3r {)1 Mt...l.Jt+~ pi e. {) n:t:f"J-VYJDJe JDT "~i-t7$ ' -=====-:.=---=-==._ I I Draft Qzudity • lutegrit)' • Creativity •· ResjJattsiveness Corrective Measures Study Report I ,. I I I Fort McCoy, Wisconsin I I Prepared for I I I U.S. Army I Corps of Engineers Omaha District I I March 1996 I I I J Rust Environment I & Infrastructure I Fort McCoy Draft Co"ective Measures Study Report

I TABLE OF CONTENTS

I Section I 1.0 INTRODUCTION ...... 1-1 1.1 PROJECT OVERVIEW ...... 1-1 1.2 PURPOSE AND ORGANIZATION OF CMSR ...... 1-1 I 1.3 FACILITY BACKGROUND ...... 1-2

2.0 CLOSED NO. 2, CLOSED LANDFILL NO. 3, AND I GRIT AREA ...... 2-1 2.1 INTRODUCTION ...... : ...... 2-1 2.2 DESCRIPTION OF CL2 AND CL3 ...... 2-1 I 2.3 MANAGEMENT ACTIVITIES ...... 2-1 2.4 PHYSICAL SITE CHARACTERISTICS ...... 2-1 2.4.1 Site Setting ...... 2-1 I 2.4.2 Topography and Drainage ...... 2-2 2.4.3 Surficial Soils ...... 2-2 2.4.4 Geology ...... 2-3 I 2.4.5 Hydrogeology ...... 2-3 2.5 SITE CONCEPTUAL MODEL ...... 2-3 I 2.6 NATURE AND EXTENT OF CONTAMINATION ...... 2-4 2.7 CONTAMINANT FATE AND TRANSPORT ...... 2-5- 2.8 DEVELOPMENT OF CORRECTIVE ACTION OBJECTIVES ...... 2-5 I 2.8.1 Introduction ...... 2-5 2.8.2 Federal Regulations and Permits ...... 2-6 2.8.3 Wisconsin Regulations and Permits ...... ·...... 2-7 I 2.8.4 Local Regulations and Permits ...... 2-8 · 2.8.5 Hwnan Health and Environmental Assessment ...... 2-8 2.8.6 Soil Objectives ...... 2-9 I 2.8. 7 Groundwater Objectives ...... 2-10 2.9 CORRECTIVE MEASURES TECHNOLOGIES ...... 2-11 2.9.1 Introduction ...... 2-11 I 2.9.2 Identification of Applicable Source Material Technologies ... 2-11 2.9.3 Identification of Applicable Groundwater Technologies ..... 2-15 I 2.10 CORRECTIVE MEASURES ALTERNATIVES ...... 2-20 2.1 0.1 Introduction ...... 2-20 2.10.2 Site-Specific Factors Affecting Development of Alternatives . 2-21 I 2.10.3 Description and Evaluation of Corrective Action Alternatives . 2-21 2.1 0.4 Recommended Alternative ...... • ...... 2-40 t 3.0 FIRE TRAINING BURN" PIT 1· ...... 3-1 3.1 DESCRIPTION OF FIRE TRAINING BURN PIT 1 ...... 3-1 I 3.2 ACTIVITIES ...... 3-1

I D:IFTMCcorJIPIXMSJ\TOC. March 1996 I Fort McCoy Draft Co"ective Measures Study Report I Section lw 3.3 PHYSICAL SITE CHARACTERISTICS ...... 3-1 I 3.3 .1 Site Setting ...... 3-1 3.3.2 Topography and Drainage ...... 3-1 3.3.3 Surficial SQils ...... 3-1 I 3.3.4 Geology ...... · .... 3-2 3.3.5 Hydrogeology ...... 3-2 3.4 SITE CONCEPTIJAL MODEL ...... ·..... : ...... 3-2 I 3.5 NATIJREANDEXTENTOFCONTAMINATION ...... 3-2 3.6 CONTAMINANT FATE AND TRANSPORT ...... 3-3 3.7 DEVELOPMENT OF CORRECTIVE ACTION OBJECTIVES ...... 3-3 I 3.7.1 Introduction ...... ; ...... 3-3 3.7.2 Federal Regulations and Permits ...... 3-4 3.7.3 Wisconsin Regulations and Permits ...... 3-4 I 3.7.4 Local Regulations and Permits ...... 3-5 3.7.5 Human Health and Environmental Assessment ...... 3-5 I 3.7.6 Soil Objectives ...... 3-7 3.7.7 Groundwater Objectives ...... 3-7 3.8 CORRECTIVE MEASURES TECHNOLOGIES ...... 3-8 I 3.8.1 Introduction ...... 3-8 3.8.2 Identification of Applicable Source Material Technologies .... 3-8 3.8.3 Identification of Applicable Groundwater Technologies ..... 3-12 I 3.9 CORRECTIVE MEASURES ALTERNATIVES ...... 3-16 3.9.1 Introduction ...... 3-16 3.9.2 Site-Specific Factors Affecting Development of Alternatives . 3-16 I 3.9.3 Description and Evaluation of Corrective Action Alternatives . 3-17 3.9.4 Recommended Alternative ...... 3-31 I 4o0 FIRE TRAINING BURN PIT 2 oo o o o o o o o o o o o o o o o o o o o o o o o o o o o o o oo o o oo o 4-1 4.1 DESCRIPTION OF FIRE TRAINING BURN PIT 2 ...... 4-1 4.2 WASTE MANAGEMENT ACTIVITIES ...... 4-1 I 4.3 PHYSICAL SITE CHARACTERISTICS ...... 4-1 4.3.1 Site Setting ...... 4-1 I 4.3.2 Topography and Drainage ...... ,...... 4-1 4.3.3 Surficial Soils ...... 4-1 4.3.4 Geology ...... 4-2 I 4.3.5 Hydrogeology ...... 4-2 4.4 SITE CONCEPTIJAL MODEL ...... 4-2 4.5 NATIJRE AND EXTENT OF CONTAMINATION ...... 4-2 I 4.6 CONTAMINANT FATE AND TRANSPORT ...... 4-3 4. 7 DEVELOPMENT OF CORRECTIVE ACTION OBJECTIVES ...... 4-3 4.7.1 Introduction ...... 4-3 a 4.7.2 Federal Regulations and Permits ...... 4-4 4. 7.3 Wisconsin Regulations and Permits ...... , ...... 4-5 I

D:IFTMCCOY IIPDCMSII7DC. ;; March 1996 I I Fort McCoy Draft Corrective Measures Study Report I Section I 4.7.4 Local Regulations and Permits ...... 4-6 4.7.5 Human Health and Environmental Assessment ...... 4-6 4.7.6 Soil Objectives ...... 4-6 I 4.7.7 Groundwater Objectives ...... 4-7 4.8 CORRECTIVE MEASURES TECHNOLOGIES ...... 4-8 4.8.1 Introduction ...... 4-8 I 4.8.2 Identification of Applicable Groundwater Technologies ...... 4-8 4.9 CORRECTIVE MEASURES ALTERNATIVES ...... 4-13 4.9.1 Introduction ...... 4-13 I 4.9.2 Site-Specific Factors Affecting Development of Alternatives . 4-13 4.9.3 Description and Evaluation ofCorrectiveAction Alternatives . 4-14 I 4.9.4 Recommended Alternative ...... 4-20 5.0 CLOSED LANDFILL 4 ...... 5-l 5.1 DESCRIPTION OF CL4 ...... 5-1 I 5.2 WASTE MANAGEMENT ACTIVITIES ...... 5-1 5.3 PHYSICAL SITE CHARACTERISTICS ...... 5-1 I 5.3.1 Site Setting ...... 5-1 5.3.2 Topography and Drainage ...... 5-1 5.3.3 Surficial Soils ...... 5-1 I 5.3.4 Geology ...... 5-2 5.3.5 Hydrogeology ...... 5-2 5.4 SITE CONCEPTUAL MODEL ...... 5-2 1. 5.5 NATURE AND EXTENT OF CONTAMINATION ...... 5-2 5.6 CONTAMINANTFATEANDTRANSPORT ...... 5-3 5.7 DEVELOPMENT OF CORRECTIVE ACTION OBJECTIVES ...... 5-3 I 5.7.1 Introduction ...... 5-3 5.7.2 Federal Regulations and Permits ...... 5-4 5.7.3 Wisconsin Regulations and Permits ...... 5-4 I 5.7.4 Local Regulations and Permits ...... 5-5 5.7.5 Human Health and Environmental Assessment ...... 5-5 I 5.7.6 Soil Objectives ...... 5-7 5.7.7 Groundwater Objectives ...... 5-7 5.8 CORRECTIVE MEASURES TECHNOLOGIES ...... 5-8 I 5.8.1 Introduction ...... 5-8 5.8.2 Identification of Applicable Source Material Technologies .... 5-8 5.8.3 Identification of Applicable Groundwater Technologies ..... 5-11 I 5.8.4 Identification of Applicable Landfill Gas (LFG) Technologies 5-16 5.9 CORRECTIVE MEASURES ALTERNATIVES ...... 5-16 5.9.1 Introduction ...... 5-16 I 5.9.2 Site-Specific Factors Affecting Development of Alternatives . 5-16 5. 9.3 Description and Evaluation of Corrective Action Alternatives . 5-17 I 5.9.4 Recommended Alternative ...... 5-30

I D:IFTMCCOY JIPDCMSI\TOC. iii March 1996 Fort McCoy I Draft Co"ective Measures Study Report I Section ~

6.0 DISPOSAL SITE (PDS) ••..••••.•••••••••...... •...... 6-1 ,. 6.1 DESCRIPTION OF PESTICIDE DISPOSAL SITE ...... 6-1 I 6.2 WASTE MANAGEMENT ACTIVITIES ...... 6-1 6.3 PHYSICAL SITE CHARACTERISTICS ...... 6-1 I. 6.3 .1 Site Setting .. ·...... 6-1 6.3.2 Topography and Drainage ...... 6-1 6.3.3 Surficial Soils ...... 6-2 I 6.3.4 Geology ...... 6-2 6.3.5 Hydrogeology ...... 6-2 6.4 SITE CONCEPTUAL MODEL ...... 6-2 I 6.5 NATUREANDEXTENTOFCONTAMINATION ...... 6-2 6.6 CONTAMINANT FATE AND TRANSPORT ...... 6-3 6.7 DEVELOPMENT OF CORRECTIVE ACTION OBJECTIVES ...... 6-3 I 6.7.1 Introduction ...... 6-3 6.7.2 Federal Regulations and Permits ...... 6-4 6.7.3 Wisconsin Regulations and Permits ...... 6-5 I 6. 7.4 Local Regulations and Permits ...... 6-5 6. 7.5 Human Health and Environmental Assessment ...... 6-5 6. 7.6 Soil Corrective Action Objectives ...... 6-7 I 6. 7. 7 Groundwater Corrective Action Objectives ...... 6-7 6.8 CORRECTIVE MEASURES TECHNOLOGIES ...... 6-8 I 6.8.1 Introduction ...... 6-8. 6.8.2 Identification of Applicable Source Material Technologies .... 6-8 . 6.8.3 Identification of Applicable Groundwater Technologies ...... 6-9 I 6.9 CORRECTIVE MEASURES ALTERNATIVES ...... 6-14 6.9.1 Introduction ...... 6-14 6.9.2 Site-Specific Factors Affecting Development of Alternatives . 6-14 I 6.9.3 Description and Evaluation of Corrective Action Alternatives . 6-15 6.9.4 Recommended Alternative ...... 6-22 I 7.0 REFERENCES ...... 7-1 I LIST OF FIGURES I Fieure Follows Paee

1-1 SWMU Location Map ...... 1-1 I 1-2 Facility Location Map ...... 1-2 2-1 CL2, CL3, and the GA Location Map ...... 2-1 2-2 CL2, CL3, and the GA Groundwater Monitoring Well Locations and I Water Table Map ...... ~ ...... 2-1 2-3 CL2, CL3, and the GA Site Conceptual Model ...... 2-3 I

D:IFTMCCOY IIPDCMSIITOC. iv March 1996 I I Fort McCoy Draft Corrective Measures Study Report

I . LIST OF FIGURES (Continued)

I Fipre Follows Page

2-4 Conceptual Presentation ofln-Situ SIS Treatment ...... 2-14 I 2-5 CL2 Conceptual Alternative 1 Cross-Sections ...... 2-23 2-6 CL2, CL3, and the GA Conceptual Groundwater Extraction System L~yout .... 2-27 I 2-7 CL2 Conceptual Alternative 3 Cross-Sections ...... 2-32 2-8 CL2 Conceptual Alternative 4 Cross-Sections ...... 2-36 3-1 Fire Training Bum Pit 1 Location Map ...... 3-1 I 3-2 Fire Training Bum Pit 1 Monitoring Well and Selected Soil Boring Locations and Water Table Map ...... ·...... 3-1 3-3 Fire Training Bum Pit 1 Site Conceptual Model ...... 3-2 I 3-4 Fire Training Bum Pit 1 ASISVE Well Locations ...... " ...... 3-18 3-5 Fire Training Bum Pit 1 Typical Air Sparging Well ...... 3-18 3-6 Fire Training Bum Pit 1 Typical Soil Vent Construction ...... 3-18 I 3-7 Fire Training Bum Pit 1 Conc~ptual Groundwater Extraction and Treatment System Layout ...... 3-23 4-1 Fire Training Bum Pit 2 Location Map ...... 4-1 I 4-2 Fire Training Bum Pit 2 Groundwater Monitoring Well Locations and Water Table Map ...... 4-1 4-3 Fire Training Bum Pit 2 Site Conceptual Model ...... 4-2 I 4-4 Fire Training Bum Pit 2 Conceptual Groundwater Extraction and Treatment System Layout ...... 4-17 I 5-1 Closed Landfill 4 Location Map ...... 5-1 5-2 Closed Landfill4 Groundwater Monitoring Well Locations and Water Table Map ...... 5-1 I 5-3 Closed Landfill4 Site Conceptual Model ...... 5-2 5-4 Closed Landfill4 Conceptual Presentation of In-Situ SIS Treatment ...... 5-10 5-5 Closed Landfill 4 Conceptual Groundwater Extraction and Treatment System I Layout ...... 5-20 6-1 Pesticide Disposal Site Location Map ...... 6-1 6-2 Pesticide Disposal Site Groundwater Monitoring Well Locations and Water I Table Map ...... 6-1 6-3 Pesticide Disposal Site Conceptual Model ...... 6-2 I 6-4 Pesticide Disposal Site Conceptual Groundwater Extraction and Treatment System Layout ...... · ...... ~ ...... 6-19 I I I

I D:IF1MCCOYJIPOCMSJ\10C. v March 1996 Fort McCoy I Draft Co"ective Measures Study Report

. LIST OF TABLES I

Follows Paa=e ,. I 1-1 SWMUs Investigated in RFI Addressed by CMSR ...... 1-1 2-1 CL2, CL3, and GA Groundwater Quality Summary ...... 2-4 I 2-2 CL2, CL3, and GA Corrective Action Objectives, General Response Actions, and Corrective Measures Technologies ...... 2-11 2-3 CL2, CL3, and GA Corrective Measures Alternatives Technologies ...... 2-21 I 2-4 Applicable Regulations for Erosion Protection/Slope Stabilization Measures at CL2 ...... 2-24 2-5 CL2, CL3, and GA Alternative 1 Capital Cost Estimate ...... 2-26 I 2-6 CL2, CL3, and GA Alternative 1 O&M Cost Estimate ...... 2-26 2-7 CL2, CL3, and GA Alternative 2 Capital Cost Estimate ...... 2-31 2-8 CL2, CL3, and GA Alternative 2 O&M Cost Estimate ...... ; ...... 2-31 I 2-9 CL2, CL3, and GA Alternative 3 Capital Cost Estimate ...... 2-35 2-10 CL2, CL3, and GA Alternative 3 O&M Cost Estimate ...... 2-35 2-11 CL2, CL3, and GA Alternative 4 Capital Cost Estimate ...... 2-40 I 2-12 CL2, CL3, and GA Alternative 4 O&M Cost Estimate ...... 2-40 2-13 CL2, CL3, and GA Corrective Measures Alternatives Cost Estimate Summary . 2-26 2-14 CL2, CL3, and GA Corrective Measures Alternatives Comparison ...... ·.. 2-40 I 3-1 FTBP1 Groundwater Quality Summary ...... 3-3 3-2 FTBP1 Corrective Action Objectives, General Response Actions, and Corrective I Measures Technologies ...... • ...... 3-8 3-3 FTBP1 Corrective Measures Alternatives Technologies ...... 3-17 3-4 FTBP1 Alternative 1 Capital Cost ...... 3-22 I 3-5 FTBP1 Alternative 1 O&M Cost ...... 3-22 3-6 FTBP1 Alternative 2 Capital Cost ...... 3-27 3-7 FTBP1 Alternative 2 O&M Cost ...... 3-27 I 3-8 FTBP1 Alternative 3 Capital Cost ...... 3-31 3-9 FTBP1 Alternative 3 O&M Cost ...... 3-31 ·.a 3-10 FTBP1 Corrective Measures Alternatives Cost Estimate Summary ...... 3-31 3-11 FTBP1 Corrective Measures Alternatives Comparison ...... 3-31 4-1 FTBP2 Groundwater Quality Summary ...... 4-3 4-2 FTBP2 Corrective Action Objectives, General Response Actions and Corrective I Measures Technologies ...... 4-8 4-3 FTBP2 Corrective Measures Alternative Technologies ...... 4-13 I 4-4 FTBP2 Alternative 1 O&M Cost Estimate ...... 4-16 4-5 FTBP2 Alternative 2 Capital Cost Estimate ...... 4-19 4-6 FTBP2 Alternative 2 O&M Cost Estimate ...... 4-19 I 4-7 FTBP2 Corrective Measures Alternatives Cost Estimate Summary ...... 4-19 4-8 FTBP2 Corrective Measures Alternatives Comparison ...... 4-19 5-1 CL4 Groundwater Quality Summary ...... 5-2 I 5-2 CL4 Corrective Action Objectives, General Response Actions, and Corrective Measures Technologies ...... 5-8 I

D:IFTMCCOYJIPDCMSJ\TOC. vi March 1996 I I Fort McCoy Draft Corrective Measures Study Report

I . LIST OF TABLES (Continued)

I FollowsPa&e

5-3 CL4 Corrective Measures Alternatives Technologies ...... 5-17 I 5-4 CL4 Alternative 1 O&M Cost Estimate ...... 5-20 5-5 CL4 Alternative 2 Capital Cost Estimate ...... 5-23 I 5-6 CL4 Alternative 2 O&M Cost Estimate ...... 5~23 5-7 CL4 Alternative 3 Capital Cost Estimate ...... 5-26 5-8 CL4 Alternative 3 O&M Cost Estimate ...... 5-26 I 5-9 CL4 Alternative 4 Capital Cost Estimate ...... 5-29 5-10 CL4 Alternative 4 O&M Cost Estimate .. : ...... 5-29 5-11 CL4 Corrective Measures Alternatives Cost Estimate Summary ...... 5-29 I 5-12 CL4 Corrective Measures Alternatives Comparison ...... ·...... 5-29 6-1 PDS Groundwater Quality Summary ...... 6-3 6-2 PDS Corrective Action Objectives, General Response Actions, and Corrective I Measures Technologies ...... 6-8 6-3 PDS Corrective Measures Alternatives Cost Estimate Summary ...... 6-15 6-4 PDS Alternative 1 Capital Cost Estimate ...... 6-18 I 6-5 PDS Alternative 1 O&M Cost Estimate ...... 6-18 6-6 PDS Alternative 2 Capital Cost Estimate ...... 6-21 I 6-7 PDS Alternative 2 O&M Cost Estimate ...... 6-21 6-8 PDS Corrective Measures Alternatives Cost Estimate Summary ...... 6-22 I 6-9 PDS Corrective Measures Alternatives Comparison ...... 6-22 I LIST OF APPENDICES Appendix

I A SWMU Corrective Action Cost Estimate Back-up Information B Revised RFI Report Groundwater Monitoring Results Tables C Selected Remediation Technologies Descriptions and Illustrations I D USEPA OSWER Directive No. 9355.0-49FS I I I I

I D:IF1MCCOYJIPDCMSJ\TOC. vii March 1996 I Fort McCoy Draft Corrective Measures Study Report

I LIST OF ACRONYMS/ABBREVIATIONS

I CFR Code of Federal Regulations CL2 Closed Landfill No. 2 I CL3 Closed Landfill No.3 CL4 Closed Landfill No.4 CMS Corrective Measures Study I CMSR Corrective Measures Study Report CMTAR Corrective Measures Technologies and Alternatives Report coc Chemical of Potential Concern I 1,2-DCE 1,2- Dichloroethene ECS Equipment Concentration Site ES Enforcement Standard I FTBP1 Fire Training Burn Pit No. 1 FTBP2 Fire Training Burn Pit No. 2 GA Grit Area I HSWA Hazardous and Solid Waste Amendments MCL Maximum Contaminant Level MCLG Maximum Contaminant Level Goal I MSL Mean Sea Level ow Observation Well I PAL Preventive Action Limit PCE Tetrachloroethene PDS Pesticide Disposal Site I POTW Publicly/Privately-Owned Treatment Works RCRA Resource Conservation and Recovery Act RFA RCRA Facility Assessment I RFI RCRA Facility Investigation SIS Solidification/Stabilization SSHP Site-Specific Safety and Health Plan I svoc Semi-Volatile Organic Compounds SWMU Solid Waste Management Unit TCE Trichloroethene I TSDF Treatment, Storage, or Disposal Facility USACE Corps of Engineers I USDA United States Department of Agriculture USEPA United States Environmental Protection Agency voc Volatile Organic Compounds I WAC Wisconsin Administrative Code WDNR Wisconsin Department of Natural Resources I WWTF Wastewater Treatment Facility I

I D:IF1MCCOY1\P/XMSJ\TOC. viii March 1996 I FonMcCoy Draft Corrective Measures Study Repon

I 1.0 INTRODUCTION

I l.l PROJECT OVERVIEW

Fort McCoy is permitted under the Resource Conservation and Recovery Act (RCRA) for storage I of hazardous in containers as specified in Chapter 40 of the Code of Federal Regulations (40 CFR) Part 264, Subpart I. Fort McCoy has also received a permit for open detonation ~ctivities I under 40 CFR Part 264, Subpart X. The provisions of the Hazardous.and Solid Waste Amendments (HSWA), enacted by Congress in 1984 (specifically sections 3004(u) and 3004(v)), and 40 CFR 264.101 stipulate that corrective actions for releases of hazardous constituents from solid I waste management units (SWMUs) are required at hazardous , storage, and disposal facilities (TSDF) seeking final RCRA permits. As a ·condition of Fort McCoy's permit, a RCRA Facility Assessment (RFA) was completed in 1987. The RFA identified eleven SWMUs requiring I a RCRA Facility Investigation (RFI). Four additional SWMUs (Closed 7, 8, 9, and 10) have been identified since the RF A.

