current and future exposures to onsite and om~ite groundwater. Residences downgradient of the Site that rely on private groundwater wells are sampled annually to ensure their groundwater is safe. Currently, there are no exceedances of vinyl chloride above MCLs in the offsite monitoring and private wells. Long term protectiveness ofOU2 remedy will be
7 achieved by enhancing the current LF AS system and ensuring its continued effective operation and maintenance; maintaining and enforcing the effectiveness of existing ICs; and implementing additional enforceable ICs further downgradient of the Site where ROD-specified groundwater cleanup goals are being exceeded until groundwater cleanup goals have been achieved throughout the plume.
On a site-wide basis, the remedy is protective of human health and the environment in the short term. The remedy will be protective in the long term when ROD-specified groundwater cleanup goals are achieved throughout the plume. Until such time, it will be necessary to continue groundwater remediation, and to institute, maintain and enforce effective ICs at the Site.
8 SITE IDENTIFICATION
Site name (from CERCLIS): Hagen Farm Superfund Site
EPA ID (from CERCLIS): WID98061 0059
NPL status: [8] Final 0 Deleted 0 Other (specify)
Remediation status (choose all that apply): 0 Under Construction [8] Operating 0 Complete
Multiple OUs?* [8] YES 0 NO Construction completion date: 8/27/1996
Has site been put into reuse? 0 YES [8] NO REVIEW STATlJS
-- --- - Lead agency: [8] EPA 0 State 0 Tribe o Other Federal Agency
Author names: Sheila A. Sullivan
Author title: Remedial Project Author affiliation: U.S. EPA Manager
Reviewperiod:** ~/21 12006 to ~/.l2/2011
Date(s) of site inspection: ~ 127 12011
Type of review: [8] Post-SARA o Pre-SARA o NPL-Removal only o Non-NPL Remedial Action Site o NPL State/Tribe-lead o Regional Discretion)
Review number: 0 1 (first) o 2 (second) 0 3 (third) [8] (fourth)
Triggering action: o Actual RA On-site Construction at OU #- o Actual RA Start at OU# NA o Construction Completion [8] Previous Five-Year Review Report o Other (specify)
Triggering action date (from CERCLIS): ~ 121 12006
Due date (five years after triggering action date): ~ 121 12011
9 Five-Year Review Summary Form, cont'd. Issues:
The SOW appended to the 2007 CD states that the LF AS system must restore the groundwater within a reasonable time period. Groundwater data evaluated to date show a reduction in contaminant concentrations in some wells since the previous Five-Year Review, but not a significant overall declining trend throughout the aquifer, especially for vinyl chloride (VC). This is necessary if the remedy is to achieve cleanup goals within a reasonable time period.
Recommendations and Follow-up Actions:
The low-flow air sparge (LFAS) system, currently in use for groundwater remediation, should be enhanced to achieve greater effectiveness in contaminant reduction. The PRP should evaluate alternatives, propose specific enhancements to the system, and implement them according to a schedule. The groundwater pump-and-treat system should remain onsite and operational until the LF AS is optimized.
When the LF AS has been enhanced and demonstrates improved remedial effectiveness, a decision document should be prepared to memorialize the Groundwater Control Operable Unit remedy change.
Protectiveness Statements:
Operable Unit 1 protects human health and the environment in both the short and long term. The source of contamination is not accessible to humans as it was consolidated and capped. Access and lCs, including fencing and deed restrictions, respectively, have been implemented to prevent current and future exposures to onsite groundwater and prevent residential/commercial activities for the onsite property.
Operable Unit 2 protects human health and the environment in the short ternl. Access and ICs. including fencing, deed restrictions, and governmental controls have been implemented to prevent current and future exposures to onsite and offsite groundwater. Residences downgradient of the Site that rely on private groundwater wells are sampled annually to ensure their groundwater is safe. Currently, there are no exceedances ofVC above MCLs in the offsite monitoring and private wells. Long term protectiveness of OU2 remedy will be achieved by enhancing the current LF AS system and ensuring its continued effective operation and maintenance: maintaining and enforcing the effectiveness of existing lCs; and implementing additional enforceable ICs further downgradient of the Site where ROD-specified groundwater cleanup goals are being exceeded until groundwater cleanup goals have been achieved throughout the plume.
On a Site-wide basis, the remedy is protective of human health and the environment in the short term. The remedy will be protective in the long term when ROD-specified groundwater cleanup goals are achieved throughout the plume. Until such time, it will be necessary to continue groundwater remediation, and to institute, maintain and enforce effective ICs at the Site.
Environmental Indicators:
Date of last Regional review of Human Exposure Indicator (from CERCLIS): 9/22/2010 Human Exposure Survey Status (from CERCLIS): Current Human Exposure Controlled; Protective Remedy in Place Date of last Regional review of Groundwater Migration Indicator (from CERCLIS): 9/22/2010 Groundwater Migration Survey Status (from CERCLIS): Contaminated Groundwater Migl'ation Under Control Ready for Reuse Determination Status (from CERCLIS): Site Wide Ready for Anticipated Use (10/1/2010)
10 I. Introduction
The purpose of the Five-Year Review is to determine whether the remedy at a site is protective of human health and the environment. The methods, findings, and conclusions of reviews are documented in Five-Year Review reports. In addition, Five-Year Review reports identify issues found during the review, if any, and identify recommendations to address them.
The Agency is preparing this Five-Year Review report pursuant to CERCLA § 121 and the National Contingency Plan (NCP). CERCLA §121 states:
Ifthe President selects a remedial action that results in any hazardous substances, pollutants, or contaminants remaining at the site, the President shall review such remedial action no less often than each jive years after the initiation ofsuch remedial action to assure that human health and the environment are being protected by the remedial action being implemented. In addition, ifupon such review it is the judgment ofthe President that action is appropriate at such site in accordance with section [104] or [106], the President shall take or require such action. The President shall report to the Congress a list offacilities for which such review is required, the results ofall such reviews, and any actions taken as a result ofsuch reviews.
The Agency interpreted this requirement further in the NCP; 40 CFR §300.430(f)(4)(ii) states:
{fa remedial action is selected that results in hazardous substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure, the lead agency shall review such action no less often than every jive years after the initiation ofthe selected remedial action.
The United States Environmental Protection Agency (U.S. EPA), Region 5 in conjunction with the Wisconsin Department ofNatural Resources (WDNR) conducted the Five-Year Review of the remedy implemented at the Hagen Farm Superfund Site (the "Site") in the town of Dunkirk, Wisconsin. This report documents the results of the review, which was conducted between October 7, 2010 and June 2011 (Attachment 1). As part of this review, U.S. EPA reviewed all data collected under the regular monitoring conducted as part of the operation and maintenance (O&M) for the Site to evaluate the current Site status.
This is the fourth such site-wide Five-Year Review for the Hagen Farm Superfund Site. The triggering action for this statutory review is the previous (or third) Five-Year Review completed on September 21, 2006. In accordance with Section 121 of CERCLA, the triggering action for the first statutory Five-Year Review was the construction start date for the Source Control Operable Unit (OUl), which was August 14,1991 as documented by U.S. EPA's CERCLIS database. This statutory Five-Year Review was conducted due to the fact that hazardous substances, pollutants, and contaminants remaining at the Site above levels that allow for unlimited use and unrestricted exposure.
11 II. Site Chronology
TABLE 1 - Chronology of Significant Site Events at the Hagen Farm Site
EVENT DATE
Site Operated as Sand and Gravel Pit Prior to Late 1950's
Waste Disposal occurs in the Gravel Pit Late 1950s to mid-1960s
Property purchased by Orrin Hagen November 1977
WDNR sampled private groundwater wells in response to complaints November 1980 - 1986
WDNR brings enforcement against WMWI and Uniroyal for public nuisance. A 1983 civil suit is also filed by residents, and settled in 1986.
Site Proposed on NPL September 18, 1985
Site Listed on NPL and WDNR dismisses its enforcement action against Uniroyal July 22, 1987 and WMWI
AOC Signed by PRP to conduct the RIJFS July 27, 1987
RVFS Conducted for the entire Site July 1988 - April 1992
ROD Signed for OU 1- Source Control Operable Unit (SCOU) September 17, 1990
Institutional Controls and access restrictions(Deed Restrictions, Site Fence) 1991 - 1993 Implemented
UAO to PRP for SCOU RD/RA work March 1991
ESD Signed for SCOU to refine ISVE cleanup standard April 1991
Remedial Design for SCOU Cap Completed August 1991
RUFS for GCOU Completed April 1992
Construction Completion of SCOU Cap May 1992
Final Inspection of SCOU Cap July 28, 1992
ROD Signed for OU2-Ground'A-ater Control Operable Unit (GCOU) September 30, 1992
UAO to PRP for GCOU RD/RA Work November 25, 1992
12 EVENT DATE
RD for SCOU In-Situ Vapor Extraction (lSVE) System Completed September 1993
Construction ofthe SCOU ISVE Completed January 1994
Final Inspection of SCOU ISVE January 12, 1994
RD for GCOU Completed May 19, 1995
Construction of the GCOU Completed April 1996
Final Inspection of GCOU and Entire Site April 17, 1996
First Five-Year Review Completed August 14, 1996
ESD for GCOU Signed August 27, 1996
Preliminary Closeout Report Signed (site-wide construction completed) August 27, 1996
U.S. EPA Approval of Low-Flow Air Sparging System Implementation Plan January 22, 2001
Second Five-Year Review Signed September 21,2001
Temporary shut-down of pump & treat system September 4, 2001
Start of Shallow Air Sparging System Operation January, 200 I
Start of Expanded, Deeper Air Sparging System Operation April,2005
Third Five-Year Review Site inspection May 11,2006
Third Five Year Review Report Completed September 21, 2006
Implementation of Enhanced Air Sparge System April 2007
Five-Year Review Site Inspection April 27, 2011
FOU11h Five-Year Review Report Due September 21,20 II
13 III. Background
Physical Characteristics
The Hagen Farm Site is located at 2318 County Highway A in the town of Dunkirk, approximately one mile east of the city of Stoughton, Dane County, Wisconsin (Figure 1). The Site occupies the southwest quarter of Section 10, Township 5 North, Range 11 East, as shown in Figure 2. The Site is defined as the area within the Hagen Farm property boundary and the area comprising the contaminant plume. The property is approximately 28 acres in size. Within the property boundary is a disposal area of approximately 10 acres. The Site is bounded on the south by Highway A and on the north by the northern face of the gravel pit and a private landing strip. The Yahara River is located about I.S miles to the west of the Site and flows in a southerly direction (Figure 3). The topography is flat to gently rolling, with the land surface generally sloping toward the river from the higher areas northeast and east of the Site. Surface water drainage in the area is poorly developed due to permeable surficial soils. The only substantial surface water bodies are Sundby Pond located about one-half mile south of the Site and the Yahara River. The current Site topography is the result of sand and gravel mining and waste disposal activities, e.g., the excavated area in the northwest corner of the property is now flat.
The Site subsoils are dominated by interstratified sands, sand and gravel, and silty sands. Sandstone bedrock is at depths of 46 to 73 feet below ground surface (bgs). Groundwater occurs at depths ranging from 3 to 46 feet bgs in the vicinity of the Site, and about 20 feet bgs in the disposal area. Groundwater flow beneath the main disposal area is to the southeast. Groundwater flow south of County Highway A appears to be generally south to southwesterly.
Land Resource and Use
The waste disposal area was originally used as a sand and gravel excavation pit. Thus, the natural habitat existing prior to extraction operations at the Site was destroyed. Presently, the waste disposal area is capped and supports vegetation such as grasses, herbaceous plants and trees. The area is frequented by wildlife, notably birds, small mammals and deer. The Site is not known to be inhabited by rare or endangered species. Land in the vicinity has been developed for agriculture, mining, and commercial purposes. Sensitive ecological habitats are not in close proximity to the Site.
The town of Dunkirk is an unincorporated township located about 10 miles southeast of Madison, Wisconsin in Dane County. Dunkirk is primarily a rural farming community of about 2,053 people as of the 2000 census. Most of the land in Dunkirk is agricultural. Dunkirk, together with the nearby towns of Rutland, Dunn, and Pleasant Springs, has adopted the county's exclusive agricultural zoning ordinance which limits non-farm development in rural areas. As of the mid-1990's, over 40 percent of each town's farmland was enrolled in the state Farmland Preservation Program, providing income tax credits to property owners who keep their land in agricultural use (Figure n.
The city of Stoughton is situated about one mile east of Dunkirk; however according to its comprehensive plan, the city has adopted a I.S-mile extraterritorial jurisdictional boundary (ETl)
14 which extends into the town of Dunkirk and includes the Hagen Farm Site. Within the ETJ, Wisconsin statutes allow the city to plan and enact extraterritorial zoning, though much ofthe land within the city's ETJ remains outside the corporate limits (not annexed). The city of Stoughton has a population of about 12,600 people. Current land use surrounding the Site includes a private 3,000-foot landing strip which ends directly at the northwest corner ofthe Site. To the east, the land is zoned for rural homes prescribing a residential density of one to 35 acres per residence. Directly west of the Site property, the land is zoned agricultural. Highway A borders the southern edge of the property. The land south of Highway A, directly across from the property is used commercially. The planned future use for the Site and immediate surrounding area is industrial. Plmmed neighborhood areas are to the northeast of the Site.
Potable water in this area is supplied from the Mt. Simon sandstone aquifer. The city of Stoughton urban service area, which includes the provision of public water supply and sanitary sewer systems, includes parts of the town of Dunkirk. Residents living in the vicinity of the Hagen Farm Site obtain their water from private wells. The Potentially Responsible Party (PRP), Waste Management Wisconsin, Inc. ("WMWI" or "Waste Management") annually samples the 11 private wells around and downgradient of the Site (Figure 4). The Uniroyal Plastics Inc. (Uniroyal) plant in Stoughton is the primary employer of Dunkirk residents and other residents of southern Dane County. Several other hazardous waste sites are located in southern Dane Co. such as the City Disposal Corp. and the Stoughton City Landfill Superfund sites.
History of Contamination
The Site was operated as a sand and gravel pit prior to the late 1950s. Observations suggest gravel operations encompassed an area bounded by the current access road to the east, the former Schroeter property boundary to the west, and the current property boundary to the north. Mining operations reportedly were terminated approximately 14 to 18 feet bgs due to the presence of groundwater or a change in sand and gravel quality.
From the late 1950s to the mid-1960s, the onsite gravel pit was used for the disposal ofwaste materials. During the period, the property was owned by Nora Sundby, since deceased. The property was subsequently purchased by Orrin Hagen in November 1977. The Site was operated by City Disposal Corporation, also the transporter of much of the waste that was deposited at the Site. City Disposal Corporation was subsequently purchased by WMWI, the current owner of the Site. Uniroyal was also named a PRP since it generated a portion of the industrial waste deposited at the Site between 1962 and August 1966.
Waste solvents and other various organic materials, in addition to the municipal wastes, were disposed of at the Site, including acetone, butyl acetate, 1-2-dichloroethylene (1 ,2-DCE), tetrahydrofuran (THF), solid vinyl, sludge material containing methyl ethyl ketone and xylenes, and toluene. In a 103(c) Notification submitted to U.S. EPA by Uniroyal in June 1981, Uniroyal indicated that F003 and F005 wastes (spent non-halogenated solvents), which are hazardous wastes according to the Resource Conservation and Recovery Act (ReRA), 42 U.S.C.§6901, were also disposed of at the Site. The Site stopped accepting waste in 1966, prior to regulation of hazardous waste disposal by RCRA Subtitle C.
15 Initial Response
In November 1980, the WDNR began sampling groundwater at nearby private water supply wells in response to complaints from local residents. Sampling of the onsite monitoring wells during the period 1980-1986 indicated certain organic compounds were present in the groundwater, including benzene, ethyl benzene, THF, xylenes, and toluene. The private wells located on adjacent properties had been affected by acetone, THF, vinyl chloride (VC), xylenes, trans-l,2-DCE, and trichloroethylene (TCE).
In 1983, the State of Wisconsin brought an enforcement action for abatement of a public nuisance against WMWI and Uniroyal. At the same time, residents nearby the Site brought a civil action against WMWI and Uniroyal, seeking civil damages for reduced property values and potential health hazards resulting from groundwater and well contamination. The State of Wisconsin obtained a dismissal of its 1983 enforcement action against WMWI and Uniroyal after the Site was listed on the National Priorities List (NPL). In 1986, the parties to the civil litigation reached a settlement. One of the terms of the settlement required WMWI to purchase the Site property from Orrin Hagen, as well as other property located adjacent to the Site. Upon acquiring these properties, WMWI razed the onsite structures. Waste Management is the current owner of the Hagen Farm Site.
The Site was proposed for inclusion on the NPL on September 18, 1985 and listed on the NPL on July 22, 1987. The two named PRPs for the Site, Uniroyal and WMWI, conducted a Remedial Investigation and Feasibility Study (RIIFS) at the Site from 1988 to 1992 under a July 27,1987 Administrative Order on Consent (AOC) between U.S. EPA and the PRPs.
Basis for Taking Action
During the RI, two operable units (OUs) were defined for the Site. Operable Unit 1, which is the Source Control Operable Unit (SCOU), was intended to address waste refuse and sub waste soils. Operable Unit 2, which is the Groundwater Control Operable Unit (GCOU), was intended to address the contaminated on- and otT-property groundwater at the Site. For purposes of this report, "on-property groundwater" is defined as contaminated groundwater on and in the immediate vicinity of the main waste disposal area. "OfT-property groundwater" is defined as contaminated groundwater at any location within the plume downgradient of the property boundary.
Operable Unit 1 - SCOU
The RIIFS for the SCOU was finalized in July 1990. The RI concluded:
1. Three disposal areas were present. Most of the waste was in one main disposal area designated as "waste disposal area A" or "area A";
2. Hazardous substances were not detected in the two smaller disposal areas (areas Band C), each of which is estimated to comprise a 1.75-acre area;
16 3. Area A is approximately six acres in size, an average of eight feet thick, and contains an estimated 67,650 cubic yards of waste;
4. Area A includes municipal waste, paint sludge, grease, rubber, and several industrial chemicals. The major contaminants found in the waste and groundwater were THF, xylenes, toluene, benzene, ethyl benzene, acetone, 2-butanone, semi-volatile organics, barium, lead, and mercury;
5. The waste is in contact with groundwater, thereby acting as a continuous source of groundwater contamination; and
6. Contaminants in the waste and groundwater around the waste pose an unacceptable current and future risk to human health, primarily from direct contact, inhalation, and ingestion of onsite groundwater,
7. No unacceptable ecological risks were found.
Operable Unit 2 - GCOU
The April 1992 RIIFS for the GCOU documented the nature and extent of groundwater contamination and evaluated possible exposure pathways. The report included the following conclusions and observations:
1. The contaminants causing the most concern in groundwater are VOCs. The most prevalent VOC in groundwater was THF with a maximum detected concentration of 630,000 micrograms per liter (ug/L) or parts-per-billion (ppb). The current state cleanup standard is 10 ug/L;
2. The occurrence, concentration, and distribution of THF suggested that there is a THF plume originating from the disposal area and extending about 3,600 feet downgradient (south) of the Site;
3. VOCs were not detected in samples collected from private wells during the investigation; The results of a treatability study indicated that THF and other VOCs in groundwater can be effectively treated using activated biological sludge; and
4. Groundwater posed a current and future unacceptable risk to human health, primarily from the potential ingestion of contaminated groundwater near the Site.
17 IV. Remedial Actions
Remedy Selection
Operable Unit 1 - SCOU
The technology screening and alternative development were conducted in the 1989 Alternatives Array Document. The FS was finalized in July 1990 and a Proposed Plan announcing the selected remedy was issued for public comment. The U.S. EPA, with concurrence from the state of Wisconsin ("the state"), issued a Record of Decision (ROD) for the SCOU on September 17, 1990. The remedial action objectives (RAOs) included:
1. Reduce or minimize direct contact with the contaminated waste and soils; and
2. Reduce or minimize release of contaminants to the groundwater.
The ROD for the SCOU addressed the contamination source including waste refuse and sub waste soils. The remedy selected to address the RAOs included:
• Consolidate three waste disposal areas (areas A, B, and C) into area A;
• Cap the consolidated wastes;
• Install and operate an In-Situ Vapor Extraction (lSVE) system through the cap;
• Evaluate natural microbial degradation ofVOCs in the waste and sub waste soils during operation of the ISVE system; and
• Prevent installation of drinking water wells within the vicinity ofthe disposal areas and protect the cap by using deed and access restrictions.
• During the full-scale ISVE implementation, a treatability study will be performed to examine the feasibility of adding essential nutrients (e.g., moisture, oxygen, nitrogen, and phosphate) to the waste/sub-soils in order to enhance the natural microbial degradation of organic compounds.
The waste consolidation and capping portion of the remedial action (RA) for the SCOU addressed the source of contamination and reduced the potential human health risks by eliminating the direct contact and inhalation exposure routes. The capping and ISVE portion of the selected RA reduced contaminant loading to the groundwater and was the tirst step to eliminating human health risks associated with groundwater ingestion.
U.S. EPA issued an Explanation of Signiticant Difference (ESD) in April 1991 after information became available that allowed U.S. EPA to fUl1her refine the ISVE cleanup standard. The ROD goal for the ISVE was 90 percent removal ofVOCs in the waste and sub waste soils. U.S. EPA,
18 with state concurrence, decided to use a groundwater/soil-gas model (model) for each VOC detected during the RI in the waste and sub-waste soils and/or the groundwater to determine the cleanup standard for the waste and sub waste soils. In addition, the ISVE was to operate for at least two years prior to running the model to insure that the model used ISVE steady state conditions and reflected ISVE parameters over time. Using the model to determine the cleanup standard ensured cleanup levels that were measurable, reliable, and consistent with the NCP.
Operable Ullit 2 - GCOU
U.S. EPA, with State concurrence, issued a ROD for the GCOU on September 30, 1992. The RAOs of the ROD for the GCOU were to address the contaminated on- and off-property groundwater at the Site and included:
1. Restore groundwater so that contamination levels meet appropriate federal and state groundwater quality standards;
2. Stop the flow of contaminated groundwater down gradient of the Site and to the Yahara River; and
3. Prevent the flow of contaminated groundwater to residential wells.
The remedy selected to meet these objectives included:
• Extract and treat on- and off-property groundwater;
• Treat extracted on-property groundwater using activated biological sludge (ABS) and treat extracted off-property groundwater using a technology to be determined by bench scale tests during the remedial design (RO) phase;
• Discharge treated groundwater to neighboring wetlands or the Yahara River;
• Treat and dispose of sludges generated from the groundwater treatment, and treat off gases emitted from the treatment process;
• Use bench-scale studies to determine the etIect of nutrients and/or oxygen on contaminated groundwater with the goal of enhancing bioremediation in the contaminated aquifer;
• Monitor all private wells located around the Site; and
• Use deed and access restrictions to prevent the installation of drinking water wells within the vicinity of the disposal area and off-property.
The treatment technologies tested on a bench-scale level for the otT-property groundwater contamination indicated that biological treatment was the most effective treatment technology for contaminated otT-property groundwater at this Site.
19 At the time of the ROD, the selected remedy of groundwater extraction and treatment ("pump and-treat") was anticipated to require as much as 30 years to restore the aquifer. The ROD also stated that the time required to achieve the RAOs was limited by the extraction technology. Remediation times are described in terms of advection flushing times. The effects of retardation and dispersion are not accounted for in the groundwater remediation time estimates. Advection flushing time is between 10 and 15 years under the selected remedy. The addition of in-situ bioremediation may decrease the remediation time to between five and 10 years, however actual cleanup time will likely be substantially longer due to the effects of retardation and dispersion.
An ESD for the GCOU was signed on August 27, 1996 and documented the following three modifications to the 1992 ROD selected remedy:
1. Discharge treated groundwater back into the ground (reintiltration), onsite, and upgradient of the capped waste disposal area, instead of to the Yahara River or wetlands;
2. Combine extracted on- and off-property groundwater into one influent stream and treat the single influent stream in an on-property treatment facility, as opposed to treating on and off-property groundwater at two separate facilities; and
3. Use tixed film biological treatment (FFBT) instead of ABS to treat all extracted groundwater. 1
Remedy Implementation
Waste Management settled claims against Uniroyal in December 1992 and is currently the only participating PRP. The remedial design and remedial action (RD/RA) for both operable units was conducted by WMWI. The remedial activities were conducted as planned, however significant modifications were later documented in the two ESDs discussed in this report.
U.S. EPA, WDNR, and WMWI conducted a tinal construction inspection of the entire Site on April 17, 1996. The agencies determined that the cap, ISVE and groundwater pump-and-treat system were constructed as designed and were functioning properly. A Preliminary Close Out Report (PCOR) for the entire Site was completed by U.S. EPA on August 27, 1996.
Operable Unit 1 - SCOU
The RD/RA activities for the SCOU were completed by WMWI under the March 1991 Unilateral Administrative Order (UAO).
Under the oversight of the U.S. EPA and WDNR (the "agencies"), WMWI completed the RD for , vvaste consolidation and capping in August 1991 and began onsite construction in September 1991. Areas Band C were exhumed and consolidated into area A, which was then capped.
I FFBT is essentially the same as ASS. but uses specific material, such as plastic balls, to allow the bacteria to stick to and be "fixed" in-place, Tests conducted during the design showed that this method provided for better operation and contaminant removal efficiency than ASS.
20 Areas Band C were backfilled with clean fill material. Approximately 30,000 cubic yards of refuse and non-native materials were removed from the smaller areas and added to area A. After consolidation, area A contained 97,650 cubic yards of waste to be capped; however, the overall footprint of area A did not change. The cap complies with Ch. NR 504.07, WAC and consists of (from bottom to top) 24 inches of clay, 12 inches of drainage gravel, a non-woven geotextile fabric to provide filtration and to keep the gravel clean, 18 inches of rooting zone soil, and six inches of vegetative topsoil.
U.S. EPA, WDNR, and WMWI conducted the final cap inspection on July 28,1992 and the construction was approved. A final construction completion report was submitted to the agencies in June 1992.
Under U.S. EPA and WDNR oversight, WMWI completed the RD for the ISVE system in August 1993 following pilot-scale testing to determine the RD parameters. Onsite construction of the ISVE began in September 1993. A final construction completion report was submitted to U.S. EPA and WDNR in February 1994. The ISVE system consists of eight vapor extraction wells, which are screened from the bottom of the waste, through the sub-waste soils, and down to groundwater. Twenty-nine gas probes, screened at various depths designed to monitor extraction well effects, were installed at various locations and depths throughout and around the landfill (Figure 5). The ISVE discharges VOCs directly to the air in compliance with the substantive requirements of a Wisconsin air-use permit (Ch. NR 445, WAC). Construction and start up of the ISVE system was completed by January 1994 and the system continues to operate.
Waste Management submitted the FS, which evaluated the natural microbial degradation of VOCs in the waste and sub waste soils in September 1994. The FS concluded that an enhanced biological treatment system would not be feasible or cost-effective as ultimately, the existing ISVE system alone is capable of enhancing the needed biological activity without nutrient additions. The U.S. EPA and WDNR agreed with this conclusion and did not pursue an enhanced natural biological treatment system.
As per the April 1991 ESD, the ISVE cleanup standard was further refined from the ROD goal of 90 percent removal ofVOCs in the waste and sub waste soils. A groundwater/soil-gas model was submitted to U.S. EPA and WDNR in August 1996, and demonstrated that the system is operating according to design. From the model, the predicted soil and corresponding soil-gas cleanup levels for THF are 0.1 ug/kg and 0.007ug/l, respectively. The predicted soil and corresponding soil-gas cleanup levels for total xylenes are 2.6 ug/kg and 23.5 lIg/1, respectively.
Operable Ullit 2 - GCOU Pump-and-Treat
The RD/RA activities for the GCOU were completed by the PRP under a November 1992 UAO. Under U.S. EPA oversight, the PRP completed the RD for the groundwater pump-and-treat system in May 1995. Onsite construction began in November 1995.
Construction of the groundwater pump-and-treat system was completed in April 1996. The system was anticipated to operate for as long as 30 years in order to achieve groundwater
21 cleanup goals. A tinal construction completion report was submitted to U.S. EPA and WDNR in January 1999.
Under the Scope of Work for the RA work plan, the groundwater restoration system was to be operated until groundwater cleanup standards were achieved in the aquifer at the point of compliance, i.e., the waste boundary, and downgradient. The cleanup standards for groundwater at this Site are the Preventive Action Limits (PALs), as set forth in Wisconsin Administrative Code (WAC), Chapter NR 140.
Table 2 shows the applicable PALs and Enforcement Standards (ES) for chemicals found at the Site, as well as the maximum concentrations of COCs from the most recent sampling data. The "Cleanup Standards" column provides the site-specific cleanup goals of the GCOU ROD (PALs) as well as conventional groundwater cleanup standards for MCLs and ESs for comparison. Each cleanup standard frozen at the time of the ROD is compared to the current 2010 regulatory levels. Since the previous Five-Year Review, changes in these levels occurred in NR 140 WAC for three contaminants (toluene, xylenes and manganese) as highlighted in red font. For toluene and xylenes, WDNR ESs and PALs became more conservative, while manganese became less conservative. The MCLs have not changed.