I The purpose of the RFI was to evaluate if a release of hazardous constituents occurred from each SWMU, and to evaluate the nature and extent of such contamination if a release has occurred. In addition, the RFI determined if a SWMU presents a threat to human health or the environment that I necessitates additional RCRA corrective action starting with a Corrective Measures Study (CMS). The RFI (Rust E&I, November 1994) was completed in three phases during the period from August I 1991 through September 1993 with the exception ofRFI work relating to Closed Landfills 7, 8, 9, and 10 which was completed in 1995. The SWMUs investigated in the RFI are presented in Table 1-1. Table 1-1 also presents the rationale for deciding which SWMUs are addressed in this I CMS report (CMSR): . Locations of the SWMUs addressed by the CMSR are shown in Figure 1-1. Detailed descriptions I of the SWMUs are presented in Sections 2.0 through 6.0 of this report. I 1.2 PURPOSE AND ORGANIZATION OF CMSR The purpose of the CMS process for Fort McCoy is to identify and evaluate corrective measures technologies and alternatives which may be appropriate to mitigate contaminated media at each of I the six SWMUs identified in Table 1-1. Prior to the CMSR preparation, a Corrective Measures Technologies and Alternatives Report (CMTAR) (Rust E&I, June 1994) was prepared to identify and evaluate corrective measures technologies and identify corrective measures alternatives which I may be appropriate to mitigate contaminated media at each SWMU. This CMSR recommends a corrective action alternative for each SWMU from the alternatives identified in the CMTAR based I upon technical, human health, and environmental criteria specified in Attachment II to Fort McCoy's RCRA Part B Permit (USACE, August 1991).

I Once the CMSR has gone through the regulatory agency approval process, the corrective measures will be designed and implemented. The United States Environmental Protection Agency (USEPA) I

I D:IFTMCCOY 1\PDCMSI\SECTION.I 1-1 March 1996 I Fort McCoy Draft Corrective Measures Study Report

I TABLE 1-1

SWMUs INVESTIGATED IN RFI ADDRESSED BY THE CMSR I FORT MCCOY, WISCONSIN i

I Addressed ·in SWMU CMSR Reason For Inclusion/Exclusion*

Closed Landfill 2 Yes Exceedances of PALs and excess risk to hypothetical I residents at SWMU.

Closed Landfill 3 Yes Exceedances of PALs and excess risk to hypothetical I residents at SWMU. Closed Landfill 4 Yes Exceedances of PALs and excess risk to hypothetical I residents at SWMU. Closed Landfill 5 No Landfill closed in accordance with NR 500 requirements.

Closed Landfill 6 No The Iandfilled debris and soil were removed and properly I disposed. Closed Landfill 7 No RFI Report recommended long-term groundwater I monitoring Closed Landfill 8 No Landfill will be excavated and disposed off-site. This removal action constitutes the presumptive remedy.

I Closed Landfill 9 No Landfill will be excavated and disposed off-site. This removal action constitutes the presumptive remedy. I Closed Landfill 10 No Landfill will be excavated and disposed off-site. This removal action constitutes the presumptive remedy.

Landfill X No No records or information exist to verify Landfill X's I existence. A field investigation also found nothing. Fire Training Bum Pit 1 Yes Exceedances of PALs and excess risk to hypothetical I residents at SWMU. Fire Training Bum Pit 2 Yes Exceedances of PALs and excess risk to hypothetical residents at SWMU.

I Active Explosive Ordnance No SWMU is a permitted open detonation unit located in Fort Disposal Site McCoy's active North Impact Area. Safety considerations I prevent cleanup at this time. Inactive Explosive Ordnance No SWMU located in Fort McCoy's active North Impact Area. Disposal Site Safety considerations prevent cleanup at this time. I Pesticide Disposal Site Yes Exceedances of PALs and excess risk to hypothetical residents at SWMU.

Notes: I PAL= Preventive Action Limits as defined in NR 140 Wisconsin Admin. Code. CMSR = Corrective Measures Study Report. I *For a more detailed discussion, refer to Section 18.0 of Rust E&I, November I 994.

I D:IFIMCCOY/lPDCMS/lTABI·/, March 1996 JACKSON COUNTY I ------~ROECO~TY ______I

en I :E ~ 0 en :z: I ..., "'0" sn1\) I ::0 tO C'l -!=?.... I !l? c.n 1\) I I

I CLOSED lANDFILL 2 I I I I I I

I I

0 112 2 MILES SCALE I SOURCE: WISCONSIN DEPARTMENT OF TRANSPORTATION ---- MAR. 1996 FIGURE 1-1 18903 & SWMU .....ENVIRONMENT LOCATION MAP I I~U~I INFRASTRUCTURE DRAFT CORRECTIVE MEASURES STUDY I FORT McCOY, WISCONSIN I Fort McCay Draft Corrective Measures Study Report

I and Wisconsin Department ofNaturalResources (WDNR) will select a corrective action alternative for each SWMU based on the information and recommendations presented in the CMSR.

I This CMSR is presented in six sections. This Section 1.0 includes facility background information, a project overview, and purpose and organization of the CMSR. Section 2.0 addresses Closed Landfill No.2 (CL2) and Closed Landfill No. 3 (CL3). Sections 3.0 and 4.0 address Fire Training I Burn Pit 1 (FTBP1) and Fire Training Buin Pit No.2 (FTBP2), respectively. Section 5.0 addresses I Closed Landfill No.4 (CL4) and Section 6.0 addresses the Pesticide Disposal Site (PDS). 1.3 FACILITY BACKGROUND

I Fort McCoy is a U.S. Army installation located in Monroe County in the southwest portion of Wisconsin (Figure 1-2). The Installation covers approximately 93 square miles or 59,779 acres, located halfway between the cities of Tomah and Sparta, Wisconsin. Fort McCoy is bisected into I north and south portions by Wisconsin Highway 21 and is generally north of Interstate Highway 90. The installation is approximately 30 miles east of La Crosse, Wisconsin.

I Fort McCoy's mission is to provide training for the readiness of Active, Reserve, and National Guard forces. The installation serves as a support installation, which includes supporting the needs of all training units and the post's tenant activities, as well as reserve centers located off post. Fort McCoy I serves as a support installation for U.S. Army Reserve centers in Illinois, Indiana, Iowa, Wisconsin, Minnesota, and Michigan. The installation is also a major mobilization site for the U.S. Army I Reserve and Army National Guard Units. Training at Fort McCoy typically include weapons firing, artillery practice and training, vehicle I maintenance and operations, and administrative functions. Wastes generated at Fort McCoy include general refuse, asbestos, coal ash, demolition wastes, and military items used for training. These wastes are related to the activities occurring at Fort McCoy which include administrative activities, I vehicle maintenance, and training by Army Reserve Units. Since the establishment of the Installation in 1905, various types of wastes were generated. The character of the waste has not I changed drastically since the 1940s when base operations expanded for World War II. I I I I I

I D:IFTMCCOYJIPOCMSJISEC110N.l 1-2 March 1996 I ~ I

I ..... 0 n 61 "C c zCi'> I .,., <11 Wisconsin I cr I I I ·I I I I I I N I I I MAR. 1996 18903 ... _..ENVIRONMENT & FIGURE 1-2 I I~U~I INFRASTRUCTURE FACILITY LOCATION MAP DRAFT CORRECTIVE MEASURES STUDY I FORT McCOY, WISCONSIN I Fort McCoy Draft Co"ective Measures Study Report

I 2.0 CLOSED LANDFILL NO. 2, CLOSED LANDFILL NO. 3, AND GRIT AREA

I 2.1 INTRODUCTION I Given the close proximity of CL2, CL3, and the Grit Area (GA), and generally similar site characteristics, all three areas will be addressed in Section 2.0. I 2.2 DESCRIPTION OF CL2 AND CL3

CL2 and CL3 are described in detail in Sections 6.0 and 7.0, respectively, of the RFI Report. The I Grit Area was considered as part ofCL3 in the RFI. CL2 includes a landfill area west of the Fort McCoy wastewater treatment facility {WWTF) west to the La Crosse River. CL3 includes a landfill area south of the Fort McCoy WWTF, and an area referred to as the Grit Area east of the WWTF. .I Both CL2 and CL3 are located in theN 112 of theSE 114 of Section 27, Tl8N, R3W, Monroe County, Wisconsin. The location of CL2, CL3, and the GA at Fort McCoy are shown on Figure 2-1. I Figure 2-2 illustrates the immediate site setting of the three areas. 2.3 WASTE MANAGEMENT ACTIVITIES

I Detailed records of wastes and volumes disposed are not available. No documentation was found I that would indicate the waste disposed would today be classified as a RCRA . CL2 is believed to have been used from 1942 to 1945 for disposal of ash, construction materials, and other nonrecyclable waste. In addition, a pile of concrete rubble was deposited on top of the I previous fill sometime between 1958 and 1965. A 1979 RCRA Abatement Survey (U.S. Army Corps of Engineers, June 1979) reported the presence of empty drums which previously contained lube oil, an empty solvent can, and oily leachate. No additional.information regarding the I empty drums is available. No empty solvent cans or oily leachate were observed during RFI field activities.

I According to the 1979 RCRA Pollution Abatement Survey, CL3 was reportedly used for only one year (1950) for disposal of ash, clinker, and noncombustible waste. The Grit Area east of the WWTF consists of low piles of residual solids from the WWTF placed there up until approximately I 1989. I 2.4 PHYSICAL SITE CHARACTERISTICS This subsection describes the physical setting of CL2, CL3, and the GA based on information I presented in the RFI. I 2.4.1 Site Setting The CL2 area forms a nearly level plateau above lower wetland areas of the floodplain. CL2 is I situated adjacent to and partially in the 100-year floodplain ofthe La Crosse River near the western

I D:IFTMCCOY JIPOCMSIISECllON.2 2-1 March 1996 I N I I I I I PESl1CIDE DISPOSAL SITE I I Cl2, CL3, AND I THE GA I I I I I I I

0 1/2 I 2 MILES SCALE I SOURCE: WISCONSIN DEPARTMENT OF TRANSPORTATION --- MAR. 1996 FIGURE 2-1 18903 1111 _..ENVIRONMENT & CL2, CL3, AND THE GA I ~~~~ INFRASfRUCTURE LOCATION MAP DRAFT CORRECTIVE MEASURES STUDY I FORT McCOY, WISCONSIN I ./ / / / / """"" +!i i / I ~ / / / I I~-- y· OWl 1~;;/~ I /, I 1/, ~ ..;, I I I (.!) (/; I ::; I ' !! I ) a t­~ o I ~ ,..... + ... / .... + .ill§& ~ //~ ~//7/J~ i II I ::::: ~ -·~~--- TOI'OGilAPHIC CONTOUR c... I I ( // 825 GROIKIWA TER CONTOUR ' // .... GROUNDWATER FLOW DIRECTION // "· \ '// ---- ESTit.4ATED LI .. ITS OF WASTE I ' '/ .fl•Btl II GROUNDWATER t.40NITORING WELL ;-·--.... l WITH CROlHlWATER ELEVATION ;' ,...._ ···-.__ j IN FEET ABOVE t.IEAN SEA LEVEL

o.., IIA>Hli.E ( j .," WASTEWATER TREATMENT FACILITY I • SURFACE SOIL SAMPLE LOCATION 0.WI31 I ) \ l ./ \ /,, I / ..> l·;;;.. ~I I'I ::R ···~ .. / ...... y + ~ ~ .. / ./ ~.;;7 I. GROUNDWATER TABLE ELEVATIONS At«> CONtOURS 0 I'' ARE DERIVED FROM THE RFI PHASE ] l(l ,/,--····/ {~·· l ~"'"- ..... INVESTIGATION. I • I ~ , . f,r CLOSED ~ I I l / II LANOF ILL • I' £:! I jl NO, 2 I wt 6 ..f/ - fl I :::E j ~ ,fl I­ wll "' I ~ II I I

\ 0' 80' 160' I SCALE- ~ \1 ---- ~ CLOSED \ ~ LANOF ILL~~ I 3 NO. J::.J· ~ \ _ / // MAR. 1996 FIGURE 2-2 18903 ~ ( I NT CL2, CL3, AND THE GA g ~ / .....ENVIRONME & GROUNDWATER MONITORING WELL I e _, ~~~~ INFRASTRUCTURE LOCATIONS AND WATER TABLE MAP

~11 DRAFT CORRECTIVE MEASURES STUDY FORT McCOY, WISCONSIN I 8L------~~------~------I Fort McCoy Draft Co"ective Measures Study Report

I boundary ofFort McCoy as shown in Figure 2-1. The 100-year floodplain elevation at CL2 is approximately 821 feet MSL. The south and west sides of CL2 drop sharply to the wetland and river. CL2 is partially vegetated by a mixture of grasses, with sedges growing off the edges in the ,. I wetland, and conifer and hardwood trees growing toward the north end of the landfill. Mostly pine I and oak woodland occupy the lands north and east of CL2. The CL3 area is generally flat with small mounds of soil-like material in the Grit Area. The Grit Area is well vegetated by a variety of grasses. Toward the south of CL3, numerous pines are I growing that provide a relatively open-canopied woodland.

A renovation/expansion of the WWTF will occur in the near future. As currently envisioned, I renovation/expansion activities will not impact CL2, CL3, or the GA. I 2.4.2 Topography and Drainage The general topographic trend at the surface of the CL2, CL3, and GA area is flat with steep grades on the west and south sides along the La Crosse River. Figure 2-2 illustrates the general topography I of the area. The minimum topographic elevation is approximately 815 feet mean sea level (MSL) on the floodplain of the La Crosse River along the western border of the area. The western portion of the area up to elevation approximately 821 feet MSL is within the 100-year floodplain. The I maximum topographic elevation of845 MSL is located at CL3. There is little runoff from most of the area due to the relatively flat land surface and high infiltration rate. However, the steep I sideslopes of filled areas have been eroded. I 2.4.3 Surficial Soils According to the Monroe County Soil Survey (USDA, 1984), soils at the CL2, CL3, and GA area I include the Impact sand series, Tarr sand series, and Dawson peat series. The Tarr sand and Dawson peat series are present at CL2. The Tarr sand is classified as an acidic soil with pH ranging from 4.5 to 6.0, clay content less than 8 percent, and less than 2 percent organic I matter. The Dawson series is a deep, poorly drained soil found on the floodplain of the La Crosse River at CL2. It should be noted that soil on and adjacent to CL2 itself is not the soil described above, and is likely fill (unknown origin) brought in to cover waste material. The CL2 surface I consists of dark brown sand-textured media (thickness not specified) vegetated with grasses and I sparse shrubs, and partially covered with ash, clinker, and concrete. The Impact sand series is present at CL3. The Impact sand is classified as an acidic soil with pH ranging from 4.5 to 6.0, clay content less than 8 percent, and less than 2 percent organic matter. In I places at CL3, these soils may have been disrupted, removed or buried to accommodate filling or other miscellaneous construction activities. I I

I D:IF7MCCOYJIPDCMSJISEC170N.2 2-2 March /996 Fort McCoy I Draft Co"ective Measures Study Report

2.4.4 Geology I

The uppermost geologic unit at the CL2, CL3, and GA area is the Quaternary alluvium. In this area, ,. the alluvium consists of medium to coarse grained, well-sorted, stratified sand that has been I transported and deposited by local meandering streams. The bedrock was not encountered during drilling at this site which extended to a maximum depth of approximately 25 feet below ground I surface. As stated in Sections 2.4 and 2.5 of the RFI Report, the alluvium varies in thickness across Fort McCoy from 0 to 100 feet thick and is underlain by a sandstone aquifer approximately 400 feet thick across Fort McCoy. The RFI Report also states that the hydraulic conductivity of the alluvium I and sandstone aquifer are approximately equal and range from 0.008 em/sec to 0.025 em/sec.