TABLE 2- Hagen Farm Groundwater Cleanup Standards and Maximum Concentrations Detected for the Chemicals of Concern
Maximum Concentrations Cleanup Standards (ug/L) Detected in 2009 Chemicals Date (ug/L or ppb) ES PAL MCL Concentration (well) I GCOU GCOU GCOU Location 2010 2010 2010 ROD ROD ROD Organic
Benzene 5/27/09 3.8 (P 17C) lonsite 5 5 0.067 0.5 5 5
l.I- DCE NO 7 7 0.024 0.7 7 7 cis-I,2-DCE 5/12/09 1.5 (P7B) lonsite NL 70 NL 7 NL 70 trans-I.2-DCE NO NL 100 NL 20 NL 100
Ethylbenzene 2/26109 49 (P 17C) lonsite 1.360 700 272 140 700 700
Tetrahydrofuran 8/31/09 2,000 (MW7) lonsite SO 50 10 10 NA NA
Toluene 8/26109 0.56 (OB 11M) loff-site 343 800 68.6 160 1,000 1,000
Trichloroethylene 8/31/09 3.6 (PW03) lotI-site NL 5.0 NL 0.5 NL S.O
Xylenes 6/30109 130 (P 17C) lon-site 620 2.000 124 400 10.000 10,000
Vinyl Chloride 6/30/09 7.9 (PI7C) lon-site 0.2 0.2 0.0015 0.02 2 .2
22 Inorganic 8/26/09 68.7(P22B) lon-site 50 10 5 I 50 10 Arsenic 2/18/09 136 (P26B) lonsite 1,000 2,000 200 400 2,000 2,000 Barium 3 2/27/09 5,370 (P7B) lonsite 300 3003 150 150 300' 300' Iron 2 2 8/26/09 25.5 (OBSIA) loffsite 50 15 5 1.5 15 15 Lead 1 3 3/25109 2,030 (MW22) lonsite 50 3 3003 25 60 50' 50' Manganese 9/8/09 0.2 (P7B) I onsite 2 2 0.2 0.2 2 2 Mercury ES - Enforcement Standard, NR 140, WAC PAL - Preventive Action Limit, NR 140, WAC MCL - Maximum Contaminant Level, Safe Drinking Water Act NL - Not listed in the ROD document NA - Not Available as MCLs have not yet been promulgated for this chemical , Secondary MCL based on aesthetic qualities of drinking water 2 Action Level value 3 Wisconsin Public Welfare Standard
The groundwater extraction system consists of four extraction wells within the contaminant plume: three on-property near the landfill (EWl, EW2, and EW3) and one off-property about 800 hundred feet south of the landtill (EW5). The system as a whole was designed to pump between 80 and 130 gallons per minute (gpm). The treatment plant was constructed on the property along the southern edge of the landfill (Figure 3), and was designed to treat high flow rates (70-100 gpm) of moderately to highly contaminated groundwater, e.g., THF concentrations greater than 2,000 ug/L. The extracted groundwater was treated for VOCs and metals prior to discharge back into the ground, in compliance with the substantive requirements of a Wisconsin Pollutant Discharge Elimination System permit. Volatile organic chemicals were treated using submerged FFBT, which destroyed VOCs, making air treatment technologies to capture off gases unnecessary. The discharge permit levels are the Wisconsin groundwater Enforcement Standards (ES) presented in Table 2.
Treated groundwater was discharged onsite to an infiltration gallery (lG) instead of the Yahara River. Studies and modeling indicated that the IG may help expedite the cleanup by flushing contaminants through the ground into the pumping wells, enhancing bioremediation through the introduction of oxygen-rich eftluent water into the aquifer. Figure 6 depicts IG area 4 in the northeast corner of the fenced area.
GCOU Low-Flow Air Sparge (LFAS) System
In August 2000, WMWI submitted a proposal to pilot test a LF AS system at the Site. The proposed LF AS was to enhance the natural degradation, as opposed to physically stripping the compounds, by raising the dissolved oxygen (DO) level in the groundwater. The DO is consumed by competing chemical reactions occurring in the substrate. Past bench-scale studies have shown that THF undergoes microbial degradation in an aerobic (oxic) environment. The bacteria degrading THF derive their energy and perform most efficiently in oxygen and nitrogen rich environments. Vinyl chloride has been shown to degrade either aerobically or anaerobically. The PRP predicted the LFAS would attain cleanup goals for the remaining groundwater contamination and would replace the pump-and-treat system permanently. U.S. EPA allowed the PRP to install the LF AS system in fall 2000 and to begin operating the system. Six shallow air sparge wells (ASO I-AS06) (Figure 7) were installed to a depth of approximately 50 feet, and are configured in a line about 60 feet apart and just downgradient of the landfill (the anaerobic zone). Once the air sparge monitoring data indicated some increase in DO levels, the PRP proposed to temporarily shut down the groundwater pump-and-treat system in order to pilot test the full-scale operation of the LF AS system. After U.S. EPA approval, the pump-and-treat system was temporarily shut down on September 4,2001 in order to determine the effectiveness of the LF AS system as an exclusive technology for restoring the groundwater to cleanup goals. U.S. EPA's review ofthe groundwater data in 2004 showed that:
• The system has had little overall effect on DO concentrations in the aquifer.
• Vinyl chloride continued to exceed standards across a large area and there was no downward trend in VC concentrations.
• The effectiveness of the air sparge system on all the remaining COCs, primarily THF, was questionable.
• Benzene and THF increases at well P 17C were of concern.
U.S. EPA asked WMWI to develop a plan to address levels ofTHF and benzene at well P17C; to investigate the air sparge system and make corrections to ensure desired DO levels were being met; and, to evaluate alternative treatment options for THF in lieu of air sparging. If the planned enhancements and actions taken by WMWI were not able to meet groundwater standards in a reasonable period of time, the WMWI may be required to restart the pump-and-treat system or perform source removal. Further, if sampling results from the new well OBS2C indicated groundwater cleanup goals were being exceeded, then pumping from EWI must be resumed.
Waste Management implemented the following corrective actions:
• Four additional deeper air sparging wells (AS07 - AS 10) (see Figure 7) were installed perpendicular to the plume and downgradient from the source area generally in the area of the shallow sparging wells. These wells began operating in April 2005.
• Additional groundwater monitoring wells were installed.
• More intensive groundwater monitoring, including monthly monitoring over a limited period of time for certain wells.
24 After reviewing the results of the work, including monitoring results, u.s. EPA found that:
• THF levels declined in well Pl7C but were still well above cleanup standards and those levels found in the well between 1999 and 2002.
• The decision on the requirement to pump from EW1 was postponed until monthly monitoring results through March 2006 could be evaluated for all wells.
• Lab methods for VC should achieve a lower method detection limit that is closer to the groundwater cleanup standard.
An evaluation of the sparging system through March 2006 indicated that several key wells did not shown a discernible downward concentration trends for COCs and there were increasing concentrations in at least one well. Further, no real increase in DO levels was evident throughout the aquifer. Some wells have shown lower concentrations ofTHF and VC since the deeper sparging system was installed; however, there has been no corresponding rise in DO levels that would indicate that biodegradation of contaminants is increasing. Many of the wells closer to the contaminant source area and the wells farther from the source area that were not expected to be affected by the sparging system are not showing trends towards increasing levels of DO. Groundwater data show there has not been a significant trend towards improvement in groundwater quality throughout the aquifer beyond the waste boundary as one would expect if the Site was moving towards achieving the groundwater cleanup standards in a reasonable period of time.
Groundwater remediation in general will continue until analyses consistently indicate that the groundwater cleanup objectives have been met. As mentioned, groundwater cleanup objectives are the attainment of PALs for contaminants and a cumulative excess lifetime cancer risk not ·6 exceeding one-in-one-million (I x I 0 ).
In September 2007, U.S. EPA and WMWI signed a consent decree (CD) requiring WWMI to perform studies and remedial response work at the Site. The CD includes a Scope of Work (SOW) for the RA Work Plan that requires continued implementation of the remedy through strict adherence to the SOW, RD/RA guidance and work plans, RODs, ESDs, all approved O&M plans and U.S. EPA guidance.
Under the SOW, if U.S. EPA determines that the LFAS cannot remove remaining groundwater contamination at an acceptable rate, then WMWI must implement appropriate corrective measures to ensure the remedy continues to be protective of human health and the environment, including reactivating the pump-and-treat system. The CD also provides detailed requirements for the scope, implementation, maintenance, and enforcement and Long Term Stewardship (L TS) of the rcs.
Access and Institutional Controls
Institutional Controls (ICs) are non-engineered instruments, such as administrative and legal controls that help to minimize the potential to exposure to contamination and that protect the
25 integrity of the remedy. The rcs may consist of governmental or proprietary controls such as zoning ordinances, deed restrictions and environmental covenants. rcs are required to assure long-term protectiveness for any areas which do not allow for unlimited use or unrestricted exposure (UU/UE). rcs are also required to maintain the integrity of the remedy.
Decision Document
Both the 1990 SCOU ROD and the 1992 GCOU ROD required that rcs and access restrictions be implemented at the Site. The RAOs specified in the OU2 ROD were to address the contaminated 011- and off-property groundwater.
The ICs were included as part of the remedy in order to:
• Prevent the installation of drinking water wells in the vicinity of the disposal area;
• Protect the cap and the treatment facility;
• Protect the remedy and safeguard human health and the environment during implementation of the remedy.
As part of the SCOU remedy, a Site security fence was installed in 1991 around the entire on property area to protect the cap and treatment facility, and to prevent public access. On-property deed restrictions to prevent the use of groundwater were recorded in 1991 and 1992 (Figure 8). As stated in the selected remedy for OU2, off-property rcs would be used to the extent necessary to implement and protect the remedy and to safeguard human health and the environment during implementation of the remedy.
Physical Area
Reier to Section III (Background) for a detailed description of the current Site land use.
IC Objectives
Table 3 below provides the rc objectives. The rcs apply to all areas that do not supp0l1 UU/UE. Figure 4 depicts these restricted areas.
TABLE 3 - Institutional Controls and Objectives
~.~======~~======~======~======r======~====~~ Map of Media, Enginee ..ed Cont..ols, & A..eas IC Objective in Decision Title of IC Instrument Implemented that Do Not Suppo..t UU/uE Based on Document (note if planned) Cu ....ent Conditions. Area of the Site where soil has been remediated to Prohibit residential or The following on-property deed restrictions commercial/industrial cleanup levels. commercial use of the onsite and conditions and access restrictions were property, including but not recorded: limited to filling, grading, All property owned by WMWI Sect. 1'0. Twp. 5 excavating, building, drilling, N0\1h, Range II East town of Dunkirk, Dane mining, farming, or other Co. (recorded in Cook Co., IL May 15. (991):
26 development, or placing waste All property owned by WMWI Sect. 10, Twp. material, except with approval 5 N011h, Range II East, town of Dunkirk. Dane from U.S. EPA, in consultation Co., WI except lots 1-3 south of County with the state, as consistent Highway A (recorded in Cook Co., IL, August with the ROD and CD 14,1991); requirements. East ~ of the Southwest 1/4 of Sect. 10, Twp. Range II East, town of Dunkirk, Dane Co., WI, except that part south of Co. Highway A (recorded in DuPage Co., IL, December 31, 1992). Groundwater - Prohibit any consumptive or On-property deed and access restrictions to Onsite and Offsite: other use of the groundwater prevent the use of groundwater and the Areas where groundwater plume exceeds groundwater that could cause exposures to installation of public wells were recorded in cleanup goals or PALs humans or animals until PALs 1991 and 1992 (see above). have been achieved, thus guaranteeing the safety of Off-property IC addressing contaminated groundwater migrating offsite. groundwater is WDNR requirement NR SJ:Z.OS(4)(g), which prohibits the installation of a water supply well in a known contaminated aquifer or within 1,200 feet of a landfill without prior approval from WONR.
WMWI sold a portion of the property on the west side of the Site (Lot 3) to a developer, however the sales agreement requires that municipal services be provided to that area if/when development occurs in compliance with current deed restrictions.
WDNR informational IC that requires placement of hazardous waste sites on an Internet accessible database (GIS Registry). The Registry requires WDNR approval for well construction if residual groundwater COC levels exceed NR 140 ES.
ICs beyond (downgradient of) the 1,200-foot restrictive boundary [(NR SI2.0S(4)(g)] will be used to the extent necessary to protect human health and the environment down gradient of the Site until contamination is remediated. (planned) Waste, Soil, and Groundwater On site Remedial Prohibit any residential or On-property deed and access restrictions were Components: commercial use including but recorded in 1991 and 1992 (see above). These - Consolidate and cap waste; not limited to filling, grading, controls have been applied to all lands owned - Install and operate an ISVE system in source area excavating, building, drilling, by WMWI in pr~ximity to the Hagen Farm Site (through the cap); mining, farming, or other use or and shall run with the land as provided by law - Extract, combine, and treat on-and off-propel1y activity that may interfere with and shall be binding on all parties and all groundwater via FFBT; the work to be performed and persons claiming under WMWI. - Discharge treated groundwater to reinfiltration area long term O&M of all remedial onsite and upgradient of cap; components, including the cap. Restrictive Covenants or a mixture of - Use LFAS to enhance bioremediation in the aquifer; ISVE. LFAS and groundwater governmental controls (i.e., Township - Monitor all private wells located around the Site pump-and-treat systems. and ordinance), periodic monitoring. (plalmed) annually. groundwater monitoring. -
27 Status of ICs - Implemented or planned ICs
In May 2006, U.S. EPA requested WMWI to perform an IC study for the 2006 Five-Year Review. Waste Management provided the requested study (Appendix) to U.S. EPA in June 2006 during which a title commitment was performed. In 2010, U.S. EPA requested that an updated IC study be completed in anticipation of a Site-wide Ready for Use (SWRAU) determination. The purpose of a SWRAU is to certify that all cleanup goals in the decision documents have been achieved for any media that may atTect current and reasonably anticipated future land uses so that there are no unacceptable risks; and that all institutional or other controls required as part of the response action have been implemented to ensure long term protection. Waste Management informed U.S. EPA at that time that ICs have not changed since the 2006 IC study.
The 2006 IC study confirmed that deed restrictions were placed on portions of all three of the property parcels owned by WMWI at the Hagen Farm Site. The entire contiguous restricted area is a smaller area than the WMWI property and lies within the property boundary. The restricted area is fenced and the restrictions run with the land. Waste Management sold a portion of the property (Lot 3) on the west side of the Site to a developer; however the sales agreement requires that municipal services (i.e., water supply) be provided to that area if/when development occurs. Additionally, under the WDNR's Bureau for Remediation and Redevelopment Tracking System, an infonnational IC has been implemented for the Hagen Farm Site. This IC requires that if residual COC concentrations in groundwater exceed Wisconsin NR 140 Enforcement Standards, the site is placed on an Internet accessible database-- the Geographical Information System Registry of Closed Remediation Sites (GIS Registry). Both closed and open hazardous waste sites are placed on this system, which provides detailed site-specific information and maps. WDNR approval for well construction is required of the property owner ofthese sites in the GIS Registry.
The September 21, 2006 Five-Year Review determined that the remedy was protective of human health and the environment in the short term, and that long-tenn protectiveness was dependent upon effective ICs at the Site. U.S. EPA determined that no changes were necessary to the existing ICs at the time, and that the ICs were adequately protective and enforceable under the deed restrictions. U.S. EPA's determination in 2006 relied in pati on Wisconsin Chapter NR 812.08( 4 )(g) prohibits the installation of a water supply well in a known contaminated aquifer or within 1,200 feet ofa landfill without prior approval from WONR. Institutional Controls are also enforceable under the September 2007 CD United States v. Waste Management of Wisconsin (07-C-0424-C).
U.S. EPA has received new information since the 2006 Five-Year Review that has led it to believe that the ICs for the Site may need to be enhanced to ensure long-term efTectiveness of the remedy. U.S. EPA is concerned about: (1) the enforceability of celiain terms in the sales contract under which WMWI sold Lot 3 to a developer which, WMWI has assured U.S. EPA, should be efTective in maintaining land and groundwater restrictions; and (2) the presence of TCE and VC in certain wells located outside the 1,200-foot protective zone created by NR 812.08( 4 )(g).
28 The sales agreement at issue required that municipal services be provided to the area if and when it is developed. The enforceability of this clause now, and in the future, should be reviewed. u.S. EPA needs to verify that the restrictions will run with the land and bind any future developers or owners of developed properties.
After 2006, one new commercial well (PW3) was installed to replace a previous well on the former Sundby property, now owned by Wingra Redi-Mix. A TCE level of 2.2 ug/L was most recently detected in PW3, which is above the PAL but below u.S. EPA's MCL and state ES standards. This well is located on or near the 1,200-foot radius of the landfill. As mentioned previously, the offsite private wells, including PW3, are annually monitored for site-related contaminants. u.S. EPA is also concerned about vinyl chloride concentrations found in offsite monitoring well OB08M, located downgradient and beyond the NR 812.08(4)(g) required 1,200-foot radius that restricts potable well installation. Vinyl chloride concentrations at this well exceed the PAL- the cleanup goal identified in the GCOU ROD. Some of the VC levels also exceed the ES, but do not exceed the MCL. Another offsite downgradient weB (P32B) shows VC above the PAL but not above the ES or MCL.
These findings reinforce the need for ICs at certain properties located beyond the 1,200-foot protective zone provided by NR 812.08(4)(g).
Recordation and Title Work
As discussed, WMWI completed an IC study and a title commitment in 2006. u.S. EPA requested that the IC study be updated or recertified in 2009 and 2010 and subsequently received confirmation from WMWI on May 16, 2011 that no new developments regarding ICs or property uses have occurred since 2006. Please see Attachment 2 for documentation.
Current Compliance
No compliance issues have been noted.
Follow-up actions Required
The ICs are in place and effective; however, in order to afford long-term protection of the downgradient groundwater, enforceable ICs are needed. A Wisconsin Environmental Protection Easement and Declaration of Restrictive Covenants is the recommended instrument, as provided for under the 2007 CD. After such a covenant is in place, it should be annually evaluated and certified to determine its adequacy and effectiveness.
Institutional controls should be established for offsite properties that are not already subject to ICs and show evidence of contamination, or are sufficiently close to such contamination to be affected by its migration. Annual monitoring and reporting concerning ICs should be included as a routine O&M activity within a separate IC monitoring section of the Annual Reports. Some
29 of the items to be monitored and reported include change ofproperty ownership, grandfathering of replacement wells, and changes to Wisconsin administrative rules or statutes relevant to ICs.
Long-Term Stewardship
Since compliance with ICs is necessary to assure the protectiveness of the remedy, planning for long-term stewardship (L TS) is required. Long-term stewardship will ensure that effective ICs are maintained. monitored and enforced and that the remedy continues to function as intended with regard to ICs. A revision of the O&M plan will be required to document LTS procedures. The revised plan should require annual certification of ICs to ensure their long term effectiveness.
Legal descriptions and maps are currently available for the restricted areas identified in Table 3 and certified by a licensed surveyor. The maps and GIS Registry information identifies the current boundaries of the restricted areas, boundaries of the Site, property ownership, streets, easements, assessor's parcel number and other recorded plat or survey information. In addition, U.S. EPA, in conjunction with WDNR and WMWI, will explore the use of communications plan and the use ofthe state One Call System.
System Operations/Operation and Maintenance (O&M)
The O&M period for the SCOU began February 22,1994 according to U.S. EPA's database. A Site wide PCOR was completed on August 27, 1996, thereby triggering the start ofO&M for the GCOU (groundwater pump-and-treat system). The PRP's current O&M contractor is BT Squared of Menominee Falls, WI. Previous O&M contractors since 2006 included RMT, Inc. of Madison, WI and Hard Hat Services, Naperville, IL.
Past estimates indicate that the total annual O&M costs average $100,000. The addition of air sparging wells to the LF AS in 2006 did not increase costs because these wells utilize the existing compressors. Since April 2007, when an oxygen generator and air dryer were added to the LF AS system, O&M costs have increased. The cost cited above are an underestimate of actual costs as they do not include oversight costs accrued by the agencies, which are billed to WMWI.
Operable Ullit 1 - SCOU
Since the cap was installed, yearly inspections to date indicate that the cap is sound and functioning as designed. Grass is mowed annually and the fence is being maintained in good condition. In accordance with recommendations from the Wildlife Habitat Council (WHC), Waste Management continues to maintain and monitor nest structures at the Site and schedule mowing to benefit grassland birds.
In 2008-2009, three instances of fence repair occurred:
• Three line posts were replaced along a 100-foot section of the south perimeter fence after a motor vehicle veered off the adjacent roadway and damaged the fencing.
30 • The top rail of the northeast corner fencing was reconnected after the rail had pulled apati at the corner post, creating a 12-inch gap near the top of the fence.
• Approximately 30 linear feet of fence was repaired after it was slightly damaged during cap mowing. One line post was replaced, and the height on two additional line posts was adjusted to reconnect the top rail along a section of the perimeter fence northwest of GP27.
In all of the above cases, the fence integrity was not compromised and there was no evidence of unauthorized entry.
There were no significant issues identified with the condition of the cap during the reporting period. In 2009, a minor settlement area occurred atop a header line between extraction wells EW08 and EWI AR. The settlement depth was less than one foot and was re-filled with soil.
Since startup of the ISVE system in January 1994, the system has operated nearly uninterrupted, except for intermittent short-term shutdowns for maintenance, adjustments such as belt, filter and lubricant replacements, evaluations of microbial VOC degradation, and malfunctions.
• ISVE performance monitoring occurred on an approximately monthly schedule from 2006-2010. Monitoring points for the ISVE system include the gas probes, gas wells, and the blower station.
• Gas probes were monitored quarterly and included measuring gas pressure and gas composition (oxygen, carbon dioxide, and methane).
The gas extraction wells and the blower station were monitored monthly. Gas extraction well parameters included gas flow, temperature, well pressure, header pressure, and gas composition measurements. Gas sampling and analysis for VOCs occurred only at operating gas extraction wells, on a semiannual basis. Blower monitoring occurred monthly and included gas flow, temperature, header pressure, air dilution valve setting, gas composition, and gas sampling and analysis for VOCs.
The VOC concentrations in the gas concentrations at the extraction wells were generally consistent during this period. Total VOCs measured at the blower remain well below air emission limits of216lb/day as per WAC Ch. NR 419. Total VOC concentrations remained consistent with historical values and ranged from 0.0273 to 12.21 parts-per-million (ppm) during this reporting period. The ISVE system flow rates ranged from 256 to 307 cubic feet per minute (cfm) during this reporting period.
In June 2008, south-central Wisconsin, including the Madison area and Hagen Farm Site, experienced record rainfall resulting in a local rise of the water table, such that water was drawn into one or more of the ISVE extraction wells. That water collected in the condensate tank causing the blower and ISVE system to shut down for about four days until the tank was emptied. The annual volumes of collected condensate that was pumped, transpOlied, and disposed of by a local septage hauler included:
31 2006 - 1,080 Gallons 2007 - 8002 Gallons 2008 - 3,200 Gallons 2009 - 2,100 Gallons
Gas well maintenance, such as replacing damaged or broken sample ports and connecting or tightening loose collars, was performed as needed.
During this rep0l1ing period, gas well EWIAR was left open to promote air How into the waste mass. Gas probes GP3 and GP 10 were also left open from January to May to promote air flow into the waste mass. Maintenance on the gas probes during this reporting period included removing approximately three inches ofthe PVC pipe at the deep and medium probes at GP5 to facilitate closing the cover on the probes. Identification tags were installed on fence posts at each of the extraction wells and probes.
Operable Ulli12 - GCOU
The shallow LF AS system, consisting of six wells, has been rmming on a continuous basis since January 2001. In March 2005, four deeper air sparge wells (Figure 7) were installed to remediate COCs located below the influence of the shallow air sparge system "expanded system." The deeper air sparging wells began operating on April 1,2005. New groundwater monitoring wells OBS 1C and OBS2C were installed to monitor groundwater quality at the approximate depth of the deeper air sparging wells and the effectiveness of the expanded treatment system.
The overall performance of the LFAS system is assessed on an ongoing basis and includes monthly groundwater sampling at eight designated monitoring wells for this purpose. The eight sampling locations include six onsite monitoring wells MW22, aBS1A, aBS 1B, P 17C, aBS1C, and OBS2C, and former extraction wells EWI and EW2. These eight wells were sampled in January through March (folJowing continuing monitoring from 2005) and then starting again in November 2006, as well as quarterly monitoring months in May and August. During those months when WMWI's sampling team performs comprehensive quarterly groundwater monitoring, only EW2 is excluded as it is not part of WMWI's sampling protocol (Attachment 8, Table 4).
Waste Management proposed that monthly monitoring at the eight monitoring wells continue through March 2009; and that starting in second Quarter 2009, these wells and other Site monitoring wells would n:vert back to the semiannual/annual monitoring program (Attachment 8, Table 5). The agencies are currently reviewing this request for reduced monitoring from the current monthly schedule.
In late April and early May 2007, an oxygen generator capable of delivering 2.5 cfm oxygen, was installed at the Hagen Farm Landtill to increase the amount of oxygen delivered to the groundwater from the LF AS system. The oxygen generator is expected to etTectively double the concentration of oxygen in air delivered to the sparge points, compared to ambient air, which the
2 The exact figure is not available; however, two additional condensate loads were hauled away in addition to the 800 gallons. system currently delivers. The generator system is to enhance the biodegradation ofVOCs in the groundwater without increasing the operating pressures of the current LF AS. An air dryer was installed as part of system improvements to prevent freezing during winter operation. The in~ line components of the modified system include the compressor, the air dryer, and the oxygen generator (along with the associated tanks).
Compressed air is routed to one of the four deep sparge points and one of the six shallow sparge points through the Programmable Logic Controller (PLC) that controls the cycling interval between the two banks of sparge points (shallow and deep).
During 2008. the following activities were completed:
• Monthly monitoring of the air sparge points to collect pressure and flow data
• The operation of the compressor(s), air dryer and oxygen generator are visually confirmed during weekly Site visits
• Field data for dissolved oxygen (DO) was collected in conjunction with routine sampling of the groundwater monitoring wells.
Compressor maintenance activities performed during the reporting period include:
• Lubricant levels in the compressors were maintained and moisture was drained from system components.
• The back~up power supply (battery) for the autodialer was replaced on May 30, 2008.
• The ventilation fan in the compressor room was repaired on July 1,2008.
• An electrical storm disrupted system operation on July 10,2008. The compressors were re~started on July 11, 2008. In July 24, 2008, the sparge point cycling was restarted and the PLC circuit board was replaced in August 20, 2008.
Operation and maintenance personnel typically visited the Site on a weekly basis to verify the system operation. Routine monitoring of the system is performed monthly. at a minimum, by (CAT) from Marshall, Wisconsin. Compressed Air Technologies maintains the compressors, oxygen generator and air dryer. Some O&M activities performed during this reporting period include:
The compressors are typically shut down for routine maintenance and service during Site visits. The compressors will also shut down in response to signals from various system sensors, including high temperature, low fluid level, electrical faults, etc.
The oxygen generator and/or air dryer were shut down from August 6 to November 4, 2008 to assess the benefits of the decreased air demand (increased available pressure) on system operation compared to the increased oxygen concentrations achieved with the oxygen generator.
33 Short-term shutdowns of the compressor(s) occUlTed during this review period. Most of the issues were not significant and usually involved replacing the control panel circuit boards and/or the temperature in the compressor room. Compressor operation resumed upon reset of the unit during the weekly visits or in response to the autodialer call. In most cases, the load was maintained by a single compressor so that the operation of the expanded LF AS system was not affected.
• CA T replaced the starter relay in Unit 2 on April 2, 2009.
• The flow meter for the shallow sparge points was cleaned and relocated on August 13, 2009. A gate valve was also added to regulate air flow between the shallow and deep sparge points.
• CAT performed routine maintenance on Units 1 and 2, and the air dryer, in November 2009. Each of the air sparge solenoids was disassembled, inspected, cleaned, and reassembled.
• Periodic checks and replacement of the incandescent bulbs inside the insulated protective cover for the aboveground pOliion of the air lines were performed when the temperature was below freezing. v. Progress since the Last Five-Year Review
The previous Five-Year Review found that the remedy was protective of human health and the envirorunent in the short term. The issueslrecommendations identified in the 2006 Five-Year Review and current status are:
1. Continue operating the expanded air sparging system without the groundwater pump and-treat system until April 1,2007 (the agreed probationary operation period) in order to generate the necessary data for evaluating its effectiveness. However, increased pressures and airflows are needed in order for the LF AS to achieve greater effectiveness.
This issue has been satisfactorily addressed. The PRP continued to operate the LF AS and collect data over the past five years. The data shows an increase of air flow with the installation of the oxygen generator in 2007. Some pressure drops have been seen in the deep sparging wells (A7- A 10) and need to be restored to previous levels. However, air flows remain clearly greater than before the LF AS was modified in both 2005 and 2007. Groundwater monitoring data evaluated for this Five-Year Review also include results ii'om 2007 into 2010. The data indicate that the expanded LF AS system has been effective in many of the wells, but some critical wells do not show the desired improvement. Though the system can continue to operate in lieu of the pump and-treat system, its capability should be further enhanced, and its effectiveness must continue to be regularly evaluated so that correcti ve measures can be implemented if indicated.3
3 In 2007, WMWI proposed installing two additional sparging well nests (upgradient of well P7B and downgradient of well MW22B) to increase contaminant removal. In January 2009, WMWI requested to forego installation of the wells in order to focus on maintaining the efficiency and runtime of the system (i.e .. change out of the desiccant for
34 2. Continue monthly monitoring in the eight wells until late in 2007. The resulting data reports should be expanded to include data on air pressure and airflow for each air sparge well. The next LF AS evaluation report submitted should include new redox cross sections as well as a clear description of how each well data is classified as oxic or as sulfate-, iron-, manganese-, or nitrate-reducing.
Monthly monitoring continued after the 2006 Five-Year Review. In May 2007, WMWI submitted an LF AS evaluation report to the agencies showing productive improvements to the LF AS, including oxygen generator, gas drier, additional deep sparging wells, and increase flow rates.
In January 2011, the WDNR GEMS data for ten key COCs were analyzed for trends, comparison to PALs, and comparison to baseline data. The data show that groundwater has not been restored to PALs, but progress has been made at numerous wells. Tetrahydrofuran concentrations have decreased and VC levels have decreased somewhat. One notable exception is VC at the offsite monitoring well OB08M. This well has seen increased VC concentrations over the past 10 years; though at small concentration change rates. From 1999 to 2000, VC concentrations hovered at 0.5 ug/L--below the MCL, but above the ES and PAL. In 20 I 0 VC concentrations were about 1.6 ug/L and approaching the MCL. Graph 1 of Attachment 3 plots the VC concentration versus time at OB08M.
Vinyl chloride concentrations at the on-property monitoring well OBS 1C have slowly decreased to sub-MCL levels (below 1 ug/L) after the LF AS system was upgraded, but still remain above PALs and ESs. Concentrations at onsite well P 17C decreased until 2006, but have subsequently not changed and remain above MCL despite the LFAS improvements (Graph 2, Attachment 3).
In summary, Issue #2 has been partially addressed. The implications of the monitoring data have not received adequate follow-up. Specifically, (l) all data should be presented and all COC data should be plotted versus time, (2) plots showing significant trends, such as VC at OB08M, should be discussed, (3) spatial plots of wells with contoured or posted concentrations for a limited number of analytes (e.g., Mn, THF, and VC) would be helpful. This monitoring data should then be re-reviewed in light of the additional information to determine a remediation time frame under the LF AS system and, depending on the outcome, remedial enhancements that could be implemented to more aggressively contain and/or treat the VC plume.
3. The SOW appended to the 2007 CD states that the LFAS system must restore the groundwater within a reasonable time period. A reasonable time period is based on a number of site-specific factors as well as the remediation technologies employed. The GCOU ROD pump-and-treat remedy anticipated a period of 30 years to restore groundwater at the Site.
the air dryer, preventive maintenance of the air delivery system, and maintaining an on site inventory of backup solenoid valves and gauges). The data collected in the intervening two years have been evaluated in this Five-Year Review to make further conclusions on LFAS efficiency.
35 Issue #3 has not been addressed as there has been no assessment by WMWI regarding the time frame required to restore groundwater quality under the current LF AS system. Such an assessment will provide additional information regarding LF AS efIectiveness.
4. The PRP performs a selective ion monitoring (SIM) scan that can achieve a Level of Detection (LOD) of 0.01 ug/L for VC, for monthly, quarterly and semi-annual samples at "offsite" wells. However, quarterly and semiannual "onsite" samples only receive a SIM scan if they come up no detect under the existing U.S. EPA method. A SIM scan should also be run for all wells, except those with consistently high VC levels.
Issue #4 has been adequately addressed. Spot checks of data submitted to the WDNR GEMS database indicates that SIM has been applied for analysis ofVC. There appears to be no use of SIM for other analytes. Selective Ion Monitoring has allowed the LOD to routinely, but not always, be less than the PAL for VC (0.02 ug/L) and to reliably be less than the ES (0.2 ug/L) and MCL (2 ug/L). When the VC concentration exceeds the calibration range of the SIM equipment, Method 8260B provides quantitative data.
5. Implement and maintain effective ICs to ensure long-term protectiveness.
Item #5 has not been fully addressed. Please see the IC section for more details. Institutional controls must be established for offsite properties that show evidence of contamination or are sufficiently close to such contamination to be affected by its migration but are not already subject to existing ICs. Armual monitoring and reporting concerning ICs should be included as a routine O&M activity.
VI. Five-Year Review Process
Administrative Components
This Site Five-Year Review was conducted by Sheila Sullivan, U.S. EPA Remedial Project Manager (RPM) for the Hagen Farm Site. Also participating were Gary Edelstein, WDNR Site Manager, Mike Peterson, District Manager of Closed Sites Management Group, WMWL and Mike Pratke, Division Manager of O&M ·staff for BT Squared, Inc.
The review components include:
• Community Involvement • Document Review • Data Review Site Inspection • Local Interviews • Five-Year Review Report Development and Review
36 Community Involvement
A notice, announcing that a Five-Year Review is underway at the Hagen Farm Site, was published on May 5, 2011 in the local newspaper, the Stoughton Courier-Hub (Attachment 4). In addition, a new web page for the Site was put up at the same time. The Site repository at the Stoughton Public Library has been upgraded to include compact disks with all site documents in addition to the hard copies.
A notice will be published in the same local newspaper at the conclusion of this Five-Year Review. The notice will announce the completion of the Five-Year Review report and that the results of the review and the report are available to the public at the Stoughton Public Library and the U.S. EPA Region 5 and WDNR offices.
Document Review
This Five-Year Review consisted of a review of relevant documents including O&M records and reports. The 2007 through 2010 Annual O&M Reports were the most recent PRP submittals reviewed. In addition, correspondences between the stakeholders were reviewed. Attachment 5 provides a list of documents reviewed for this report.
Data Review
The hydrogeologic data provided in the PRP's Annual Reports indicates a downward gradient from the water table to deeper pervious strata for a portion of time during the review period. As a result, contaminants can be driven downward into the fractured bedrock where it is more difficult to both monitor and remove them than in the shallow sand and gravel aquifer. Moreover, flow direction in the fractured rock is not well characterized, e.g., the degree to which the fractured rock acts as a porous medium or as a network of preferential pathways. Although these components need to be better characterized, a more expedient way to increase protectiveness is to define and use a large "buffer zone" around the estimated plume to accommodate flow direction uncertainties.
The monitoring data showed VC and THF concentrations in the fractured bedrock that exceed the groundwater PALs. The LF AS has been etTective in reducing the concentration of THF, even in the fractured bedrock; however, there have been mixed results concerning VC reduction.
Tetrahydrofuran
Tetrahydrofuran has historically has been found in concentrations in the thousands of ppb at the waste boundary that decrease with distance from the boundary. In recent years, substantial progress has been made in reducing THF concentrations. There are statistical exceedances ofthe PAL [not individual measurements, but the upper confidence limit (UCL)4 calculated using 2009
-l The UeL is the upper limit of a confidence interval. The confidence interval defines the range where the true value is most likely to be. There is onlv one true value and it is very unlikely to exceed the ueL value. Using the VeL in data evaluation provides a conservative assessment that leads to protective conclusions.
37 and 2010 data] at MW7 and P7B located adjacent to the waste boundary, and at P17C and OBS 1C located south of the LFAS on WMWI property. The on-property wells P 17C and OBS 1C wells show statistically significant downward trends, i.e., THF concentrations are approaching the PAL of 10 ug/L (Graph 3, Attachment 3). There are no statistical exceedances elsewhere and no statistically significant increasing trends in any of the sampled monitoring wells. A review ofthe concentration history plots indicates the system improvements, i.e., increased sparging pressure and air flows in the deep wells, and increased DO concentration have had a substantial positive effect. Tetrahydrofuran is being successfully managed at this Site, but continued O&M of air sparging flows is imperative). Graphs 8-9 of Attachment 3 provide THF trends for source area well MW22 and off-property well OBS2C.
Vinyl Chloride
The LFAS has not been as etTective for VC contamination. Vinyl Chloride concentrations on property adjacent to the \Vaste (MW7, P7B) exceed the PAL (0.02 ug/L), ES (0.2 ug/L) and MCL (2.0 ug/L). Vinyl chloride concentrations at monitoring well OBS 1C, located on the landfill property just south of the air sparging wells, have slowly decreased to sub-MCL levels after the LF AS system was improved. Concentrations at P 17C located on the southern boundary of the property decreased until 2006 and have subsequently not changed, remaining above the MCL despite the LF AS improvements. There is no obvious cause for this, except for the possibility that there is competition between THF and VC, and that VC will degrade faster once THF is further depleted.
Because this well is at the property boundary and groundwater flow at this location is southward (away from the property), VC is migrating offsite at concentrations exceeding the MCL. Well P17C is located at the property boundary, within the 1,200-foot regulated distance of Wisconsin Chapter NR 812.08(4)(g). As VC has not been found in offsite wells at levels exceeding the MCL, the current protectiveness of the remedy is intact. Enhancements to the LFAS will maintain and ensure protection in the long term.
At OB08M, the UCL concentrations of VC remain above the PAL and ES and approach the MeL. There is a significant increasing trend in VC concentrations at OB08M, though the estimated concentration rate change is low (Graph 1, Attachment 3). Moreover OB08M is about 1,900 feet from the waste boundary and therefore not subject to Wisconsin Chapter NR 812.08( 4 )(g) requirements. Even if the LFAS local treatment of the groundwater can reduce the plume concentrations of VC that extend offsite to OB08M, it could take many years to remediate the contamination found in OB08M. Currently, there is no guarantee that the LFAS intercepts and adequately treats the entire plume that exists and migrates otTsite within the fractured bedrock. FUlther, the monitoring network is not sufficient to identify the preferential paths in which the plume migrates.
Because OB08M is located outside the zone of influence of both the LFAS and the original pump-and-treat system, but is reportedly already aerobic [DO concentration exceeds three milligrams-per-liter (mg/L)], the fact that VC concentration is increasing instead of decreasing under aerobic conditions does not support the assumption that monitoring and natural attenuation (MNA) will successfully remediate the &roundwater.
38 Historical concentrations of VC found in P 17C, OBS 1C, and OBS2C (though limited) demonstrate clearly that the plume is relatively narrow and does not fall exactly in a straight line. This suggests that the plume follows a preferential path in weathered and fractured bedrock, but the location of the plume is uncertain. For that reason, other bedrock wells that were installed before the discovery of bedrock contamination in those monitoring wells would not be expected to intersect that preferential path or one connected to it, and would therefore show non-detects. Thus, estimating a path between these separate, non-detect data points does not mean there is not a set preferential path; in fact, the path could even lie between the non-detect data points.
The time required for sparged "treated" groundwater to travel from the sparge line to OB08M can only be roughly estimated, as there are no studies that provide definitive data. Using several data sources, U.S. EPA determined a range of travel times from one to 18 years, with the most likely being about six years. Because the most recent LF AS enhancements were made in 2007, it is unlikely that any remedial results will be seen in OB08M yet, and will likely be diminished due to various biochemical and hydrogeological factors. This estimate also assumes that the LF AS system is capable of preventing any contamination from migrating downgradient, which is currently not the case.
As a result of the plume extent and concentrations, we recommend that additional downgradient offsite ICs be considered south of the property at least as far south as the OB08M monitoring well. Although VC concentrations at OB08M are below the MCL, they far exceed the PAL standards for cleanup. The MCL is exceeded at PI7C and for an unknown distance between P17C and OB08M. Therefore, the plume length should be conservatively estimated when delineating IC areas. The plume estimation will inform stakeholders as to the timeframe during which groundwater cleanup standards should be achieved under the current remediation scenario, as well as the potential enhancements that could be made to the system to accelerate removal of the VC plume.
Benzene
Statistical analysis of benzene indicated PAL exceedances at monitoring wells P7B, P 17B, and P17C (Graphs 4-7, Attachment 3). Well P7B, adjacent and side-gradient to the waste boundary, has a UCL of 1.4 ug/L, above the PAL and ES, but below the MCL, and there is no trend. At P17B, the mid-elevation screen, the UCL is 0.52 ug/L, below the ES and barely above the PAL of 0.5 ug/L, and there is a downward trend that implies the PAL will be met in the near future. At P17C, the UCL is 3.06 ug/L, below the ES and MCL but above the PAL; no benzene concentration trend has been observed in these wells. Benzene is biodegradable in aerobic conditions; hence, concentrations should continue to decrease at P 17C if the oxidation-reduction potential (ORP) 5, also referred to as "redox" potential is increased.
~ . Oxidation Reduction Potential CORP) or reduction-oxidation potential "redox" are chemical reactions that play an important role in the geochemistry of groundwater. Redox reactions determine the mobility of many inorganic compounds as well as biological materials such as nitrogen and sulfur. Redox conditions determine how biological material can break down complex hydrocarbon contaminants such as benzene, THF and TeE in the groundwater at this Site.
39 Trichloroethylene
In recent years, of the eleven private wells that are annually sampled and analyzed by WMWI, trichloroethylene (TeE) has been found in the annual water quality sample of private drinking water well PW03 on the former Sundby property. The concentrations were 0.6 ug/L (estimated value) in 2008,3.6 ug/L in 2009, and 2.2 ug/L in 2010. These levels exceed the PAL of 0.5 ug/L, but not the ES and MeL (5 ug/L). Between 2003 and 2006 the annually reported result was non-detect. Trichloroethylene has not been found at other private wells. Typical degradation products of TCE, such as cis-l ,2-dichloroethene and VC have not been detected. No products that typically degrade to TCE, such as tetrachloroethene, have been detected either.
The agencies believe that three consecutive years of PAL exceedance are not atypical. The propelty owner has been informed by annual letter from WMwr ofthe results; appropriate notifications by regulatory agencies needs to be confirmed. The WMWlletter indicates that the concentration is below MCLs, but does not refer to Wisconsin criteria.
Inorganics
Arsenic PAL (one ug/L) exceedances have been statistically identified at 15 monitoring wells (1004, MW7, P7B, MW22, P22B, MW23, MW26, P26B, MW27, P27B, OBSlB, OBSle, OB08M, Pl7B, and PI 7C). Among these, eight wells show downward trends and the others have no significant trend. Five of the wells with higher concentration are located near the landfill (1004, MW7, P7B, MW22, P22B), four are located on-property (OBS IB, OBS 1C, P17B, and P17C); and one is the downgradient OB08M. The UCL concentration exceeded the ES and MeL (10 ug/L) at three monitoring wells: P22B located within the waste boundary (69.55 ug/L); P27B located off-site and to the south (15.84 ug/L); and, OBS 1C located on-property just south of the air sparging wells (12.72 ug/L). Arsenic occurs naturally in some Wisconsin groundwater, but no specific ACL has been proposed for the Hagen Farm Site at this time. While there is no evidence that the dissolved arsenic originates in the landfill, it does not necessarily mean that dissolved arsenic is unrelated to the Site.
Lead exceedances have been found at OBSIA (UCL of25.5 ug/L) and OBSIB (UCL of3.3 ug/L). The deep well at this location, OBS 1C, has a UCL of 0.3 ug/L, well below the PAL (l.5 ug/L). Because exceedances are found only at this location and decrease with depth, the cause appears to be localized and shallow. As for private wells, lead is seen above PAL usually at one location, which may be related to plumbing.
No mercury exceedances of the PAL were seen in the monitoring or private wells with sufficient datu and no trends were observed.
On occasion, other contaminants have detected in the annual private well samples. Iron and manganese exceedances are routine at about half of the wells. Nitrate plus nitrite PAL exceedances are not uncommon, and may result from agriculture, fertilizer use, or other human activities.
40 MNA Parameters
Routine monitoring program at the Site includes a number of MNA parameters:
• Dissolved oxygen (DO) • Dissolved nitrate plus nitrite (N03+N02) • Dissolved iron (Fe) • Dissolved manganese (Mn) • Dissolved sulfate (S04) • Oxidation-reduction potential (ORP)
These MNA parameters indicate whether the groundwater chemistry environment is conducive to certain biological conditions in the aquifer that break down the groundwater contaminants. Table 6 (Attachment 8) provides a methodology for using concentrations of DO, N03+N02, Fe, Mn, S04, and sulfide to determine the general redox category as well as the predominant redox process.
Applying the Table 6 classification scheme at several wells, as well as concentrations measured from calendar years 2009 and 2010 and similar data show a likely scenario in which the landfill is a reducing environment, the LF AS creates a locally oxic environment, and adjacent to the latter is a nitrate-reducing environment. A small distance south of the LF AS wells, the bedrock well OBS 1C is iron- or sulfate-reducing while eat shallower depths, OBS 1B probably indicates an oxic environment. A long narrow deep plume, characterized as a mixed manganese-reducing plume, extends at least as far south as OB08M.
As stated elsewhere, the higher air pressure at the LF AS had a distinct and beneficial local effect. The 2010 AR suggests a manganese reducing environment. Data indicate that natural seasonal variability exists in the redox environment. Oxidizing conditions are found near the LF AS sparge wells, except for the deepest screens in the plume, OBS 1C and the more southern P17C. At P 17B, shallower than P 17C and further from the LF AS wells than OBS 1, the environment is less reducing but still not oxic. U.S. EPA's interpretation of the MNA parameters is as follows:
• There are contradictory results in the MNA parameters data. • The DO concentrations do not always reflect aquifer conditions (Attachment 8, Table 7) • The LF AS is creating a locally oxic environment and, in combination with precipitation, is making the redox environment less reducing to the south. • The groundwater south of the waste boundary is not a typical oblong plume. There is a three-dimensional nature (generally, it extends southward at depth and is less concentrated near the ground surface) and there is a preferential path nature (there is a narrow, not fully characterized, region in the fractured bedrock). • ORP provides more reliable data than DO concentrations.
When the MNA results are combined with the COC concentration data, the MNA conclusions can be expanded:
41 • The enhanced LF AS system is causing THF concentrations to decrease. Preventive Action Limit exceedances, based on UCLs from two years' worth of field data (excluding MW7) persist at OBS 1C and P17C, but there are downward trends at both locations. • Continued operation of the enhanced LF AS is expected to result in THF attaining PAL in a reasonable time frame (except at MW7, which is essentially the waste boundary). • The enhanced LF AS system has lowered VC concentrations locally, but the effect appears to have stalled. There has been no observed beneficial effect further south, such as at OB08M. • Exceedances ofthe benzene PAL (0.50 ug/L), based on UCLs and excluding P7B, are limited to P17B (0.52 ug/L) and P17C (3.06 ug/L). There is a downward trend at PI7B, but there is no downward trend at P 17C. Therefore, within a short time, only P 17C may exceed the PAL. Lowering the concentration to PAL requires a more oxidizing environment. • The LF AS has no apparent impact on arsenic, mercury, or lead concentrations. The elevated lead concentrations at OBS I A and OBS 1B may be the result of historical soil contamination and seem to be localized.
Annual Reporting
The annual O&M reports or Annual Reports affect the evaluation of field activities and data. As such, the reports should include more than the currently provided information, such as COC concentrations vs. time for a greater number of sampling locations and a review of IC status. This information would help to provide a more comprehensive picture to inform the agencies as to the efficacy of LF AS. The agencies have prepared comments that will be provided to WMWI under separate cover. Some of these concerns are touched upon in this review.
The PRP has proposed that the following modifications to the routine groundwater monitoring program described above are warranted:
The monthly performance monitoring program would be replaced by qUaI1erly monitoring and include the same sample points and parameters that were monitored monthly to assess the per10rmance of the cap, ISVE and LFAS remedial components.
The semi-annual monitoring program would be modified to include sampling of the existing 19 groundwater monitoring wells. Additionally, groundwater elevations are measured at 17 wells. The samples would be analyzed for VOCs, select dissolved metals, indicator parameters and field parameters.
The annual monitoring program would consist of groundwater sampling at the same 36 monitoring wells currently in the program. These are the same points as included in the semi annual program. The samples would be analyzed for VOCs, select dissolved metals, indicator parameters and field parameters. Analysis of samples for the expanded list of dissolved metals (23 in total), pesticides, herbicides, polychlorinated biphenyls would be discontinued.
Sampling at private wells located further downgradient and side-gradient from the Site would be discontinued. Future priYate well sampling would be performed at PW3, PW4, PW5, and PW9
42 so that information on groundwater quality continues to be provided in the areas where development is present. The agencies are in the process of reviewing these requests.
Site Inspection
The Five Year Review Site inspection was conducted on April27, 2011 by Sheila Sullivan, U.S. EP A RPM for the Site. Also participating was Gary Edelstein, WDNR Site Manager, Mike Peterson, District Manager of Closed Sites Management Group, WMWI, and Mike Pratke, Division Manager ofO&M staff for BT Squared, Inc. Attachment 6 provides a copy of the Five Year Review site inspection form. The purpose of the inspection was to assess the protectiveness of the remedy, including the status of access restrictions and ICs. No significant issues were identitied at any time regarding the drainage structures, or the fence. Examination of the cap revealed that the grass cover was in good condition. The cap and the surrounding areas were undisturbed. There is a riprap layer that acts as a toe drain for the gravel drainage layer situated above the clay cover. There is a geotextile layer above the drainage layer that appears to be installed between the gravel and the riprap. Attachment 7 provides photographs taken during the Site inspection.
Interviews
Messrs. Michael Peterson and Michael Pratke were interviewed and conducted the Site tour. The discussions focused on the LF AS operations and potential options for remedy enhancement. The RPM also visited the Stoughton Public Library, which is the local repository for the Site files and administrative record. The contents of the files were reviewed and found to be complete.
VII. Technical Assessment
Question A: Is the remedy functioning as intended by the decision documents?
Yes. The review of documents and the results of the Five-Year Review Site inspection indicate that the SCOU portion of the remedy is functioning as intended by the ROD and ESD. The consolidation and capping of the wastes, in combination with the access restrictions and ICs effectively block the exposure routes of concern and reduce overall human health risk onsite, as well as protect the remedy. The ISVE system has reduced contaminant loading from the source to the groundwater. This review found that O&M of the cap and drainage structures has been effective.
The GCOU portion of the remedy no longer uses all components as documented in the ROD and ESD. The GCOU currently utilizes only the LF AS system to address groundwater contamination since 2001 when it was substituted on an interim basis for the pump-and-treat system for in situ treatment. Most of the remaining groundwater contamination is in the anaerobic zone immediately downgradient of the SCOU. The LFAS system was installed to aerate this zone and provide more efficient remediation than was provided by the groundwater pump-and-treat system. The LFAS is well-maintained and shows the ability to reduce some contaminants, but VC contamination remains a concern.
43 Comprehensive groundwater data, O&M records and other information pertaining to the current LF AS system indicate that it is operating as well as can be expected under its current configuration. However, remediation is not fully effective in removing the VC plume which continues to move southward from the landfill. Because vinyl chloride is not present in offsite wells at levels exceeding the MCL, the current protectiveness ofthe remedy is intact.
Enhancements to the LF AS will maintain and ensure protection in the long term. The agencies believe the data do not WalTant recommissioning the pump-and-treat system at this time, and that a more robust LF AS system is preferable. The agencies recommend augmenting the current LF AS system, which could be accomplished for example, by installing additional strategically placed sparge points. The PRP should also investigate strategies for ensuring that uninterrupted groundwater restoration will continue should the LF AS system prove ineffective. The PRP should evaluate alternatives and propose specific enhancements to the system and implement them according to a schedule that has improvements in place and operational. For the time -being, the pump-and-treat system should remain onsite. When the LF AS system has demonstrated effectiveness, a decision document should be prepared to memorialize the GCOU remedy change.
A study of the ICs at the Site was performed by WMWI in 2006 and recertified. As a result of its assessment ofICs with respect to the most recent groundwater data, U.S. EPA believes that while onsite ICs are protective in both the short and long term, offsite ICs should be enhanced to ensure long-term protectiveness.
This would involve the use ofICs flUther downgradient (south) of the landfIll property, at least as far as the OB08M monitoring well. The downgradient VC levels detected at two locations (OB08M and P32B) outside of the 1,200-foot radius boundary exceed the PAL, and in some cases, the ES, but do not exceed the MCL. This finding reinforces the need for off-property ICs to prevent the potable use of groundwater. To assure LTS of the Site, future O&M work should include mechanisms to ensure the regular inspection of ICs and an annual certification to the agencies that ICs are in place and effective. If the plume length and breadth is estimated in a conservative fashion, then future concentrations at OB08M could be used as part of a "trigger" to modify restrictions. res to restrict the potable use of groundwater should be evaluated beyond the 1,200-foot restrictive boundary [(NR 812.08(4)(g)] to the extent necessary to ensure long-term protectiveness of human health and the environment downgradient of the Site. The PRP should also report on whether the restrictions contained in its sale contract for Lot 3 also run with the land and bind future owners. The PRP should investigate and implement appropriate ICs for properties located more than 1,200 feet beyond the landfill boundary, where the PAL is or may be exceeded in groundwater.
44 Question B: Are the exposure assumptions, toxicity data, cleanup levels and RAOs used at the time ofremedy selection still valid?
Yes. There have been no changes in the physical conditions of the Site since the last Five-Year Review that change the protectiveness ofthe remedy. There are no changes in land use or anticipated land use on or near the Site that change the effectiveness of the remedy.
Changes in Standards and To Be Considereds
There have been changes to the Wisconsin NR 140 groundwater cleanup standards for three chemicals. More stringent standards for toluene and xylenes have been adopted and less stringent standards for manganese. These changes do not impact the validity or protectiveness of the remedy.
Changes in Exposure Pathways, Toxicity, and Other Contaminant Characteristics
There have been no changes in the toxicity factors for the contaminants of concern that were used in the baseline risk assessment. These assumptions are considered to be 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 warranted. There has been no change to the standardized risk assessment methodology that could affect the protectiveness of the remedy.
Question C: Has any other information come to light that could call into question the protectiveness ofthe remedy?
No. There is no new information available since the 2006 Five-Year Review that could question the protectiveness of the remedy.
Technical Assessment Summary
The LF AS system has replaced the pump-and-treat system on an interim basis. According to the information collected since the last Five-Year Review, the current LFAS remedy appears to be making progress towards meeting the groundwater cleanup standards in some wells. Some wells, however, are not showing improvement, which is necessary if the LF AS is to achieve groundwater remediation in a reasonable time period.
The PRP should investigate strategies for ensuring uninterrupted groundwater restoration should the LF AS system prove ineffective. In order to achieve greater effectiveness, we recommend augmentation of the current LF AS system. This can be accomplished, for example, by installing additional strategically placed sparge points. While recommissioning the pump-and-treat system is not necessary, it should remain onsite for the time being should an enhanced LF AS system or other additional measures prove ineffective.
There have been no changes in the physical conditions of the Site that would affect the protectiveness of the remedy. While the PALs and ESs have changed for toluene, xylenes and
45 manganese after the RODs were implemented, these do not affect the RAOs. Changes in the toxicity factors for three of the COCs used in the baseline risk assessment do not affect the remedy's effectiveness or protectiveness of human health and the environment. There has been no change to the risk assessment methodology that could atIect the protectiveness of the remedy. There is no recent information that could question the protectiveness ofthe remedy.
VIII. Issues
Table 8 presents the issues identified at the Hagen Farm Site as a result of this Five-Year Review.
TABLE 8 - Issues
Affects Current Affects Future Issue Protectiveness Protectiveness (YIN) (YIN)
The SOW appended to the 2007 CD states that the LF AS system must restore the groundwater within a reasonable time period. Groundwater data evaluated to date show a reduction in contaminant concentrations in some wells since N y the previous Five-Year Review, but not a significant overall declining trend throughout the aquifer, especially for vc. This is necessary if the remedy is to achieve cleanup goals within a reasonable time period.
IX. Recommendations and Follow-Up Actions
Based on the issues identified in the previous table, the following recommendations in Table 9 are made to resolve the issues.
TABLE 9 - Recommendations and Follow up Actions
Recommendations and Party Oversight Milestone Affects ~ssuc Follow-LJ p Actions Responsible Agency Date Protectiveness(YIN) Current Future
The SOW appended to The LF AS, currently in use PRP U.S. EPA, Sept. 2013 N Y the 2007 CD states that for groundwater remediation. with the LF AS system must should be enhanced to achieve WDNR restore the groundwater greater ·effecti veness in input within a reasonable time contaminant reduction. The period. Groundwater PRP should evaluate data evaluated to date alternatives. propose specific show a reduction in enhancements to the system. contaminant and implement them
46 Recommendations and Party Oversight Milestone Affects Follow-Up Actions Responsible Agency Date Protectiveness(YIN) Issue
Current Future concentrations in some according to a schedule. The wells since the previous groundwater pump-and-treat Five-Year Review, but system should remain onsite not a significant overall and operational until the declining trend LFAS is optimized. throughout the aquifer, especially for This At such time when the LF AS PRP Sept. 2014 vc. U.S. EPA, N Y is necessary if the has been enhanced or with remedy is to achieve demonstrates improved WDNR cleanup goals within a remedial effectiveness, a input reasonable time period. decision document should be prepared to memorialize the GCOU remedy change.
x. Protectiveness Statement
Operable Unit I protects human health and the environment in both the short and long term. The source ofcontamination is not accessible to humans as it was consolidated and capped. Access and ICs, including fencing and deed restrictions, respectively, have been implemented to prevent current and future exposures to onsite groundwater and prevent residential/commercial activities for the onsite property.