2.4.5 Hydrogeology I

Groundwater monitoring wells were installed near CL2 and CL3 during the RFI. Well locations are shown in Figure 2-2. All the wells monitor the Quaternary alluvium sand. The depth to the water I table is approximately 17 to 19 feet be,Iow the ground surface across the eastern portion of the area, decreasing to approximately 8 to 10 feet across the western portion of the area, with the water table encountering the ground surface along the western edge of CL2 next to the La Crosse River. The I groundwater flow is to the west northwest toward the La Crosse River at a hydraulic gradient of 0.008 to 0.014 ftlft. The hydraulic gradient is the change in hydraulic head (feet of water column) divided by the length of groundwater flow. This is determined by measuring the elevation of water I in monitoring wells and the distance between the wells. The in-situ hydraulic conductivity for the alluvium at CL2, CL3, and the GA calculated from RFI data has a geometric mean ranging from I 0.0061 em/sec to 0.0098 em/sec. Hydraulic conductivity is a measure of an aquifer's ability to transmit water. The larger the value of hydraulic conductivity, the greater an aquifer's ability is to transmit water. · I

Most of the area is a recharge area with the exception of the low elevation wetland and floodplain areas at the south and west sides ofCL2 and CL3. I 2.5 SITE CONCEPTUAL MODEL I A site conceptual model for the CL2, CL3, and GA area is shown in Figure 2-3. Potential contaminant transport mechanisms include precipitation infiltration, groundwater flow, leachate seepage, and and soil erosion. Secondary releases may occur through groundwater I discharge. Horizontal groundwater flow is anticipated to dominate over vertical flow. It is likely that waste extends into the groundwater at portions of the site. Potential contaminant receptors I include, primarily, aquatic species of animals and plants, and wetland plants located along the La Crosse River next to CL2. The La Crosse River is the only body of surface water potentially affected by CL2, CL3, and the GA. Humans could be exposed from ingesting soil, river water, or I groundwater, or dermal contact. Plant uptake of contaminants could also occur atop the waste, and animals could be exposed to the waste during burrowing. Secondary receptors could include wildlife that may ingest potentially contaminated aquatic animals or plants. I I

D:IF7MCCOYJIPIX'.MSJISEC170N.2 2-3 March 1996 I I I I NORTHWEST SOUTHEAST

CLOSED LANDFILL NO. 3 WASTE CONSISTS OF METAL DEBRIS I WITH SOME GLASS AND CONSTRUCTION DEMOLITION MATERIAL ~ ~ ~ I c./) 1- 0 -' ~ 1- 0 GRIT AREA -' 0.. SURFACE SOIL I ..:,;/ II I ~

SH, CLINKER E0 I AT SURFACE ~ I I ~ ~ 1'­ "' I ~ v

~ GROUNDWATER FLOW DIRECTION ~ I Q) ,_::> II UJ ORIGINAL ~ 0 FLOODPLAIN SURFACe CLOSED LANDFILL NO. 2 I WASTE CONSISTING OF DARK BROWN ORGANIC RICH SAND, FILL, OCCASIONAL GLASS AND METAL I I , I ~ :;:: / NOT TO SCALE j I :g UAD 1996 ~ .•. ~... 1-IGUI-

I 2.6 NATURE AND EXTENT OF CONTAMINATION

Sampling and analysis of the various media (soil, waste, groundwater, surface water, sediment, I leachate) at CL2, CL3, and the GA has occurred both during and after the RFI. Description of these activities as well as analytical results are presented in detail in Sections 6.0 and 7.0 of the RFI report. I Inorganics (metals) are the predominant category of compounds detected consistently in samples from the area. Concentrations of inorganic compounds detected in soil/waste were generally significantly lower in CL3 and the Grit Area as compared to CL2. Of the metals detected in samples I from the area above background in the soil/waste, iron, manganese, and selenium were the only metals somewhat consistently detected in groundwater at concentrations above background and WDNR Preventive Action Limits (PALs). The PAL is genemlly set as 10 percent or 20 percent of I the Enforcement Standard (ES). The ES is defined inNR 140.05 as a numerical value expressing the concentmtion of a substance in groundwater which is adopted under Wisconsin Statute 160.07 and NR 140.10 and NR 140.12. The numerical values for PALs and ESs are presented in NR 140.10 I and NR 140.12. Of these three metals, background groundwater values for iron and selenium exceed WDNR PALs. Iron and manganese are not NR 140 parameters. Evaluation of surface water and sediment sample analytical results indicates that inorganic compounds are not migrating I into the La Crosse River.

Several organic compounds (VOCs, SVOCs, ) were detected in soil/waste samples from I the area, but their occurrence was very sporadic with relatively low concentmtions. Of the VOCs detected in soil/waste, only acetone, methylene chloride, and tetrachloroethene were detected in I groundwater. Acetone and methylene chloride are chemicals commonly used in laboratories, laboratory contaminants, and may not be site-related. Tetrachloroethene was detected and reported at values without a "J" (estimated value) code in only two wells (OW-102 and 106). A result is an I estimated value, or J coded, if(1) the reported value is above the labomtory method detection limit but below the labomtory quantitation limit or (2) there are problems associated with the labomtory's quality control analytical results. Of the SVOCs detected in soil/waste, only bis (2-ethylhexyl) I phthalate was detected in groundwater. Bis (2-ethylhexyl) phthalate is a chemical commonly used in laboratories, a laboratory contaminant, and may not be site-related. None of the pesticides detected in soil/waste were detected in groundwater. A summary of CL2, CL3, and GA area I groundwater monitoring results is presented in Table 2-1. Evaluation of surface water and sediment sample analytical results indicates that organic compounds are not migrating into the La Crosse I River. Figure 2-2 illustrates the areal extent of estimated limits of waste at CL2, CL3, and the GA. The I areal extent of estimated limits of waste for CL2 is approximately 4.5 acres based upon RFI results. The areal extent of estimated limits of waste for CL3 and the Grit Area east of the WWTF remain I the same as shown in the RFI report at 2.2 acres and 1.3 acres, respectively. Based upon RFI test pit results, it appears contamination (including waste material) extends at least to the water table at CL2 with waste material detected at depths below the observed water table. The I depth to the water table varies across CL2, CL3, and the GA as discussed in Section 2.4.5. I

I D:IFTMCCOY /IPDCMSI\SECTION.1 2-4 March 1996 ------

FortMcCo) Draft Corrective Measures Study Repor

TABLE2-l

GROUNDWATER QUALITY SUMMARY CL2, CL3, AND THE GA FORT MCCOY, WISCONSIN

Analytes Detected at Levels WeiiiOI Welll02 Welll03 Welll04°l Well105 Well106 Welll21 Welll22 Welll31 Exceeding NR 140 Public Health Sampling Event Sampling Event Sampling Event Sampling Event Sampling Event Sampling Event Sampling Event Sampling Event Sampling Event Standards I 2 3 4(l) 5 I 2 3 4(1) 5 I 2 3 4(l) 5 I 2 3 4 5 I 2 3 4 5 I 2 3 4 5 I 2 3 4(1) 5 I 2 3 4(1} 5 I 2 3 4 5 PAL ES - - -- NS 2J - - - NS -- - - NS ------. . - - . . - - . NS . - . NS NS - - . NS NS . . . - 0.5 5.0 Tetrachloroethene 2J - - . NS . 14 - . NS . . . • NS . 2J • . . 3J 2J • . - 3J IJ 0.6 - . NS . -- NS NS . . - NS NS IJ . . - 0.5 5.0 Trichloroethene -- . . NS . IJ - . NS - - . • NS - - . . . - ...... - . NS . - . NS NS . - . NS NS - . . - 0.5 5.0 Bis(2-Ethylhexyl) 2BJ • . . NS . 5J • . NS 2BJ • . • NS . . . . lOB - . . - 57B . . . . . NS 5J - - NS NS 2J - . NS NS - . . 7BJ 0.3 3.0 phthalate Cadmium . - . . NS . - . . NS - . . - NS . . . - . . . . - . . --- . NS 5 - - NS NS -- . NS NS - - -- 0.5 5.0 Chromium . - . . NS 123 - - . NS 22J • . - NS . . . - . . . . - . -- . . . NS . . . NS NS - . . NS NS . - - - 10.0 100.0 Lead . . . - NS - 1.9. - NS . . 10.0 • NS . . - - . . - 13 . . - . . 17 2.1 NS . 29 - NS NS 1.6J • - NS NS -- - . 1.5 15.0 Selenium . . . - NS II . . - NS II . - • NS . . - - . . - - . . - - . . - NS . . . NS NS . . - NS NS - - . . 10.0 50.0 Nitrate & Nitrite - - - . NS 2,520 4,350 •• NS 7,570J4,510- - NS . . - -- 2,920 •• - - . . - . . NS -- . NS NS 2,940 • . NS NS 2,080 • 2,200 • 2,000 10,000 Mercury - . . . NS - . . . NS . . . • NS . - - I.SB . . -- 1.3B - - . . 1.2B - NS . . - NS NS . -- NS NS - • 1.6B - 0.2 2.0 Antimony 125 - - . NS . . - . NS - - . • NS - . . . - 49 . . - . 87 -- - . NS - - . NS NS - . . NS NS . - - . 1.2 6.0 NOTES:

All values in ug/1. ES Enforcement S\andard NS Well not sampled. PAL Preventive Action Limit (I) Samples analyzed only for VOCs. Sampling Event I • Phase I RFI, April • May 1992 (1) Well 104 is upgradient ofCL2 and CLJ. Sampling Event 2 - Phase 2 RFI, October - November 1992 J Estimated value. Sampling Event 3 • Phase 3 RFI, May- August 1993 B Analyte found in associated blank. Source of mercury was acid used to preserve samples analyzed for metals in Phase 4. It is not site related. Sampling Event 4 • Interim Monitoring, July 1994 - Analyte not detected in sample at or above the PAL value. Sampling Event 5 - Interim Monitoring, June 1995 i Wells 121, 122, and 131 were not installed until Sampling Event2. II

D'IF1MCCOYIIPOCMSJITAB1-I March/996 I Fort McCoy Draft Co"ective Measures Study Report

I RFI test pit results for CL3 indicate the presence of waste material at depths up to 12 feet. The test pit excavation did not extend any deeper than 12 feet nor to the water table due to trench sidewall I failure. For the Grit Area east of the WWTF, it appears contamination is essentially limited to the top 2 feet I of soil with the exception of sporadic detections of zinc at depth as described in the RFI report. This observation correlates well with the understanding that WWTF grit was spread on the ground I surface. 2.7 CONTAMINANT FATE AND TRANSPORT

I Data from Sections 6.0 and 7.0 of the RFI Report indicate elevated concentrations of approximately 17 metal compounds in the soil/waste. The presence of eight of these metal compounds (antimony, cadmium, chromium, iron, lead, manganese, selenium, and zinc) in groundwater at concentrations I above background and WDNR PALs indicates that some of the metal compounds present are leaching into the groundwater. Of these eight metals, only five are NR 140 public health parameters (antimony, cadmium, chromium, lead, and selenium). Aluminum, arsenic, copper, nickel, and I magnesium were also detected in groundwater above background values, however, either no PALs have been established for these constituents or their detected values did not exceed a PAL. The fact I that more of the metal compounds detected in the soil/waste are not detected at those elevated levels in groundwater demonstrates that certain metals present in the soil/waste are either not mobile in the I site environment or are not present in quantities necessary to create a groundwater impact. While several VOCs, SVOCs, and pesticides were detected in the soil/waste, they were found very sporadically and at low concentrations. In addition, of the VOCs, SVOCs, and pesticides detected I in the soil/waste, only three VOCs and one SVOC were detected in the groundwater. From these four compounds, three (acetone, methylene chloride, and bis (2-ethylhexyl) phthalate) are commonly used in laboratories, and the fourth (PCE) was detected in only one well (OW-102) during only one I ofthe three RFI sampling events at concentrations exceeding 1.0 ug/1 without a "J" (estimated value) code. Benzene, which was not detected in the soil, was detected in groundwater only once (OW-102) in the first sampling round and at a level below the ES. It does not appear to be site I related. I 2.8 DEVELOPMENT OF CORRECTIVE ACTION OBJECTIVES I 2.8.1 Introduction The purpose of this section is to identify applicable soil and groundwater contaminant limits for the chemicals of potential concern (COCs) identified in the RFI Report for CL2, CL3, and the GA, and I use those to develop soil and groundwater corrective action objectives. These soil and groundwater contaminant limits are based on public health and environmental criteria, information gathered during the RFI, and applicable WDNR and USEPA regulations. These soil and groundwater I contaminant limits will be considered during the identification and development of appropriate corrective action technologies and alternatives. I

I D:IFTMCCOY JIPDCMSJISEC770N.1 2-5 March 1996 Fort McCoy I Draft Co"ective Measures Study Report

The COCs identified for groundwater and soil at CL2, CL3, and the GA are: I

Chemicals of Potential Concern ,. I Benzene (groundwater) Tetrachloroethylene (groundwater) . I Trichloroethylene (groundwater) Bis(2-ethylhexyl)phthalate (groundwater) Cadmium (groundwater) I Chromium (groundwater) Antimony (groundwater, soil) Lead (groundwater) I Nitrate+Nitrite (groundwater) Selenium (groundwater) Arsenic (soil) I The above compounds were selected as COCs based on any one of the following: ·I • COC equals or exceeds an NR 140 PAL in groundwater samples collected from a downgradient monitoring well. I • COC is a primary contributor to calculated human health risks associated with groundwater exposure pathways under hypothetical future residential use risk scenario at CL2, CL3, and the I GA.

• COC is a primary contributor to calculated human health risks associated with soil exposure I pathways under hypothetical future residential use risk scenario at CL2, CL3, and the GA.

2.8.2 Federal Regulations and Permits I 2.8.2.1 Groundwater Standards I The established Safe Drinking Water Act Maximum Contaminant Levels (MCLs) identified in 40 CFR 161 for the identified COCs are presented below. I Federal MCL Chemical of Potential Concern uWI I

Benzene 5 Tetrachloroethylene 5 I Trichloroethylene 5 Bis(2-ethylhexyl)phthalate<1> 6 Cadmium 5 I Chromium 100 Antimony 6 I

D:'FTMCCOY/IPDCMSI'SEC170N.2 2-6 March 1996 I I 7 FMM£~ / Draft Corrective Measures Study Report

I Lead 15(2) Nitrate+Nitrite' 10,000 I Selenium 50 Arsenic 50

I O> Di(2-ethyl hexyl) phthalate is a synonym for bis(2-ethyl hexyl) phthalate. <2> Action Level; No MCL established

I 2.8.2.2 Soil Standards I There are no federal soil quality standards which apply with respect to soil cleanup objectives. 2.8.2.3 Surface Water Standards

I Surface water standards are established under 40 CFR 122.2 of the Clean Water Act. These standards address point source discharges and are not directly applicable to measurable surface water I quality. I 2.8.3 Wisconsin Regulations and Permits 2.8.3.1 Groundwater Standards

I Wisconsin has implemented the Safe Drinking Water Act under NR 809 and has either adopted the federal standard or developed a more stringent level. Groundwater quality standards are contained in NR 140. The groundwater quality standards consist of PALs and ESs. The PALs, ESs, and . I Wisconsin MCLs for the identified COCs are listed below.

PAL ES Wisconsin MCL I Chemical of Potential Concern u~l uWI u~a

Benzene 0.5 5 5 I Tetrachloroethylene 0.5 5 5 Trichloroethene 0.5 5 5 I Bis(2-Ethylhexyl)phthalate 0.3 3 N/A Cadmium 0.5 5 5 Chromium 10 100 100 I Antimony 1.2 6 6 Lead 1.5 15 N/A Nitrate+Nitrite 2,000 10,000 10,000 I Selenium 10 50 50 Arsenic 5 50 50

I NOTES: NIA =No standard available I

I D:IFTMCCOYIIPDCMSJISEC710N.2 2-7 March 1996 Fort McCoy I Draft Co"ective Measures Study Report

2.8.3.2 Soil Quality Standards· I

WDNR has issued NR 720 regulations which address residual soil contaminant levels. A human ,. health and environmental assessment was completed and approved for CL2, CL3, and the GA during I the RFI. Contaminant concentration limits for soil resulting from that assessment and an evaluation of the NR 720 regulations are discussed in Section 2.8.6. I 2.8.3.3 Surface Water Standards I Surface Quality Standards are contained in NR 102-105. Surface water standards for the COCs were not exceeded. I 2.8.4 Local Regulations and Permits

There are no local regulations or permits which contain soil or groundwater cleanup objectives. I 2.8.5 Human Health and Environmental Assessment I A human health assessment of potential risks was completed for CL2, CL3, and the GA using Phase 1 and Phase 2 RFI data (SEC Donohue, November 1994). As required by USEPA and I WDNR, potential exposure scenarios were evaluated and include scenarios involving hypothetical residents and trespassers. COCs which contribute to excess risk are based on hypothetical residents living at CL2, CL3, and the GA include the following: I Chemical Media Affected I Antimony Soil, Groundwater Arsenic Soil I As stated in 40 CFR 300:430(e)(2)(i)(A)(2) of the National Contingency Plan (NCP), "for known or suspected carcinogens, acceptable exposure levels are generally concentration levels that represent an excess upper bound lifetime risk to an individual of between 10-4 (1 in 10,000) and 10-6 I (1 in 1,000,000) using information on the relationship between dose and response." In addition, USEPA's Office of Solid Waste and Emergency Response (OSWER) Directive No. 9355.0-49FS (Presumptive Remedy for CERCLA Municipal Landfill Sites) (see Appendix D), it is stated "that I based on site-specific conditions, an active response is not required if groundwater contaminant concentrations exceed chemical-specific standards but the site risk is within the Agency's acceptable I risk range (10-4 to 10-6)." Therefore, consistent with Sections 5.1 and 5.2 ofthe'approved human health risk assessment, for the purpose of discussion in the CMS Report, excess risk is defined as total excess cancer risk levels to any population exceeding 10-4 and noncarcinogenic hazard index I (Ill) greater than 1E+OO (1.0). The excess health risk based on exposure to soil for the hypothetical residential scenario is based on contaminant (antimony and arsenic) concentrations detected at CL2. I This identification of COCs which contribute to excess risk based on the hypothetical scenario of residents living at CL2, CL3, and the GA is presented since this scenario was one of the criteria used I

D:IFTMCCOYIIP!XMSIISEC110N.2 2-8 March 1996 I I Fort McCoy Draft Co"ective Measures Study Report

I to include an SWMU in the CMS. This hypothetical residential scenario asswnes both daily contact and conswnption of soil and groundwater at the site 350 days per year for a period of 30 years. However, it should be noted that there are several institutional controls that would prevent residential I development on at CL2, CL3, and the GA. These controls include: I • NR 812.08 prohibits the installation of new water supply wells within 1,200 feet of a solid waste site.

I • CL2, CL3, and the GA are expected to remain the property of the U.S. Army and continue to have associated access restrictions.

I • If CL2, CL3, or the GA do not remain the property of the U.S. Army, restrictive covenants could be written into a site property deed to notify a prospective purchaser of the location and I source of solid waste/contamination and that land and groundwater use must be restricted. Therefore, the residential scenario will not be considered applicable to CL2, CL3, and the GA. The most likely exposure scenario would be that of a trespasser. This scenario asswnes 16 trespassing I events a year for 9 years with ingestion of and contact with contaminated soil, and contact with sediment and surface water in the La Crosse River. Contact with or ingestion of groundwater does I not apply to a trespasser since they do not have access to the groundwater. _ As concluded in the above referenced hwnan health assessment, trespassers at CL2, CL3, and the I GA are not exposed to excess health risks based upon existing soil, sediment, and surface water 4 contaminant concentrations as detected during the RFI (carcinogenic risk=1E-06<10 ; HI=2E-01<1.0). In addition, wastewater treatment plant workers orally exposed to soils are not 4 I exposed to excess health risks (carcinogenic risk=5E-06<10 ; HI=3E-02<1.0).

Field assessment of ecological communities at CL2, CL3, and the GA indicate a potential risk only I at the portion of CL 2 adjacent to the La Crosse River. An event that would disturb CL2 and release contaminants could potentially present an ecological risk situation. Such events could include I uncontrolled erosion or excavation. 2.8.6 Soil Objectives

I For the purpose of addressing NR 720.19, it is proposed that existing .soil contaminant levels be considered acceptable for residual soil contaminant levels. Based on the hwnan health assessment I results using the trespasser scenario, existing soil contaminant levels do not create an excess health risk. As stated in Section 5.3 of SEC Donohue, November 1994, Human Health Assessment appendix to the RFI, lead exposures to soils and groundwater are not a concern. This determination I was made based on calculations using the geometric mean value for all soil or groundwater samples at a particular SWMU. The actual measured groundwater contaminant concentrations from the RFI, which indicate .only sporadic exceedances of NR 140 groundwater standards (see Table 2-1), I preclude the need to calculate predicted groundwater concentrations. Given the age of waste material present at CL2, CL3, and the GA, it is expected that groundwater contaminant I concentrations will decrease over time. The environmental assessment determined that an ecological

I D:IFTMCCOYJIPDCMSJISECTJON.2 2-9 March 1996 Fort McCoy I Draft Corrective Measures Study Report risk is present only if portions of CL2 are disturbed by uncontrolled erosion or excavation. I Therefore, existing soil contaminant levels are acceptable if institutional and engineering controls are provided to prevent uncontrolled erosion or excavation. ,. I 2.8. 7 Groundwater Objectives I Site-specific groundwater objectives identified for CL2, CL3, and the GA were developed by reviewing and evaluating the Federal MCLs, Wisconsin MCLs, and Wisconsin groundwater standards (PALs and ESs). I

The following paragraph is based on excerpts from 57FR31780 and 31797 (pages 31780 and 31797 of the July 17, 1992, Federal Register): The Safe Drinking Water Act (SDWA) requires USEPA to I publish maximum contaminant level goals (MCLGs) for contaminants whichmay have any adverse effect on the health of persons and which are known or anticipated to occur in public water systems. MCLGs are to be set at a level at which no known or anticipated adverse effects on the health of I persons occur and which allows an adequate margin of safety. At the same time the USEPA publishes a MCLG, it must also promulgate a National Primary Drinking Water Regulation which includes either 1) a MCL, or 2) a required treatment technique. An MCL must be set as close to the I MCLG as feasible. Under the SDWA, "feasible" means "feasible with the use of the best technology, treatment techniques, and other means which the Administrator finds, after examination I for efficacy under field conditions and not solely under laboratory conditions (taking cost into consideration)." Other technology factors that are considered in determining the MCL include the ability of laboratories to measure accurately and consistently the level of the contaminant with I available analytical methods.

As presented in 2.8.2 and 2.8.3 above, ESs are generally equal to federal and Wisconsin MCLs. I Since the ESs are generally the same as corresponding MCLs, they represent the lowest possible contaminant concentrations "technically and economically feasible" as required by NR 140.24(2). However, since WDNR interprets State of Wisconsin law to require that PALs be the goal of I groundwater remediation, PALs are proposed as the groundwater objectives which means corrective measures will be developed to attempt to reduce groundwater contaminant concentrations to levels less than the PAL. The selected groundwater objectives for the COCs are presented below. I Chemical of Potential Concern PAL (ua/1) I Benzene 0.5 Tetrachloroethylene 0.5 I Trichloroethylene 0.5 Bis(2-ethylhexyl)phthalate 0.3 Cadmium 0.5 I Chromium 10.0 Antimony 1.2 Nitrite+Nitrate 2,000 I Selenium 10.0 Lead 1.5 I

D:IFTMCCOY JIPDCMSIISEC110N.2 2-10 March 1996 I I Fort McCoy Draft Corrective Measures Study Report

I The COCs to be addressed in the following technologies and alternatives sections will be those COCs detected in groundwater at levels equal to or exceeding the PAL in downgradient monitoring I wells as shown in Table 2-1. The exception is Bis(2-ethylhexyl)phthalate which is a common laboratory contaminant. I 2.9 CORRECTIVE MEASURES TECHNOLOGIES I 2.9.1 Introduction In this section, potentially applicable corrective action technologies are identified for contaminant source material and groundwater based on an evaluation of contaminants detected. Medium-specific I (soil and groundwater) corrective action objectives developed in Section 2.8 were evaluated and appropriate general response actions were identified that satisfy the corrective action objectives. Potentially applicable technologies were then identified for each general response action as listed I in Table 2-2 and are discussed in Sections 2.9.2 and 2.9.3.

Relevant site-specific conditions were considered in the identification of corrective action I technologies to be retained for consideration in developing corrective action alternatives. Corrective action objectives were reviewed and applicable technologies were selected based on past experience I and verified performance information. The identified technologies that have proven effectiveness for the media and COCs and can be practically implemented, operated and maintalned given site­ specific conditions are identified as being retained for co~ideration in developing corrective action I alternatives. Table 2-2 identifies which technologies have been retained for consideration in developing the corrective action alternatives presented in Section 2.1 0.

I 2.9.2 Identification of Applicable Source Material Technologies I 2.9.2.1 Source Material Institutional Actions Fencing

I A chain link fence (six feet tall) with lockable gates could be constructed around CL2, CL3, and GA to restrict site access and disturbance of source material. Fencing would reduce the potential for I ingestion of or direct contact with waste material. Fencing would also reduce the potential for disturbance of a soil cover that may be placed over the CL2 waste material. The construction and maintenance costs for fencing are considered low in comparison to the other technologies evaluated. I Fencing will be retained for consideration in developing corrective action alternatives. I Land Use Restrictions Land use restrictions would be implemented to minimize the potential for human contact with waste material. Restrictive covenants could be placed on deeds to the CL2, CL3, and GA property to limit I the potential for land development, source material disturbance, and cover (if implemented) intrusions. Restrictive covenants, written into a site property deed, notify any potential purchaser I of the property that contaminated media remain on-site, and that the land use must be restricted. If

I D:IFJMCCOY JIPDCMSIISECTJON.2 2-11 March 1996 I Fort McCoy Draft Corrective Measures Study Report

I TABLEl-2

CL2, CL3, AND THE GA I CORRECTIVE ACTION OBJECTIVES, GENERAL RESPONSE ACTIONS AND CORRECTIVE MEASURES TECHNOLOGIES I FORT MCCOY. WISCONSIN

Technologies I Retained for General Response Corrective Measures Further Corrective Action Objectives Actions Technologies Considered Evaluation

I Prevent site access and disturbance of Institutional . Fencing Yes source material to minimize potential . Land Use Restrictions Yes for ecological impacts to LaCrosse I River. Erosion Control . Soil Cover Yes . NR 504 Cover System No . Erosion Protection Yes . Slope Stabilization Yes I . River Relocation No Remove source material to eliminate Removal . Excavation Yes in-place to minimize potential for • Ex-situ SIS No (I) I ecological impacts to LaCrosse River. Reduce concentrations of COCs in Institutional . Groundwater Use Restrictions Yes I groundwater to levels below NR 140 . Groundwater Monitoring Yes PALs, and limit groundwater use. . Surface Water/Sediment Monitoring No Containment • Low-Permeability Barrier No(l) I . Hydraulic Barrier Yes Removal . Extraction Wells Yes I • Collection Trenches No Treatment . Biological Treatment No< I) . Carbon Adsorption No(J) I • Air Stripping Yes<1> . Air Sparging/Soil Vl,lpOr Extraction No I . Natural Attenuation Yes Discharge . POTW Yes . Surface Water Yes

I NOTE:

(I) These technologies have additional information and illustrations provided in Appendix C in addition to the descriptions I presented in Sections 2.9.2 and 2.9.3. I

I D:IF1MCCOYJIPOCMSJ\TAB2-2. March 1996 I Fort McCay Draft Corrective Measures Study Report

I enforced, deed restrictions would reduee the potential for the ingestion or direct contact with waste material. It is anticipated that deed restrictions at the CL2, CL3, and the GA would limit excavation. The effectiveness of deed restrictions depends on continued enforcement. Deed restrictions are ,. I subject to changes in political jurisdiction, legal interpretation, and level of enforcement. Administration of land use restrictions would be the only cost, but would remain perpetually. Land I use restrictions will be retained for consideration in developing corrective action alternatives. I 2.9.2.2 Source Material Erosion Control Actions Soil Cover

I A soil cover would nummtze erosion potential through physical means and by virtue of run-on/runoff drainage control. A soil cover would also further isolate and prevent disturbance of the waste material. A soil cover would involve adding rooting zone soil, topsoil, and revegetating, I as needed. Native grasses will be used to the extent practicable when vegetating the soil cover. A soil cover at CL2 would reduce the potential for waste material being transported by surface runoff to the La Crosse River. A soil cover is a low-cost technology relative to other source control I technologies and could be constructed using common construction methods and equipment. The installation of a soil cover should not cause a problem with implementation of other technologies. I Soil cover will be retained for consideration in developing corrective action alternatives. I NR 504 Cover System The NR 504 cover system is the prescribed cover system by the WDNR solid waste regulations for solid waste sites. The cover system is characterized by a 2-foot thick, natural clay barrier layer I compacted to a hydraulic conductivity of 1 x 1o- 7 em/sec. The clay layer is designed and constructed to minimize the infiltration of precipitation and must be properly placed and protected to ensure long-term performance. The entire configuration of a NR 504 cover system for this site would I include the following components, in ascending order: compacted natural clay layer, sand drainage layer, protective soil layer, vegetative layer, and vegetation.

I The NR 504 cover system has been implemented at m~y landfills and proven to reduce infiltration into the landfill contents. The installation of this cover system does not require specialized equipment, but its construction is subject to a rigorous quality assurance/quality control (QA/QC) I program. An NR 504 cover system is a moderate to high cost technology. Since the objectives of a cover at CL2 are to prevent direct contact with the waste and minimize erosion of waste material, I and not minimize infiltration (portion of waste is in groundwater), the added expense of a NR 504 cover system is not justified. Therefore, the NR 504 cover system will not be retained for I consideration in developing corrective action alternatives. Erosion Protection

I Erosion protection would be implemented at CL2 to reduce the potential for erosion of waste material and damage to other technologies (soil cover, fence, etc.) by flood waters of the adjacent I La Crosse River. These measures would reduce the potential for contaminant migration and

I D:IF7MCCOYJIPDCMSJISECllON.2 2-12 March 1996 Fort McCoy I Draft Co"ective Measures Study Report decrease the maintenance needs of· other technologies remaining on-site long term. Erosion I protection may utilize gabions (rock filled wire baskets), riprap, berms, diversion channels, or other engineered structures. The costs of these erosion protection measures are relatively low and these measures can be constructed using common construction methods and equipment. Erosion I protection will be retained for consideration in developing corrective action alternatives. I Slope Stabilization

Slope stabilization would be required only at CL2 where landfill sideslopes are steep along the I La Crosse River. Measures could include regrading to a stable slope where possible, reconstructing embankments or flood protection. Relative costs for slope stabilization at CL2 are low and slope stabilization could be constructed using common construction methods and equipment. Slope I stabilization will be retained for consideration in developing corrective action alternatives.

River Relocation I

Erosion of CL2 sideslopes could be prevented by relocating the La Crosse River to the west. Relative costs for river· relocation would be high given the costs associated with performing I environmental impact studies to address impacts to existing wetlands and wildlife in addition to costs for design, permitting and construction of the river relocation and replacement wetlands. With I the significant potential for adverse impact to existing wetlands and wildlife during construction of river relocation, the permitting and approval process would be extremely lengthy. According to WDNR, unless it can be demonstrated that river relocation is required due its being adversely I impacted by CL2, it is unlikely river relocation and replacement wetlands would be approved. A consideration here is that it is sometimes difficult to construct replacement wetlands which support the same type and diversity of wildlife as the natural wetland area. With these considerations, and I the RFI Report's conclusion that CL2 is not adversely affecting surface water and sediment quality, river relocation will not be retained for consideration in developing corrective action alternatives. I 2.9.2.3 So.urce Material Removal Actions

Excavation I

Excavation .could be required in conjunction with any above ground source (waste) material treatment or disposal actions. Excavation would involve removal of source material using standard I excavation/construction equipment or special equipment adapted to minimize disturbances. Special care and precautions (silt fence, sheet piling, berms, etc.) would be necessary during excavation next I to the La Crosse River to avoid adverse short-term impacts (siltation, runoff, spills, etc) to the surface water or wetlands. Depending on how much of the waste material is present below the water table at CL2 and CL3, it may not be practical to remove all of the waste material. That would result I in a small source of groundwater contamination remaining in-place. Relative costs for excavation are moderate to high depending on excavated volume and the depth of waste below the water table. Depending on the end-use of the area, the area may need to be backfilled to conditions similar to I existing grades and contours. Excavation will be retained for consideration in developing corrective action alternatives. I

D:IFTMCCOY /IPDCMSIISEC110N.2 2-13 March 1996 I I Fort McCoy Draft Corrective Measures Study Report

I 2.9.2.4 Source Material Dispo·sal Actions I Off-Site Landfill Off-site landfilling would involve the transportation of excavated source material from the site to I an appropriate licensed landfill able to accommodate the needed capacity, pending waste testing and WDNR approval per NR 722 for volumes.exceeding 250 cubic yards. Disposal in an off-site landfill may also require pretreatment of the source material prior to acceptance by the landfill. The disposal I of source material in an off-site licensed landfill is an effective means for controlling release of contaminants to the environment. However, off-site disposal could result in additional liability for the Army if the off-site landfill becomes the source of problems in the future. Relative capital costs I iiicluding transportation, testing and treatment/disposal fees are high. Off-site landfills will be retained for consideration in developing corrective action alternatives ..

I 2.9.2.5 Source Material Treatment Actions I In-Situ Solidification/Stabilization Solidification/stabilization (S/S) reduces the. mobility of hazardous substances and contaminants in the environment through both physical and chemical means. Unlike other remedial technologies, I SIS seeks to trap or iinmobilize contaminants within their "host" medium (i.e., the soil, sand, and/or building materials that contain them), instead of removing them through chemical or physical I treatment. Leachability testing during laboratory treatability studies or pilot-scale testing at the site is typically performed to measure the degree of iinmobilization of contaminants achieved by the S/S I treatment. In-situ (in-place) S/S techniques typically use auger systems and injector head systems to apply S/S treatment agents to in-situ wastes and soils. The augers are typically mounted vertically on crawler I cranes and mix the waste/soil with the S/S treatment agents delivered to the augers by the injector head system. The S/S treatment agents are typically liquid based and delivered by pipes or hoses to the augers from on-site mixing/storage tanks. See Figure 2-4 for a conceptual presentation of the I in-situ S/S process. Due. to the addition of S/S treatment agents, the resultant volume of treated material is larger by approximately 15 percent to 100 percent depending on the amount of S/S treatment agent required to achieve satisfactory treatment. This volume increase is termed bulking I and could result in an increase of surface elevations by several feet across a treated site. An estimate of the amount of bulking cannot be made until treatability studies are performed in pre-design I activities to determine the proper reagent/waste mix. The proper reagent/mix is impacted by many factors including, but not limited to, waste type/composition, moisture content, and the allowable leachate concentration required for the treated mass. Following treatment, a cover with vegetation I is generally placed over the treated mass.

SIS is used primarily to treat inorganic compounds. Relative capital costs are high given the need I for specialized equipment, materials and procedures. Additional costs can also be incurred when the physical nature of the waste (size, hardness, etc,) prevents adequate mixing, resulting in portions of I the waste having to be excavated and disposed off-site. S/S techniques can be used alone or

I D:IFTMCCOYJIPDCMSJISEC770N.2 2-14 March 1996 ~-~--~---~~-~-~----

SOURCE: REMEDIATION TECHNOLOGIES SCREENING MATRIX AND REFERENCE GUIDE EPA/542/8-94/013 NTIS P895-104782, OCTOBER 1994

~~ Emissions, Reagent ~es Dust and'or andVOC Binder ~~ Control ~~ 3:: J> ;u w n w 0 tn CJ z ::u-n 'Injector J>Zrnn -n•-or -iVl-IN Head "Tln- Do -1 c· ··· ..-Caisson ~::ucl>n"Tl ::u rr- 3::~ VJ C> 0 -i ~ ""0· c g < (/) ::0 )> ::0 -<, rn z rn . (/) :e_, 3:: ::0-1 rnz ° N tnl>rn -1• 4~7 94P·2110 8/22/94 g~l>-II.t> z::u-1~rn ~~3:- z rnoC> lr.7 TYPICAL AUGER/CAISSON AND REAGENTnNJECTOR HEAD IN SITU ~ZZl> C-1 . SOLIDIFICATION/STABILIZATION SYSTEMS CJ 0 -< 11

..... CP w 0 VJ I Fort McCoy Draft Corrective Measures Study Report

I combined with other treatment and disposal methods to yield a product or material suitable for land disposal or, in other cases, that can be applied to beneficial use. In-situ SIS will be retained for consideration in developing corrective action alternatives. I ,. I Ex-Situ Solidification/Stabilization Similar to in-situ SIS, ex-situ SIS treated contaminants are physically bound or enclosed within a stabilized mass (solidification), or chemical reactions are induced by the stabilizing agents to reduce I the contaminants mobility (stabilization). With ex-situ SIS treatment, however, the waste material must first be excavated and sorted prior to I treatment. Treatment components could consist of a waste staging/sorting area, a pug mill mixing system that mixes the waste and stabilizing agents fed to it by conveyors or augers and a treated waste staging/sampling area. The staging, sorting and ex-situ SIS treatment would be performed in I an area adjacent to CL2, CL3 and the GA. In addition, following ex-situ SIS treatment, the treated waste would then need to be disposed of either on-site or off-site.

I Expected treatment results are essentially the same as in-situ SIS treatment with the exception that mixing of the waste and treatment agents can be better controlled ex-situ. However, given the additional costs and safety and environmental concerns associated with the excavation and handling I of the untreated waste and subsequent disposal of the treated waste, ex-situ SIS stabilization will not I be retained for consideration in developing corrective action alternatives. 2.9.3 Identification of Applicable Groundwater Technologies I 2.9.3.1 Groundwater Institutional Actions I Groundwater Use Restrictions Groundwater use restrictions would be imposed to prevent the use or installation of new private wells and public drinking .water supply wells at CL2, CL3, and the GA. Either voluntary or legal I restrictions (or both) on groundwater use may apply. Voluntary groundwater use restrictions are restrictive covenants written into a site property deed to notify any purchaser of the location and source of groundwater contamination and that groundwater use must be restricted. Legal I groundwater use restrictions would involve notifying the WDNR Bureau of Water Supply of the groundwater impacts. The Bureau keeps maps and lists of sites with groundwater impacts; however, I it is the responsibility of the well driller to be apprised of specially designated areas. NR 812.08 prohibits the installation of new water supply wells within 1,200 feet of a solid waste site I such as CL2, CL3 and the GA. Both voluntary and legal groundwater use restrictions depend on enforcement for their effectiveness. Relative costs for groundwater use restrictions are low. Groundwater use restrictions will be retained for consideration in developing corrective action I alternatives. I

I D:IF1MCCOY JIPDCMSI\SEC710N.2 2-15 March 1996 I Fort McCoy Draft Co"ective Measures Study Report

Groundwater Monitoring I Groundwater monitoring using monitoring wells would be continued at CL2, CL3, and the GA to I track groundwater quality and the effectiveness of other remediation technologies. Groundwater monitoring is a commonly used method to determine groundwater quality. Monitoring consists of collecting groundwater samples from monitoring wells and analyzing those samples to define I contaminant migration or establish increasing or decreasing concentration trends over time. Laboratory analysis detection limits will be set low enough to determine if the PALs have been exceeded. If the PAL is below the lowest detection limit, the lowest detection limit commercially I available will be utilized for evaluating groundwater standard exceedances. Relative capital costs are low; O&M costs are moderate. Groundwater monitoring will be retained for consideration in developing corrective action alternatives. I Surface Water/Sediment Monitoring I Surface water/sediment monitoring would be implemented at CL2 to track long-term surface . This commonly used method would involve collecting samples of surface water and sediment along the La Crosse River upstream, adjacent to and downstream of CL2 to determine if I contaminants are migrating in appreciable concentrations into the river. There are no capital costs; O&M costs are low. Since surface water/sediment monitoring conducted during the RFI determined CL2 is not adversely impacting surface water or sediment quality, surface water/sediment monitoring I will not be retained for consideration in developing corrective action alternatives. I 2.9.3.2 Groundwater Containment Actions

Low-Permeability Barriers I

Low-permeability barriers can be an effective component of a-groundwater containment system. The barriers can consist of a soil, bentonite and water mixture, cement and water mixture, or sheet piling I and would probably be located adjacent to the La Crosse River next to CL2. They are most effective if keyed several feet into a low permeability layer such as relatively impermeable bedrock or clay. However, a low-permeability barrier alone will only divert groundwater flow, it will not contain it. I To contain groundwater, the groundwater that flows up to and then around or under the barrier must be collected by extraction wells or collection trenches and subsequently treated and discharged. I Relative costs for low-permeability barriers would be high given the need for specialized equipment, materials and procedures to construct a barrier. Given the lack of a low-permeability layer at CL2 to key into, and the possibility of adverse impacts to the La Crosse River and adjacent wetland area I during construction ofthe low-permeability barrier, low-permeability barriers will not be retained for consideration in developing corrective action alternatives. I Hydraulic Barriers

Hydraulic barriers would be used to minimize migration of contaminated groundwater. A hydraulic I barrier would consist of a series of groundwater extraction wells or collection trenches placed adjacent to the La Crosse River next to CL2. Extracted groundwater could require treatment prior I

D: IF1MCCOY /IPIX'.MS/ISECT/ON.2 2-16 March 1996 I I Fort McCoy Draft Corrective Measures Study Report

I to discharge. Relative capital costs are moderate, O&M costs (pumping system and well maintenance) are moderate. Hydraulic barriers will be retained for developing corrective action I alternatives. I 2.9.3.3 Groundwater Removal Actions Extraction Wells

I Extraction wells would be used to collect impacted groundwater downgradient of CL2 adjacent to the La Crosse River. Generally, extraction wells would be drilled and screened in a highly permeable water-bearing zone. The wells are fitted with a pump to extract groundwater and create I a negative pressure zone to promote groundwater flow towards the wells. Extracted groundwater could require treatment prior to discharge. Relative capital costs for extraction wells are low to moderate; O&M costs are moderate. Since wells can be installed using a drill rig with little or no I excavation activity as associated with collection trenches, installation of extraction wells, if required, should have minimal potential for adverse impact on the La Crosse River. Extraction wells will be I retained for developing corrective action alternatives. Collection Trenches

I Collection trenches may be used in place of extraction wells for collecting impacted groundwater and may be very effective, depending on the hydrogeology of the site. Collection trenches are also I used frequently in lowering the local water table and controlling the direction of groundwater flow at a site. Extracted groundwater would require treatment prior to discharge. Relative capital costs I for collection trenches are generally low to moderate; O&M costs are moderate. Collection trenches will not be retained for developing corrective action alternatives here due to constructability difficulties in the saturated sandy soils and questionable effectiveness in the high I permeability sandy soils. The saturated sandy soils would make construction of a collection trench difficult and costly due to stability/sloughing potential. Given the need to install the trench adjacent to the La Crosse River next to CL2, dewatering or stabilizing the area during construction would also I be difficult and expensive. In addition, construction of the collection trench, including dewatering, could have an adverse impact on the La Crosse River and adjacent wetlands. Even if a trench could be constructed at CL2, it would have reduced effectiveness since collection trenches operate on the I basis of permeability differential. Groundwater generally prefers . flow from areas of low permeability (silts, clay) to areas of high permeability (sands, gravels). Since the area at CL2 already I naturally contains a high permeability material (sands), the effectiveness of a collection trench at CL2 would be reduced since there would be minimal difference in the permeability of the native material (sands) and the collection trench material (sands). This would result in only partial capture I of the groundwater moving past CL2. I I

I D:IFTMCCOY/IPDCMSIISEC710N.2 2-17 March 1996 I Fort McCoy Draft Corrective Measures Study Report

2.9.3.4 Groundwater Treatment Actions I Biological Treatment I ' On-site biological treatment of extracted groundwater may use either an attached or suspended­ growth biological treatment process. In suspended growth systems such as activated sludge I processes (ASP), contaminated groundwater is circulated in a mixing tank where a microbial population degrades organic matter and produces new cells. The new cells form a sludge, which is settled out in a clarifier. The sludge is eventually discarded to be further treated prior to disposal, I generally at a landfill. In attached growth systems, such as rotating biological contactors and trickling filters, microorganisms are established on fixed surfaces in a tank to degrade organic groundwater contaminants. Attached growth processes produce less sludge than ASPs. Attached I and suspended systems often are used together in series.