Operable Unit 2 protects human health and the enviromnent in the short term. Access controls and ICs, including fencing, deed restrictions, and govermnental controls have been implemented to prevent current and future exposures to onsite and offsite groundwater. Residences downgradient of the Site that rely on private groundwater wells are sampled annually to ensure their groundwater is safe. Currently, there are no exceedances of VC above MCLs in the offsite monitoring and private wells. Long term protectiveness of the OU2 remedy will be achieved by enhancing the CUlTent LF AS system and ensuring its continued effective operation and maintenance; maintaining and enforcing the effectiveness of existing ICs; and implementing additional enforceable ICs further downgradient of the Site where ROD-specified groundwater cleanup goals are being exceeded until groundwater cleanup goals have been achieved throughout the plume.
On a site-wide basis, the remedy is protective of human health and the environment in the short term. The remedy will be protective in the long term when ROD-specified groundwater cleanup goals are achieved throughout the plume. Until such time, it will be necessary to continue groundwater remediation, and to institute, maintain and enforce effective ICs at the Site.
47 XI. Next Review
The next statutory Five-Year Review for the Hagen Farm Superfund Site is required by June 2016, five years from the date of this review.
48 Tables
Table 1 - Chronology of Site Events Table 2 - Hagen Farm Groundwater Cleanup Standards and Maximum Concentrations Detected Since 2006 Table 3 - Assessment of Access and Institutional Controls Table 4 - Current Monitoring Schedule (Attachment 8) Table 5 - Proposed Future Monitoring Schedule (Attachment 8) Table 6 - Oxidation Reduction Classification and Processes (Attachment 8) Table 7 - Dissolved Oxygen Monitoring Data (Attachment 8) Table 8 - Issues Table 9 - Recommendations and Follow-up Actions
Figures
Figure 1 - Site Location Overview Map Figure 2 - Stoughton Jurisdictional Boundary Map Figure 3 - Site Features Map Figure 4 - Site Map Showing Institutional Controls and Monitored Private Well Locations Figure 5 - Soil Vapor Extraction Wells and Gas Probe Locations Figure 6 - Site Map Showing Groundwater Monitoring Well Locations Figure 7 - Site Map Showing Low Flow Air Sparge Point Locations
Attachments
Attachment I - u.S. EPA Notification of Five-Year Review Stmt Attachment 2 - PRP Celtification of Current IC Status Attachment 3 - Groundwater Data Trend Plots for Key Wells Attachment 4 - Newspaper Notice Announcing Stmi of Five-Year Review Attachment 5 - Documents Used to Prepare Five-Year Review Attachment 6 - Five-Year Review Site Inspection Checklist for Hagen Farm Attachment 7 - Photography Log from April 27, 2011 Five-Year Review Inspection Attachment 8 - Additional Tables
Appendix
Appendix I - Institutional Controls Investigation of May 2006 Performed by Waste Management Wisconsin
49 Hagen Farm EPA 10# WI0980610059
Dane County, WI ...... Coo
State
Legend Site C::==::=J___ Meters 'iJ"V'il\7 Fence .-IC_-IC___ o 90 180 360 540 720 ~ Landfill IFigure 11
Produced by Andrea Hicks U.S. EPA Region 5 on May 6,2011 EPA Disclaimer.. Please be advised that aeras depicted in the map have been estimated. The map does Image Date: 2009/2010 not create any nghts enforceable by any party. EPA may refine or change this data and map at any time. / City of Stoughton Comprehensive Plan :.. ..:......
Gl Stoughton Areo School District Jurisdictional Boundaries ----I'--, -, 1'( '~ ( 11' 'J O\P" or 1) l.J1'o. ~ I " ,HIISt. ' f'RINGS 0 - , --I -- Existin;: E1:1 Boundary (3 ~lib o , EXIsting E1J Boundary (1.5 ~mc,) --MunicIpal Boundaries --, --Urban Set\';ce Atea.o; ., ••••• School DisrnctBoundaty .. ., _ Interstates H 6>1..• • I.., -l'S & Cnunt}' Highways L.., LocaJ Road. Sectlon Boundaries r.J. , , , , I ff: &2)J ...... , f2.. , -1, , I I >, I " \~ 0[' ... , I ,.\Ul IC 111- ' " ' - ~I TOWN r [)' ·Io;IRJ.. I Figure 2 I ,I : ... I " ...... 1_., C...... 1-_., ,--t' L L ______GJ• , __ _ I \d-pw"".u..-.u..;.~ L____ • t., .c-·fi .).. ...", . N ...... ~ ...... : -(!3'-- A Hagen Farm WID980610059 Dane County, WI
Legend o 365 730 t Ditch __'::=:=:::JI Feetl!! D Hagen Farm Property EPA DisQaimer: Please be advised F .9 3 D Ponds that areas depfcted in Ihe map have I Ure ~ Fence been estimated. The map don not create any rights enforceable Capped Main Disposal Area by any party. EPA may refine of Wisconsin and Southern Railroad change thts data and map at any time.
D Groundwater Treatment Building Created by Andrea Hicl
Hagen Farm Dane County, WI WID98061 0059
Legend 1:\ o__ -=====0.1 0_____.2 0:4Miles ...... N :...... : Hagen Farm Property D Land and Groundwater Restrictions*
Produced by Andrea Hicks Well Restricted Area: 1200 feet from landfill * U S EPA Reg;on 5 on April 29, 2011 Image Date: 2009 I Figure 41 G2Sl) Landfill
'iJ"VVV Fence • Well Restrictions found in the ''WONR Approved Private Water System Area" (1995)
· t W II L t' EPA Disclaimer Please be advised that areas depicted In the map have been estimated The map does • Pnva e e oca Ions not create any rights enforceable by any party EPA may refine or change thIS data and map at any time Soil Vapor Extraction Wells and Gas Probe Locations legend Hagen Farm Site Gas Extraction Well Figure 5 • Gas Probe Approximate Limits of Waste Well Locations Legend Hagen Fann Site MW1 • Monitoring Well Location and Number --- Fence PW11 A Private Well Location and Number Approximate Limits of Waste Figure 6 Expanded Low Flow Air Sparging System Locations Legend Hagen Farm Site A Shallow Air Sparge Well
• Deep AirSparge Well Approximate Limits of Waste Figure 7 \: Attachment 1
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGlON V 77 WEST JACKSON BOULEVARD CHICAGO. ILLINOIS 60604
RESPOND TO rIlE.\ ITL;"!TlON OF SR-hJ
October 7,2010
Mr. Michael Peterson, P.E. District Manager, Closed Sites Management Group Waste Management of Wisconsin W124 N9355 Boundary Road Menominee Falls, WI 53051
VIA TELEFAX and FIRST CLASS U.S. MAIL
Re: Notification of Five-Year Review Start for the Hagen Farm Site, Town of Dunkirk, Wisconsin
Dear Mr. Peterson,
This letter is to notify you that the U.S. Environmental Protection Agency (EPA) has begun the process of the fourth Five-Year Review for the Hagen Farm Superfund Site ("the Site") in the Town of Dunkirk, Wisconsin. A statutory Five-Year Review for the Site will be conducted as required by Section 12 I of the Comprehensive Environmental Response Compensation and Liability Act (CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA). The law requires that completed remedial actions, which result in any hazardous substances, pollutants, or contaminants remaining at the Site above levels that allow for unrestricted use and unrestricted exposure, shall be subject to a Five-Year Review to determine if the remedy remains protective of human health and the environment.
The Five-Year Review for the Hagen Farm Site is due on June 15, 2011, and we are providing you this notification so that EPA, the Wisconsin Department of Natural Resources (WDNR), and Waste Management of Wisconsin and its consultants can begin the necessary coordination activities.
As part of the process, a site inspection will need to be scheduled as soon as possible. Currently, all relevant Site information since the previous Five-Year Review is being collected and evaluated. This includes any information pertaining to institutional controls (ICs) at or near the Site. The desired schedule for beginning the other components of the Review is as follows: • Public notification via placing notice in local newspaper - ASAP; • Data and document exchange and review - in progress; • Ie study update and file review - completed; • Begin drafting Five-Year Review Report - December 15,2010; • Begin review/approval process of the Five-Year Review Report - March 17, 2011
The above schedule is cursory; as I am sure you know there are many elements involved in preparing a Five-Year Review report. In addition, EPA will be working with its consultant, in conjunction with WDNR to evaluate the issues and recommendations resulting from the previous Five-Year Review.
I look forward to working with you to complete the Five-Year Review Report in a timely manner. If you have any questions, concerns, or related information, please do not hesitate to contact me using the information provided below.
Sincerely, )Ju~~ () 4~-~~~~ Sheila A. Sullivan Remedial Project Manager Superfund Division u.S. EPA, Region 5 Tel: (312) 886-5251 E-mail: S uBi van.sheila(iiJ,epa. gov cc: Gary Edelstein, WDNR
2 Attachment 2
WASTE MANAGEMENT lfllASTIE MANAGEMEh'BY Closed Sites Managemem Group W124N9355 Boundarv Road May 16,2011 Menomonee Falls, WI 53051 (262) 253-8626 (262) 255-3798 Fax
Ms. Sheila A. Sullivan Remedial Project Manager U.S. EPA Region 5 Waste Management Division 77 West Jackson Boulevard, HSRL-6J Chicago, illmOIs 60604
Re: Institutional Controls Hagen Farm Superfund Site
Dear Ms. Sullivan:
This is to follow up on our phone conversation on Friday, May 13, 2011 regarding the Institutional Controls in place for the Hagen Farm Superfund site. To my knowledge there have been no changes in the Institutional Controls that were established for the site sine the last five year reVIew.
Please call me at 262-532-4024 if you have any questions.
Sincerely, Waste Management of Wisconsin, Inc.
Michael L. Peterson, P .E. District Manager - Closed Sites cc: Mr. Gary Edelstein - WDNR Mike Prattke - BT Squared, Inc. Lisa Zebovitz - NGE
from everyday collection 1;0 environmental protection, Think Green;' Think Waste Management. Attachment 3 Groundwater Data Trends for Key Wells Graph 1
OB-8M • Standard Vinyl chloride Baseline Hagen Farm • Trend ,
10 • I . --- Observations Standard (0.02 ugIL) Median Nondetect Trend Window UCL for 5O%tile PI for 1 Sample Detects Nondetects
-
0.1 .
I 01/01/1995 01/01/2000 01/01/2005 01/01/2010 01/01/2015
Standard Test (95~.): Exceedance
Start of Oxygen Generator
10
1
~:::1. - c:: - EW1 Q ~ ----- EW2 ....C! c:: -OBS-1A QI uc:: -OBS-1B Q 0_1 U -----· OBS-1C _P17C
0.01 PAL = 0.02 f-lg/L ES=0.2 f-lgiL
0.001 Jan-96 Jan-98 Jan-OO Jan-02 Jan-04 Jan-06 Jan-08 Jan-10 Note: Non-detects are plotted as 1/2 the Limit Date of Detection (LOD) with open data markers. On Property Wells Vinyl Chloride
Includes December 2010 data Graph 3
Tetrahydrofuran Hagen. Farm Site 100000 ~------''--'------.r--.--~r-~~------~
Shutdown Start of Air --.Sparge JI' Pump and Treat 10000 ~------~--~------+---~~~hM~------~ /" .r Sparge Down
1000
. ~,,;.. r= 0 ".tI 100 .tl -EW1 r= - EW2 QI u -OBS-1A =0 U _OBS-1B 10 - OBS-1C _P17C
PAL = 10 /lgIL 1 ES=50 /lgfL
0.1 Jan-96 Jan-98 Jan-DO Jan-02 Jan-04 Jan-OS Jan-08 Jan-10
Dale Note: Non-detects are plotted as 1/2 the Limit of Detection (tOO) with open data markers. On Property Wells Tetrahydrofuran
Includes December 2010 data Graph 4
P-7B • Standard Benzene Baseline Hagen Farm Trend
100------~------~------~------__, --- Observations Standard (0.5 ugll) Median Nondetect Trend Window UCL for 50%tile PI for 1 Sample Detects Nondetects
10 \ \ ~ \ I \I ~
I 01/01/1995 01/01/2000 01/01/2005 01/01/2010 01/01/2015
Standard Test (95%): Exceedance
P-17 ... Standard Benzene Baseline Hagen Farm .. Trend
10------~------~------~------_r------_, --- Observations Standard (0.5 ugll) Median Nondetect Trend Window UCl for 50'lotile PI for 1 Sample Detects Nondetects
....J C, :l ai c: Q) N c: Q) tD
01/01/1995 01/01/2000 01/01/2005 01/01/2010 01/01/2015
Standard Test (95%): Exceedance
P-17C .. Standard Benzene Baseline Hagen Farm Trend
100~------r------~r------'------1 ---- Observations Standard (0.5 ugIL) Median Nondetect Trend Window UCl for 50%tile PI for 1 Sample Detects Nondetects
<::! 10 Ol ::s ai c:: Q) N t c:: Q) m
•
01/01/1995 01/01/2000 01/01/2005 01/01/2010 01/01/2015
Standard Test (95%): Exceedance
1000 +------~--~~~~~~--~--~~--~Sy~s~re=m~------~
~ Pressur Start of Chang Oxygen Generator
100
.-. ...:I bb :1. " s:: 0 ~.s 10 Q,js:: s::v 0 U 1
PAL =0.5 flg/L ES", 5 flg/L
0.1
0.01 Jan-96 Jan-98 Jan-DO Jan-02 Jan-04 Jan-06 Jan-08 Jan-10 Date Note: Non-detects are plotted as 1/2 the Limit On Property of Detection (tOO) with open data markers. Benzene
Includes December 201,0 data Graph 8 Tetrahydrofuran Hagen Farm Site
100000 Start of Air Shutdown Start of Deep Start of Oxygen Sparge ...... I Pump and Treat /AirSpa: ge Generator I¥" / 10000 System Itt" PressurE \ir Sparge Down I Change
1000
~ ~ ::1. ~ '-' ....0= 100 ~ - 11 ~ v~= .. I-MW22 1 =0 U \ r\ 10 ~ I!\
PAL = 10 flglL
\ ~ 1 \ r\A \ J{l~~~ ES= 50 flg/L \ ~ ~ ~ ~ U 0.1 Jan-96 Jan-98 Jan-OO Jan-02 Jan-04 Jan-06 Jan-08 Jan-10 Note: Non-detects are plotted as 1/2 the Limit Date of Detection (LOD) with open data markers. Source Area Well Tetrahydrofuran
Includes December 2010 data Graph 9 Tetrahydrofuran Hagen Farm Site
10000 Shutdown Start of PeeP 1/ Pump and Treat V Air Spa ~e Start of Air 1/ Systen Sparge ...... A Sparge Down ./' ¥ ~:;~ e 1000
Start of Oxygen Generator - /' -. 100 l- =0 '.0 ~ =~ I -oss-zel PAL:: 10 f.1g/L ES=SO f.1g/L ~ ~,-- ~ .. IJI.M~ l T 0.1 Jan-96 Jan-98 Jan-OO Jan-02 Jan-04 Jan-06 Jan-08 Jan-10 Note: Non-detects are plotted as 1/2 the Limit Date of Detection (LOD) with open data markers. Off Property Well Tetrahydrofuran Includes December 2010 data _..- _ ____A.£, ".-&..U,",U." "pUlL- JJ!'VUIU-LOI0t recelvea. n .! surrounding areas as sore<;l annually by the UW Depart In Advanced Poetry Red. she said. .'ment of German'. The competition abeth Erickson and Brig] \In'-Scheel and Steink . 'gets middle sch~ol and high school both received first prize:. Attachment 4 said they believed:. stu~ents involved with the language In the theme-relat s been enough prog ade toward a'boundary ' lent to satisfy CARPC tain approval to amend ~ y's urban service' area . Ide Kettle West. \&. EPA 8eglns RevieW', of Hagen Farm Superfund Site Dunkirk. Township. Wisconsin be to The U.S. Environmental Protection Agency is conducting · a five-year.review ofthe Hagen Farm Superfund site, 2318 rHub County Highway A, in the town of Dunkirk.. The , ing : Superfund law-requires regular checkups of sites that have ' been cleaned up - With waste managed on-site - to make 671 sure the cle~up continues to protect people and the environment: This is the fourth five-year review ofthis . on . site .• ~hton~com : ..The' EPA's cleanup ofcontanlinated soil consisted of consolidating three waste disposal areas into o~e, capping the 'consolidated ~aste, and iDStalling and-op~ting ~ in place vap~r extraction syst~m. -f,.. separate plan for contaminated ground water. consisted ofa pump-and-treat. · system. EPA is now rurining a trial'to see ifthe pump-and-' treat system can be replaced by a syste~ that pumps aii .' feater , into the ground water to help bacteria break down the ' . . pends contaminants .. ncla!. .'-:. More ~oimatiOt;l is' available at the Stoughton Public _Library, 304 S. Fourth S1. and at . , www.epa.gov/regionS/cleanup/hagenfailn. The review" . should be co~~eted by JUne. · The five-year review is an·opportunity for you to tell the . . EPA about site conditions and any concerns you have. . Contact: - - '. . Susan Pastor-' . :. Shella Sullivan. .. Community Involvement ~ Remedial Project Manager·' Coordinator . - ,-, 312~88'6-525l ' . 312-353-1325 ' [email protected]·, [email protected] You may call Region 5 toll-free at 800-621-8431, 8:30a.m to.4:30 p.in: s: weekdays. . Attachment 5 LIST OF DOCUMENTS USED FOR FIVE-YEAR REVIEW 1. BT Squared, Inc. "2009 Annual Report, Hagen Farm, Town of Dunkirk, Dane County, Wisconsin, March 2010", Prepared for Waste Management of Wisconsin, Inc., March, 2010. 2. BT Squared, Inc. "2010 Annual Report, Hagen Farm, Town of Dunkirk, Dane County, Wisconsin, March 2011", Prepared for Waste Management of Wisconsin, Inc., March, 2011. 3. Hard Hat Services "Hagen Farm Site, 2008 Annual Report", Prepared for Waste Management of Wisconsin, Inc., March, 2009. 4. Montgomery Watson. "Technical Memorandum for Remediation Technology Modifications, Hagen Farm Groundwater Control Operable Unit", August 21, 2000. 5. Montgomery Watson Harza, "Low Flow Air Sparge System Implementation and Monitoring Plan, Hagen Farm Site Groundwater Control Operable Unit". Prepared for Waste Management, Inc. January 2001. 6. Montgomery Watson Harza. "Air Sparging System Performance and Work Plan, Hagen Farm Site, Stoughton, WI", Prepared for Waste Management, Inc. January 2005. 7. RMT. "Hagen Fann-Updated Interim Evaluation of Groundwater Monitoring Results", Technical Memorandum from K. Quinn and D. Hall to M. Peterson, March 31, 2005 (transmitted by Waste Management to USEPA, March 30, 2006). 8. RMT, Inc., "Technical Memorandum Re: Hagen Farm Interim Evaluation of Groundwater Monitoring Results." Prepared for Waste Management, Inc, October 14,2005. 9. RMT, Inc., "Technical Memorandum Re: Hagen Farm Second Interim Evaluation of Groundwater Monitoring Results." Prepared for Waste Management, Inc, March 31, 2006. 10. RMT. "Hagen Farm-Evaluation of Expanded Low-Flow Air Sparge System", Technical Memorandum from K. Quinn and D. Hall to M. Peterson, Prepared for Waste Management of Wisconsin, Inc., May 31, 2007. 11. RMT. "Annual Operation and Maintenance Report Number 20 for the Source Control Operable Unit January 1, 2006, through December 31, 2006, Annual Operation and Maintenance Report Number 15 for the Groundwater Control Operable Unit January 1, 2006 through December 31, 2006, Annual Groundwater Monitoring Program Repolt Number 10 January 1,2006 through December 31,2006, Hagen Farm, Town of Dunkirk, Wisconsin, May 2001", Prepared for Waste Management of Wisconsin, Inc., May 2007. 12. RMT. "Annual Progress Repolt, Annual Operation and Maintenance Report Number 21 for the Source Control Operable Unit 11112007 through 12/3112007, Annual Operation and Maintenance Repolt Number 16 for the Groundwater Control Operable Unit 1/l/2007 through 12/3112007, Annual Groundwater Monitoring Program Report Number 11 1/112007 through 12/31/2007, Hagen Farm Site, Town of Dunkirk, Wisconsin, March 2008." 13. Subterranean Research, Inc. "Technical Memo: Hydrologic Review of Remedy, Hagen Farm Superfund Site, Dunkirk, Dane County, Wisconsin (draft)." Prepared on behalf of U.S. EPA Region 5 Groundwater Evaluation and Optimization System, April 29, 2011. 14. U.S. Environmental Protection Agency, "Hagen Farm Site, WI. Source Control Operable Unit Declaration for the Record of Decision", September 17, 1990. 15. U.S. Environmental Protection Agency, "Explanation of Significant Differences for the Hagen Farm Superfund Site Groundwater Control Operable Unit, Dane County, WI". August 27, 1991. 16. U.S. Environmental Protection Agency, "Hagen Farm Site, WI. Groundwater Control Operable Unit Declaration for the Record of Decision", September 30, 1992. 17. U.S. Environmental Protection Agency, "Explanation of Significant Differences for the Hagen Farm Superfund Site Source Control Operable Unit, Dane County, WI". April 1996. 18. United States Environmental Protection Agency (U.S. EPA). June 2001. Comprehensive Five-Year Review Guidance, Office ofSolid Waste and Emergency Response. Directive 9355.7-03B-P. 19. U.S. Environmental Protection Agency. September 2000. Institutional Controls: A Site Managers Guide to Identifying, Evaluating and Selecting Institutional Controls at Superfund and RCRA . Corrective Action Cleanups", Office of Solid Waste and Emergency Response. OSWER Directive 9355.0-74FS-P. EPA 540-F-00-005. 20. United States Environmental Protection Agency (U.S. EPA). 1996d. Drinking Water Regulations and Health Advisories. Office of Water. Washington, D.C. 21. U.S. Environmental Protection Agency, "Five-Year Review Report, Third Five-Year Review for Hagen Farm Superfund Site, Town of Dunkirk, Wisconsin", Prepared by Wisconsin Department of Natural Resources and USEPA, September 21,2006. 22. U.S. Environmental Protection Agency, "Scope of Work for the Remedial Action Work Plan at the Hagen Farm Superfund Site, Stoughton, WI". Appended to Consent Decree. 2006 23. U. S. Environmental Protection Agency, "U.S. EPA Region Y, Consent Decree [United States v. Waste Management of Wisconsin (07-C-0424-C»). August 2007. Attachment 6 s·Ite I nspectlon CheckJ"ISt / --- I. SITE INFORMATION Site name: Hagen Farm Date of inspection: if -27--to 1/ Location and Region: Town of Dunkirk, Dane EPA ID: WID 980 610 059 County, Wisconsin. USEPA REGION 5 Agency, office, or company leading the five-year Weather/temperature: Ovef'u;!;tj dC;//'lf review: United States Environmental Protection {)tht',ltdf(.;;f ::'f'nitkll()1 ')tJ::f Agency, Region 5 Remedy Includes: (Check all that apply) 181 Landfill cover/containment J Monitored natural attenuation 181 Access controls J Groundwater containment 181 Institutional controls J Vertical barrier walls 181 Groundwater pump and treatment __ Surface/storm water management 181 Other: Lona-term aroundwater monitorinai In-situ Val!or Extraction (ISVEli Air Sl!araina Attachments: !] Inspection team roster attached 181 Site maps attached (Figures 1-3) II. INTERVIEWS / PARTICIPANTS (Check all that apply) I. O&M Site Manager A. Waste Management of Wisconsin, Inc. (WMWI) Michael Peterson, PEt District Mgr.• Closed Sites Group W124 N9355 Boundary Road. Menomonee Falls. WI 53051 262-532-4024; FAX: 262-255-3798; email: [email protected] Interviewed 181 at site C at office L: by phone C Other: 2. O&M staff: A. BT Squared. Inc. Michael Prattke. Division Manager N84 W13540 Leon Road. Menomonee Falls. WI 53051 Interviewed){ at site IJ at office C byphone [ Other: Phone no. (262) 345-1220, Ext. 101; FAX: (262) 345-1224; email: [email protected] B. BT Squared Inc. Paul Grover. Senior Tecbnician 2830 Dairy Drive. Madison. WI 53718 Interviewed ,J at site ..: at office '-= by phone .J Other: Phone no. (608) 216-7344; FAX: (608) 224-2839i email: [email protected] Comments, problems, suggestions: The O&M contractor offered to be available at the time of the site inspection and was contacted prior to the inspection to provide copies of recent data related to the operation and maintenance of the air sparge and in situ vapor extraction systems at the site, as well as copies of recent groundwater sampling results. 3. Local regulatory authorities and response agencies (i.e., State and Tribal offices. emergency response office, police department, office of public health or environmental health, zoning office. recorder of deeds, or other city and county offices, etc.) Fill in all that apply. Agency vJ PAl rt Contact G-itVy SJei?fe.i)l j p. ~. e.;'~~-rlLr H.041tA."f:.'.( ~o~) 2' 7- ZS',? Name " Title I &te Phone no . Problems; suggestions; 0 Report attached .!l!M Q r/. 4fl ~' eAdsteiVl@ Wi !'CD-tJ.~i·j/1 f).jI(t2\/ Agency Contact Name Title Date Phone no. Problems; suggestions; 0 Report attached Agency Contact Name Title Date Phone no. Problems; suggestions; 0 Report attached Agency Contact Name Title Date Phone no. Problems; suggestions; 0 Report attached 4. Other interviews (optional) 0 Report attached. Stmu'ii-t'hw.. Pt..tll1{;<"" Llol"LlJ'll I / III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply) I. O&M Documents gf O&M manual ~ Readily available ~ Up to date o N/A l1Q As-built drawings ~ Readily available Qg: Up to date ON/A Q(l Maintenance logs Jl:l Readily available 2"}.Up to date 0 N/A Remarks 'DrC', \VI",., ts ire&J) .