Biological treatment is used primarily to treat nonhalogenated VOCs, SVOCs, and petroleum I hydrocarbons. Halogenated VOCs, SVOCs, and pesticides also can be treated, but the process may be less effective and may be applicable only to some compounds within these groups. The treatment system could be located in a building at or adjacent to CL2. Relative capital costs for biological I groundwater treatment are moderate to high; O&M costs are high. Biological treatment will not be retained for developing corrective action alternatives given that it is less effective than air stripping at removing the low levels of halogenated VOCs detected in the groundwater. I Air Stripping I

Air stripping would involve pumping extracted groundwater into an air stripping vessel which uses air and water mixing to remove or strip VOCs. Types of aeration methods include packed towers, 'I diffused aeration, tray aeration, and spray aeration. The treatment system could be located in a building at or adjacent to CL2. j The target contaminant groups for air stripping systems are halogenated (PCE, TCE) and nonhalogenated VOCs. Removal efficiencies around 99 percent can be achieved for these types of contaminants. The technology can be used but may be less effective for halogenated and I nonhalogenated SVOCs and fuels. Relative capital costs for air stripping are moderate; O&M costs are low, unless vapor-phase carbon is needed (moderate if needed) to treat the exhaust air stream. Air stripping will be retained for consideration in developing corrective action alternatives. I Carbon Adsorption I Carbon adsorption would remove organic compounds from the groundwater that preferentially sorb onto carbon versus remaining in the water. On-site carbon adsorption of extracted groundwater I would involve piping extracted groundwater through a series of canisters/tanks containing activated carbon to which dissolved organic contaminants adsorb with subsequent discharge of the treated water. The technology requires periodic replacement or regeneration of the saturated carbon which I increases the cost of this technology. I

D:IF1MCCOYJIPDCMSJISECnON.2 2-18 March 1996 I I Fort McCoy Draft Co"ective Measures Study Report

I The target contaminant groups for carbon adsorption are halogenated and nonhalogenated SVOCs. The technology can be used, but may be less effective in treating halogenated VOCs (PCE, TCE), fuel hydrocarbons, pesticides, and inorganics. Relative capital costs are moderate to high; O&M I costs are moderate to high. Carbon adsorption will not be retained for developing corrective action alternatives and cost estimates given that it is generally less effective than air stripping at removing I the halogenated VOCs detected in the groundwater. I Air Sparging/Soil Vapor Extraction Air would be injected under pressure through wells below the water table to strip VOCs from groundwater. Air sparging (AS) would be conducted in conjunction with a soil vapor extraction I (SVE) system to remove stripped VOCs from the unsaturated zone. The ease and low cost of installing small-diameter air injection points allows· considerable flexibility in the design and construction of an AS remediation system. However, given the presence ofthe waste mass and the I location of CL2 with respect to the La Crosse River, design and installation of an effective AS/SVE system would be difficult. Relative capital costs for air sparging are low; O&M costs are low unless vapor-phase carbon is needed (moderate if needed) to treat the exhaust air stream. AS/SVE will not I be retained for developing corrective action alternatives because it does not provide treatment of inorganic groundwater contaminants which may need to be treated ex-situ and the difficulties I associated with designing and installing an effective AS/SVE system in a landfill setting. I Chemical Precipitation On-site chemical precipitation of extracted groundwater would be used for removing inorganic contaminants as pretreatment for other processes or to address discharge limits for inorganics. I Precipitation is a process by which the waste stream is altered to reduce the solubility of metals. The metals precipitate out as a solid phase (sludge) and are taken out of the solution by solids removal processes. Metals precipitation is not one unit operation but a combination of coagulation, I flocculation, sedimentation, and, in some cases, filtration processes. Relative capital costs are moderate; O&M costs are moderate to high due to sludge processing and off-site disposal. The treatment system could be located in a building at or adjacent to CL2. Chemical precipitation will I be retained for consideration in developing corrective action alternatives. I Natural Attenuation Natural attenuation would consist of volatilization, , recharge and dispersion, I adsorption, and chemical reactions with subsurface materials to reduce groundwater contaminant concentrations to acceptable levels. Non-destructive attenuation mechanisms include recharge and dispersion, and adsorption. The rest of the attenuation mechanisms are destructive to the I contaminants. All of these processes are naturally occurring. Natural attenuation is effective generally when contaminant concentrations are low, the contaminants have been in place for extended periods, and contaminant concentrations are steady or decreasing over time. Costs for I natural attenuation are low since it is naturally occurring and the only costs associated with it are related to monitoring activities. Once monitoring activities cease, natural attenuation becomes a no- I

I D:IFTMCCOY JIPDCMSJISEC110N.2 2-19 March 1996 I Fort McCoy Draft Co"ective Measures Study Report cost option. Natural attenuation will he retained for consideration in developing corrective action I alternatives.

,. 2.9.3.5 Groundwater Discharge Actions I Publicly/Privately-Owned Treatment Work (POTW) I If groundwater extraction is required, POTW discharge could be implemented for groundwater in conjunction with extraction and, possibly, treatment. Extracted or treated groundwater may I potentially be piped and discharged to a POTW including the on-site WWTF. Pretreatment may be required before discharge to a POTW. The relative capital cost depends on the distance to the POTW, while O&M costs are relatively low depending on pumping costs and POTW charges. I Assuming the on-site WWTF can accept the extracted groundwater with no pre-treatment, the relative capital cost should be low. Discharge to a POTW will be retained for consideration in developing corrective action alternatives. I Sutjace Water I If groundwater extraction is required, discharge to surface water could be implemented for groundwater in conjunction with extraction and treatment. Discharge to surface water involves the piping of treated groundwater to an outfall at a surface water body such as the La Crosse River or I a tributary to it subject to a WPDES permit. The relative capital cost is distance-dependent, and thus should be low at CL2, CL3, and the GA, while O&M costs are relatively low. Discharge to surface I water will be retained for consideration in developing corrective action alternatives.

2.10 CORRECTIVE MEASURES ALTERNATIVES I 2.10.1 Introduction I In this section, the corrective action technologies retained in Section 2.9 for CL2, CL3, and the GA source material and groundwater are further evaluated and assembled into corrective action alternatives. I

Assembling suitable corrective action alternatives was an iterative process that systematically combined the retained technologies into alternatives that meet the corrective action objectives (see I Sections 2.8.6 and 2.8. 7) and are the most practicable for site-specific conditions. The first step of the process consisted of evaluating all pertinent combinations of retained technologies. The I preliminary assemblage of alternatives was further evaluated to develop alternatives that were most suitable for CL2, CL3, and the GA considering the interaction of the selected technologies and site­ specific conditions. Based on this evaluation, the most suitable corrective action alternatives were I recommended to be carried forward in the CMS. I I

D:IFTMCCOYJIPDCMSIISECTION.2 2-20 March 1996 I I Fort McCoy Draft Corrective Measures Study Report

I 2.10.2 Site-Specific Factors Affectmg Development of Alternatives

The following factors related to CL2, CL3, and the GA were considered the most critical in ,. I developing corrective action alternatives: I • Groundwater flow is toward the La Crosse River. There are no current nor anticipated groundwater receptors located between CL2, CL3, and the GA, and the La Crosse River.

I • CL2, CL3, and the GA are expected to remain the property of the U.S. Army and continue to have associated access restrictions. This will also aid in the establishment and the enforcement I of land use and groundwater restrictions. • NR 812.08 prohibits the installation of new water supply wells within 1,200 feet of a solid waste I site. • CL2 is located adjacent to and partially within the 100-year floodplain of the La Crosse River.

I • There is currently little runoff from CL2, CL3, and the GA due to the flat topography and high soil infiltration rate.

I • Contamination in the GA is limited approximately to the top 2 feet of soil. I • As discussed in Section 2.7, the inorganic public health contaminants detected in groundwater at levels exceeding PALs include antimony, cadmiwn, chromiwn, lead, and seleniwn.

I • As discussed in Section 2.7, organic contaminants were detected sporadically and at low concentrations in groundwater. Only benzene, TCE, PCE, and Bis(2-ethylhexyl)phthalate were I detected above PALs. • Evaluation of La Crosse River surface water and sediment adjacent to and downgradient from CL2 indicates that inorganic and organic compounds which were sporadically det~cted in I soiVwaste and groundwater at and adjacent to CL2 are not migrating into the La Crosse River.

Based on these factors, it is recommended that the four corrective action alternatives identified and I discussed below be carried forward for evaluation in Section 2.1 0.3.

\ I 2.10.3 Description and Evaluation of Corrective Action Alternatives I 2.10.3.1 Introduction The following sections describe the four corrective action alternatives proposed for consideration and present an evaluation of the alternatives based on technical, environmental, hwnan health, and I institutional criteria as required by Fort McCoy's RCRA Part B Permit. Table 2-3 identifies the technologies in each of the four alternatives. I

I D:IF1MCCOYJIPDCMSJISECTION.2 2-21 March 1996 I Fort McCoy Draft Corrective Measures Study Report

I TABLE2-3

CL2, CL3, AND THE GA t CORRECTIVE MEASURES ALTERNATIVES TECHNOLOGIES FORT MCCOY, WISCONSIN

I Alt#l Alt#2 Alt#3 Alt#4 ... ·.

· ... ··.·· ······· I Access, X X X Land Use I Restrictions Perimeter Fence X X X (Optional) I Soil Cover X X X Erosion Protection X X X I Excavation and X Disposal

In-Situ Stabilization X I ·.· .... >< •··········

...... ······.·············· ·•·.·. ··············································.t•····. ········· >···············································<}1······················... ··... ·.·... •.··.··...... •... ·.·•···· I Use Restrictions X X X X Natural Attenuation X X X X I Monitoring X X X X Extraction and X I T1 I I I I I

D:IFTMCCOY!IPDCMSI\TAB1-3. March 1996 I Fort McCoy Draft Corrective Measures Study Report

I 2.10.3.2 Corrective Action Alternative 1 a Alternative 1 Access, Land and Groundwater Use Restrictions, I CL2 Soil Cover, Erosion Protection/Slope Stabilization at CL2, Natural Attenuation, I Groundwater Monitoring

Alternative 1 consists of access, land and groundwater use restrictions; CL2 soil cover and erosion I protection/slope stabilization; natural attenuation of low-level groundwater contamination; and groundwater monitoring. These components are descnbed below:

I • Existing access restrictions to CL2, CL3, and the GA associated with the Fort McCoy facility would be maintained. A chain-link fence (6 feet high) with lockable gates could be constructed around the perimeters ofCL2 (approximately 1,700 feet), CL3 (approximately 1,300 feet), and I the Grit Area (approximately 850 feet) to further restrict site access. The chain-link fence would be tied into the existing Wastewater Treatment Plant perimeter fence. This fence would only 'I be constructed if deemed necessary at a later date due to unauthorized access to and disturbance of the area.

I • Restrictive covenants would be placed on deeds to the property to restrict land and groundwater use. I • Erosion protection/slope stabilization measures would be implemented between CL2 and the La Crosse River (approximately 1,000 feet). Steep sideslopes along the La Crosse River would be reduced by grading the material back onto the central portion of CL2. This would not only I reduce the steep sideslopes, but also provide fill material for raising the elevation of the central portion of CL2 to improve surface runoff and reduce infiltration. This would act as a foundation for the proposed soil cover. An erosion control geosynthetic mat or armored surface component I (interlocking concrete block, gabions (rock-filled wire baskets), rip rap, or similar materials) would then be constructed on the soil cover side-slope adjacent to the river to minimize the potential for erosion of soil cover and waste materials. Vegetation may be used to supplement I the geosynthetic mat or armored surface component. The armored surface component may also I need to be supported by a subsurface anchor component or a sheet pile wall. • A soil cover would be placed on CL2 to minimize disturbance and erosion of source material and promote stormwater runoff. The soil cover thickness would be a minimum of 18-inches. I The soil cover would consist of natural soil with sufficient organic and moisture content to support vegetative growth. The slope of the soil cover would be designed to facilitate runoff while minimizing erosion. The elevation of the surface at CL2 would be increased I approximately 18 to 36 inches across the site to account for the cover thickness and increased slope. The area of the soil cover would extend slightly beyond the estimated limits of waste at I CL2 as shown in Figure 2-2 and is estimated to be approximately 196,000 square feet

I D:IFTMCCOYIIPIXMSIISEC110N.2 2-22 March 1996 I Fort McCay Draft Co"ective Measures Study Report

(4.5 acres). The actual extent of the soil cover would be verified based on data collected during I a pre-design limits of waste investigation. It is anticipated that this investigation would consist of a series of test pits along the north, east, and south perimeter of CL2. ,. I • Special care would be taken when excavating/constructing next to the La Crosse River to minimize adverse short-term impacts such as siltation from surface runoff or sloughing of I sideslopes. Use of silt fences, sheet piling, temporary berms, or other means would be used to minimize the temporary impacts on the La Crosse River. I • Low and sporadic detections of COCs in groundwater would be reduced over time by natural attenuation through volatilization, biodegradation, adsorption, and other physical and chemical reactions within the subsurface environment. I

• Groundwater monitoring would consist of semi-annual sampling and analysis of 6 groundwater monitoring wells (OW102, OW103, OW104, OW106, OW121, OW122). Monitoring wells I OW102, OW103, OW121, and OW122 would probably need to be replaced following regrading, cover placement, and erosion protection activities along the La Crosse River. The groundwater monitoring wells are illustrated on Figure 2-2. Observation wells (OWs) are I screened across the water table. I' Screened Interval Monitorin~ Well (feet below ~ound surface) I OW-104 (upgradient) 12-22 OW-102 2-7 OW-103 2-7 I OW-106 15-25 OW-121 2-7 OW-122 2-7 I

Compounds which equaled or exceeded their PALs (VOCs, nitrate/nitrite, and metals) during previous monitoring events in downgradient monitoring wells would be analyzed for during I groundwater monitoring.

Figure 2-5 presents a conceptual cross-section view of Alternative 1 at CL 2 along the La Crosse I River. I Effectiveness CL2, CL3, and the GA are expected to remain the property of the U.S. Army and continue to have I associated effective access restrictions. The perimeter fences around CL2, CL3, and the Grit Area, if required, would provide a further effective access restriction. I Land and groundwater use restrictions will be effective, as CL2, CL3, and the GA are expected to remain the property ofthe U.S. Army. lfCL2, CL3, and the GA do not remain the property ofthe I

D:IFTMCCOY IIPOCMSJISECTION.2 2-23 March 1996 I I NORTHWEST SOUTHEAST I I I I

I II EXISTING CONDITIONS I I I SLOPE AND HEIGHT OF RE-SHAPED NATM PLANTINGS WASTE AND SOIL COVER TO BE I DETERMINED DURING DESIGN

RIP-RAP AND/OR I EROSION NET I I I POST -GRADING/COVER CONDITIONS I I "6-;;; 9 NOT TO SCALE ~r------.------~ I ~ MAR. 1996 FIGURE 2-5 18903 g RIJUENVInjONMENT & CL2, CL3 AND THE GA e .N ALTERNATIVE I CONCEPTUAL CROSS-SECTIONS --- INFRASTRUCTURE I f. DRAFT CORRECTIVE MEASURES STUDY z FORT McCOY, WISCONSIN I g~------~------~ I Fort McCoy Draft Corrective Measures Study Report

I U.S. Army, the effectiveness of deed restrictions will depend on continued enforcement and could be subject to changes in political jurisdiction and legal interpretation. NR 812.08 would supplement groundwater use restrictions by prohibiting the installation of new water supply wells within I 1,200 feet ofCL2, CL3, and the GA. I The CL2 soil cover and erosion protection/slope stabilization would be effective in minimizing the potential for disturbance and erosion of sol.rrce material and subsequently the potential for ecological impacts to the La Crosse River. By promoting runoff, the soil cover would also be effective in I reducing infiltration and subsequent migration of source material contaminants to groundwater. Given that waste has not been added to CL2, CL3, and the GA in approximately 30 or more years, I as discussed in Section 2.3, groundwater contaminant concentrations are expected to decrease over time through natural attenuation. Groundwater data indicate that natural attenuation is currently active in the groundwater. Groundwater monitoring would be used to monitor the effectiveness of I natural attenuation;

Semi-annual groundwater sampling and analysis is a proven effective means of monitoring I groundwater quality. I Implementability and Reliability Based on the site-specific factors summarized in Section 2.1 0.2, access, land and groundwater use I restrictions, the soil cover and erosion protection/slope stabilization at CL2, and natural attenuation in conjunction with groundwater monitoring would be reliable and readily implementable. I Construction of Alternative 1 should be able to be completed in one construction season. It is anticipated that the regulatory requirements outlined in Table 2-4 would have to be addressed I to construct the CL2 soil cover and erosion protection/slope stabilization components. Operation and Maintenance

I Semi-annual groundwater monitoring would be the only Alternative 1 operational requirements. For Alternative 1, the operation period for groundwater monitoring would be dependent on the time to achieve acceptable levels of COCs in groundwater. It is assumed, for cost estimating purposes, that I groundwater monitoring will be performed for 30 years.