~...d Fe j- n't"N " rhv', f,~ /}'w- l\Y.' ;v\-h~; o¥'d. :.,1l,,,,,,1-'l'Hl,'1IJ- b.. ; Idi~ 0i1~lt~_. ~·oies <'fcte;~L~('i.',uei1f:; a~rnl1ll',)+i1U'\ed hdtJf..iWI:(ilrllcrlCi'cfi'cl L.q- Cf-Ht:J:nf.r.,fq;('n ("''').... 2. Site-Specific Health and Safety Plan ~Readily available J&Up to date o N/A o Contingency plan/emergency response plan o Readily available o Up to date ~/A Remarks C.cIJ.e<;. k"f't: t1,j, uJf-j v...'L (~rlJ Q-rH t..;'lljr~:.dtc 6 3. O&M and OSHA Training Records ~ Readily available 'gj Up to date o N/A , 01 Remarks C.C e D r I Cc/"/ .'t"d"llY 4. Permits and Service Agreements o Air discharge permit 0 Readily available o Up to date KJ N/A o Effluent discharge 0 Readily available o Up to date .Q!:l N/A o Waste disposal, POTW 0 Readily available o Up to date ~ N/A o Other pennits __--:-______0 Readily available o Up to date ~N/A Remarks Nt:, pe{'w,its tH' $(o:i ,,',{c " .. .r..cn'~I'lt.s r- J' 5. 6. 7. 8. Leachate Extraction Records o Readily available 0 Up to date .gj N/A Remarks Lr,~' t' hI< t". e)f tuo.t:'tzc It ;.> )11) t c, Cc ilill"71t:M c'f Sf It'f red ve t11edy 9. Discharge Compliance Records o Air 0 Readily available 0 Up to date aN/A o Water (effluent) 0 Readily available 0 Up to date ~N/A Remarks No reeo.-rls ~'elf';('A'1 Ct;j P(\.I+Ct SeleillA Ite..WifAJ to. I. 7 2. O&M Cost Records o Readily available 0 Up to date g .Funding mechanism/agreement in place , Original O&M cost estimate ,lAiN l!..! r d ',d )"It r{',' ,,'iJ Ide 0 Breakdown attached 041-1 {cst.> (cLf' tyl)S Fill..: -~eo'-lkv'~f'L2 ft[ p{cp"dl:.I,) ri:.>Wc:'r0 Total annual cost by year for review period if available ,/ ~ From To / 0 Breakdown attach~d Date Date Total co§.v/ "" From To o Breakdown attached Date Date /' 'fotal cost ... From To ," o Breakdown attached Date Dat!!/ Total cost From To o Breakdown attached Date ,,/ Date /' Total cost From --- To o Breakdown attached _,gate' Date Total cost 3. Unanticipated or Unusually High O&M Costs During Review Period Describe costs and reasons: V. ACCESS AND INSTITUTIONAL CONTROLS j?lA licable 0 N/A A. I. o Location shown on site map o N/A fl'Vt1'L 8. I. c. 8 I. Implementation and enforcement Site conditions imply lCs not properly implemented o Yes ~No o N/A Site conditions imply lCs not being fully enforced o Yes ~No o N/A Type of monitoring (e.g., self-reporting, drive by) ______Frequency ______Responsible party/agency ______Contact ______Name Title Date Phone no. Reporting is up-to-date l~'1-> I:> net i''t;vkdy (cr-~j;cd ~ Yes 0 No o N/A Reports are verified by the lead agency o Yes 0 No o N/A Specific requirements in deed or decision documents have been met ~ Yes 0 No 0 N/A Violations have been reported 0 Yes 0 No J&N/A Other problems or suggestions: 0 Report attached .Dud re.:.inch(;)J(5 c>-V"e.. IL',c...... rlni-fi~· .Nlvc....'t" Cy\J;1ed i]u U!f1 kJT l~ / D. General I. Vandalism/trespassing 0 Location shown on site map $I No vandalism evident Remarks______ 2. Land use changes on site .lKl N/A Remarks Ne 1a....vc1 uS, c.l1lL"'J~ s Itt. ile CCi'·".-tcd 5:"1CC. /4.S L/Zi,'t'-Y'4{,i,'t}?d,', ... ,; 3. Land use changes off site ~ N/A Remarks /J() ~i'H(-,,'~yJ-= k'-+14 '-< &N. Q1f",Vlrd tv... kf'. eel l-Ue"J ~~t·1(t~ lost hl'e -rr. /!IV'"e. J VI. GENERAL SITE CONDITIONS A. Roads .&l Applicable 0 N/A I. Roads damaged o Location shown on site map ~Roads adequate o N/A Remarks,______~ B. Other Site Conditions Remarks /0[.4-- VII. LANDFILL COVERS JlitApplicable 0 N/A A. Landfill Surface 9 I. Settlement (Low spots) o Location shown on site map t;E Settlement not evident Areal extent Depth Remarks j..;()'-l1df.u c.OY{f in ojt1-vV'Ci.L, q-tecl CC"tl{J.'-b-r)", -rtu.... u/c:v.5~·o t.~~.'" Ci.41.J d«-£)maJcd ('IAJ7'I~ );;/1/ !"l.t~{/hspe.cJJI:;?1S j 2. Cracks o Location shown on site map Qi(,Cracking not evident Lengths Widths Depths Remarks 3. Erosion o Location shown on site map 9l Erosion not evident Areal extent Depth Remarks 4. Holes o Location shown on site map ~Holes not evident Areal extent Depth Remarks 5. Vegetative Cover ~Grass ~ Cover properly established ..:Kl. No signs of stress o Trees/Shrubs (indicate size and locations (;m a diagram) Remarks }}.nYu:aJ Y1"",:;; t1jj) (~~'ei'\.ts lkp r(('Tt'd Pf~ ~ fin."nJ; 1'Jj', Hl""/~' dllYJe.1 t1 flu i;;,Jl ~ pi'~,~~ -.JilrlJ'f~ i'<.1.b; hit:- S~ 5~li"vbs pr~~h?I)Bri..- \I.:f~bC~I'Vlt1).IJCLloM'~rith'CtO"!'fiItJ(~;tf-Ct"/et+ te, ..er 6. Alternative Cover (armored rock, concrete, etc.) yw/K u Remarks 7. Bulges o Location shown on site map lfJ Bulges hot evident Areal extent Height Remarks . 8. Wet AreaslWater Damage ~Wet areas/water damage not evident o Wet areas o Location shown on site map Areal extent o Ponding o Location shown on site map Areal extent o Seeps o Location shown on site map Areal extent o Soft subgrade o Location shown on site map Areal extent Remarks 9. Slope Instability o Slides o Location shown on site map ~ No evidence of slope instability Areal extent Remarks B. Benches o Applicable ~N/A (Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channeL) L. Flows Bypass Bench o Location shown on site map 81 N/ A or okay Remarks 2. Bench Breached U Location shown on site map J5'N/A or okay Remarks 10 3. Bench Overtopped o Location shown on site map Zl N/A or okay Remarks C. Letdown Channels o Applicable ~N/A lChannellined with erosion control mats. riprap. grout bags. or gabions that descend down the steep side slope of the cover and will allow the runoff water collected by the benches to move off of the landfill cover without creatiIlK erosion gullies.) I. Settlement o Location shown on site map o No evidence of settlement" Areal extent Depth rfA.· Remarks , 2. Material Degradation o Location shown on site map o No evidence of degradation Material type Areal extent j\! JA Remarks 3. Erosion o Location shown on site map o No evidence of erosion Areal extent Depth /ilIA Remarks , 4. Undercutting o Location shown on site map o No evidence of undercutting Areal extent Depth /II/A Remarks 5. Obstructions Type o No obstructions o Location shown on site map Areal extent Size NIA Remarks 6. Excessive Vegetative Growth Type ~ No evidence of excessive growth o Vegetation in channels does not obstruct flow o Location shown on site map Areal extent Remarks D. Cover Penetrations ~Applicable o N/A I. Gas Vents o Active o Passive /11ritiift:;,*,/ t1~atty- ~Properly secured/locked $1 Functioning ~ Routinely sampled ,g Good condition o Evidence of leakage at penetration o Needs Maintenance o N/A Remarks J:1l -$:-t-JLYC-I?t:V'th·l-n:rhc17. 1I1.~,eri t:(;1'VL'-J.,·{Sh Itil pj{Jd:n(..!~ 12-M1f)/~ a.t;t~ (l'W"'iit·}')M,,U'11' 'Nt. r:M1ik'1.$1.j-f'.(~'li'~i'<~/, k T:<;il~ i:.' i1.-.vierf. Fe ("~ (ocd 5i.ut-~fur·Vi£!.fricr 2. I Gas Mt'lnitoring Probes ?" . ve,r-tiH'6 ~ Properly secured/locked ~ Functioning 0.Routinely sampler-1 )5,t ood condition o Evidence of leakage at penetration o Needs Maintenance o N/A Remarks 3. :\1onitoring Wells (within surface area of landfill) ~Properly secured/locked g Functioning ~Routinely sampled J&Good condition o Evidence of leakage at penetration o Needs Maintenance o N/A Remarks Iv.. ttl '1-2. P12P-. ~h.J P22L a.'t ic(·..}tJ. ~.)'tij ),-ia.i~JfrIL i)C't...t:k" J '~. rsl! e ~1"'it.~L, Vt/,>,/j (j.c:1;~._,;.;f- f,rH.;-EM-t--Jpe.c:h 'en ~...,-,d AA j'.1-pe~.;{e1 fD .1te 1.i('..e.iL up I:::; .-J/zr 11 4. Leachate Extraction Wells o Properly secured/locked o Functioning o Routinely sampled o Good condition o Evidence of leakage at penetration o Needs Maintenance P{N/A Remarks 5. Settlement Monuments o Located o Routinely surveyed )KlN/A Remarks E. Gas Collection and Treatment o Applicable .Kl N/A I. Gas Treatment Facilities o Flaring . o Thermal destruction o Collection for reuse o Good condition o Needs Maintenance Remarks ~ t1.~ is .r~G:~ i:Q ttL.e ,J-rmi.phere. 2. Gas Collection Wells, Manifolds and Piping o Good condition o Needs Maintenance Remarks 3. Gas Monitoring Facilities (e.g.• gas monitoring of adjacent homes or buildings) o Good condition o Needs Maintenance ~N/A Remarks F. Cover Drainage Layer ]15I...Applicable o N/A I. Outlet Pipes Inspected .a Functioning o N/A Remarks 2. Outlet Rock Inspected ~ Functioning o N/A Remarks G. Detention/Sedimentation Ponds jl{'Applicable o N/A I. Siltation Areal extent Depth o N/A ~ Siltation not evident . Remarks S-ecl.{)'VuuJ- oc:n-i ai/eeL- #,J 'wlLd .folr,ue~·(" Pt'eMu1- I'm SE o,,,,hh-t. ~l the s; t-e, i.!> Ji."11 - tieD tpy, it> i'1 'tICfwHlIC1G) F"'i~ {etUl'v'e.:t kC)'VL 1t1ltlirfi {.tV'!?' 2. Erosion Areal extent ' Depth JKl Erosion not evident Remarks 3. Outlet Works J&'[ Functioning .' o N/A Remarks 4. Dam o Functioning .D(N/A Remarks H. Retaining Walls o Applicable ~N/A I. Deformations o Location shown on site map o Deformation not evident Horizontal displacement Vertical displacement Rotational displacement I'.J/It Remarks 12 2. Degradation o Location shown on site map o Degradation not evident Remarks JJ/A I. Perimeter Ditches/Off·Site Discharge IX Applicable ON/A I. Siltation o Location shown on site map ~ Siltation not evident Areal extent Depth Remarks 2. Vegetative Growth o Location shown on site map o N/A ~ Vegetation does not impede flow Areal ex tent Type Remarks 3. Erosion o Location shown on site map ~ Erosion not evident Areal extent Depth Remarks 4. Discharge Structure ftl Functioning o N/A Remarks VIII. VERTICAL BARRIER WALLS o Applicable ~ N/A I. Settlement o Location shown on site map o Settlement not evident Areal extent Depth Remarks ~/A 2. Performance Monitoring Type of monitoring o Performance not monitored Frequency o Evidence of breaching Head differential NJIt Remarks IX. GROUNDWATER/SURFACE WATER REMEDIES MApplicable o N/A A. Groundwater Extraction Wells, Pumps, and Pipelines .J8J Applicable ON/A I. Pumps, Wellhead Plumbing, and Electrical ~ Good condition 0 All required wells properly operating 0 Needs Maintenance 0 N/A Remarks 'T"ft..t,~ ~wa,·h}'Y\.~ +no~IW'_nr: ~ll-':;~WI- en't"_ 7'll'lr,,0t?t"a:n'1d /} t..F/t.S - - ~dSh>;.'W. ?'W "polact~k.~o.rhnI··Hm .' ~.1. d-.<;.".srem .i5 a,tl"it:t1C1hl" in-(ihl .~ V't";J"{"1.waJ.e~ '-fw,Ll.fJ1,~",ul- f 2. Extraction System Pipelines, Valves, Valve Boxes, and Otller Appurtenances ~ Good condition o Needs Maintenance Remarks 3. Spare Parts and Equipment o Readily available 0 Good condition 0 Requires upgrade 0 Needs to be provided Remarks t1tL 11''t'71¥fd.H/Me4· iJU111.Dt~fJ. ~ ...... fJfr... H i, """t-/J",I"-i"I!JJl 1-v.",",~.J...·'lrI SPt'tf'{.,. !JCLV'~ t:.a.-n JU_l')blr.u·~1';''A "l~ ,U¥',. t1..Ii'ct..i1a h I~ (in sib if J1eerledl I V· B. Surface Water Collection Structures, Pumps, and Pipelines o Applicable J&N/A I. Collection Structures, Pumps, and Electrical o Good condition o Needs Maintenance Remarks tJ(.4 2. Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances o Good condition o Needs Maintenance Remarks ;J/It- 3. Spare Parts and Equipment o Readily available o Good condition NIlequires upgrade o Needs to be provided Remarks C. Treatment System a Applicable o N/A rn Re..f!ei"t"'Lt'- to ~ i- FA- S :i(,J.. leWl 1. Treatment Train (Check components that apply) -[j o Metals removal o Oil/water separation )Ia--B ioremediation o Air stripping o Carbon adsorbers o Filters o Additive (e.g., chelation agent, flocculent) o Others Aif :2pj.iJ"f" QflntS ~ Good condition r 0 Needs Maintenance Sampling ports properly marked and functional o Sampling/maintenance log displayed and up to date ~ Equipment properly identified o Quantity of groundwater treated annually o Quantity of surface water treated annually Remarks ·The... f..,f;::A:-S s:...ot:m.f'\CA 1""'t.ofcU'Pd. ftlil D~-J..'Y'lll~tr.erJ~E~JI1" ~ aA1 ! \1. -rhm beeS;s ~- ~ ('rM,..m"&4A4A all'! ~i'iTC""£fR-i' ,."k'J .., ~'lMl.Hi uJdi-evdtl.r ~ d-"CJp n~ 2. Electrical Enclosures and Panels (properly rated and functional) U l' u .. o N/A $l Good condition o Needs Maintenance ;0 Remarks 3. Tanks, Vaults, Storage Vessels DN/A ;;(Good condition o Proper secondary containment o Needs Maintenance Remarks 4. Discharge Structure and Appurtenances o N/A g Good condition o Needs Maintenance Remarks r,1 A·/"h"ttfzht.. ~iev' V. ,-- ../ 5. Treatment BuiJding(s) o N/A )5l,Good condition (esp. roof and doorways) o Needs repair o Chemicals and equipment properly stored Remarks 6. Monitoring Wells (pump and treatment remedy) ~ Properly secured/locked o Functioning o Routinely sampled .& Good condition o All required wells lo~ated 0 Needs Maintenance o N/A Remarks c.1-l~"V'e~;t;ttw Yil·,f- l-~ D. Monjtorjn~ Data I. Monitoring Data ~ Is routinely submitted on time J&.Js of acceptable guality 2. Monitoring data suggests: U0 i~e_p,.;rt-#) f1..Lli e;q;)ft!HLcJ-,C"1'L o Groundwater plume is effectively contained o Contaminant. concentrations are declining 14 D. Monitored Natural Attenuation I. Monitoring Wells (natural attenuation remedy) o Properly secured/locked o Functioning o Routinely sampled o Good condition o All required wells located o Needs Maintenance I&N/A Remarks X. OTHER REMEDIES If there are remedies applied at the site which are not covered above, attach an inspection sheet describing the physical nature and condition of any facility associated with the remedy. An example would be soil vapor extraction. '- () VIi ~ F/~ a..i I' :;pa..v"jt.- ~jO tent.. Ik'lllf.l iruk.:..t.l t!J .fft'~})IJdt:..~Jr.J" /..I/.J.. ,..J..JM. OJ XI. OVERALL OBSERVATIONS fJ1./ A. Implementation of the Remedy Describe issues and observations relating to whether the remedy is effective and functioning as designed. Begin with a brief statement of what the remedy is to accomplish (i.e., to contain contaminant plume, minimize infiltr~tion and gas em~sion,_ etc.). I. _. ~~ - ~,~ t.ta&4£l~£. {::u.,AfmgJ1.i:t-C:P-!tJ.1.!;~~~!YL tUltf4:J,ut.1-71 bi}r].. 41 '::tJ.J. (2 k 1) ~s~~ ~;!', h~ttw V6~t)~ p':';~e ~.ud '::. ,c ttUntJct~~ ""<, .• B. Adequacy of O&M Describe issues and observations related to the implementation and scope of O&M procedures. In particular. discuss their relationship to the current and long-term protectiveness of the remedy. ~ ~ ~ ~ . -~ d Ii c;t . ~~ ,~~~ ~,it~-:::;Jtd:~-~~~ < . ~ta,~!~J- t:\Md ~'-t-t.eA-;"focr~t1I!. m tvYl ,,-,VU1J..LJ:.J ~l_ C. Early Indicators of Potential Remedv Problems 15 Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high frequency of unscheduled repairs, that suggest that the protectiveness of the remedy may be compromised in the future. . !V&-'Vte D. 0 16 ATTACHMENT 7 HAGEN FARM FIVE-YEAR REVIEW SITE INSPECTION APRIL 27, 2011 [This page intentionally left blank] Hagen Farm Five-Year Review Site Inspection, April 27, 2011 Pagel Photo 1-In-situ vapor extraction (ISVE) shed facing Photo 2 - Close-up of ISVE electrical panel northwest. The electrical panel is visible to the left of the shed. Hagen Farm Five-Year Review Site Inspection, April 27, 2011 Page 2 Photo 3 -Interior of ISVE shed which houses the air Photo 4 - risers from underground condensate tank. The compressors. The compressors generate a vacuum which is risers show that there are floats set up to detect condensate transferred to the vapor extraction wells. levels in the tank that trigger automatic shut off of the system. Hagen Farm Five-Year Review Site Inspection, April 27, 2011 Page 3 Photo 5 - Looking eastward from edge of landfill. Monitoring Photo 6 - ISVE gas extraction well EW8, facing northeast wells P22B, P22C and MW 33 are visible in the mid-ground. Hagen Farm Five-Year Review Site iNspection, April 27, 2011 Page 4 Photo 7 - Full view of gas probe GP 13 Photo 8 - View of the inside of GP13 Hagen Farm Five-Year Review Site Inspection, April 27, 2011 PageS Photo 9 - From east edge of landfill facing southward toward Photo 10 - Sign posted on western gate of property line. groundwater treatment building, visible in the background. Similar signs are also posted on the gates located on the east Rip rap is visible in foreground as it extends southward. and north sides, as well as on the main access gate on the south side of the property. Hagen Farm Five-Year Review Site Inspection, April 27, 2011 Page 6 Photo 11 - Facing southeast toward groundwater monitoring Photo 12 - View of one of the bluebird houses installed to well cluster MW26, MW26B, and MW26C. The main road increase the wildlife habitat at the site. There are (County Highway A) is in the background. approximately 6-8 of these houses, as well as several Purple Martin houses on the Site property. • Hagen Farm Five-Year Review Site Inspection, April 27, 2011 Page 7 Photo 13 - View of groundwater extraction well EW2 used Photo 14 - View of well P17C looking southward. Well P17C for the pump-and-treat system. is located on the southern edge of the property line and showed the highest levels of Vinyl Chloride. County Highway A is visible in the background. Hagen Farm Five- Year Review Site Inspection, April 27, 2011 Page 8 Photo 15 - View of air sparge manifolds in treatment plant. Photo 14 - View southward toward main gate. Wingra Redi The lines feed the compressed air from the oxygen generator Mix cement plant is visible across County Highway A and air compressors out into the air sparge points located just beyond the southeast boundary of the landfill. Hagen Farm Five-Year Review Site Inspection, April 27, 2011 Page 9 Photo 16 - Digestion tanks used for groundwater treatment Photo 17 - View of the oxygen concentrator or generator under the pump-and-treat system. which works by bleeding off N02 in order to concentrate the oxygen. The air dryer on the right side contains dessicant to keep moisture out of air to prevent clogging Hagen Farm Five-Year Review Site Inspection, April 27, 2011 Page 10 Photo 18 - View of the two air compressors for the low flow Photo 19 - Blowers used for the aeration of the pump-and air sparge system . The square white units on either side of treat system. The pump-and-treat system is not in use at the the tank are the compressors. The air receiving tank is present time. between the compressors. Attachment 8 Additional Tables Tables 4-7 Table 4 Current Groundwater Monitoring Program - Hagen Farm EW2 .x X X X E IG04 (1) X X A -MWI (1) (1) X A MW7 m x x A MW22 X X X X A MW23 (1) X X A MW26 X X X A MW27 X X X A MW29 m (1) x A MW30 (1) (1) X A MW32 (1) (1) X A MW33 (IT X X A OBSIA X X X X A OBSIB X X X X B OBSIC X X X X B OBS2C X X X X B OB8M ·x X X B OBI1M X x x C P7B X X X C P17B X X X ( Pl?C x x x X B P17DR X X X B P22B X X X ( .P22C (I) X X B P26B X X X C P26( X X X B P27B X X X ( P28B X X X C P28C (l) (1) X ' B P29B (i) (1) x C P29C ( (1) X B P30B ( (I) X C P30C ( (I) X B P32B X X B P33B (1) X X B P35B (1) (1) X B P40D (IT X X B PWIR X D PW2 X Q PW3 X D PW4 X D PW5 X D PW6 X D PW7 X D PW8 X D PW9 X D PWIO X D PWll X D (1) - Water elevation only A - Water table sand or sand and gravel B - Piezometer bedrock C - Piezometer unconsolidated sediment 0 - Private Well E - Groundwater Extraction Well Monthly well samples analyzed for indicators, metals, VOCS and field parameters identified on pages 8-11. Quarterly (May & November) well samples analyzed for indicators, metals, VOCs and field parameters identified on pages 8-11. Semi-annual (February) well samples analyzed for indicators, metals, VOCs and field parameters identified on pages 8-11. Annual (August) well samples analyzed for indicators, metals, VOCs, SVOCs, Pesticides and Herbicides, and PCBs identified on pages 8-11. Current Groundwater Parameter Lists Indicator Parameters - Annual Indicator Parameters - Semi-annual Indicator Parameters - Quarterly Indicator Parameters - Month Hardness-Tolal As CAC03 (Fillered) Sullale-Dissolved Sulfate-Dissolved Sulfale-Dissolved T alai Dissolved Solids (TDS) Alkalinity, Filtered Alkalinity, Filtered Alkalinity, Filtered Total Suspended Solids (TSS) Nilrale+Nilrite-Dissolved Nitrate+Nitrite-Dissolved Nitrate+Nilrile-Dissolved Chloride-Dissolved Sulfale-Dissolved Alkalinity, Filtered Cyanide - Soluble AmmDnja~Dissolved Soluble Tolal Kjeldahl Nilrogen Nilrate+Nitrite~Dissolved Chemical Oxygen Demand-Dissolved Phosphorous-Dissolved Field Parameters - Annual Field Parameters - Semi-annual Field Parameters - Quarterly Field Parameters - Monthly pH (Field) pH (Field) pH (Field) pH (Field) Temperalure (Field Test) Temperalure (Field Tesl) Temperature (Field Test) Temperature (Field Test) Electrical Conduclance (Field) Electrical Conductance (Field) Eleclrical Conductance (Field) Electrical Conductance (Field) Field EH/ORP Field EH/ORP Field EH/ORP Field EH/ORP Color Color Color Color Dissolved Oxygen (D.O.) (Field Tesl) Dissolved Oxygen (D.O.) (Field Test) Dissolved Oxygen (~.O.) (Field Test) Dissolved Oxygen (0.0.) (Field Tes Odor Odor Odor Odor Turbidily Turbidity Turbidity Turbidity Waler Elevalion Water Elevation Groundwater Elevation Groundwater Elevalion Metals - Annual Metals - Semi-annual Metals - Quarterly Metals - Monthly Aluminum, Dissolved Barium, Dissolved Iron, Dissolved Iron, Dissolved Barium, Dissolved Iron, Dissolved Manganese, Dissolved Manganese, Dissolved Calcium, Dissolved Manganese, Dissolved Chromium, Dissolved Arsenic, Dissolved Cobalt, Dissolved Lead, Dissolved Copper, Dissolved Mercury, Dissolved Iron, Dissolved Magnesium, Dissolved Manganese, Dissolved Nickel, Dissolved Potassium, Dissolved Silver, Dissolved Sodium, Dissolved Vanadium, Dissolved Zinc, Dissolved Antimony, Dissolveo Arsenic. Dissolved Beryllium, Dissolved Cadmium, Dissolved Lead, Dissolved Selenium, Dissolved Thallium, Dissolved Mercury, Dissolved VOCs - Annual VOCs - Semi-annual VOCs - Quarterly VOCs - Monthly 1,1,1-Trichloroethane t,t,l-Trichloroethane t,t,l-Trichloroethane Benzene l,I,2,2-Telrachloroetnane 1,1,2,2-1 e\lachloroelhane l,l,2,2-1etrachloroethane Elhylbenzene 1,I,2-Trichloroethane t,I,2-Trichloroethane t,t,2-Trichloroethane Naphthalene I,I-Dichloroelhane 1,l-Oichloroethane l,l-Dichloraethane Tetrahydrofuran I,I-Dichloroelhene l,t-Dichloroelhene 1,1-Dicnloroethene Toluene 1,2-Dibromo-3-Chloropropane 08CP 1,2,4-T richloroben:ene 1,2-0ibramo-3-Chloropropane OBCP Total Xylenes 1 ,2-0ibromoelhane (ED B) 1,2-Dibromo-3-Chloropropane OBCP t,2-0ibromoethane (EOB) Vinyl chloride 1,2-0ichlorobenzene t,2-0ibromoethane (EOB) 1,2-0ichlorobenzene 1,2-0ichloroethane 1,2-Dkhlorobenzene 1,2-0ichloraelhane t,2-Dichloropropane t,2-0ichforoethane t,2-0ichloropropane t,3-Dichlorobenzene t,2-0ichloropropane 1,3-Dicnlorobenzene 1,4-Dichlorobenzene t,3-Dichlorobenzene 1,4-0ichlorobenzene 2-Hexc:tnone t,4-Dichlorobenzene 2-Hexanane Acetone 2-Hexanone Acetone Benzene Acelone Benzene Bromochloromethane Benzene Bromochloromethane Bromoform Bromoform Bromoform Bromomelhane Bromomethane Bromomethane Carbon Disulfide Carbon Disulfide Carbon Oisullide Carbon Tetrachloride Carbon Tetrachloride Carbon Tetrachloride Chiaro benzene Chlorobenzene Chi oro benzene Chloroelhane Chloroelhane Chloroethane Chloroform Chloroform Chloroform Chloromethane Chloromethane Chloromelhane cis-t,2-0ichloroethene cis-I,2-0ichloroethene cis-I,2-Dichloroethene cis-t,3-0ichloropropene cis-t,3-Dichtoropropene cis-t,3-Dichloropropene Oibromochloromethane Dibrornochloromethane Oibromochloromethane Dichlorobromamethane Oibromomethane Dichlorobromomethane Ethylbenzene Dichlorobromomethane Ethylbenzene Methyl Elhyl Ketone Dichlorodifluoromethane Melhyl Elhyl Kelone Methyl Isobutyl Ketone Ethylbenzene Methyl Isobutyl Ketone Melhylene chloride Methyl Ethyl Ketone Methylene chloride Naphthalene Melhyl Isobulyl Ketone Naphthalene Styrene Methylene Chloride Slyrene T elrachloroethene Mefhyl-t-Bufyl Ether (MTBEJ Telrachlaraethene Tetrahydrofuran Naphthalene Telranydrofuran Toluene Styrene Toluene Total Xylenes Tetrachloroelhene Total Xylenes trans-l,2-Dichloroelhene Tetrahydrofuran Irans-1,2-Dichloroethene trans-l,3·0fchroropropene Toluene Irans-1,3-Dichloropropene Trichloroethene Total Xylenes Trichloroethene Vinyl chio(ide trans-l,2-0ichlorcethene Vinyl chloride trans-l,3-0ichloropropene Trichloroethene Trichlorofluoromethane Vinyl chloride SVOCs - Annual 1,2,4-Trichlorobenzene Pesticides and Herbicides - Annual 2,2'-Oxybis(1-Chloropropane) 4,4'-DDD 2,4,5-Trichlorophenol 4,4'-DDE 2,4,6-Trich/orophenol 4,4'-DDT 2,4-Dichlorophenol 2,4-Dimethylphenol Aldrin 2,4-Dinitrophenol alpha-BHC 2,4-Dinitrotoluene alpha-Chlordane 2,6-Dinitrotoluene beta-BHC 2-Chloronaphthalene deUa-BHC 2-Ch!oropheno! 2-Methy!naphthalene Dieldrin 2-Nitroaniline Endosulfan I 2-Nilrophenol Endosulfan II 3 j 3'-Dichlorobenzidine Endosulfan Sulfale 3-Nitroaniline Endrin 4-Bromophenyl phenyl ether 4-Chloroaniline Endrin aldehyde 4-Chlorophenyl phenyl ether Endrin ketone 4-Nilroaniline gamma-BHC (Lindane) 4-Nilrophenol gamma-Chlordane Acenaphthene Acenaphthylene Heptachlor Anthracene Heplachlor epoxlde 8enzo(a)"nlhracene Methoxychlor 8enzo(a)pyrene Toxaphene 8enzo(b)fluoranthene 8enzo(ghi)perylene Benzo(k)fluoranthene PCBs - Annual 8is(2-chloroethoxy) methane PCB 1016 8is{2-chloroethyl) elher PCB 1221 Bis(2-ethylhexyl) phthalate PCB 1232 8utyl benzyl phthalate Chrysene PCB 1242 Cresol, 4,6-Dinitro-O PC81248 Cresol,o- PCB 1254 Gresol, p- PC81260 Cresol, p-Chloro-m Dibenzo(a,h)anthracene Oibenzofuran Diethyl phthalate Dimethyl phthalate Di-n-butyl phthalate Di-n-oclyl phlhalate Fluoranlhene Fluorene Hexachlorobenzene Hexachlorobuladiene Hexachlorocyciopentadiene Hexachloroethane Indeno(I,2,3-cd)pyrene Isophorone Naphthalene Nllrobenzene N-Nitroso-Di-n-propylamine N-nilrosodiphenylamine Penlachlorophenol Phenanthrene Phenol Pyrene Table 5 Proposed Groundwater Monitoring Program - Hagen Farm Samplinl Frequency WelllD Monthly Ouanerlv· Semi-annual Annual Well Type EWIINF E EW2 E IG04 (I) X A MWI 0) X A MW7 -(I) X A MW22 X X X A MW23 (I) X A MW26 X X A MW27 X X A MW29 (I) X A MW30 (I) X A MW32 m X A MW33 (I) X A OBSlA X X X A OSSIB X X X B OBSIC X X X EI OBS2C X X X B 088M X .X El OBIIM X X C P7B X X C PI7S X X C PI7C X X X B PJ7DR X X B P22B X X C P22C (/J X B P26B X X C P26C X X B P27B X X C P28B X X C P2BC (J) X B P29B (J) X C P29C (J) X B P30B (J) X C P30C (I) X B P32B X X B PHS {Jl X B P35B (I) X B P40D (I) X B PWIR 0 PW2 D PW3 X D PW4 X D PWS X D PW6 D PW7 D PWB D PW9 X D PWIO D PWII D (11- Water elevation only A - Water table sand or s,md and gravel 8 - Piezometer bedrock C- Piezometer unconsolidated sediment 0-Private Well E - Groundwater Extraction Welt Quarterlv (MaV & November) well samples analVzed for indicators, metals, VOCs and field parameters identified on page 6. Semi·annual (February) well samples analyzed for indicators, metals, VOCs and field parameters identified on page 6. Annual (August) well samples analvzed for indicators, metals, VOCs, and field parameters identified on page 6. Proposed Groundwater Monitoring Program - Hagen Farm Groundwater Monitoring Points GrouR.! Group B Groupe Group D Group E MW-22 MW26 P29C PW3 OHB OBS1A MW27 P30B PW4 OBS1B OB11M P30C PW5 OBS1C OBBM P33B PW9 OBS2C P17B P35B P17C P17DR P40D DUP P22B MW1 P26B MW7 P26C MW23 P27B MW29 P288 MW30 P32B MW32 P7B MW33 P22C P2BC P29B IG04 Groundwater Monitoring Schedule Monlt!,;!ring Points Frgguenclt Parameters (Protocol) Group A Wells Quarterly A,B,C,D,F,G Group B Wells Semi-annual A. B, C, 0, F, G Annual Group C Wells Annual A,B,C,D,F,G Semi-annual G Group 0 Wells Annual A,B,C,E,F Group E Samples Quarterly A.B Quarterly sampling performed in February, May, August and November Semi-annual sampling performed in February Annual sampling performed in August Private well samples are not filtered. QA/QC samples: Dedicated sampling equipment is in place. therefore the following QA/QC samples are appropriate: Results from 1 duplicate and 1 trip blank wi" be reported for each sampling event. Proposed Groundwater Monitoring Program Parameters Protocol A Protocol B Volatile Organic Compounds (VOCs) Volatile Organic Compounds (VOCs) Method 8260 Selective Ion Methodology (SIM) 1.1,1-Trichloroethane Vinyl chloride 1.1,2.2-Tetrachloroethane 1.1.2-TrichioroethUle I.I-Dichloroethane Protocol C I.I-Dichloroethene Indicator Parameters 1.2,4-Trichlorobenzene Sulfate 1,2-Dibromo-3-Chloropropane DBCP Alkalinity 1,2-Dibromoethane (EDB) Nitrare+Nirrite 1.2-Dichlorobenu:ne 1.2-Dichloroethane 1.2-Dichloroprol'ane Protocol D 1.3-Dichlorobenu:ne Metals 1,4-Dichlorobenu:nc Iron 2-Hexanooc Manganese Acetone Benu:ne Bromoform Protocol E Bromomethaoe Metals Carbon Disulfide Iron Carbon Tetrachloride Manganese Chlorobenzene Arsenic Chloroethane Lead Chloroform Chloromethane cis-I,2-Dichloroelhene Protocol F cis-I,J-Dichloropropene Field Parameters Dibromochloromethane Electrical Conductance Dibromomethane Temperature CC) Dichlorobromomethane pH Dichloroditluoromethane Field EhlORP Ethylbenzcnc Dissolved O"ygcn (D.O.) Methyl Ethyl Ketone Color Methyl Isobutyl Ketone Odor Methylene chloride Turbidity Methyl-I-Butyl Ether (MTBE) Naphthalene Styrene Protocol G TClrachloroedrene Water Elevation (ft. MSL) Tctrahydrofuran Toluene Total Xylene! trans-I,2-Dichloroethene crans-I.3-Dichloropropene Trichloroethcne Tnchlorotluoromethane Viny I chloride Table 6 Distinguishing General Water Chemistry Criteria (mg/L) Predominant Redox Fe(III)- from FE2/H2S Redox Comments Process S04(2-)- Ratio Category Reduction 02 N03 MN2 FE2 S04 Oxic 02 reduction ~ 0.5 < 0.05 < 0.1 Suboxic Further definitions of redox processes not < 0.5 < 0.5 < 0.05 < 0.1 possible Anoxic N03 reduction < 0.5 ~ 0.5 < 0.05 < 0.1 MN4 reduction < 0.5 < 0.5 ~ 0.05 < 0.1 FE3/S04 reduction FE3 reduction < 0.5 < 0.5 ~ 0.1 2: 0.5 > 10 Mixed FE3-S04 < 0.5 < 0.5 ~ 0.1 ~ 0.5 ~ 3, ~ 10 S04 reduction < 0.5 < 0.5 ~ 0.1 ~ 0.5 <3 Methanogenesis < 0.5 < 0.5 ~ 0.1 < 0.5 Criteria for more than one redox process Mixed are met This table is copied from Chapelle et al. (2009), Table 1. Table 7 Dissolved Oxygen Results - Groundwater Monitoring Program Hagen Farm Site - Town of Dunkirk, Dane County, Wisconsin Frequency I 2010 Sample Point January February March April May June July August September October November December \ Quarterly MW26 6.8 5.1 2.8 5.1 MW27 4.4 5.9 3.5 4.8 ~ OB11M 10.5 5.3 2.3 2.9 OB8M 3.4 5.2 1.3 11.5 P17B 8.5 6.5 4.7 6.6 P17DR 13.2 9.6 12.6 16.3 P22B 6.6 4.8 0.8 4.7 P26B 10.7 7.6 7.2 6.7 P26C 11.3 8.5 7.3 10.7 P27B 8.9 3.5 4.7 2.6 P28B 9.3 1.4 1.9 3 P32B 11.4 5:8 3.3 3.7 P7B 4.5 4.5 1.7 3.3 Semi-Annual IG-04 12.3 6.5 MW23 10.3 2.1 MW33 11.6 2.9 I MW7 9.7 4.1 P22C 16.9 12.5 P33B 13.1 4.6 P40D 12.2 4.2 .. Note: Results reported In mg/l (milligrams per liter) Prepared by: GK Checked by: GS 8T SQUARED Project #3821 , Dissolved Oxygen Results - Groundwater Monitoring Program Hagen Farm Site - Town of Dunkirk, Dane County, Wisconsin Frequency I 2010 Sample Point January February March April May June July August September October November December Annual , MW1 8.1 MW29 7.4 MW30 1.3 MW32 4.2 P28C 5.5 P29B 5.3 P29C 5.6 P30B 3 P30C 11.4 P35B 4.6 Monthly EW11NF 9.3 8.9 9.5 5.7 9.1 9 9.4 7.9 7 8.2 9.6 7.4 EW2 9 10 9.2 8.1 10.3 10.2 9.1 9 6.6 7.3 9 8.2 MW-22 6.2 8.9 7.9 6.6 9.3 8.2 9.7 5 7.2 6.4 7.5 8.3 OBS-1A 8.5 8.2 7.8 5.3 9.1 6.5 5.5 4.7 4.6 4.6 3.6 4.4 OBS-18 12.1 13.9 12.9 9.3 8.5 10.8 8.4 10 10.5 10.8 14.5 12.3 OBS-1C 5.6 6 4.1 2.1 3.9 1.7 1.5 2.5 2.8 3.4 4.8 6.8 OBS-2C 11.2 17.4 12.7 9.4 9 11 12.8 8.3 10.7 12.4 12.4 13.7 P17C 3.4 5.2 5.3 1.6 3.7 1.9 0.8 1.2 1.9 2.1 2.8 2.7 I Note: Results reported in mg/l (milligrams per liter) Prepared by: GK Checked by: GS BT SQUARED Project #3821 Appendix EPA Region 5 Records elr. 111111111111 263849 VUM. n 11 C ~ J\\§ ~ ~ WASTE MANAGEMENT U ;I Closed Sites Management Group " • . N96 WIJ600 Counry Lme Road JUN 1;j ~006 Germantown, Wisconsin 53022 June 9, 2006 (262) 253·8626 Emergency Enforcement (262) 255·3798 Fax Services Section Mr. Ross del Rosario Remedial Project Manager U.S. Environmental Protection Agency Region 5 77 West Jackson Boulevard Chicago, IL 60604-3590 Re: Hagen Farm Institutional Control Study Dear Mr. del Rosario: Enclosed is a report titled "Institutional Control Study" for the Hagen Fann Superfund site as requested in your April 19,2006 letter. We have answered your inquiries to the best of our ability based on the infonnation in our files. If you require additional information or have any questions, please do not hesitate to call me at 262-532-4024. Sincerely, Waste Management of Wisconsin, Inc. -)-l1.A<.~·' L. Illr?-/S-c'Y- Michael L. Peterson, P.E. Project Manager - Closed Sites Enclosures cc: Gary Edelstein - WDNR Jeffrey Cahn - USEPA - wlo enclosures Lisa Zebovitz INSTITUTIONAL CONTROL STUDY 1. Current Map of Restricted Areas (areas that do not support unlimited use and unrestricted exposure): Provide map(s) that identify the current boundaries of the restricted areas (areas that do not support unlimited use and unrestricted exposure), boundaries of areas covered by exiting ICs, boundaries of the Site, streets, easements, encumbrances, property ownership, assessor's parcel number or other recorded plat or survey information. Waste Management of Wisconsin, Inc. (WMWI) has completed an updated survey of the site. An updated site map is enclosed. Deed restrictions have been placed on all the property owned by WMWI at the Hagen Farm site. The fenced-in area represents the area where remedial activities were conducted pursuant to the Record of Decision. The following is a list of parcels owned by WMWI: 0511-103-8905-0 0511-103-8000-7 0511-103-9500-0 Note that parcel 0511-103-8905-0 is within the fenced area of the site but is not impacted or part of the remediated area. 2, GIS Information: Provide Geographic Information System (GIS) coordinates that shows the current boundaries of restricted areas (areas that do not support UUIVE), areas covered by existing institutional controls, boundaries of the Site, easements and other encumbrances. Identify the accuracy of the coordinates (i.e. within 0.01 feet). Please format the coordinates of the restricted areas, areas covered by existing rcs and Site boundaries into an ESRI polygon-shape tile. The shape file shall be projected into the UTM, NAD 83 projection system. Please identify the UTM zone. Provide an attribute name in the shape file for each polygon submitted. For example: "site boundary", "no restrictions", "recreational only", "industrial only." Attached is a copy of the coordinate data for the wells, fencing and building at the site, in NAD 83 format. A revised site map is also enclosed as indicated above. The restricted area is within the fenced area. 3. Documentation on Existing Proprietary Controls: Provide copies by the Recorder of Deeds (or other appropriate land records office) showing clerk's recording stamps of existing proprietary controls (environmental restrictive covenants/easements etc.) for the restricted areas. Provide map and GIS infonnation that depicts the boundaries of the restricted area covered by the existing proprietary control, streets, easements, property o"Ynership and parcel numbers. Copies of deed restrictions are attached in the ALTA Commitment. All of the property owned by WMWI at the Hagen Farm site is subject to these deed restrictions. The electrical easements to the bomes are probably no longer applicable as tbe homes have been removed. 4. Legal Assessment of Existing Proprietary Controls a. Title Evaluation i) Obtain from a title company a title insurance commitment using ALTA Commitment fonn 1982 as amended "for information only purposes" for the restricted areas. Include copies of documents referenced in the title commitment. Include copies of encumbrances, utility right ofways, leases and subleases impacting restricted areas. ALTA Commitment is attached. ii) Does the title commitment identify/exempt existing proprietary controls for restricted areas? Yes. iii) Provide map and GIS information that identifies parcel numbers and boundari~s of current encumbrances (such as utility easements) that impact restricted areas. Discuss efforts to obtain subrogation agreements for such encumbrances. Include copies of SUbrogation agreements that have or will be obtained for such encumbrances. The ALTA Commitment identifies the easements which affect the property owned by WMWI. Tbe restricted area does not appear to be impacted by any of tbe easements otber tban tbose installed as part of tbe remedial action (private water and sewer systems). b. Other Assessment: Assess whether existing proprietary controls have been executed in a legally enforceable manner. Discuss whether a grantee or prior owner "holds" the proprietary controls. Discuss whether the current owner is under an obligation for compliance with the land and groundwater restrictions described above. Discuss whether existing proprietary controls "run with the land" (i.e. restrictions are binding on subsequent property owners). Discuss whether existing proprietary controls implement the Ie objectives/perfonnance standards described above. Assess whether the boundaries of the area covered by existing proprietary controls match the boundaries of restricted areas based on current information. WMWI is the current owner of the property and is responsible for operation and maintenance of the remedial actions completed at the site. A review of the deed restriction indicates that they run with the land. The deed restrictions apply to all the property owned by WMWI at the site. The restricted area is a smaller area than the property boundary. 5. Documentation on Government Controls: Identify and provide a current, dated and official copy of existing governmental controls [ordinance, statutes etc.] that implement the IC objectives/performance standards for the restricted areas described above. Discuss whether the governmental control restricts all areas of unlimited use and unrestricted exposure at the Site. Does the governmental control contain a figure showing the current boundaries of the restricted areas based on the most recent information? Wisconsin Department of Natural Resources (WDNR) regulations prohibit installing a water supply well in a known contaminated aquifer or within 1,200 ft. of a landfill, unless WDNR grants a variance. Enforcement of the water supply well prohibition is dependant on the property owner or well driller contacting WDNR prior to weJJ iDstaJJation. To our knowledge no new wells have been installed except for a replacement well on the Sundby property. The Hagen Farm site is listed as a Superfund Site on the WDNR database which is reviewed in conjunction with the permitting of new water supply wells. 6. Discuss compliance with Institutional Controls: Discuss whether the property is being used in a manner consistent with the restrictions. Summarize results of site inspection and interviews with owners, lessees and other holders of property interests. Are owners, lessees and other holders of property interests aware of and complying with the restrictions? Has land use or expected land use on or near the site changed? Are there any new developments, either constructed or planned, in the area? Are there any new construction permits pending? Does the property owner have any plans to sell or transfer the property? Tbe Institutional Controls are functioning as anticipated. Tbere are no signs of trespass onto tbe facility. Only one new bouse bas been built and is approximately Y. mile east of the site. It is unknown if a water well permit for tbe house was requested. WMWI sold a portion of tbe property on tbe west side of tbe site to a developer. The sales agreement required city sewer and water be provided for any future development. 7. Assess Monitoring: Discuss how, when and by whom compliance with the institutional controls is monitored. Discuss whether the results of the IC monitoring are routinely and promptly shared with EPA and the State. Discuss whether there are measures in place to ensure that modifications to the restriction require EPA and the State approval. RMT, WMWl's Consultant, is onsite at least once a month to conduct maintenance on tbe GCOU and SCOU treatment systems. Tbe site is cbecked for any signs of trespass. WMWI also conducts periodic inspections of the site. Tbis inspection includes checking tbe fencing and surrounding areas for unusual condition or activities. 8. Discuss effectiveness of Institutional Controls: Discuss whether existing Ies are preventing exposure. Discuss whether there is potential human or ecological exposure. Discuss whether land and/or resource use has changed since execution of the ROD. If so, what are the plans regarding property's ICs. Discuss how the current land and resource uses relate to exposure assumptions and risk calculations. Discuss whether there are any unintended consequences resulting from the use of a particular restriction. Assess whether the controls are effective in the short term in maintaining land/groundwater restrictions above, maintaining performance standards and preventing exposure. Assess whether the controls will be effective in the long tenn in maintaining the land and groundwater restrictions above, maintaining remedy perfonnance standards and preventing exposure. The institutional controls are functioning as intended. There have been no signs of trespass or use of the site that would impact human health or the environment. There have been no changes to land use since execution of the ROD, except for a portion of buffer land being sold to developers. As discussed above, the sales agreement requires city sewer and water be provided for future development. The controls prohibit any groundwater use that could cause exposure to humans or animals. They also restrict any activity which might interfere with the remedial work as well as other intrusive activities. These controls are effective and should continue to be effective in maintaining land and groundwater restrictions, maintaining remedies, performance standards and preventing exposure. 9. Recommendations: Propose any corrections to existing institutional controls that are necessary to ensure that the land and groundwater use restrictions described above are implemented correctly, are maintained and wil1 be protective in the short term and the long term. Propose controls for remaining areas that do not support unlimited use and unrestricted exposure but are not covered by existing controls. Include a title commitment for any proposed proprietary control. Propose subrogation agreements for any encumbrance that negatively impacts restricted areas. Propose monitoring requirements and modifications to the Operation and Maintenance. Plan to ensure that Ies are maintained and complied with in the short term and in the long term. The monitoring plan must include a schedule and an annual certification to EPA that les are in place and remain effective. No changes necessary. Hagen Farm Site Well Data 5/25/06 WELL 10 Northing Easting Ground Top of Casing Top of PVC AS 01 331844.7 2186876.6 870.25 874.24 873.80 AS 02 331865.4 2186920.5 869.29 872.98 872.61 AS 03 331883.9 2186977.0 866.91 870.30 869.92 AS 04 331914.8 2187028.5 867.49 869.29 868.89 A.S 05 331943.2 2187081.5 867.95 871.43 871.24 AS 06 331973.6 2187137.8 865.95 869.24 869.19 AS 07 331850.5 2186906.8 869.16 872.87 872.86 AS 08 331860.8 2186954.6 867.24 870.61 870.63 AS 09 331911.0 2187003.2 867.57 870.12 870.18 AS10 331922.3 2187059.8 867.66 870.01 867.64 GP1 332130.3 2186923.8 884.94 887.83 GP2 332096.2 2186913.0 885.19 887.91 GP3 332052.7 2186903.6 884.72 887.53 GP4 332023.8 2186895.4 884.40 887.29 GP5D 888.05 GP5M 332145.0 2186916.5 885.36 888.32 887.91 GP5S 887.51 GP6 332167.5 2186882.8 886.64 889.21 GP7 332194.5 2186841.4 888.12 890.81 GP8 332221.1 2186799.8 888.59 891.39 GP9 332294.5 2186756.3 888.38 892.28 GP10 332295.2 2186918.4 885.69 889.31 GP 11 332275.8 2187071.2 879.19 883.19 GP12 332267.3 2187063.6 879.27 883.49 GP13 332242.4 2187037.6 880.36 884.11 GP14 332219.5 2187016.6 880.21 883.88 GP15 332212.4 2187008.0 880.59 884.27 GP16 332288.1 2187129.7 871.30 874.40 GP17 332169.5 2186755.0 887.98 891.90 GP18 332163.6 2186972.1 883.41 886.98 GP19 332021.9 2186792.6 887.04 890.80 GP20 332009.7 2187042.3 870.59 874.53 GP 21 332147.9 2187113.8 869.63 872.77 GP22 331894.4 2186938.7 869.97 874.09 GP23 331847.7 2186801.7 874.53 878.54 GP24 331979.5 2186669.5 882.23 885.85 GP 25 332168.6 2186664.7 883.10 886.79 GP 26 332333.2 2186670.0 885.42 889.24 GP27 332553.7 2186748.2 881.90 885.70 GP28 332640.1 2186942.6 876.76 880.44 GP 29 332482.9 2187089.0 875.54 879.62 113 04 332662.8 2187160.3 872.41 875.43 874.86 Horizontal datum is NAD 83 Vertical datum is NAVD 88 Hagen Farm Site Well Data 5/25/06 WELL ID Northing Easting Ground Top of Casing Top of PVC IG 01 332743.0 2187224.9 874.31 877.49 876.79 IG02 332822.4 2187176.0 876.03 878.92 878.45 IG 03 332742.1 2187124.7 876.61 879.81 879.07 MH north 331863.0 2187127.7 866.22 MH south 331858.6 2187126.8 866.14 MW7 332269.4 2187157.5 875.66 877.96 877.32 MW22 332036.0 2187006.2 880.00 883.62 882.95 MW23 332184.3 2186650.2 885.00 889.50 889.25 MW26 331823.2 2186581.3 881.79 883.96 883.76 MW27 331330.4 2186837.4 870.18 872.84 872.38 MW28 331998.7 2186601.8 862.03 865.21 MW30 331453.5 2187067.8 866.50 869.50 869.35 MW32 330421.4 2186594.3 858.02 861.36 860.93 MW33 331819.8 2187253.6 864.30 " 866.97 866.71 MW35 329815.4 2186671.0 861.89 865.30 865.04 OB 11M 331076.8 2186686.5 867.53 869.84 869.48 088M 330012.0 2186198.6 860.71 863.78 863.54 OBS1A 331815.5 2186976.8 866.69 869.82 869.23 OBS18 331821.4 2186977.1 866.61 869.85 869.25 OBS1C 331819.4 2186971.3 866.23 869.68 869.38 aBS 2C 331534.8 2186872.9 863.65 865.93 865.81 P7B 332267.3 2187157.0 875.78 877.89 877.63 P8 north 332031.8 2187108.9 869.19 871.10 P8 south 332026.7 2187107.6 869.13 871.26 P 17B 331629.9 2186978.6 863.22 865.79 865.27 P 17C 331633.4 2186969.5 863.63 867.34 866.98 P 17DR 331693.3 2187012.5 863.31 865.81 865.46 P228 332048.8 2186996.8 880.91 884.09 883.93 P22C 332057.3 2187002.8 881.14 884.26 883.84 P 268 331826.8 2186587.5 883.96 883.74 883.29 P 26C 331832.8 2186585.4 881.75 883.95 883.80 P 27B 331336.0 2186826.1 870.13 872.64 872.19 P 288 330995.2 2186621.6 861.90 864.28 864.01 P 28C 331002.9 2186615.9 861.38 863.43 863.24 P 30B 331449.0 2187073.6 866.68 868.85 868.26 P 30C 331453.9 2187078.9 866.44 867.89 867.23 P328 330424.7 2186585.8 857.55 860.68 860.41 P 33B 331822.5 2187244.0 864.14 866.90 866.44 P 358 329809.8 2186669.3 861.73 865.16 864.78 P40D 331763.5 2186756.1 875.73 878.77 Horizontal datum is NAD 83 Vertical datum is NAVD 88 NAD 83 Coordinate Values of Fence Point Nos. NorthinQ§ Eastings Elevations Code 2017 332863.61100 2187293.50900 874.72000 fence 2018 332863.55300 21 B6656.68200 884.93000 fence 2019 332572.65800 2186657.13200 895.77000 fence 2022 331444.24600 2187292.54700 866.52000 fence 2023 331530.28300 2187126.18800 865.71000 fence gate 2024 331541.19200 2187105.38800 865.52000 fence gate 2026 331885.61800 2186426.61200 879.37000 fence 2028 332570.68600 2186444.68200 899.59000 fence ; ...... ,'.. ' : . ::-,,~,:,:,. .:: '.::''':.