The CL2 soil cover and erosion protection/slope stabilization and the perimeter fences (if required) I would be maintained by Fort McCoy through routine inspections and maintenance. Monitoring wells may require periodic well screen cleaning and other minor maintenance. It is anticipated that I the useful life of the monitoring wells would be at least 15 years. I Safety Safety of nearby residents, environments and site workers with regard to physical hazards during I implementation would be addressed by provisions in the construction contractor's Site-Specific

I D:IFTMCCOY JIPDCMSJISEC170N. 2 2-24 March 1996 I Fort McCoy Draft Co"ective Measures Study Report

I TABLE2-4

CL2, CL3, AND THE GA I APPLICABLE REGULATIONS FOR EROSION PROTECTION/ SLOPE STABILIZATION MEASURES AT CL2 I FORT MCCOY, WISCONSIN

I Applicable Regulation Regulated Activity Description Regulatory Agency

Sec. 404 Clean Water Act Placement of dredge or fill US ACE I material into waters ofU.S. including wetlands. I Sec. 401 Clean Water Act Water quality certification USACEIWDNR required from the State for I projects affecting wetlands. Endangered Species Act Federally funded projects require WDNRIUSFWS assessment of impacts to I endangered species. Environmental Impact Required for federally funded EPAIUSACE I Assessment National project which may impact Environmental Policy Act environment. (NEPA)

I NR 103 WAC Requires practicable alternatives USACEIWDNR analysis and water quality certification (Sec. 401) for I activities which may adversely impact wetlands. I Chapter 30 Wisconsin Regulates alterations to navigable WDNR Statutes waterways in the State including contiguous wetlands and below I ordinary high water mark. I I I I

March /996 I D:IFTMCCOYJIP~2-4. I Fort McCoy Draft Corrective Measures Study Report

I Safety and Health Plan (SSHP). Potential site safety hazards during construction could include, but not be limited to, heavy equipment operation, chemical exposure, slip/trip/fall hazards, heat/cold stress, wildlife (ticks, snakes, etc.) and vegetation (poison ivy, etc.) Temporary environmental I controls (silt fencing, sheet piling, dust suppression, etc.) and ambient air monitoring would be implemented as needed during construction of CL2 soil cover and erosion protection/slope I stabilization. I Environmental Evaluation Environmental controls (sheet piling, silt fence, berms, etc.) would be employed during the construction of Alternative 1 components to minimize adverse short-term impacts (siltation, runoff, I spills, etc.) to environmentally sensitive areas along the La Crosse River. Encroachment into the river channel to implement erosion protection and slope stabilization measures will be minimized to the extent practical. The corrective action design will focus on methods to minimize short-term I surface water quality problems related to construction activities.

An ecological field assessment conducted during the RFI (results presented as an appendix to the I RFI Report) concluded that the primary exposure pathway of concern is the ingestion or direct uptake of contaminated soil or water by ecological communities adjacent to CL2. This exposure pathway would be mitigated by the implementation of the CL2 soil cover and erosion I protection/slope stabilization measures in Alternative 1 which would minimize the potential for erosion of and contaminant migration from the CL2 source material. Access and land use I restrictions in Alternative 1 would further minimize the potential for source material disturbance and subsequent environmental impacts.

I Human Health Evaluation

Access, land use, and groundwater use restrictions in Alternative 1 would prevent residential I development at CL2, CL3, and the GA. Therefore, the most likely human health risk exposure scenario for CL2, CL3, and the GA is that of ingestion of and direct contact with contaminated surface soil by hypothetical site trespassers or a wastewater treatment plant worker. The human - I health assessment concluded that trespassers and wastewater treatment plant workers are not exposed to excess health risks under current site conditions.

I There are no current nor anticipated groundwater receptors located between CL2, CL3, and the GA, and the La Crosse River and NR 812.08 prohibits the installation of new water supply wells within I 1,200 feet of a solid waste site. I Institutional Evaluation Institutional needs for Alternative 1 would include enforcing existing site access restrictions, I enforcing·land and groundwater use restrictions, and performing routine groundwater monitoring. The design and implementation schedule for Alternative 1 components may be effected by Federal, I state and local environmental and public health standards, regulations, guidance, advisories,

I D:IF1MCCOYJIPDCMSJISECT/ON.2 2-25 March 1996 I Fort McCoy Draft Co"ective Measures Study Report

ordinances or community relations. · Design and construction of CL2 soil cover and erosion I protection/slope stabilization measlrres would be impacted by the following: ,. I • Regulatory requirements outlined on Table 2-4 . • Community relations which would be addressed by USEPA, WDNR, USACE, and Fort McCoy I after the public comment period.

It is anticipated that the other components of Alternative 1 would not be significantly effected by I Federal, state and local environmental and public health standards, regulations, guidance, advisories, ordinances or community relations. I Cost Evaluation

The cost for Alternative 1 includes capital costs to construct the perimeter fences (if required), and I CL2 soil cover and erosion protection/slope stabilization measures including replacement of four monitoring wells, and annual operation and maintenance costs associated with semi-annual groundwater monitoring, and periodic fence, soil cover, and erosion protection/slope stabilization I inspection and maintenance. It is assumed that costs for recording deed restrictions would be negligible. I The estimated conceptual capital construction cost for Alternative 1 is $713,000 as presented in Table 2-5. The estimated conceptual present worth O&M cost for Alternative 1 is $1,030,000 as I presented in Table 2-6. Additional detail and supporting documents for the cost estimates are presented in· Appendix A. I 2.10.3.3 Corrective Action Alternative 2

Alternative 2 I

Access, Land and Groundwater Use Restrictions, CL2 Soil Cover, I Erosion Protection/Slope Stabilization at CL2, Groundwater Extraction/Treatment, I Natural Attenuation, Groundwater Monitoring I Alternative 2 consists of access, land and groundwater use restrictions; CL2 soil cover and erosion protection/slope stabilization; groundwater extraction and treatment; natural attenuation of residual low-level groundwater contamination; and groundwater monitoring. These components are I described below:

• Existing access restrictions to CL2, CL3, and the GA associated with the Fort McCoy facility I would be maintained. A chain-link fence (6 feet high) with lockable gates could be constructed around the perimeters ofCL2 (approximately 1,700 feet), CL3 (approximately 1,300 feet), and I

D:IFTMCCOY 1\PDCMS /\SECTION. 2 2-26 March 1996 I I FortMcCuy Draft Corrective Measures Study Report I TABLE2-5 ' CL2, CL3, AND THE GA ALTERNATIVE I CAPITAL COST ESTIMATE I FORT MCCOY, WISCONSIN

I Capital Cost Item Quantity Unit Unit Cost Item Cost Pre-Design: I Site Survey (CL2) 1 LS $4,000 $4,000 Limits of Waste Investigation (CL2) 1 LS $5,000 $5,000 I Wetlands Delineation 1 LS $7,000 $7,000 Pre-Design Subtotal $16,000

Construction:

I Perimeter Fences (CL2, CL3, GA) (Optional) I LS $65,000 $65,000

Soil Cover:

I Clearing and Grubbing (CL2) 2.5 AC $6,250 $16,000

Soil Borrow, Haul, and Placement 10,000 CY $15 $150,000 I Vegetation 4.5 AC $2,000 $9,000 Soil Cover Subtotal $175,000 I Erosion Protection/ Slope Stabilization: Erosion Control Mat 5,600 SY $2 $11,000 I Rip Rap 860 SY $58 $50,000 Replace Monitoring Wells 4 EA $2,000 $8,000 a· Erosion Protection Subtotal $69,000 Construction Subtotal $309,000 I Construction Global Markups: Scope Contingency (15%) $47,000 I Subtotal $356,000 Health and Safety (30%) $107,000

Subtotal $463,000

I Permitting (10%) $47,000

Engineering (20%) $94,000 I Construction-Related Services (15%) $70,000 Prime Fixed Fee (5%) $23,000 I Construction Total $697,000 TOTAL CAPITAL COST $713.000 I Note: l) Cost assumptions are presented in Appendix A to CMSR.

I D:IFTMCCOYJIJ'DCMSI\TAB2-5. March 1996 I Fort McCoy Draft Corrective Measures Study Report

I TABLE2-6

CL2, CL3, AND THE GA I ALTERNATIVE 1 O&M COST ESTIMATE I FORT MCCOY, WISCONSIN Annual Total I O&Mitem Quantity Unit Unit Cost Cost Groundwater Monitoring (30 years): I Groundwater Sampling 1 event (I) YR $49,000 $49,000 and Analysis I Scope Contingency (15%) $8,000 Subtotal $57,000 I Administration (1 00/o) $6,000 Groundwater Monitoring Subtotal $63,000 I Site Inspection and Maintenance (30 years): Inspection and 1 event YR $3,000 $3,000 I Maintenance Scope Contingency (15%) $500 I Subtotal $3,500 I Administration ( 10%) $400 Inspection and Maintenance Subtotal $4,000 I Total Annual O&M Cost $67,000 Total Present Worth ofO&M (30 yrs) $1 030.000 I Note: (I) Includes two sampling events per year at six wells. I Cost assumptions are presented in Appendix A to CMSR. I I I

I D:IFTMCCOY/IPDCMSI\TAB1-6. March 1996 I Fort McCoy Draft Corrective Measures Study Report

I the Grit Area (approximately 850feet) to further restrict site access. The chain-link fence would be tied into the existing Wastewater Treatment Plant perimeter fence. This fence would only be constructed if deemed necessary at a later date due to unauthorized access to and disturbance I of the area. ,.

I • Restrictive covenants would be placed on deeds to the property to restrict land and groundwater use.

I • Erosion protection/slope stabilization measures would be implemented between CL2 and the La Crosse River (approximately 1,000 feet). Steep sideslopes along the La Crosse River would be reduced by grading the material back onto the central portion of CL2. This would not only I reduce the steep sideslopes, but also provide fill material for raising the elevation of the central portion of CL2 to improve surface runoff and reduce infiltration. This would act as a foundation for the proposed soil cover. An erosion control geosynthetic mat or armored surface component I (interlocking concrete block, gabions (rock-filled wire baskets), rip rap, or similar materials) would be then constructed on the soil cover side-slope adjacent to the river to minimize the potential for erosion of soil cover and waste materials. Vegetation may be used to supplement I the geosynthetic mat or armored surface component. The armored surface component may also be supported by a subsurface anchor component or a sheet pile wall.

I • A soil cover would be placed on CL2 to minimize disturbance and erosion of source material and promote stormwater runoff. The soil cover thickness would be a minimum of 18-inches. I The soil cover would consist of natural soil with sufficient organic and moisture content to support vegetative growth. The slope of the soil cover would be designed to facilitate runoff while minimizing erosion. The elevation of the surface at CL2 would be increased I approximately 18 to 36 inches across the site to account for the cover thickness and increased slope. The area of the soil cover would extend slightly beyond the estimated limits of waste at CL2 as shown in Figure 2-2 and is estimated to be approximately 196,000 square feet I (4.5 acres). The actual extent of the soil cover would be verified based on data collected during a pre-design limits of waste investigation. It is anticipated that this investigation would consist I of a series of test pits along the north, east and south perimeter of CL2. • Special care would be taken when excavating/constructing next to the La Crosse River to minimize adverse short-term impacts such as siltation from surface runoff or sloughing of I sideslopes. Use of silt fences, temporary berms, sheetpiling, or other means would be used to I minimize the temporary impacts on the La Crosse River. • Groundwater extraction using approximately 10 groundwater extraction wells would be used to collect groundwater at the downgradient edge of CL2 next to the La Crosse River. The I collected groundwater would then be treated ex-situ using air stripping and chemical precipitation in a small groundwater treatment plant (approximately 50 gpm) located in a building (approximately 3,600 square feet) at or adjacent to CL2, with discharge either to the I on-site WWTF or the La Crosse River. Potential locations for the 10 wells and treatment plant building are shown on Figure 2-6. Actual well and building locations would be determined I

I D:IFTMCCOYJIPD('MSJ\SECTJON.2 2-27 March 1996 I

7~600 ~ + ;; i ,/ I ~ / / / .1 _.....--··--· I v 5 //.1/t.f,.-:;.~ .. · ··"" '"'... -~ • .,., J .. /' / I lj t I ' ~ I I I ~ I 1- I ' ~ ~ I ) ~ I b ...... -,t- ,//.· ~ + .wm2.. <:!> I ..·'/:_ i II I ;/ / --o>t--- TOPOGRAPHIC CONT~ t I I \ 825 GROlNlWATER CONTOLI! '-, GROUICWATER FLOW DIRECTION

ESTit.IATED LIIIITS OF WASTE

I £L •828 19 GROUNlWATER t.tOHITORING WELL WITH CROIH>WATER ELEVATION IN FEET ABOVE MEAN SEA LEVEL •o,.. -E WASUoWAlErl TREAH£NT ~AC!LITY I 0 SURFACE SOIL SAIM'LE LOCATION 0ljt31 I .1-a-- FENCE I CONCEPTUAL LOCATION OF ALTERNATIVE @ N0.2 GR~ATER EXTRACTION WELLS I it, CONCEPTUAL LOCATION OF ALTERNATIVE / I §I / N0.2 CROl.N)wATER TREATIIENT BUILDING ,..... ---. _. .. / B ~ /// .·--- + /. // .,l /',-...... "'~ ~ ~~~ ~ ' ,..-· .. -" / / I • I I. GROt.NlWATER TABLE ELEVATIONS AND CONTOURS ~ / / // ARE DERIVED FROiot TH£ RFI PHASE 3 I I IHVESTIGAT ION. ~ /' ,.//'' !.!:! I It' // Is j .,/',./ ::i I .f // ...~ ...... M // II UJ ,, // ~ -a·- ...... --. // I // / • I / / / I + .. ~ '/ ~~ O'i'IOlf' // /\ f/ -o '---...:::,.i-7 0' 80' 160' I l;; ../~" SCALE- -- N \p // -- :;:: / CLOSED t I.AM)F ILL . ;, .1>1 ,§ NO. 3 .~/ ·' I \ MAR. 1996 FIGURE 2-6 18903 ~ ( .... .~~,~... / '{: .l CL2, CL3, AND THE GA ~ . .. IIIII ...ENVJRONME NT & CONCHRllJAL GROUNDWATER EXTRACTION 0 ·~.. ,;. ·;.'"..'W:·1fo p;.f:..V.; 'J'h:' I L.- ·~U~I INFRASTRUCTURE !.. AND.TTREATMENT SYSTEM LAYOUT DRAFT CORRECTIVE MEASURES STUDY I FORT McCOY. WISCONSIN I Fort McCoy Draft Corrective Measures Study Report

I during the design of the system: Residual groundwater contamination not collected by the groundwater extraction system, if any, would be addressed by natural attenuation.

I • Groundwater monitoring would consist of semi-annual sampling and analysis of six groundwater monitoring wells (OW102, OW103, OW104, OW106, OW121, OW122). I Monitoring wells OW102, OW103, OW121, and OW122 would probably need to be replaced following regrading, cover placemen~ and flood protection activities along the La Crosse River. The groundwater monitoring wells are illustrated on Figure 2-2. Observation wells (OWs) are I screened across the water table.

Screened Interval I Monitorin~ Well (feet below ~round surface)

OW-104 (upgradient) 12-22 I OW-102 2-7 OW-103 2-7 OW-106 15-25 I OW-121 2-7 OW-122 2-7

I Compounds which equaled or exceeded their PALs (VOCs, nitrate/nitrite, and metals) during previous monitoring events in downgradient monitoring wells would be analyzed for during I groundwater monitoring. I Effectiveness CL2, CL3, and the GA are expected to remain the property of the U.S. Army and continue to have associated effective access restrictions. The perimeter fences around CL2, CL3, and the Grit Area, I if required, would provide a further effective access restriction.

Land and groundwater use restrictions will be effective, as CL2, CL3, and the GA are expected to I remain the property of the U.S. Army. IfCL2, CL3, and the GA do not remain the property of the U.S. Army, the effeetiveness of deed restrictions will depend on continued enforcement and could be subject to changes in political jurisdiction and legal interpretation. NR 812.08 would supplement I groundwater use restrictions by prohibiting the installation of new water supply wells within I 1,200 feet ofCL2, CL3, and the GA. The CL2 soil cover and erosion protection/slope stabilization would be effective in minimizing the potential for disturbance and erosion of source material and subsequently the potential for ecological I impacts to the La Crosse River. By promoting runoff, the soil cover would also be effective in reducing infiltration and subsequent migration of source material contaminants to groundwater.

I Approximately 10 groundwater extraction wells, if required, would be used to collect impacted groundwater downgradient of CL2. The collected groundwater would be treated, if required, using I air stripping and chemical precipitation in a small groundwater treatment plant (approximately

I D:IF7MCCOYJIPDCMSJISECTJON.2 2-28 March 1996 Fort McCoy I Draft Corrective Measures Study Report

50 gpm) located in a building (approXimately 3,600 square feet) at or adjacent to CL2. Given the I sporadic nature of low-level PAL exceedances, the effectiveness of the groundwater treatment units may be reduced due to the sporadic nature of low concentration influent. Residual low levels of ,. groundwater contamination not collected by the groundwater extraction system, if any, would be I addressed with natural attenuation. I Semi-annual groundwater sampling and analysis is a proven effective means of monitoring groundwater quality. I lmplementability and Reliability

Based on the site-specific factors summarized in Section 2.1 0.2, access, land and groundwater use I restrictions, the soil cover and erosion protection/slope stabilization at CL2, groundwater extraction and treatment, and natural attenuation in conjunction with groundwater monitoring would be reliable and readily implemented. Construction of Alternative 2 should be able to be completed in I one construction season.

It is anticipated that the regulatory requirements outlined in Table 2-4 would have to be addressed I to construct the CL2 soil cover and erosion protection/slope stabilization components.

Operation and Maintenance I Semi-annual groundwater monitoring, and operation of the groundwater extraction and treatment I system would be the Alternative 2 operational requirements. For cost estilJlating purposes, it is assumed that the groundwater extraction and treatment system would be operated for a period of 5 years before its operation would be discontinued with natural attenuation and monitoring I continuing for another 25 years. For Alternative 2, the operation period for groundwater monitoring would be dependent on the time to achieve acceptable levels ofCOCs in groundwater. It is assumed, for cost estimating purposes, that groundwater monitoring will be performed for 30 years. Since I Alternative 2 does not remove the waste material, the length of time monitoring will be required is estimated to be similar to Alternative 1. I The CL2 soil cover and erosion protection/slope stabilization and the perimeter fences (if required) would be maintained by Fort McCoy through routine inspections and maintenance. Monitoring 'and extraction wells may require periodic well screen cleaning and other. minor maintenance. It is I anticipated that the useful life of the wells would be at least 15 years. I Safety

Safety of nearby residents, environments and site workers with regard to physical hazards during I implementation would be addressed by provisions in the construction contractor's SSHP. Potential site safety hazards during construction could include, but not be limited to, heavy equipment operation, chemical exposure, slip/trip/fall hazards, heat/cold stress, wildlife (ticks, snakes, etc.), and I vegetation (poison ivy, etc.). Temporary environmental controls (silt fencing, sheet piling, dust suppression, etc.) and ambient air monitoring would be implemented as needed during installation I

D:IF1MCCOY/IPDCMS/ISECT/ON.2 2-29 March 1996 I I Fort McCoy Draft Corrective Measures Study Report

I of the groundwater extraction wells and construction of the groundwater treatment plant, CL2 soil I cover, and erosion protection/slope stabilization. Environmental Evaluation I Environmental controls (sheet piling, silt fence, berms, etc.) would be employed during the construction of Alternative 2 components to minimize adverse short-term impacts (siltation, runoff, spills, etc.) to environmentally sensitive areas along the La Crosse River. Encroachment into the I river channel to implement erosion protection and slope stabilization measures will be minimized to the extent practical. The corrective action design will focus on methods to minimize short-term I surface water quality problems related to construction activities. An ecological field assessment conducted during the RFI (results presented as an appendix to the RFI Report) concluded that the primary exposure pathway of concern is the ingestion or direct I uptake of contaminated soil or water by ecological communities adjacent to CL2. This exposure pathway would be mitigated by the implementation of the CL2 soil cover and erosion protection/slope stabilization measures in Alternative 2 which would minimize the potential for I erosion of and contaminant migration from the CL2 source material. Access and land use restrictions in Alternative 2 would further minimize the potential for source material disturbance and I subsequent environmental impacts. I Human Health Evaluation Access, land use, and groundwater use restrictions in Alternative 2 would prevent residential development at CL2, CL3, and the GA. Therefore, the most likely human health risk exposure I scenario for CL2, CL3, and the GA is that of ingestion of and direct contact with contaminated surface soil by hypothetical site trespassers or a wastewater treatment plant worker. The human health assessment concluded that trespassers and wastewater treatment plant workers are not exposed I to excess health risks under current site conditions.

There are no current nor anticipated groundwater receptors located between CL2, CL3, and the GA I and the La Crosse River and NR 812.08 prohibits the installation of new water supply wells within 1,200 feet of a solid waste site.

I Institutional Evaluation

I Institutional needs for Alternative 2 would include enforcing existing site access restrictions, enforcing land and groundwater use restrictions, and performing routine groundwater monitoring.

I The design and implementation schedule for Alternative 2 components may be effected by Federal, state and local environmental and public health standards, regulations, guidance, advisories, ordinances or community relations. Design and construction of CL2 soil cover and erosion I protection/slope stabilization measures, and construction and operation of the groundwater extraction and treatment system would be impacted by the following: I

I D:IFTMCCOYJIPDCMSJISEC110N.2 2-30 March 1996 I Fort McCoy Draft Corrective Measures Study Report

• Regulatory requirements outlined on Table 2-4. I

• Community relations which would be addressed by USEPA, WDNR, USACE, and Fort McCoy ,. after the public comment period. I • It is anticipated that implementation of Alternative 2 will not require a local construction permit. I • It is anticipated that operation of the air stripper will not require a Wisconsin Air Permit. The air stripper will be operated to meet NR 419 and NR 445 emissions criteria. I

• If the extracted groundwater is treated and discharged to the surface, it is ·anticipated that a WPDES permit will be required. I

• Groundwater treatment system residuals (sludge) must be disposed in accordance with applicable regulations. I

It is anticipated that the other components of Alternative 2 would not be significantly effected by Federal, state and local environmental and public health standards, regulations, guidance, advisories, I ordinances, or community relations.

Cost Evaluation I

The cost for Alternative 2 includes capital costs to construct the perimeter fences (if required), CL2 I soil cover and erosion protection/slope stabilization measures including replacement of four monitoring wells, and groundwater extraction/treatment, and annual operation and maintenance costs associated with groundwater extraction/treatment, semi-annual groundwater monitoring, and I periodic fence, soil cover and erosion protection/slope stabilization inspection and maintenance. It is assumed that costs for recording deed restrictions would be negligible. I The estimated conceptual capital construction cost for Alternative 2 is $1,639,000 as presented in Table 2-7. The estimated conceptual present worth O&M cost for Alternative 2 is $1,792,000 as presented in Table 2-8. Additional detail and supporting documents for the cost estimates are I presented in Appendix A.

2.10.3.4 Corrective Action Alternative 3 I Alternative 3 I Excavate and Remove CL2, CL3, and the GA, Transport and Dispose In Off-Site Landfill, I Backfill Area, Groundwater Use Restrictions, Groundwater Monitoring I I

D:IFTMCCOY IIPDCMSIISEC110N.2 2-31 March 1996 I I Fort McCoy Draft Corrective Measures Study Report I TABLE2-7 ' CL2, CLJ, AND THE GA ALTERNATIVE 2 CAPITAL COST ESTIMATE I FORT MCCOY, WISCONSIN

I Capital Cost Item Quantity Unit Unit Cost Item Cost Pre-Design: - I Site Survey (CL2) I LS $4,000 $4,000 Limits of Waste Investigation (CL2) I LS $5,000 $5,000 I Wetlands Delineation I LS $7,000 $7,000 Pre-Design Subtotal $16,000 I Construction: Perimeter Fences (CL2, CL3, GA) (Optional) I LS $65,000 $65,000

Soil Cover:

I Clearing and Grubbing (CL2) 2.5 AC $6,250 $16,000

Soil Borrow, Haul, and Placement 10,000 CY $15 $150,000 I Vegetation 4.5 AC $2,000 $9,000 Soil Cover Subtotal $175,000 I Erosion Protection/ Slope Stabilization: Erosion Control Mat 5,600 SY $2 $11,000 I Rip Rap 860 SY $58 $50,000 Replace Monitoring Wells 4 EA $2,000 $8,000 I Erosion Protection Subtotal $69,000 Groundwater Extraction I LS $130,000 $130,000 I Groundwater Treatment/Discharge: Metals Treatment I LS $160,000 $160,000 I Air Stripper I LS $28,000 $28,000 Building I LS $100,000 $100,000

Discharge I LS $20,000 $20,000

I Groundwater Treatment Subtotal $308,000

Construction Subtotal $747,000 I Construction Global Markups: Scope Contingency (15%) $112,000 I Subtotal $859,000 Health and Safety (30%) $258,000 I Subtotal $1,117,000

I D:IFTMCCOYIIPOCMSI\TAB2-7. March 1996 I Fort McCoy Draft Co"ective Measures Study Report

I ·TABLE 2-7 (Continued)

CL2, CL3, AND THE GA ALTERNATIVE 2 CAPITAL COST ESTIMATE I ,. FORT MCCOY, WISCONSIN

I Capital Cost Item I Quantity I Unit I Unit Cost Item Cost Pennitting (5%) $56,000 I Engineering (20%) $225,000 Construction-Related Services ( 15%) $169,000 I Prime Fixed Fee (5%) $56,000 Construction Total $1,623,000 I TOTAL CAPITAL COST $1.639000 Note: 1) Cost assumptions are presented in Appendix A to CMSR. I I I I I I I I I I I

I D:IFTMCCOYJIPDCMSJ\TAB2-7. March 1996 I Fort McCoy Draft Co"ective Measures Study Report

I TABLE2-8

CL2, CL3, AND THE GA I ALTERNATIVE 2 O&M COST ESTIMATE ,. FORT MCCOY, WISCONSIN

I Annual Total O&Mitem Quantity Unit Unit Cost Cost I Groundwater Monitoring (30 years): Groundwater Sampling and I event (I) YR $49,000 $49,000 I Analysis Scope Contingency (I5%) $8,000 I Subtotal $57,000 Administration (I 0%) $6,000 I Groundwater Monitoring Subtotal $63,000 Site Inspection and Maintenance (30 years): I Inspection and Maintenance I event YR $3,000 $3,000 Scope Contingency (I5%) $500 I Subtotal $3,500 Administration (10%) $400 I Inspection and Maintenance Subtotal $4,000 Groundwater Extraction and Treatment Operation and Maintenance (S years): I Groundwater Extraction I YR $13,000 $13,000 Groundwater Treatment I YR $I26,000 $I26,000

Subtotal $I39,000

I Scope Contingency (15%) $2I,OOO

Subtotal $I60,000

I Administration {10%) $I6,000

Groundwater Extraction and Treatment Subtotal $I76,000

I Total Annual O&M Cost $243,000

Total Present Worth of O&M ~I-792_000

I Note:

(I) Includes two sampling events per year at six wells. I Cost assumptions are presented in Appendix A to CMSR. I Present Worth Factors: 1> i = 5%,5 yrs- 4.329; 2> i = 5%; 30 yrs- I5.373

I D:IFTMCCOY JIPDCMSJ\TAB2-8. March 1996 I Fort McCoy Draft Corrective Measures Study Report

I Alternative 3 consists of excavation ~d removal of CL2, CL3, and the GA; transport and disposal ofCL2, CL3, and GA material in a licensed off-site landfill; backfill of the excavated areas to grades and contours similar to existing conditions; groundwater use restrictions; and groundwater I monitoring. These components are described below:

I • Excavation and removal ofCL2, CL3, and GA waste material, if required, would involve the use of standard excavation/construction equipment (backhoes, dozers, loaders, etc.). Depending on how much of the waste material is present below the water table at CL2 and CL3, it may not I be practical to remove all of the waste material. That would result in a small source of groundwater contamination remaining in-place. Special care would need to be taken when excavating to minimize potential adverse impacts to the La Crosse River and adjacent wetlands. I Silt fences, temporary berms, sheetpiling, or other means could be used to minimize temporary impacts due to potentially contaminated runoff from the excavation area. It is assumed that excavation would proceed from the south end of CL2 to the north end of CL2 with the area I backfilled from north to south. The Fort McCoy wastewater treatment facility discharge pipe would have to be re-routed either prior to or during excavation and removal of the CL2 waste material. CL3 and the GA could be excavated and backfilled in a similar manner. The actual I methods and procedures would be determined during the design phase of the remediation. The I areas that would be excavated (estimated limits ofwaste) are shown on Figure 2-2. • Off-site landfilling of the CL2, CL3, and GA material would involve the transport of the I excavated material by truck to a licensed landfill. • Backfilling of the excavated areas to grades and contours similar to existing conditions would involve the placement, compaction, and vegetation of these areas with clean soil. As noted I above, there is the potential that not all of the waste material could be removed during the excavation process. Therefore, for cost estimating purposes, it is assumed the area will be backfilled and vegetated to preclude the potential for direct exposure to waste material which I could remain following excavation. Figure 2-7 presents a conceptual partial cross-section of CL2 following waste removal and backfilling. Actual cross-sections and height of backfill will I be determined during design activities. • Restrictive covenants would be placed on deeds to the property to limit groundwater use;

I • Groundwater monitoring would consist of semi-annual sampling and analysis of six groundwater monitoring wells (OW102, OW103, OW104, OW106, OW121, OW122). I Monitoring wells OW102, OW103, OW121, and OW122 would probably need to be replaced due to excavation activities. The groundwater monitoring wells are illustrated on Figure 2-2. I Observation wells (OWs) are screened across the water table. Screened Interval I Monitorin~ Well (feet below ~round surface) OW-104 (upgradient) 12-22 I OW-102 2-7

I D: IF7MCCOYJIPDCMSIISECTION.2 2-32 March 1996 I NORTHWEST SOUTHEAST I I I I I II EXISTING CONDITIONS I I I I NATIVE PLANTINGS SLOPE AND HEIGHT OF BACKFILL TO I BE DETERMINED DURING DESIGN I I

POSSIBLE WASTE REMAINING I AFTER EXCAVATION I POST -EXCAVATION CONDITIONS

<:: "0 I ~ j NOT TO SCALE I !r------~-M-AR-.-19_9_6 ______F_I_G_U-RE __ 2___ 7 ______18_9_03~ g ...... ENVIRONMENT & CL2. CL3 AND THE GA I ~ ·~~· INFRASTRUCTURE ALTERNATIVE 3 CONCEPTUAL CROSS-SECTIONS f. DRAFT CORRECTIVE MEASURES STUDY ~ FORT McCOY, WISCONSIN I c~------~------~ I Fort McCoy Draft Corrective Measures Study Report

I OW-103 2-7 OW-106 15-25 OW-121 2-7 I OW-122 2-7 I Compounds which equaled or exceeded their PALs (VOCs, nitrate/nitrite, and metals) during previous monitoring events in downgradient monitoring wells would be analyzed for during I groundwater monitoring. Effectiveness

I Excavation and removal of CL2, CL3, and GA material, if required, would be effective in removing almost all of the source of groundwater contamination and the threat of direct contact with waste material. Depending on how much of the waste material is present below the water table at CL2 and I CL3, it may not be practical to remove all of the waste material. That would result in a potential small source of groundwater contamination remaining in-place. Short-term adverse impacts to the La Crosse River would be minimized by the use of silt fence, temporary berms, sheetpiling, or other I means.

Disposal of CL2, CL3, and GA material in a licensed off-site landfill is an effective means for I controlling the release of contaminants to the environment. However, this off-site disposal could result in additional liability for the Army if the off-site landfill becomes the source of problems in I the future. Semi-annual groundwater sampling and analysis is a proven effective means of monitoring I groundwater quality. · I Implementability and Reliability Based on the site-specific factors summarized in Section 2.1 0.2, the excavation, removal, and disposal of CL2, CL3, and GA material in an off-site licensed landfill in conjunction with I groundwater monitoring would be reliable and implementable. However, implementation of the excavation and backfilling will be complicated by the location of CL2 immediately adjacent to the La Crosse River. Even if precautions are taken to minimize short-term impacts to the La Crosse I River, there is still the potential impacts would occur given the volume of material to be moved and the location of the river relative to CL2. Depending on how much of the waste material is present I below the water table, it may not be practical to remove all of the waste material. That would result in a potential small source of groundwater contamination remaining in-place. Construction of I Alternative 3 should be able to be completed in one construction season. It is anticipated that the regulatory requirements outlined in Table 2-4 would have to be addressed I to remove and backfill the area. I

I D:IFTMCCOYIIPIXMSIISECT/ON.2 2-33 March 1996 Fort McCoy I Draft Corrective Measures Study Report

Operation and Maintenance I

Semi-annual groundwater monitoring would be the only Alternative 3 operational requirements. For ,. Alternative 3, with the removal of almost all ofCL2, CL3, and the GA material, it is assumed, for I cost estimating purposes, that groundwater monitoring will only need to be performed for 5 years to demonstrate acceptable groundwater quality. Monitoring wells may require periodic well screen I cleaning and other minor maintenance. · Safety I

Safety of nearby residents, environments and site workers with regard to physical hazards during implementation would be addressed by provisions in the construction contractor's SSHP. Potential I site safety hazards during construction could include, but not be limited to, heavy equipment operation, chemical exposure, slip/trip/fall hazards, heat/cold stress, wildlife (ticks, snakes, etc.), and vegetation (poison ivy, etc.). Temporary environmental controls (silt fencing, sheet piling, dust I suppression, etc.) and ambient air monitoring would be implemented as needed during excavation, removal and backfilling of CL2, CL3, and the GA. I Environmental Evaluation

Environmental controls (sheet piling, silt fence, berms, etc.) would be employed during the I implementation of Alternative 3 components to minimize adverse short-term impacts (siltation, runoff, spills, etc.) to environmentally sensitive areas along the La Crosse River. Encroachment into I the river channel to implement Alternative 3 will be minimized to the extent practical. The corrective action design will focus on methods to minimize short-term surface water quality problems related to construction activities. I

An ecological field assessment conducted during the RFI (results presented as an appendix to the RFI Report) concluded that the primary exposure pathway of concern is the ingestion or direct I uptake of contaminated soil or water by ecological communities adjacent to CL2. This exposure pathway would be almost completely removed in Alternative 3. I Human Health Evaluation

Groundwater use restrictions would be imposed until groundwater quality is acceptable as a result I of waste removal and natural attenuation. The human health assessment concluded that trespassers and wastewater treatment plant workers are not exposed to excess health risks under current site I conditions. Therefore, the potential for excess health risks are further reduced with the removal of waste. I There are no current nor anticipated groundwater receptors located between CL2, CL3, and the GA and the La Crosse River and NR 812.08 prohibits the installation of new water supply wells within 1,200 feet of a solid waste site. I I

D:IFTMCCOY/IPDCMSIISEC170N.1 2-34 March 1996 I I Fort McCoy Draft Corrective Measures Study Report

I Institutional Evaluation

Institutional needs for Alternative 3 would include enforcing groundwater use restrictions and I performing routine groundwater monitoring. I The design and implementation schedule for Alternative 3 components may be effected by Federal, state and local environmental and public health standards, regulations, guidance, advisories, ordinances or community relations. Removal of CL2, CL3, and the GA material would be impacted I by the following: I • Regulatory requirements outlined on Table 2-4. • Community relations which would be addressed by USEPA, WDNR, USACE, and Fort McCoy I after the public comment period. It is anticipated that the other components of Alternative 3 would not be significantly effected by Federal, state and local environmental and public health standards, regulations, guidance; advisories, I ordinances or community relations. I Cost Evaluation The cost for Alternative 3 includes capital costs to excavate, remove, and dispose CL2, CL3, and GA I material in an off-site landfill and backfill the area including replacement of four monitoring wells, annual operation and maintenance costs associated with semi-annual groundwater monitoring, and periodic fence inspection and maintenance. It is assumed that costs for recording deed restrictions I would be negligible.

The estimated conceptual capital construction cost for Alternative 3 is $17,415,000 as presented in I Table 2-9. The estimated conceptual present worth O&M cost for Alternative 1 is $282,000 as presented in Table 2-10. Additional detail and supporting documents for the cost estimates are I presented in Appendix A. 2.10.3.5 Corrective Action Alternative 4

I Alternative 4 I In-Situ Stabilization ofCL2 and CL3, Access, Land and Groundwater Use Restrictions, Erosion Protection/Slope Stabilization at CL2, I CL2 and CL3 Soil Cover, Natural Attenuation, I Groundwater Monitoring I

I D:IFTMCCOYJIPDCMSJISECTJON.2 2-35 March 1996 I Fort McCoy Draft Co"ective Measures Study Report

I TABLE 2-9

CL2, CL3, AND THE GA I ALTERNATIVE 3 CAPITAL COST ESTIMATE FORT MCCOY, WISCONSIN

I Capital Cost Item Quantity Unit Unit Cost Item Cost

Pre-Design:

I Site Survey (CL2, CL3, GA) 1 LS $5,000.00 $5,000

Limits of Waste Investigation (CL2, CL3, 1 LS $8,000.00 $8,000 I GA) Wetlands Delineation 1 LS $7,000.00 $7,000 I Pre-Design Subtotal $20,000 Construction: I Erosion Control: Gab ions 400 LF $10.00 $4,000

Silt Fencing 1,700 LF $1.00 $2,000

I Erosion Control Subtotal $6,000

Excavation/Backfill/Revegetation (CL2, CL3, GA): I Clearing and Grubbing 7.0 AC $6,250.00 $44,000 Excavation above groundwater 105,300 CY $2.50 $264,000 I Excavation in groundwater 13,700 CY $6.50 $89,000 Surface Debris Handling 2,000 CY $5.00 $10,000 I Backfill Soil Borrow, Haul, and 142,800 CY $10.00 $1,428,000 Placement

Vegetation 8.0 AC $2,000.00 $16,000

I Confirmation Soil Sampling 149 Each $900.00 $134,000

Replace Monitoring Wells 4 Each $2,000.00 $8,000 I Excavation/Backfill/Revegetation Subtotal $1,993,000 Construction Subtotal $1,999,000 I Construction Markups: Health and Safety (30%) $600,000 I Subtotal $2,599,000 Permitting (5%) $130,000 I Engineering (100/o) $260,000 Construction-Related Services (15%) $390,000 I Construction Subtotal $3,379,000

I D:IF7MCCOYJIPDCMSI\TAB2-9. March 1996 I Fort McCoy I Draft Corrective Measures Study Report TABLE 2-9 (Continued)

CL2, CL3, AND THE GA I ALTERNATIVE 3 CAPITAL COST ESTIMATE FORT MCCOY, WISCONSIN I Capital Cost Item Quantity Unit Unit Cost Item Cost I Disposal: Characterization Sample Analysis 1,036 EA $1,200.00 $1,243,000

Hauling 170,000 Ton $30.00 $5,100,000

I Disposal 170,000 Ton $28.00 $4,760,000

Reporting/Documentation 1 LS $10,000.00 $10,000 I Disposal Subtotal $11,113,000 Capital Cost Subtotal $14,512,000 I Global Markups Scope Contingency (15%) $2,177,000

Prime Fixed Fee (5%) $726,000

TOTAL CAPITAL COST 1\17 41'\ 000 I Note: I) Cost assumptions are presented in Appendix A to CMSR. I I I I I I I I

I D:IF1MCCOY/IPDCMSI\TAB2-9. March 1996 I Fort McCoy Draft Corrective Measures Study Report

I TABLE2-10

CL2, CL3, AND THE GA I ALTERNATIVE 3 O&M COST ESTIMATE I FORT MCCOY, WISCONSIN Annual Total I O&Mitem Quantity Unit Unit Cost Cost Groundwater Monitoring (5 yrs): I Groundwater Sampling 1 event 0) YR $49,000 $49,000 and Analysis I Scope Contingency (15%) $8,000 Subtotal $57,000 I Administration (10%) $6,000 Groundwater Monitoring Subtotal $63,000 I Site Inspection and Maintenance (5 yrs): Inspection and 1 event YR $1,000 $1,000 I Maintenance Scope Contingency (15%) $200 I Subtotal $1,200 I Administration ( 10%) $100 Inspection and Maintenance Subtotal $2,000 I Total Annual O&M Cost $65,000 Total Present Worth of O&M ~2R2_000 I Note: (I) Includes two sampling events per year at six wells. I Cost assumptions are presented in Appendix A to CMSR. I I I

I D:IFTMCCOYJIPDCMSJ\TAB2-JO. March 1996 I Fort McCoy Draft Corrective Measures Study Report

I Alternative 4 consists of in-situ stabilization of CL2, CL3, and GA material; access, land and groundwater use restrictions; CL2,'CL3, and GA soil cover; erosion protection/slope stabilization I at CL2; natural attenuation; and groundwater monitoring. These components are described below: • CL2, CL3, and GA material would be stabilized in-situ using specialized equipment to inject I and mix stabilizing agents with the waste mass as described in Section 2.9.2.5. As part of the pre-design and design effort, bench scale (lab tests) and pilot scale (field tests) tests of SIS treatment would be performed to determine the proper reagent mix and equipment necessary I to SIS treat the waste at CL2, CL3, and the GA. Prior to treatment, the steep sideslopes along the La Crosse River would be reduced by grading the material back onto the central portion of CL2. In addition, the Fort McCoy wastewater treatment facility discharge pipe would have to I be re-routed prior to beginning in-situ stabilization activities. The effectiveness and cost of the SIS treatment depends in part on the difficulty of injecting and mixing the stabilizing agents. It is not uncommon to have to excavate and dispose of a portion of the waste material off-site I due to the inability of the stabilization equipment to penetrate and mix buried debris. This contingency is addressed in the cost estimate for this alternative.