- .. :. -'-.-: ~ .. '-., ...... ~....-: ..-.~ :':.-.~.;": .. : ~:';':"':-:':'-:- .... , ':':' '.~".: :;~.; '.":.: "-: -' .; : ',",.,' ...... ' -." .. ~.: . :. '. ' .'.' . , A. L T. A. COM MIT MEN T Chicago Title Insurance Company SCHEDULE A Prepared for: CHICAGO TITLE INSURANCE COMPANY cc: NBUII0202601164 171 N. C~ ST., t04ND CHICAGO, IL 60601 Attention: KATIE MORAN Commitment No.: Office File No.: Effective Date: C-165017-A May 15, 2006 at 5:59 A.M. 1. Policy or Policies to be issued: Ai..TA OWNER'S POLICY - 1992 Amount $ 1.00 Proposed Insured: ALTA LOAN POLICY - 1992 Amount $ ------Proposed Insured: 2. TItle to the fee simple estate or Interest In the land described or referred to In this Commitment Is at the effective date hereof of record in WASTE MANAGEMENT OF WISCONSIN. INC. 3. The land referred to ;n Ihls Commitment Is described as follows: (See "EXHIBIT A" attached hereto and ~de a part hereof) Dane County Title Company 901 S. Whitney Way, Madison, Wisconsin 53711 (608)271~2800, (608)271~883~ Fax, (800)626-9735 Toll Free, www.danecountytitle.com ' ...... UEXHIBIT An Chicago Title Insurance company OfflCa File Number: Commitment Number: c-155017-A PARCEL I: Lot One (i) of Certified Survey Map No. 10610 recorded in the DANE COUNTY, Wisconsin Register of Deeds Office in Volume 63 of Certified SUrvey Maps, page 34, as Document No. 3604254, in the Town of Dunkirk, Dane County, Wisconsin. TAX ROLL PARCBL NUMBER: 026-0511-103-8905-0 PARCEL II: The East 1/2 of the Southwest 1/4 of Section 10, Township 5 North, Range 11 East, in the Town of Dunkirk, Dane County, Wisconsin, except that part lying South of County Trunk Highway "A", TAX ROLL PARCEL NUMBERS: 026-0511-103-8000-7 026-0511-103-9500-0 EXHIBIT A ...... ''''::' ~..;.">, ..... ',':.. '.:"::' ...• :- ::.~;:<.:-:.:.::. '. :.•.. :.,": ..:...... : .::':,":~. A. L T. A. COM MIT MEN T Chicago Title Insurance company SCHEDULE B - SECTION 1 Offfce File Number: Commitment Number: C-165017-A Raqulremen1s The following are the requirements to be complied with: a. Payment to or for the account of the grantors or mortgagors of the full consideration for the estate or interest 10 be Insured. b. Payment to the Company of the premiums, fees and charges for the policy. c. Proper instrument(s) creating the estate or Interest to be insured must be executed and duly filed for record, to wit: NONE * .... *** ...... PARCEL I: 2005 net real estate taxes: $ 9.96 (paid in full) PARCEL II: 2005 net real estate taxes: $ 200.93 (paid in full) 2005 net real estate taxes: $ 84.69 (paid in full) SCHEOUU; B· Sec:Uon 1 .', ~- , " , ~,' ...... '.,. '., " ..... :-:.. , : ~ ;.' :.' . A. L. T. A. COM MIT MEN T Chicago Title Insurance Company SCHEDULE B- SECTION 2 Office File Number: Commitment Number: C-165017-A Exceptlona The policy or pollolee 10 be le9ued will conteln exceptJons 10 the followIng unless the same lire dIsposed of 10 Ihe satlsfacllon 01 the Company. 1. Defects, liens, encumbrances, adverse claim. or olher matters, If any, created, first appearing in Ihs public recorde or atlaohlng subsequenllo the eHectlve dale hereof bul prior to the date the proposed Insured acquIres for value 0' record the estate or Inlersst or mortgage thereoo covered by thill Commitment. NOTE: exception 1. will be removed only" no Intervening matlers appear of record between thllllffec~ve dale of this commlbnent and the recording of thelnBlrumenls called lor at item (0) 01 Schedule B-1, or if e gap endorsement lal88Ued In oonJuncUon wllh this oommlQnlHltand fle requlramenta for the Issuance ot 'gap' coverage 8S describsd In ths endorsement are met, InckJdlng the payment 01 the premium. 2. Special lIIlIea or 118BB6IIments,1f a~ NOTE: exception 2. will be removed only if the Company racelvea wril18n evidence from the munlcipaUty Ihatthare are no special assessments agalnllt the land, or thai all suc:h llema have bean paid In fuY. S. Liens. hook-up ·chargee or lee8, deferred chargee, reserve capaolty assessmenta, Impact fees, or olher charges or fees due and on the development or Improvement of the land, whether assessed or oharged before or after the Dale of the PoRcy. The Company ausures ths prforHy of the lien of the Insured mortgage over any suah lien, chargee or fee. NOTE: Exc:epUon 3. will bil femoved only II the Company rseelves (') written evidence from the municipality that there are no deferred charges, hookup feea, or other 1888 or charges attaching to the property; (2) evidence that the land contains a camp/eled buildtng; and (3) a stalement showing \hal tha land haa a waler and sewer Uge account If the land 19 Vllcant, this exception will not be removed. 4. Any lien, or right to a lien, 'or 8i1rvlcae, 'abor, or material herelofore or hereafter furnished, Imposed by law and not shown by the publlo rSOtlros. NOTE: ExcI/PUon 4. w~I be removed only If the Company recslvN the Conalruction WOI1c and Tenants Affidavit on the form fumished by Ule Company and tho following III true: NO WORK DONE: The Afljdev~ must establish that Ulera ha" b...." no nenable conatnJctlon work In Ule previous six monlhs. REPAIR WORK DONE: If repelrwork haa b"n dona on an axlBtlng al!ucl\Jraln the last elK months, the affidavit must aooura/ely dlsclO8B all partiee wllo hav.. dohe lienable work In the 1a8t ail< months, and lIave altaohed to It original full waIve", of Uen from eaoh person orcompan)r NEW CON!,TRUCTION: If Iha proparty contaIns a newly-built sbuolure, \he Affidavil musllnoorporale a oomplele \lsI 01 aU parties who hllve done Uenabla work In the lasl6ll< montha, and have altached to It original fuU waivers 0' lian from each person or company. II Excepl/Oll .,. la removed, It wUI be replaced by Ihe following BlIceptlon: 'Any construction lien claIm by a party not shown on \hs Conslruclion Work and Tenants A//ldavit supplied 10 th.. Company.' 5. Rights or claims of parties In pcS88ssion not shawn by the publlo feooi'dS. NOTE: Exo!!pifon 5. will be removed only it the Company receives l/1e ConstnJction Work and Tenanls Affldavft 011 the form furnIshed by the Company. If the attld8vlt showa that there lire tenants, exception a. will ba replaced by an alCceptlon for tha rights of Iha tenants dia:losed by the Alndavlt. 6. Encroachments. overlaps, boundary Hne dleputss, and any other matl&r8 which would be disclosed by an aCCUIa!1I SUl\llly and Inspection of the premises. SCHEDULE B. SKtlon 2 paga1 ,::":.:';':;':: .... -...... ::~ .• :-.. :-•.•..: .....' .. : .. "~,: ...... ~ ' :'.~"",-:",::.: ...... :...... ,.,: .. ", ..... : ...... "':.' A. L T. A. COM MIT MEN T chicago Title Insurance Company SCHEDULE B • SECTION 2 Office File Number: Commitment Number: C-165017-A Excepdons (oontlnued) 7. EaaemenlB or claims of Bal!6menls not shown by publlo r8OOrda. S. Any claim of advel8e po888as1on Dr prescripUve easement. NOTE: Exception 6. 7. & 8. will be removed only II the Company receives an orlginalautVey which (1) has a current date, (2) Is sattsfactory to the ComJl8.ny, and (3) complies with currentALTAlACSM Minimum Survey Standards or Wisconsin Administrative Code AE-7. If the survey shows mat1ers which affect the Ulle 10 the property, Exceptions f. g. & h. will be raplacad by exceptions descrtbing Ihose matiere. 9. General and epeolallaxes lor the year 2006 and aub89quent years. 10. Public or private rights, if any, in such portion of the subject premises as may be presently used, laid out or dedicated in any manner whatsoever, for street, highway or alley purposes. 11. Easement, Restrictions and conditions contained in instrument recorded on March 18, 1954, as Document No. 869614. 12. Right of Way contained in instrument recorded September 13, 1949, as Document No. 785973. 13. Easement contained in instrument recorded on October 21, 1965, as Document No. 1145371. 14. Easement contained in instrument recorded on June 20, 1974, as Document No. 1401538. 15. Easement contained in instrument recorded on August 30, 1977, as Document No. 1535850. 16. conditions contained in Affidavit recorded on August 18, 1981, as Document No. 1716619. 17. Deed restriction and conditions recorded on May 15, 1991, in Volume 15889 of Records, page 36, as Document No. 2262327. lB. Deed restriction and conditions recorded on August 26, 1991, in Volume 16585 of Records, page 1, as Document No. 2284942. 19. Deed restriction and conditions recorded on January 4, 1993, in Volume 24133 of Records, page 13, as Document No. 2428937. 20. Approval Document recorded on August 8, 1995, in Volume 30508 of Records, page 65, as Document No. 2694911. 21. Covenants and Conditions contained in Private Sewage System Maintenance Agreement recorded on October 5, 1995, in Volume 31005 of Records, page 15, as (See continuation attached hereto.) SCHEDULE e· 6ectlon 2 page 2 ...:....::...... : ..... :'...... ".;.:.,'...... , ...... : ...... ''':'';': . .. ":.. :- ..... : .... : .... A. L. T. A. COM MIT MEN T Chicago Title Insurance Company ContinuaUon of Schedule B-2 Office File Number: Commitment Number: C-165017-A Document No. 2709319. 22. Any law, ordinance or governmental regulation relating to environmental protection and the effect of any violation thereof unless notice of a lien, defect or encumbrance resulting from a violation has been recorded in the office of the Register of Deeds prior to the dAte of this commitment. 23. Rights of tenants under unrecorded leases, if any. Schedule B-2 of this Policy consists of 3 pages. ConlinuaUon A. L. T. A. COM MIT MEN T Chicago Title Insurance Company SCHEDULE A Prepared for: CHICAGO TITLE INSURANCE COMPANY cc: NBU#020260ll64 171 N. CLARK ST., #04ND CHICAGO, IL 60601 Attention: KATIE MORAN Commitment No.: Office File No.: Effective Dafe: C-165017 March 31, 2006 at 5:59 A.M. 1. Policy or Policies to be issued: ALTA OWNER'S POLICY ·1992 Amount $ 1.00 Proposed Insured: ALTA LOAN POLICY - 1992 AmountS ------Proposed Insured: 2. Title to the fee simple estate or interest in the land described or referred to in this Commitment is at the effective date hereof of record in WASTE MANAGEMENT OF WISCONSIN, INC. 3. The land referred to in this Commitment 19 described as follows: Lot one (1) of certified Survey Map No. 10610 recorded in the DANE COUNTY, Wisconsin Register of Deeds Office in Volume 63 of Certified Survey Maps, page 34, as Document No. 3604254, in the Town of Dunkirk, DANE COUNTY, Wisconsin. TAX ROLL PARCEL NUMEER: 026-0511-103-8905-0 Dane County Title Company 901 S. Whitney Way, Madison, Wisconsin 53711 (608)271-2800, (608)271-883~ Fax, (800)626-9735 Toll Free, www.danecountytitle.com A. L. T. A. COM MIT MEN T chicago Title Insurance Company SCHEDULE B - SECTlON 1 Office File Number: Commitment Number: c-165017 Requirements The following are the requirements to be complied with: a. Payment to or for the account of the granlor8 or mortgagors of the full consideration for the estate or interest to be insured. b. Payment to the Company of the premiums, f?es and charges for the policy. c. Proper instrumenl(s) creating the estate or interest to be insured must be execuled and duly tiled for rectlrd, 10 wit: NONE ...... 2005 net real estate taxes: $ 9.96 (paid in full) SCHEDULE B· Section 1 A. l. T. A. COM MIT MEN T Chicago Title Insurance Company SCHEDULE B - SECTION 2 Office File Number: Commitment Number: C-165017 ExcepUons The policy or poJlcies 10 be issued will conlain exceptIons 10 the 'ollowing unless Ihe same are disposed 0110 the 9alislacUon 01 the Company. 1. O"lecls. "ens. encumbrancea, adverse clalma or olher mallera, II any, crealed, IIrst appearing In the publlo recorda or aUachlng subsequent to the ellective date hereol bul prIor 10 the dale the proposed Insured acqulre8 lor value 01 record Ihe satata or Interest or mortgage thereOll oovered by this Commitment. NOTE: ExcepUon I. will be removed only il no Inlervening mattera appear 01 record between Ihe ellecllve date ollhls commitment and Ihe recording 01 the instruments called for at Item (e) 01 Schedule B-1. or If • gap endorsement Is Issued In conjunction wit" this commitment and "e reQUirements for the l88Uance of ·gap· OOI/e18g8 as deSClibed In the endoll!ement are mel, r.clxIlng !he payment of the premium. 2. Special taxes or a_88menls, if any. NOTE: Exception 2. will be removed only il the Company receives written Itvldence Irom Ihe municipality Ihal there are no apeclal aSS9asments against the land, or that all such items have been paid In lull. 3. Uens, hook-up charges or fees, delerred charges, reserve capacity assessments, impact fees, or other charges or Ieee due and on the development or Improvement of the land. whether assessed or charged belore or IIHer the Date 01 the Policy. The Company aSSlll"eS the priority 01 the lien ot tile Insured mortgage over any such lien, charges or lee. NOTE: Exceplion 3. will be removed only if the Company receive" (1) written evidence from the municipality thet there are no deferred chargee, hookup fe8.9, or other feea or charges altachlng 10 the property; (2) evldence thaI the land contains a completed building; and (3) I!I etalement showing that ths land haa II water and sewer use llcoount. lithe land is vacant. Ihls exception will nol be removed. 4. Any lien, or right to a lian, for services, labor, or mllterlal heretolore or hereafte, lurnished, imposed by law and nol shown by the pUblic records. NOTE: Exceplion -4. will be removed only Illho Company receives tho Conslructlon Work and Tenanl8 Afflclavil on tho lonn tumi8l1ed by the Company and the tollowing Is lrue: NO WORK DONE: Ths Affidavit musl salab."" thaI there hae been no lienable conlllrucUon worle tn the prell10uB six months. REPAIR WORK DONE: If repair work has been done on an axisbng BlruclUl'8ln ths laslsll! monlhll, the afftdavit must acourstely dISclose all partlss who have done lienable work In the Isst Bill months, and haye attachad to it original full walvers 01 lien lrom each pSr9 NEW CO NSTRUCTION: 11 Ihe property contalne a newly-built stnJcture. the Affida'lit must Incorporale a ccmplele list 01 all p>lrti3S who have done Renable work In th.. la"t Me monthe. and have alleched 10 It original iuD waJl/6f8 01 lien lrom each person or company. II ExcepUon 4. Is removed, II wlll be replaced by the followIng exception: ·Any constructJon lien claim by a party nol shown on ths Construction Work and T snants AlfidaVit suppfied to the Compan)'.· 5. Rights or claIms 01 parUea In pos98ss/on not shown by the pubQc records. NOTE: Exception 5. win be removed only If the Company reoeiv6llthe Construction Work and Tenants AffidaVit on the lorm fumlshed by Ihe Company. If Ihe aJlldllvil showa thaI Ihsre are tenants, Exception II. will be replaced by an excsplion lor Ihe righls 01 the tSMnla disclosed by the Affidavit. 6. Encroachments, overlaps, boundary line disputes, and any other mailers which would be disclosed by an accurale survey and Inspection 01 the premises. SCHEDULE B - Section 2 page 1 A. l. T. A. COM MIT MEN T Chicago Title Insurance Company SCHEDULE B • SECTION 2 Office File Number: Commitment Number: C-165017 ExcepHons(conHnued) 7. Easements or claims 01 Ba99lTlenia nol shown by public records. 8. Any dlilm of adveflle possession or prescriptive easement. NOTE: &oeptlO/l S. 7. & 9. will be removed only lithe CO"'pany receiv8B an originlilaurva)' which (1) ha. iI cuneot dale. (2) i8 satisfactory 10 the Company. and (3) compiles with current ALlAlAOSM Minlml.lm Survey Slandards or WiBCOflan Admlnlstnllive Code AE·7. It the survey showa mattere which allact the UUe 10 the property. Exoeptlons I. 9. & h. win be replaced by excopllons describing 1/10911 malters. 9. Gooeral and specla11a1l88 for the year 2006 and subsequent yaars. ]0. Public or private rights. if any, in such portion of the subject premises as may'be presently used, laid out or dedicated in any manner whatsoever, for street, highway or alley purposes. II. E~sement. Restrictions and conditions contained in instrument recorded on March 18, 1954, as Document No. 869614. 12. Right of Way contained in instrument recorded Septernj:)er 13, 1949, as Document No. 785973. 13. Easement contained in instrument recorded on October 21, 1965. as Document No. 1145371 14. Easement contained in instrument recorded on June 20, 1974. as Document No. 1401538. J5. Easement contained in instrument recorded on August 30. 1977. as Document No. 1535850. 16. conditions contained in Affidavit recorded on A~gust 18. 19B1. as Document No. 1716619. 17. Deed restriction and conditions recorded on May 15. 1991. in Volume 15889 of Records, page 36, as Document No. 2262327. 18. Deed restriction and conditions recorded on August 26, 1991. in Volume 16585 of Records. page 1. as Document No. 2284942. J9. Deed restriction and conditions recorded on January 4. 1993. in Volume 24133 of Recorda, page 13. as Document No. 2428937. ::0. Approval Document recorded on August B, 1995. in volume 30508 of Records. page 65. as Document No. 2694911. :!1. Covenants and Conditions contained in Private Sewage System Maintenance Agreement recorded on October 5, 1995, in Volume 31005 of Records. page 15, as (See continuation attached hereto.' SCHEDULE B - SacUon 2 PI!!. 2 A. L. T. A. C O.M MIT MEN T Chicago Title Insurance Company Continuation of Schedule 8-2 Office File Number: Commitment Number: C-155017 Document No. 2709319. 22. Any law, ordinance or governmental regulation relating to environmental protection and the effect of any violation thereof unless notice of a lien, defect or encumbrance resulting from a violation has been recorded in the office of the Register of Deeds prior to the date of this commibment. 23. Rights of tenants under unrecorded leases, if any, Schedule 8-2 ot this Policy conaiats of 3 pages. Contlnu.Uon DANE Co T1TUl C...... It.l'.l.It: .,t r:1l JWm p~I'" lit the' onutl\ *corn.r of Melloll 10. row" S )II'l"ti., 1I1'''T'r 11 I!:~"l: \I'flllea lIor~h ,.l"tIfr c,nhrUflll ot MJ,' I.etlo" 10 " oll ••"tn",," "'f 101)0,11' to t1'lll eDn~~rUIie 61 CD'''''J '''''''Ilk 1!1RIIY"1 'A": tW,"o:>. U. ";1" $7' '01, /\ln~ Uft •.•111 ""ntr.r 11nl st COIIAIl;t 1'rU1K K1C;hw,~ "A' 1\ .u"\"nnD 01 9~•• " \0 /I PQ1n~; elllnce )t. 0 20' "& ~ dl~tl\ll'CI 01 )).'" ;" \~Il pol1lt 01 bt;(~nntl'lr.: thOnee cOl'Ctllllin« II. 0 .ta' 11. Il f.ln\:'IUc" ar 132&.1' to Il 1I0tnt: tl"nee II. l.?~ I~l. t. 1\ IIJd"nDo lit 252' '0 • ao1nt,; than... N. ~7° 17' t. ~ 41.~,ftC. 01 ,~.(O, to a ?Oint on the ~~et-"ut ee/lte:-Uhtl D1 ,.,14...etlan 10. '·,,14 pol"' ~lnr~ l>?"" ... ~nll'll' "10",, the 0:01(1 ."a\-oven ,.1I1IP'U", UD. Ule CIl1\~IJ' t cor.,... ot ""Uon 10; ,...... - S 1/- lu-:oJ-7 P,44(:t'/ ; ,-? .,: I :S .. I 4 ..... i ....•. ~ ! ~ J Q 1 ....c.o . ! ~. A i i i i __~__ ""'L~ .<.~. , ,'{. IiB012/0!6 ,,,P.AI.J ,f r ~~~~~~~______'______~'S5A~1 4 3"..-;;,.'-' .. I ------~r.p~.~.~~--______~(SEALJ .~ : .----,---- '.;.': ---.-----_.. ------ •...... ,', 0'," . ""TAT,.; ..'; _ .. ______/ "" I ...... t)" nI __, ______.-__1 '/ -----___A...... '''__, I '.1'1':, ••.• \ .: !~Wl ______~~ ____r-______~ Nolo.,. "- c:.q. W.r;::J I ..,c-.o___ CO I, ~ ~ J ••• "'1' '. I .1,:' I -, I " ... ! \ , 'I I ~- w'o r \.~ I I I 'I ir i !' ___OS~~.~~U14u!"- .' pAll'S.J:O TlTLB r 153!jS50 IUCllII1'4 11. 5~"by. peROnal rep,uuUt1va uf r.ne ••t .... Of Nn"(;J S~dby .. dec••••d. party of ~~e e.cond PA~t .. I'I ~!!!!.H.~!!!. I I·. I1I1l1UAS. the t:l.nt plrti...n ~ _,,8 of ell • .follcwiJlv I .... (luo:rUwd real ..taU located til DAue CoWlty.. W1I001111n. hue5.l1 ..••.j. •• .rev ~&I...r.ed too ... Percel A. by ,,1rt.ve of lnd ColI~401:. .eeaE.... 111 Y"LV1IIII It ,,~ ....onJ•• p4g& 4114, ,ill which tJocyappe.ar u' ' .''. , IfIlE~. the pi.rty Clf the 88eall'd, put ie th~ hDldu o( tbe '.:'. : l~el tic1. ~ the tollawtnv .se.crtbc4 r ••l ••t.te sltuat~d 1n DaDa I COvnty. N1scdnl1n, lIecaLlI.tt., 1.!...~.4 to a. Parcel ._ .."".:,.,..... PIIBCU. .• , ~-< ", "'f tot rwo /2). C~fi.d 'urv.y ~.p No. 21'2. -ecordad JUly T, 1911 l.D Vol_ '·of C.rtUh4 SlIrVey Hap. of Cane. Collnty all PIl'''. 3,. an4 In AI Iloc'IJaellt t 152651 • .'., '. " . )/1-10 -3- /2... --1i:"6' Z3~ l.r IiIIOU/028 ..! ." "'"~. p."~ at the 9"'64& buUd1Jlg of tha ••UlI>4 party th.~ J. a1tuat.d on lar~.l I .n~g.o~•• on pert gf 'arcel A. o~.d by ~h. f1rlt ~rtl0' • .nd the f£r't pacti•• de.Ire ~ qrant ~o .( the aecoa4 party an ...... nt to ~••p and M'intoin auch aao~o&chln9 9alr19_ \4 Jt. ·PrCII'"t looauOl\ Oft n14 'areel II. ..:.:a. ~'" lION. 't1IE1I&rORE. thS (urt pa:t"ties dO lIereby IJrant. ulliqn and let OYer unto the ••eoftd ~.rty. hi. aocc~.oc. and •••igne. an oas....nt. Whi.~h Ihall r4n with tM 1M" U • ban.lit attached to '.rcel ~. above ~.er~. conailtill, ot tile ri,lIt co keep lAd ...1JII.a1A the Uta". ral.ned to ••re,& anoro.c_t 'n iuo plre.ent. },,\,,:,,~. ' ~ Location Oft the re.l ••tlt. of the first parti••• ~o,.ther ~itb thee:: ,;"-)¥~ W) d.,orilled •• foll""s. -...... c..o, '.~t aE ~. North6.'~ 1/4 at tn. 50u~.t 1/4 Of SactioB ~ :,:'~' 10. 'roW'l'l.~ 5 IIOrth. Rang.·U Uat. !'Dom at DYI\Irl.rll:. OUI> Co....t,.. wi.cc>ntlnl to_adDI"~ 1:111 ",..1:IIout cOrllN' of tGt Z, Cert.Lf'Let 5urY~ U47Z Z'aco:e-ded in Vol_ t, ·P.,. nl, ..1' lI01Iot. b.1"9 ~ha lntaz'Hel:UoD ot the lIIOrtbeutUl:r 11M 0% eot>nty 'I'nIlk Hi.,""I,. ",,- and tbe hatUly line ot· ~U.4 I.Ot 2: 'l'7le:\Ca. O· 2" 33" :s. 1":30 t.at.. Alan. the Xutuly 11M ot ••id Lot 2 eM> the JlOln~ Of lleo;1IInins- of ilU.s "u.dpt~., add POint kin" J. f ...~ aouth.rly of tM -"tMr:z.,- od'!. ot: a .!:Cn. vau"., 'tIIltII"..... S4' 10' 11, S.2t t ••t, Tben~ ~ 1° OS' Sa" z. lD,DO t.at parallal to and 3.00 ~."t -eAatc~ly ot ..1d ."0118 Va..I,1I . . :': L' Tile"". II ... S" 10" If, 5.61 t ••" t.o the E..t"dy H:no ot ul11 loOt 1: _I Tn"n". S O· 2" 33" ~. 3D.aO.f••t aloft9 .ald !Asterly line to the ~lnt '.':":.-:: of bavln:nin, ot th1. dea.rlptton. .. I· -.:' - ..,,,\. I \.....J. r·. ::;~~r .. -,' I ;', ~.' .~:. :,~. :: IIlt.ahad. ~.to 1. Mev t , •••• prapazad by ~tdaa ',: ~~. l.n~ .~.o,o.. , .ho~1n, the IIr&a4( ~h. aa"~Qt h.. ~An .' . q ..ant04. ....-./1. "',r- ' 1lI01S/02. ~C\)Tln.E uPO" r....".l 01 tho 9"'''''''.'' frtt ."it 1'."0,,. It h f.ath.z .~oa\t thu ~h. tirat pUU•• shall i" no _'I t>.. ru\'On."b\.~ for the .lqIelllll of ....."uin1n' Iny part ot th.'V.~.~. buildinj. RL~her4 8. a~7. jot,," 1ft ~••••c~\to~ of tb~. lna~T~"~ tor t)IO !lUPOI. ,;,~ eCCclpdng the .... &JId kiD., PllIl!4' b7 it.. tel'll•• II.M ,tor tba fl1%th9r PIIJ."P!'U of eon.aIIUJI, u h. terw. I.. per...... l r~••"'!'taU9. ot ~. estatll of Nora .Smol'by •••~• .a. lud cont.n.et vllMo" j" till 110nG connace ...f.nK to 11'00"•• J :. I :' ;':,',' ':.:. " SigneturGS of OZrin M. P.~, Ida ~•• Rlgan ana Ricb~c4 R. Sua4by. A'IItlIut..ieoud tlIb ~ day of ~ MY . '1171. .,....~.j.~ (:~.i;" ~I~u--. ~ C~~}ib IILll..UI'!,:B. Orltton Tttl•• ~"r &ta~. ell' of ~l.con.1n ,I',;") • AytbO%ise4 under Seo. '0',01 .J'" • ...:.. " .. ; 05/03/01 08_:5_'_F~Z~'____ !lANE .CO n~. 004820 CERTIFIED SURVEY MAP P'lE1lIII CUTlflCAlI Royd Oakl:Dpccrinlt Inc. STATI ., "IImI". ) caaon ., QIoIIi ) la. 561D Medical CIn:Ie. SUita 8 ~Iton, WlsCOl\lln 53719 Pnone (608) 274-(1500 FIX (608)274-4530 R1ch11rd L Palmer, ProfnslonailAnd SutVeyor, 502180 Description: Loti 1 and 2, C.rtitiod SUNe)' Mip N~ber 2472, recorded In Volume 9, Peg" 388 and 399. iI Document Numbw 1526587, lying In part of the NorthWUI 1/4 of IN BouthMlt 1/4 anel part of the SOUIhwut 1/4 of \1'1. Sou\hweat 1/4 of SeeIIon 10, Townlhlp 05 North, Ibllll' 11 EaIt, Town of Dunkirk. Dan. County, WlSCOnaIn, me... filly deecr1bed as folowa: Commencil'lll at 1M Wut 114 camet of said Sec!Ion '\0; Th.n~ S 00"20'52" Eo 268.00 (Nt along th. W." h or Uld S41dion 10; Thence S 85"21'19" E, 721.87 feet: Thence S 74·,,5'SS· E. ~O, teet ttl. poInl an h Nallh 1m of IIIid Certified Survey Map Number 2472: Thence N 88·S3'W E. 183.21 'aat to !he NartI'Wiut com.r of Lot 1, aald Certlfted Survey Map Numb.,. 24 72 ta (fie point Of beQitlniI10 ofChi. ct.saip6on; Thence continuing N Br5~'55· E, 210.81 rlet to !hi Northeast comer of said Certified Sulvey Map Numbllll' 2472; lMnce S 00"3S'1r E, 86'.85 feot 10 the SouIhNlt com. of NId Certiflad Survey Map Number 2"72 lind tn. centllfin. of County TNnk Hlp., "A."; Thence N e3"2S'1r W, 2&1.00 ....t along saId centertin,1O the Southwest comer at LDt 2 of said Certified SUlVey tap Number 2''12:." :::: "" ihtnCe N 28·38'41" E, 33.00 fee, alDnQ the Wetl8l1y IJne DI ,aJd LDt 2 ID the Nortl'I right-of-way 0' County TNnk 1tgt1'Qy W': Thence COf\dnulnll along laid WUIarIy una being lIIe 8ft: of II;UrVe to the left havlng a radius of 300.00 fNt and • chonS burIng N 12·8r"," E. 141.00 fut; Th.nce N 00'35'35" W, 277.7$ feet to the Southwest comer of Lot , of AId Certlflad SUrvey Map NllmDtr 2472; 1'hence 8Iong tha Wut IIr'II of laid Lot 1 being the arc Of a CI.ItV& to the left having I radius of 80.00 f.et and Chord bearing N OO"35'a5" W. 100.22 feet; Thence. N 00·35'35" W. 186.5O.rona &aid WNt line to the point Of beg{nning of 1/'111 dalCription. ;$810 parc.at con~lna 171.885 aqul,. r.et or 3.948 acres including rtght-or.~. " ~\\\t,"nIlJllflill ~~'f:!.:1\5<:'0 NSJ'~A ,I' ~ .u...., ... '1f-~ I ~a.-,..CI,...,,'.~OO"" s* R~L... = a-a i( N :.gafILiD I"CaI _",:,lS~r~,~Z~b__""~Ma~C""P...A....____~___ Y2....oi1__~ I ~••'___~l~!illilg..l~Ilj~.~.1;~IS!~ip~'t:~r~.~...!:.r;-==:--____ '\.."f'1io'...- ....t:O~~ .;,."_....:;;;.___-.i0... c.w:a ullolnPuw.tRP-...,_!2jl!ol!.;:C;lilOftWi·!.6llJ.ft--i51.o1)~S'iJit...-____ :1'1111. SI.lR"~'~· 71111//Jm~\\\\\\'i.iI&I~oit.LQCA:na.: t.otg 1 'ad 2. C1n1t1ad Sumy lIUNzIF at'" !Fl!.8rs1.sI U Vellee g, 'a9.. 391-391, SURVnG ~y. 81,.fBl lyi", ip R'd Af"' .. 111 " lb. J1I 1/. and pert; Dtwnf b~ @ pf p. '" 114 of n lit pC "c1;iRR lOs t p! W, CUCItED D:t'_-l~_____ 8 1;1 ,. AM 9' pyP]d.sJr. Dpa Co!qJty, !i.eop.ln Al'rJU)VED ~y...."..",..,.:::;,..___~ !'iel4 BoO~ 'ag•• .....u. nat. of ~uzv'Y __r~2~ 2002 nix Id.t,'U!'''!1!!~!~ • D1.r CODt:. (,tsSiealg DiU L4w.l (a' PLaT File 11570 offiC4 ~, No. 1'510 Shut --l...-0f....!..-.5b_'f.\.' ---_.--05/0"0' 04:14 --PAl IOal711'"------DAN! C~ ~OOllOU Lot 1 '1S2.54~ Squo,.. , ..t or 3.7J Acrel --05/0~/O'------01:51 PAl 10'2111131---- -'--'-- D4JiB CO TITLE OtJ4822 DAm: COUNTYZONINO AND NATURAL. REaOURCA COt.UITT£E Cll\TIRCATE APJIIOYOd fOt I'ICOI'dJnD "r Oal\8 c~ ~ and tfItInI RIIOWCeI Commlllae action clatecf Ih/8 ~ clay ofe-.-.. ".1 ,G .2002 .,. ---.------05/0)/0. 08:00 FAX 101271113_- ~COTlTU1 • I _ft. Z1to ",_Sn ,..._ "* _.1 .._ ...... "r.-ru Io...... '130508' ~. pz..Ul•••1 Ill.•'U, 'Il,...... 0.... ~n & fd,wc.. " ..t.n: .,...... 'J WOo ____ d .h_'-. 1_. • __ ?ftIP....., ..ndMd .. 1M. " It ~ PIf .t ,.d... 11, UJI', UUI :r... If 1ruIIUI..... , JMM c.-e;" VU....S.. "_~ , ..~ 17UC ••...- ., -., t.- .,...... ,...... _... 110_ ~ ~17lT7 P .., Widl .... V1~" ~.... .t 'hcu ""'17 ~_ c-C7 ..&~_ d ...... Wi....a P.D. sa 7911 'f.l_ " .. 'aau 11 aU II. !I&4tI.. W1 )J107 _.0-1. ~ 11& '11. IIf...... COle.....,ue. -~ • _,",,- • .,.raU_ .f 1.2110 c.n... ,~~~~; ~ I'Q~: ~~~7! ~ ..._ .. _l1 ..r ...... sr._ . u.o. _ .... a..,. .t ... '~'Qa" ...... 11 ...... 1.aooIflll .tA"•. tu ao__ .e keaau ...... ~..010)0 _q III •...-1 ~ _ _ ~U- Ie -" • ,r(YaU -leu .,...... ,..... foll"li.. __: 1. n... _ loud....f .,.. ? ___ ..11 _...... ~ ~'''100 ••_ ~c t. JlU,''''.'de. f_ tM ChS\~ 11.11 ~.l.,.c"'a ,n~ .... dt.t it:""U M 'Uc•••dJ la... ,.. "I "1:41a I ",U __nit: 1',.. 1M --.zal:)' il\ IL4\M.ct_ "01 'dlU ~l..a:Dc •• 2. 'DIa> .... _U ,Wl ... ~.... u ella pnpaId 1_,. ac lUllt ~U~ V .tr. cH ...... ei _ l..-bU. '00 ,. 'DI&t __U eMU h CIOIIIt:r\a&U' "'til • wI.~ .r 'I loll U ,.11 -bl· •. ~n 1. U&Il q _ no,_Jl>lU., It .....~ _ •• ~ u...... U 10 ....._ .... _ -'*'.., "U CiOUl.ft' _c.,...... CNlS • ...U ... _ a_-d..lC~ -"V"iMl • _ ., Iti.o .,,....-.1 ao tl>&c Obo ..-11"'~ 10 ...oro·or ...... '11_ d.au .".....&1. 5. That. lIII ~ .,.~ Ch.c tU ,.tul UNcru.U...f dI.I ..11 •• tJt.e "'-...... "1\.4 ,",.r'tJ N. M~ c...... u IIflC.bll\ I ,.In,. .r 1:\, IIIaU of tt.Ia 6""""'1. tU _.ooal I/\~l h ...... , •• f. Ihtc" J¥I>IIon:r _r 1lWl'i·~r..ta '" tile .11 KiU. enn••u4 .. ___ *1 "lela "'" ...-I...... u •__ct.. ,,-0....~ ..:,. DAIlE CO TITLE ~02S/02' V30508P 6& "t..-a_t... waU _ow nna .. cI. VIU .... oKe _ ...U CiU.., .\.oU nvorrc .,. __Uoa .e eM ...11 ... die _la_ fen. " n..• ..au wu,___1 II 'N4l~ ..... clio fZ-.re, _ Iw.."" Iioo 0Ml_..., ...... 'lhol, ..ud.I.. _~ ...... 1 _, ....."•••" ...... '"_ &.1.010 ., ... _ -,. ".£Itu of Do... Vld&ia 10 __ .t r-eol.t< It _ ~_\ 10_1, Tft _ IlUe r..,..Ola foe.., t... .._~ .Ldo. .~. ro""~",, • 1 . IiiJOU/OU _ 2 ...."'AU MwM.·II"t8TbI~ ~~ ASRII!IIIMSWf COVIMIINT ' !leo •• aT~n , lftS-W-OI Q2:~ .. "'-~-______!ila.IS!t!:!d"""""I~~~a..~ ~!",..!.. 18:88 ..--...... '.... 1 ...._~"--_...._._..;h=Ah_..;:.,.·___,...___\ ...... V3tD05P 15 ..... /!lIt___...... _"...-._-_~_-- .... .._ ...... ,-----.---.---~ ...,., ...... _...."..,,,... ---3t...:.t'...... -.#'T.. ~ """0#z.." _,,,,_,"'1," lJa...... , ~M;,.,J, ",,' .J7)f' l,E61S 11. I T), . "'_... l1· . a .,pt ftlPAJRf.O ft "'i"r-r _-'...... _ "...... ___.... "....~..... __~'11100...... , - 1~ ...... __._._••_ ...... ___ .• _.- -..- · ...... ~ ...... ---~.-... ·...w_~--~..;..--"...- _--_._...... _-..:_~_-...... _----,-.--...... _-. ·....__ _.--...-.~1\10.._.-...... -....__...~"...-.,...... ~_--_ ...... --...... ---...... I!....~...... ""...... ,.-:_-...... ""'...... --.4-..-.-...... "...- • :.-.. e ...... _ ...... __...... _ ..."._11 __..._ ·I_.~._...... _...___.."'-.Dooo-._ - ar;f • '. "'~ -'~. - .... ~. ~O~~~3'___ ~O TI'!'LB IiII018/02' . !'1ELl~L.o:l.~ " S1'':1 III' 1I'f~. 1 - SURVEY PLAT_ a#IffI't P:II' iIAIIE JH_ t:IOJlCI A, IIU~ _ 'lQ/W1'! ',,"CnIt C",~•., 'vU4~ KMu-,lIh,_S.. S"III ~.... 611-..1....'7\\ \rUT IIrrta )6lD ""'col Ct.r\. •"'.~iI'ii lfait_.,..... ,.It_)QtI III. 'l7U Jdl·m·'2~" ~O-fl/' ~ ~ J" 1~ ~(' J,,.,. ;t... , .Q ~,"",/F.I .,?'~ ~ ~ I t~ ~ ..... ~ ., ~~ HW /Itt :;""11'• "-"l~ • I '...... -:;)..;~ .. •.'0':. ..,..,...... "~. ~. . .:~ '. .. ~ sc.ou I 1 I..., • ..:tJLJr.n -, • to_ leau"" . ) • 1..' ..·'.... ot.1ou ...... • l,ntlilo It -',' :::~~.~C~I~.'_/__.~~~~_~_~~:·~'___ (~~~.~.'~.______":"-1'_-....~f't'\..,..-~- ., . DEED P.&STRIctIOM r.r: All proper~y ~Id ~1 Wl.~' ~a~a;...n~ 02 W1'~Dn.l~, I~c., lYl~q J" Section 10, Tovnship , .orth, ~ng. 11 t4.~, town ot DUnkJrk, Dan. county, Wl.co~a!n. w••to ".n.9"on~ of wllo_il\, tl\c., the :01 .,.."ar oC cart.ill 1.119 1)'11\' ill 1tc:'I:1cm 10, 'fo""ab1p S 1I0n1\, ~'ill 11 Eut, 'rown d Oupltirlt, Oan. eCIIIJI~l" IIhCDlldJl, boil\9 nlljaot to an 1tG.£"uuative ord~ tr~ ~I D.S. tn.!ron••"eal protoction AQanCY r.qu1ri~ ths r.c:~iSlll" ot • ,.014 r'5ulcUon v1t... tlle lIa,h\." cf :lall4. for tlaM Co~ty r,g~ing .11 1.n~a it IV"_ situatad 1~ ~o.igity ~o the tenar l'ndrill )cll''''' .. 1:1\. Ha,an FIIrIO c1ta, "araby ...lta. ~a toll~in~ 4ealaratton. aa to llaitations, ro.t1'io1:10", 1n4 ua •• to IIIl!e/\ ••old l.,. Tn. t~lloVlft9 ~r. prohibita' O~ th. aboYG-r_tarancad property' 1. .ny eO!l&\lapt.l... "I: oelle" ~"4l of U,. 'ito\U\~'!.r tl\a~ cou14 CIU•• ~po.u~, to nllaelll or ani~.ls; l. any va. ot, or I~tiyit)', that .ay intutll:'c "i~h ~D worl<. \:0 h* pcrtor.u4 .t thl Hegln fUJI ait, 115 "Qllired by tlla ebove-r.tora"ced Adll~twtr.tlv. or~~r; an4 J. an;, luid."tlal or c:o:nel'~ill lin, j:\c:1Udl~ but not lLa1t.4 ta anv til!1~. grad1ng, .kc~vr.tin9, ~1I1td1"Q, drllHno;. wining, 'aral"", or other dlvftlO1..."I:, Dr plce!"9 va,eo ••cDrial, I~CDpt vlth thl approY~l of U.S. X'A. In oo"allltatlon vl~ tho 5t.ate. .a conaiat.ent \11th tlla rlqulrl.."t. of ~ha .bava-~atl~lncD4 Adlinllt~.tlv. orrSllr. Cou~ty ot COok ) ) .~. s~~ ot 11l1~oi.1 ;ars~n.lly ca•• ~tor• • ~ this l(tft day of Kay, 1"1. Oo~ld R. Pric., rru1de~t ~f1d CUl 3. FI'."l<, Secr.tary of ';11110 abO .... "1./11..'11 cgrporat.!,,", vane 1\a,..,PSlIt ot "le..ollst.•" Inc., 0 IIltlCl>1I111n Corporation. knooo" to .It ~o .. tlIe pv...na ""0 ellac.lltact tho r~e90i"9 ~:latr1Ul.!\t J1l1i ~ ... Imo..·., to 1:1_ .....10 p::.sUent anL\ S.cr.t~ ot sOlid c"rporIUOD••~4 .c!tnCl'"1cI'.!,u tl\.t -e1l1lY _.~~c! tho :o"'0jJo1", inn:nlunt .. lucll otricOtS, .. the dUd Of ~~id CtcJlO:at~on. Irf it.. authority:. ".) ._ -.'.(.J J.~ . •. ~...... ,L ~'.• 1·.....,L,o..•• • OF"'eI6.~ S~.III..' e.ATrii n",., a PIN'O>I .JI..tuy PIIb1io, eo"~ Cour.ty. 1IO\~~f "aft $"'[ Of ~Lql 11Uno1. ~f to;UlI"'rtI !""I(S III~ ThJ.C i"atrllllaJIt d.r.tUd toy Ir:!l to M r.t>lZTl~ to, Davl., E. ."....rt: ~~.oo1It. Gane:al e"un."l W.at. ".I1I~..ant ot ~i.~o~.~n. Inc. W1Z4 ".tl~ a~nd.¥Y RODd Hen...one.. Fall., WI 'lDSl U4/Ul-4GOO 2 Jul 16 01 03: 14p DaVld E. Stewart 414-785-8103 p.3 DEED RFSI'RlCTlON ~\'l 21433 PAtE 13 RE: The East 1/2 of the Southwest 1/4 of Section 10, Township 5 North, Range 11 East, Town of Dunkirk, Dane County, Wisconsin, except that part lying South of County Trunk Highway A. 2428937. Waste Management of Wisconsin, Inc., the fee owner of the above-described land, a/k/a the "Hagen Farm", being subject to· Administrative Order V-W-92 C-l72 dated November 25, 1992 and issued by thle U.S. Environmental Protection Agency requiring the recording of notice of this Administrative Order and a deed restriction with the Register of Deeds for Dane County regarding the former landfill known as the Hagen Farm sit.~, hereby makes the following declarations as to limitations, restrictions and USC!!S to which the above-d~cribed 'land may be put to and further hereby specifies that such declarations shall run with the land as provided by law and shall be binding on all parties and all persons claiming under Waste Management of Wisconsin, Inc. The following is prohibited on the above-describc~d land: The installation of any drinking water wells. Dated at Menomonee Falls, Wisconsin this 'J/r;;t-day of December, 1992. WASTE MANAGEMENT OF WISCONSIN, lNC. ~~'Chard L. Ancelet, President County of Waukesha ) ) 5S. State of Wisconsin ) Personally came before me this 3b taay of Deoember, 1992, Richard L. Ancelet, President of the above-named corporation, Waste Management of Wisconsin, Inc., a Wisconsin Corporation, known to me to be the person who executed the foregoing instrurnen t and to me known to be such President of said corporation, and acknowledged that he executed the foregoing instrument as such officer, as the deed of said corporation, by its authority. NoW;£~~ My commission expires / t ,P-tf"-'iJll. ~ !r Jul 16 01 03: l~p David E. Stewart ~14-785-8103 p. /,1 / .2/~ Attest,~/~~~~~~/__~______HOWard L. Kruse, Assistant Secretary County of DuPage ) VOL 2143.3rACE 14 ) ss. State of lliinois ) aIl Personally came befcA'e me this .3O day of December, 1992, Howard L. Kruse, Assistant Secretary of the above-named corporation, Waste Management of Wisconsin, Inc., a Wisconsin Corporation, known to me to be the person who executed the foregoing instrument and to me known to be such Assistant Secretary of said corporation, and acknowledged that he executed the foregoing instrument as such officer, as the deed of said corporation, by its authority. This instrument drafted by and to be returned to: David E. Stewart/ Esq. "OffiCIAL SEAL" 250 North Sunnyslope Road - Suite 330 CARRIE L. ABATANGELO Notary Public. State of III/nol' Brookfield, WI 53005 My ColllmilSlan upire, se,t. 211. 19M (414) 785-8168 ~ .. v1"/ l'IIt'uc; ~e.:-~"ty, 1111110h lIy co,..i""l..~ olPl.ru 3·Z~-'J.5 ~~!s ~~st~u~.~~ ~lf~QQ by a~Q ~D ~~ ~~~ned ~.. , 0...,£41 r. n.VIl' A.~OC(.t. a.n.~.l C~u~l ~.~. M~ft~,...~t (If ~15~~"a1", x"~, W124 W.'2J 50u~rr Ro.~ K~~~onao r.ll., M: 5'0'1 '.1'/2!S1.-400Cl . r-.J ' .• t: -., f> .=-. I • •••• D£tD 11.' ,-•. ,eno/: 1'71& Eut \ 0' til. swtl\Won. ~ of Se,;t.icn lG, ~ S l!O~lI. QftV" 11 t.~. lClOln Of DWlltirt. 0,". County, Inllcon,.IJl, except t/lU l'.~ 1)'.1"9 '"t." or e~nl;y t1'\l:1~ R.t-VI'IlNll' "A.-, r,aU On. C11, ~ (21 II'd 1'1>:'•• III Ind ell 01 t;.l'Io lal1C1",1uin 1:1'1. ana de.i,n.c~ •• PToPQft4 ROa4 ot ~ct1'i~ Survey Kap no, 241; .-cc«dH all I)ooll.ant II~ 15,nn t): Volu.. ., JI",.. 191 a. '" Df DI~ Co~nty ~~ifled S~oy Map' a~d ~. land 11!n9 tctwecn the WOf~ 11n. of 'U!d ~ , a: GaitS C&~tit~~4 sU:~.Y KIp Ko, 2"2, anA 1:118 nort"",..l:c~l\· ~19l'11:'""t_}' 11.,\. Df eaunty frunk Mi9h~ay .~. at II ~int .PO~1: 122 t ••t " ..n:II1f..tarlY UM Ulf .1IIo~a1: e .. ro\er at ••14 LIN:). "«J IInct l'IL'19...en~ /;1% 'l'ilCOna11l", tne:, the rae Olol"Dr <.of -tl1o abav. ~e.crlbed l~"d~ lyJ~ i~ S.~1on 10, ~v"ahl, S North. ~aNJe 11 faat. fOlm of Q..:1kirk, P6'n. eDWI~~, !,/LlIGona.i.n. ~Ln1 .....;I.~t 1:1) 011 ....dll~nhtrt.\;iyD or6u fi~ tlIe U.s. ",..ircn...nt.al l'rotec:tioll ,o.Q'nc:y ~.QU1rln, tne T~corai", ~r • d•• a ~~atrletlo~ With the k.gilt.~ at u.~c:. tor Oano co",,.t,. uqardl"'l 1)1 l.~ il. """'I Il'tIlDh:i 111 pr'>xiloit.y 1:0 tha :o:iOU' llinOftll. 1\1\0"'" ~~ ,,'a j;.,qaa rllt"ll IILte. ~e~aby Daka. t~~ tol1~1~ a.el.~atlon. 3& to '{.!tatio~" ~••trictiQ~ Inc us•• ~D ~~lcb &&lG l ..!I4G ~bn~ It ~T.~tly ~. "I' ~. ggt to ,n~ f~or ".r~ .peelfI•• ~.t .~e" ~.cl.J'.tions alI.U J'WI ...1 th the ~Ind'," p%f:~l,"ed .~I' l.v .tId "'1.11 ~ lI,h,di"o 0" IU. p~i.. &JICl all piIJ:aor.•.,ci,laS..1..' under Ifun II."!!."o",,,,: uC IIbcQ71dn, l"c. . '. :.' 'n. tD1!lJVin; Ira proli.Uj~Ud an the .lkwa-~.terencad property. .1. Atly oo"o.pt!"·e>r othor u,. CIt till!. ~gund..n.r 'C1Ia~ could eau•• axpo.~~e ~o ~ua.nc or .n~l'l J. eny ....It 0(, ?r ~c:':~":4ty, th~t ,.... y i"-ta.r't:~. 'd~1I \110 'fCOf'J< 1:.0. :,,, ~r .. or""ft4l:2 6'".: t.1'I" I!"S"')T- !.. p:'~"" .1~t. ~~ rs;'C""l"~t! ~J t;"",, abDv.-r~!~ren~.d ~mLr.i.~:~tl~l :~~~: ~r.~ J. MI? :-aU4t1\t:ial ·or ~o"'trClJal USIJ. iac:l\lCilli 0Ilt. roe li.ttaa to any tl111n,. ~rG41"" ..~vatlnf. ~lloinq. dl'iUill9. lIilli"V, t*"'1119. or "tIlu ~"&l",..nt. or plaCl/1, vut. ",",uf:u,l. nc.,.t with til. approvil of V.5. ~PA, 1n oonlllltAeJon vitb th. ata~., .. aonall~&ftC Vlth the r~Jr.~t. af the .~~-ratcranc.4 ~ln1~atlva oriar. ':., D.tld at JI...tcll""'~.r, 11lil'lDi~ Cl>b t:t!! dly or ~"."..t, ""1 ,'1-. .." DttD Jl' c· .,enol: t71A Jut ~ at til. SlHItlIIto.sl. \ ot S.c;t1en 10, ToWn 5 1I0rtn. Raftq. 11 EI~. lown of Dunltirll:. D,n. ecunt)'. IIi.canlin, .x~.pt tllU pu·,. lyl"1 ,out." ot C~ncy Tnlnll. 1119"""':' ""-. Lat. on. CI-I. two 12) ,I'd ~•• I') .nll aU ot 1otlo land. "i"Ulin 1:1\. ane d••i~n.ted •• ~apo.e4 Roa4 ot CGrtlf!~ Jurv.y Kap "0. 241; nC:~d" I .. Ooou ..nt II--.r lUIS" ~t Vc>lUH •• :P",.. HI &"" :In Df Pane Colint)' ~~1f 1.. 1t SIIr'IQy I(.p~ .~. ,outbWllet ~"rMr at ••," L~ ,. ~C4lP'& ownlcip.l .nd ,onl"" Ol"cl1."'"'''' 'nd r~"oriad .un.nt. to:: ~bUc utiliU•••1Id no::orcS..t b111l4!nlr reetz-leUo".. ~lll paTel. 1, 5~~ac1: 1:0 • public TO'~Y ov~ 1:he poutbY..~.~lr ".00 ('et thQreot. SI14 plfel1 cont.inl~, 2.'1'.• 1~ aqu~r. teftt or 57,0'1 .er.. to the centarllna of C.7.K. ~A·. IIUU lU.,.glloan>; ot \lUCOI\II111 ". tnc~, tile ta. o.,n.r r.t -1:)10 aboYe ~e.crlbsd l~"d~ lYl~ 111 $e~lo" 10, TcV"Shl, , Horth. ~.~e ~1 Eut, rown at D,,!,kirk, P6n. COlUlt!', H1Kon1l111. "1119 .,.Io'..ct tD .fI l'ocl..!l\htntj,YD orelu trOll tba U.S. 'ny1ron••lltel !'rot.<:tlol1 .'Vanq ~.qu1rln9 the rocordl", or I ~ ••d ~~.trletlo~ 1I1~h the R.gi.t.r o~ u.e.:. tar o"no r:"""t)' zaqardi"V .,1 l.~ 1'. DYne. Ilt~Dte;l 111 proxi.d.t.y to tbe ~o=""' lllndtUl lI~n ~:: ,,:0• ....'9.11 fI'c-- du. II~~~Y ~a~ tn~ [oll~l~ ~.cl&~.'lon. o. to 'i.!tI;1o~s, r •• trlc~i~~ .~ us•• to ~bldb aalO 1.. 114, tbnt It ~r.~tly own• ..y b. 9Qt co .nt tvrtbor heroay .peelfl•• ~.t sucb ~tcl.r.tiono aII.ll J'UI ,,1til tn. l.nO· .. ,r",,!oI""Y 1." 1M 1110.11. be b.iI.4!", on .11 putt.. ami 1111 pozaor.•.':.1.1w1.., W\4er lIast' M.ne,...",,: ... e lI!eeo.r.dn, al!. . . _ n:e t.,1:'""in9 era prollijj~.ted ~n tha eh l. "'Y Go"e_pUYe 'CU' other u,a ot the 9l=Qunci..a~u ~n could CIU•• axpo.u~. tQ ~~ftC or an~l'l ,. Dny ...1t or. "r ac"'!":~ty, tll~t laoy i .. ~u ,. MY ::a.UlI>cial Dr co...r~1111 un, iocll,lCill'i bt.It rot. l1aited to any tl111n" QrA~lnq, ~C4Y.tlnf, ~llG1nq • .srilli1'oO...in1r.o, hn11'oO. er c.thu ~"elDptent, ~r placln9 ...... t ....tus...l, .lCC:'Ipt witll thll .PProyal of II.5. EPA. In cD1IauluU"n "itb th. IIt.~., •• lI0118bl:."" VUlt the raquJre~ts of the abore-retarance4 ~1"1atr.tlYA o"~r. '. Ililt.d at ".&tc:llestcr, IIIinoi. Chill!!L!! do)" "t ;l,Ufi\I.t. ~'n ,..~. bAN'£ CD TITLI ~ .' V't"J 1'Isl:ll.C.' cc;o.J)~ty, UU"ch JI)' co'Ub.,.11>~ clpi%"Ut 1!·2~-7$ T~!. ~~~~~~.n~ ~.ft_d by and ~D ~~ r~~ne4 ~o: D.~l' r. Seev•• , ",.:oact .. t. .. ' _"_''_'____._ ~-:.::ti-n i!P&.~.. ~~~~.. ..-~~~ :. ..•.. ~oo"oz• .... ".', , .... r..:. ~d-- __. ,11l_._bot_IeO••. ____tU...... ,,.,...~_--. __....,,-,"III ta I~ 1OCIifMIa.-liI' sn-l ..lot", poIIO&-"__.. __~ lit ... ..nIIla "'"'-' _ .,:k",..".pa 1tIIl~_. e:ttnllld tile ~1!lO !. 1111 ~ tlIft'1<: -w..L ".'.,. . 1.. __'"""'*" I ...... lot 111;1'.~ 11119II!doI ...L IO'~""": ··ll...,hJo!!t.. •• ----'-- 1l"INoNIIt . ' .• aT~n 07 wmto:tlill 1";' . COUll"' $-_..-_., ___.~ wIooo~""""ldInIooIrtoh 1hL-...... _.:...• __.1(. _____ . ,-:-_~--,____~, ~~ -Silua Itt, u ,udL.- •.• _. ______. boinc lllIIoMeoI .. OIl""" -Wc •.r.o"""",,"-t for Qat , ...... _~ b ~ : ., 1M ...... ,'111, o.-lb!.l., J."-If __._~ _. _____, r-- :,(' Ga:------•• FA! 'O'27l"~' IiIIOOS/021 .··I·.·.·t:::r=aI..~ ..:-····"'...1 .' f"."'" _-...... 1_", "'. roll"","" till ...... ir• ..... of _>!l.asil'M__ n.. ~ IlQo ~ Ill) 01: \lot, , ..,!MIt.' ClIo ~ (111\) .r ~"'..;.~. !_~ S ...... I-ro ll. _ C!IInGIir .,...~). :.; , : . L_...... 1.Il0l __Or" -",J...--..~---...,-511 ~~~ 05/03/0.----.-- D':55 FA! 80127J113. ~o TI1LB aJOO./DZI ''"':''t' .' ~_.J.:;,...•.. "", •. ~ .• "" .'-"-.' _. }III !;QU>tr\' DI' • .•• • • .__ _ ..... .... ,.,...... Ifp ...WW ..... I...... ~ ia...J ...... - ..... ~ ...'" ...... u.iI...... -I.tI.u~ ...... - •• r_..., ...... '". ... ".i» ...... ,...... ~ .... I ...... G...... ,."-'~ .... ~ ...... ~fi---.....,... ,.,c...... ___.•_._~. ~--.- AtaIt'I'~·· .. -·· a.. Pi- ll..u.a...... ____... fit.",., h*..... 1_ ~ c:...., _ hr... NnW _'r.:' ...... 2lI4 _ ...... ~ __ '''~ .• kr... _,..__1 ___•__ ... __ .l1co1.l~__ ....~~. ____ L ______«_,.,.....:..u ... loW c.-. ~ ".... .H ....., _".... ... .,. ." --.,.,______au_ •..,"',..,.,.....,.~ -=- ______"'--'-'-- .. ~-.-~~--- .. -.....- ... ------ - .... . _. ------....-._.__ . " ... - ...., .. ",...... a, I I I i J I I I .. .. r ta017/0U 1.716&:1!) ,i "'b~.' /I. II_U';11l. bol.. line "'11 ....~~ ... Gal~ ...,,,,,, .... .a,.", f I. Th•• th. u ....141- loy .". lIi"'.....1' a.,¥_t of ",,'"cal llUo.Itcoo I •• ~ h..ur~...... tt l,tthJ1n. ' . J , 1. l\'P1: ."",.... '11••" ,,,C_,,, tloat' _e...... ,.,.....c "" • ,an1J>n ! of .b~ 1\"'d- A~_ ).SO ../1 ...141;),1 WtatO \00 ",/1 .. 1.1-01c111....l"J~• 10'" J ",(I !lotch ~. UI1 1.~·..,1<:hl"'..thy1alt. CDO-.,ll I'IG, '. un a-s.at 01171" 1IcaW 14 ",/1 1. 3-~.dtl4lt..lh,1.ae 16 ••/1 tn~. of n~ndll".4I\..,1.... (1.,11 Vn1d..UI~ _-,ltln"'.." .,. lCo30 .,/1 ... -n,.ol .. »1" .... t'bNa r ••IIl,•• tJa.e »,.l'l:IIMt JKI..,,:we 1\ t.bl. t.1.... thll .h. "'at.... It lha .1NIv..d...CfU"" ,.""cn,. ._111 ••, " .."Ii 'DC' """...... ,,1.I)A ~ flW con.o.-pt1... b, •.u..1f 51", • ..,. be »t" for 11_ ...... -'UOOI. ). no•• IYY,bor. illl_U08 ..~ k ~Jd_ hoe do. l)opll'boI...... ~s~·~ S.o•••, """....'" )11 cc:wa".l...... cce,;,uatr [ea- ,. ,., t. I'U till. 4.-c .... "tal.1lI .1 ,boo IIUce""SII DtPUtll!lllt III J!o.~al 1UI000Z'CU. ~~. . .- i : ~,.,.. , r . '~r. , '~'. [ ,~~ .J; .. .~. \> ."~ ... 11.453'i'l r~. Cc' ':'Iii.( iN•..,....,.ur.:. • •"d. ~J • .2.J..- .!I\"" ar ""t~l, tJd, t.r 101<' lo:o<.= :~ a. S"O....; •• IOnI\...,..... WlSCDl(lUO 1'01'11. ,lI!l) I, l orT e:J':!J....~. co.,..n. W)~TII. ~ m -' ill o....U..rwCOl .r t» .\:1 cl ~ ,u.~C) 01110< .." .dI.~ ._ ...... !Quk ....UtftLI... I_ IIIU ,014. tl:t Iftd,7f. .D.(" ....at ~ ..., .a::"~ till -=11:' lin au _ ~""~ .... I~a. m4 ~T tMft pru_b _ ~ • .oIl, '-17, bQr.t~. ct a1!.-a ""'t:a "". ' ..UII ..... 1;.1 ..,d.... 1.D .....t *" ri,.. .-: ...0'. ~ ..~~ ...mt ~ n., &Hatl l..a'ft,IaahU' ".:ltr.1ttlll,. -;.rIII '\..b4 t!J.Je; :.:; ~ ••• ftt. !. calC'Uct. 11&1.t.&1a, .'111 ~.~" -.i.,fltM.. ~ f .... IJla fW'?!'1e r6 ~w~lM clcC":'ric "DoI.:- .....,.. l~n,U an~ ~~. ua ~Ii ••r.ba!~,. __ ....rn-. 'I'U Ulld atr..,•..c ~T tM ;nII. o.f ~..."c= :.i :::'",t. Ii ~:rr ia loc&~K JJ\ nO' T4MI G: t\r.l.Ut. "'-"r ,c ,a",e, SUIC:. vf ),W-'~, ~ ~, CO:1l i'1."lc-..:'S"l, c!' ••c:-:...... '01.&-: gaot cr:! ~ n 1/4 ~ ;.cd.c T'ct :~. ;':"I. rl.,.. (S). ~I' ..., .. (U) lut, A_ biB: 10 ~ IIortll .r c-.q 1'N>II: !l1~ 10.. Th...._. Ct' ~~t a! ~ ~ rna'''' __ ••~'.' 1.., a.. (5~ ·r... 1a ...~u _ ..4 ...... ~ .~~oft" IlIO!••~ ,\rip ~d~1 ..,. ~1N1C111.r~ Wit" u t-l\OO'J: !W clio ...... gt .... '-10£0ll' 141&U11~ to dr. Ctv_ ~, •• ::II. ,""t.:'. rn..l ,U'·b..~ w1~ia tIItr .ir..... dd P,. leasl ,I: ~o..lJ tJlI.,.Gf c.t I":~:~'¥' ~I: ~t~ )o:.,fI'''~! ~-:::--_,",,:,.;;':' ....., ...... '.,.<1- p&. [)f lrnoGS ""~. :a. 1:Ba,.r ... u..-t. 'ft ht ~ ad ....1 ""'.4..t... 0.,. rt ...... bU. . ,."~" ' . ./ Si~ ..." ....:04 1. ,-- of rd'(:7.J-. ""-;:"'7"~ 7 (.SLU.) ~;:)~/l4"" e!nMi'~iiOWi••• _".... J'l1t1I 0' Iff'~lfl 1". ~\IIIDAn ) 'e.nnU7 .... ~ - tIW ~ ~ of ~r• .1JM. tile I"l. 434 "d89 -'I!'; 434- ;·-,100 .D.....1IUo:t ~:.n E. s..-.Ar. ~~ ~. \~-. &a" ". 7- ~. u ...."'.: ~to C"l'...... , II\H~"'~ ••'"'.... ,~~:::. .-• • I • ~., . ·.... / . ,1, 1: " / ./ -. -~, ~,),,,,,; .."., { .r. .' .' )" . / .'" :. .~~~", ';,";"1 j ,! I .•. ~)~.~f(?!':" I! 1 ./If .... ~_ "'c" '4 .;~.. 0;.," .... ~' ; .~. '.~" ;.i:, ..' .' ./ r \\ ~"".. ,.~ .\. ;' ...... ':, ...... ~ :tf''!' [ ...... ::. r' '~'.}(" : WOAI(ltiB COPY f ~ f· t f···· J'