I • A soil cover would be placed on CL2, CL3, and the GA following SIS treatment to minimize disturbance and erosion of the stabilized material and promote stormwater runoff. The soil cover thickness would be a minimum of 18-inches. The soil cover would consist of natural soil I with sufficient organic and moisture content to support vegetative growth. The slope of the soil cover would be designed to facilitate runoff while minimizing erosion. The elevation of the I surface ofCL2, CL3, and the GA would be increased approximately 18 to 36 inches across the sites over and above the increase caused by the bulking of the SIS treated waste as discussed in Section 2.9.2.5. The area of the soil cover would extend slightly beyond the estimated limits I of waste as shown in Figure 2-2 and is estimated to be approximately 8.0 acres. The actual extent of the soil cover would be verified based on data collected during a pre-design limits of I waste investigation. • Erosion protection/slope stabilization measures would be implemented between CL2 and the La Crosse River (approximately 1,000 feet) to protect the SIS treated material. An erosion I control geosynthetic mat or armored surface component (interlocking concrete block, gabions (rock-filled wire baskets), rip rap, or similar materials) would be constructed on the soil cover side-slope adjacent to the river to minimize the potential for erosion of soil cover and waste I materials. Vegetation may be used to supplement the geosynthetic mat or armored surface component. The armored surface component may also be supported by a subsurface anchor I component or a sheet pile wall. Figure 2-8 presents a conceptual partial cross-section of CL2 after in-situ stabilization, cover placement, and erosion protection/slope stabilization.

I • Special provisions would be necessary when excavating/constructing next to the La Crosse River to minimize adverse short-term impacts. This could include the use of silt fences, temporary berms, sheetpiling, or other means to minimize temporary impacts on the La Crosse I River. I

I D:IFTMCCOYJIPDCMSIISECTJON.2 2-36 March 1996 I NORTHWEST SOUTHEAST I I I I I

II I EXISTING CONDITIONS I I SLOPE AND HEIGHT OF IN-SITU NATIVE PLANTINGS STABILIZED WASTE AND SOIL COVER I TO BE DETERMINED DURING DESIGN I I I I POST IN-SITU I STABILIZATION TREATMENT/COVER CONDITIONS

c: ""0 I ~ :i!: "6 / V>e 3 NOT TO SCALE I ror------~------, I MAR. 1996 FIGURE 2-8 18903 ~ RIKrENVInjONMENT & CL2, CL3 AND THE GA I .,.e INFRASTRUCTURE~ ALTERNATIVE 4 CONCEPTUAL CROSS-SECTIONS f. DRAFT CORRECTIVE MEASURES STUDY :z FORT McCOY, WISCONSIN I g~------~------~ ------I Fort McCoy Draft Corrective Measures Study Report

I • Low and sporadic detections of COCs in groundwater would be reduced over time by natural attenuation through volatilization, biodegradation, adsorption and other physical and chemical reactions within the subsurface environment. I j • Existing access restrictions to CL2, CL3, and the GA associated with the Fort McCoy facility I would be maintained. A chain-link fence (6 feet high) with lockable gates could be constructed around the perimeters ofCL2 (approXimately 1,700 feet), CL3 (approximately 1,300 feet), and the Grit Area (approximately 850 feet) to further restrict site access. The chain-link fence would I be tied into the existing Wastewater Treatment Plant perimeter fence. This fence would only be constructed if deemed necessary at a later date due to unauthorized access to and disturbance I of the area. • Restrictive covenants would be placed on deeds to the property to restrict land and groundwater­ I use. • Groundwater monitoring would consist of semi-annual sampling and analysis of six groundwater monitoring wells (OW102, OW103, OW104, 0Wi06, OW121, OW122). I Monitoring wells OW102, OW103, OW121, and OW122 would probably need to be replaced following S/S treatment and cover placement activities. The groundwater monitoring wells are I illustrated on Figure 2-2. Observation wells (OWs) are scr1eened across the water table. Screened Interval I Monitorin" Well (feet bdow jUOund surface)

OW-104 (upgradient) 12-22 I OW-102 2-7 OW-103 2-7 OW-106 15-25 I OW-121 2-7 OW-122 2-7

I Compounds which equaled or exceeded their PALs (VOCs,, nitrate/nitrite, and metals) during previous monitoring events in downgradient monitoring wells would be analyzed for during I groundwater monitoring. I Effectiveness In-situ stabilization of the CL2, CL3, and GA material would be effective in treating the inorganic contaminants in the waste material. However, it is not as effective for organic contaminants and is I not effective for any contaminants if the. stabilization equipment is prevented from contacting and mixing waste by buried debris or other obstructions. Therefore, there is the potential that untreated or partially treated waste would remain in-place after S/S treatment, resulting in the potential for I groundwater contamination. I

I D:IFTMCCOY /IPDCMSIISECTION.2 2-37 March 1996 I Fort McCoy Draft Co"ective Measures Study Report

CL2, CL3, and the GA are expected to remain the property of the U.S. Army and continue to have I associated effective access restrictions. The perimeter fences around CL2, CL3, and the GA, if required, would provide a further effective access restriction. ,. I Land and groundwater use restrictions will be effective, as CL2, CL3, and the GA are expected to remain the property of the U.S. Army. lfCL2, CL3, and the GA do not remain the property of the I U.S. Army, the effectiveness of deed restrictions will depend on continued enforcement and could be subject to changes in political jurisdiction and legal interpretation. NR 812.08 would supplement groundwater use restrictions by prohibiting the installation of new water supply wells within I 1,200 feet ofCL2, CL3, and the GA.

The CL2, CL3, and GA soil cover and CL2 erosion protection/slope stabilization would be effective I in minimizing the potential for disturbance and erosion of stabilized waste material and subsequently, the potential for ecological impacts to the La Crosse River. By promoting runoff, the soil cover would also be effective in reducing infiltration and subsequent migration of stabilized I waste material contaminants to groundwater. Residual low levels of groundwater contamination would be addressed with natural attenuation. · I Semi-annual groundwater sampling and analysis is a proven effective means of monitoring groundwater quality. I lmplementability and Reliability I Based on the site-specific factors summarized in Section 2.1 0.2, access, land and groundwater use restrictions, the soil cover for treated material at CL2, CL3, and the GA, erosion protection/slope · stabilization at CL2, natural attenuation, and groundwater monitoring would be reliable and readily I implementable at CL2, CL3, and the GA. However, due to the potential problems noted above with performing a complete in-situ stabilization treatment, in-situ S/S may not be readily implementable nor reliable long-term. Construction of Alternative 4 should be able to be completed in one I construction season.

It is anticipated that the regulatory requirements outlined in Table 2-4, would have to be addressed I to construct the CL2 soil cover and erosion protection/slope stabilization components. I Operation and Maintenance

Semi-annual groundwater monitoring would be the only Alternative 4 operational requirements. It I is assumed, for cost estimating plJ@Oses, that groundwater monitoring will be performed for 30 years to document the long-term effectiveness of the S/S treatment. I The CL2, CL3, and GA soil cover and CL2 erosion protection/slope stabilization and the perimeter fences (if required) would be maintained by Fort McCoy through routine inspections and maintenance. Monitoring wells may require periodic well screen cleaning and other minor I maintenance. It is anticipated that the useful life ofthe monitoring wells would be at least 15 years. I

D:IF1MCCOYJIPDCMSJISEC170N.2 2-38 March 1996 I I Fort McCoy Draft Corrective Measures Study Report

I Safety

Safety of nearby residents, environments and site workers with regard to physical hazards during I implementation would be addressed by provisions in the construction contractor's SSHP. Potential site safety hazards during construction could include, but not be limited to, heavy equipment I operation, chemical exposure, slip/trip/fall hazards, heat/cold stress, wildlife (ticks, snakes, etc.), and vegetation (poison ivy, etc.). Temporary environmental controls (silt fencing, sheet piling, dust suppression, etc.) and ambient air monitoring would be implemented as needed during stabilization I of CL2, CL3, and GA material; construction of CL2, CL3, and GA soil cover; and CL2 erosion protection/slope stabilization.

I Environmental Evaluation

Environmental controls (sheet piling, silt fence, berms, etc.) would be employed during the I implementation of Alternative 4 components to minimize adverse short-term impacts (siltation, runoff, spills, etc.) to environmentally sensitive areas along the La Crosse River. Encroachment into the river channel to implement erosion protection and slope stabilization measures for will be I minimized to the extent practical. The corrective action design will focus on methods to minimize short-term surface water quality problems related to construction activities.

I An ecological field assessment conducted during the RFI (results presented as an appendix to the RFI Report) concluded that the primary exposure pathway of concern is the ingestion or direct I uptake of contaminated soil or water by ecological communities adjacent to CL2. This exposure pathway would be mitigated by the implementation of the CL2 soil cover and erosion protection/slope stabilization measures in Alternative 4 which would minimize the potential for I erosion of and contaminant migration from the treated CL2 source material. Access and land use restrictions in Alternative 4 would further minimize the potential for treated source material I disturbance and subsequent environmental impacts. Human Health Evaluation

I Access, land use, and groundwater use restrictions in Alternative 4 would prevent residential development at CL2, CL3, and the GA. Therefore, the most likely human health risk exposure scenario for CL2, CL3, and the GA is that of ingestion of and direct contact with cqntaminated I surface soil by hypothetical site trespassers or a wastewater treatment plant worker. The human health assessment concluded that trespassers and wastewater treatment plant workers are not exposed I to excess health risks under current site conditions. There are no current nor anticipated groundwater receptors located between CL2, CL3, and the GA I and the La Crosse River and NR 812.08 prohibits the installation of new water supply wells within 1,200 feet of a solid waste site. I I

I D: IF7MCCOY IIPDCMSIISEC110N.2 2-39 March 1996 I Fort McCoy Draft Co"ective Measures Study Report

Institutional Evaluation I Institutional needs for Alternative 4 would include enforcing existing site access restrictions, I enforcing land and groundwater use restrictions, and performing routine groundwater monitoring. The design and implementation schedule for Alternative 4 components may be effected by Federal, I state and local environmental and public health standards, regulations, guidance, advisories, ordinances or community relations. Design and construction of CL2 soil cover and erosion protection/slope stabilization measures, and stabilization of CL2, CL3, and GA material would be I impacted by the following:

• Regulatory requirements outlined on Table 2-4. I

• Community relations which wouldbe addressed by USEPA, WDNR, USACE, and Fort McCoy after the public comment period. I

It is anticipated that the other components of Alternative 4 would not be significantly effected by Federal, state and local environmental and public health standards, regulations, guidance, advisories, I ordinances or community relations. I For Alternative 4, the operation period for groundwater monitoring would be dependent on the time to achieve acceptable levels of COCs in groundwater. It is assmned, for cost estimating purposes, that groundwater monitoring will be performed for 30 years to document the long-term effectiveness I of the in-situ S/S treatment.

Cost Evaluation I

The cost for Alternative 4 includes capital costs to perform in-situ stabilization of CL2, CL3, and GA material, construct the perimeter fences (if required), CL2/CL3/GA soil cover, and CL2 erosion I protection/slope stabilization measures including replacement of four monitoring wells, annual operation and maintenance costs associated with semi-annual groundwater monitoring, and periodic fence, soil cover, and erosion protection/slope stabilization inspection and maintenance. It is I assumed that costs for recording deed restrictions would be negligible. I The estimated conceptual capital construction cost for Alternative 4 is $22,752,000 as presented in Table 2-11. The estimated conceptual present worth O&M cost for Alternative 4 is $1,030,000 as presented in Table 2-12. Additional detail and supporting documents for the cost estimate are I presented in Appendix A.

A summary of the cost estimates for all four alternatives is presented in Table 2-13. I 2.10.4 Recommended Alternative I Based on the site-specific factors identified in Section 2.1 0.2, the alternatives evaluation performed in Section 2.1 0.3, and the comparison presented in Table 2-14, Alternative 1 is recommended for I

D:IFJMCCOYIIPDCMSIISECTION.2 2-40 March 1996 I I Fort McCoy Draft Corrective Measures Study Report

I TABLEl-11

CL2, CL3, AND THE GA I ALTERNATIVE 4 CAPITAL COST ESTIMATE FORT MCCOY, WISCONSIN

I Capital Cost Item Quantity Unit Unit Cost Item Cost

Pre-Design:

I Site Survey (CL2, CL3, GA) I LS $5,000 $5,000

Limits of Waste Investigation (CL2, CL3, I LS $8,000 $8,000 I GA) Wetlands Delineation I LS $7,000 $7,000 I Pre-Design Subtotal $20,000 Construction: I Perimeter Fences I LS $65,000 $65,000 Clearing and Grubbing 7.0 AC $6,250 $44,000

Stabilization of Landfill Material:

I Bench-Scale Test I LS $100,000 $100,000

Pilot-Scale Test I LS $200,000 $200,000 I Mobilization/Demobilization I LS $160,000 $160,000 Stabilization 119,000 CY $100 $11,900,000 I Surface Debris Handling 2,000 CY $5 $10,000 Subsurface Debris Handling 5,000 CY $10 $50,000 I Debris Hauling 10,000 Ton $30 $300,000 Debris Disposal 10,000 Ton $28 $280,000 I Characterization Sample Analysis 70 Each $1,200 $84,000 Confirmation Soil Sampling 149 Each $900 $134,000 I Replace Monitoring Wells 4 Each $2,000 $8,000 Stabilization Subtotal $13,226,000 I Cover Stabilized Material: Soil Borrow, Haul, and Placement 19,000 CY $15 $285,000

Vegetation 8.0 AC $2,000 $16,000

I Cover Stabilized Material Subtotal $301,000

Erosion Protection/ Slope Stabilization: I Erosion Control Mat 5,600 SY $2 $11,000 Rip Rap 860 SY $58 $50,000 I Erosion Protection Subtotal $61,000

I D:IFTMCCOY IIPDCMSI\TAB2-II. March 1996 I Fort McCoy I Draft Corrective Measures Study Report TABLE 2-11 (Continued)

CL2, CLJ, AND THE GA I ALTERNATIVE 4 CAPITAL COST ESTIMATE FORT MCCOY, WISCONSIN I Capital Cost Item I Quantity I Unit I Unit Cost Item Cost I Construction Subtotal $13,697,000 Construction Global Markups:

Scope Contingency (15%) $2,055,000

I Subtotal $15,752,000

Health and Safety (30%) $4,726,000

I Subtotal $20,478,000

Permitting (I%) $205,000 I Engineering (2%) $410,000 Construction-Related Services (3%) $615,000 I Prime Fixed Fee (5%) $1,024,000 Construction Total $22,732,000 I TOTAL CAPITAL COST ~22 7

I D:IF1MCCOY JIPOCMSJ\TAB2-l I. March 1996 I Fort McCoy Draft Corrective Measures Study Report

I TABLE2-12 I CL2, CL3, AND THE GA ALTERNATIVE 4 O&M COST ESTIMATE I FORT MCCOY, WISCONSIN Annual Total I O&Mitem Quantity Unit Unit Cost Cost Groundwater Monitoring (30 yrs):

I Groundwater Sampling 1 event <1> YR $49,000 $49,000 and Analysis I Scope Contingency (15%) $8,000 Subtotal $57,000 I Administration (1 0%) $6,000 Groundwater Monitoring Subtotal $63,000 I Site Inspection and Maintenance (30 yrs):

Inspection and 1 event YR $3,000 $3,000 I Maintenance Scope Contingency (15%) $500 I Subtotal $3,500 I Administration (1 0%) $400 Inspection and Maintenance Subtotal $4,000 I Total Annual O&M Cost $67,000 Total Present Worth ofO&M $1.030.000 I Note:

(I) Includes two sampling events per year at six wells. I Cost assumptions are presented in Appendix A to CMSR. I I I

I D:IF1MCCOYIIPIXMSJ\TAB2-12. March 1996 I Fort McCoy Draft Corrective Measures Study Report

I TABLE 2-13

CL2, CL3, AND THE GA I CORRECTIVE MEASURES ALTERNATIVES COST ESTIMATE SUMMARY FORT MCCOY, WISCONSIN I Alt#l Alt#2 Alt#3 Alt#4 I··· .. ·.•· ...... ········ •.•·/ / · ...... ·. I• .•...... •· . •••• •source > I•···· ...... /·.·.•· ...... I /)...... ·····•···· \ I > ..• ..... I Access, X X X Land Use I Restrictions Perimeter Fence X X X (Optional) I Soil Cover X X X Erosion Protection X X X I Excavation and X Disposal

In-Situ Stabilization X I ,.>. s ..••••...•.•.. ... >·.•·. < c Gr~undwate; · I. ./. p / . •••• ...... I Use Restrictions X X X X Natural Attenuation X X X X I Monitoring X X X X Extraction and X Treatment I .... > J < ··•·cost •.. •·.• . I .•. ... >·····•• I ··> .. .·.·•• •.1·•·•· •i < .•..•. ·••••·•· / I> ·····•·•· ······ .} . ·····•··· ·.······················· Capital $713,000 $1,639,000 $17,415,000 $22,752,000

I AnnualO&M $67,000 $243,000 $65,000 $67,000 (30 yr) (5 yr) (5 yr) (30 yr) I $67,000 (25 yr) Present Worth O&M $1,030,000 $1,792,000 $282,000 $1,030,000 (30 yr) (30 yr) (5 yr) (30 yr) I Total Cost $1,743,000 $3,431,000 $17,697,000 $23,782,000

NOTES:

I *Present Worth Factor (5% rate): 5 years = 4.329 I 30 years= 15.373 I

I D:IF1MCCOYJIPOCMSJITAB2-JJ. March 1996 I Fort McCoy Draft Corrective Measures Study Report

I TABLE 2-14

CL2, CL3 AND THE GA I CORRECTIVE MEASURES ALTERNATIVES COMPARISON FORT MCCOY, WISCONSIN I Evaluation Criteria Alt#l Alt#2 Alt#3 Alt#4

Effectiveness Should be Should be Only effective if Only effective if all I (perfonns intended effective effective complete removal of waste mass can function) of waste achieved be satisfactorily (Section 2.10.3.4) treated I (Section 2.10.3.5) Implementability lmplementable Implementable May not be fully May not be fully and Reliability {can and reliable and reliable implementable; is implementable; I be done and will it reliable concern with long- last/ perfonn over (Section 2.10.3.4) tenn reliability the long-tenn) (Section 2.10.3.5) I Operation and Low Medium Low Low Maintenance (O&M) Cost

I Safety Concerns Low Low Medium Medium During Construction/ I Implementation Environmental Adequately Adequately Adequately Adequately Concerns addresses addresses addresses concerns addresses concerns concerns in concerns in in Section 2.8.5 in Section 2.8.5 I Section 2.8.5 Section 2.8.5

Human Health Adequately Adequately Adequately Adequately I Concerns addresses addresses addresses concerns addresses concerns concerns in concerns in in Section 2.8.5 in Section 2.8.5 Section 2.8.5 Section 2.8.5 I Institutional Addresses Addresses Addresses Addresses Concerns institutional institutional institutional control institutional control control needs control needs needs identified in needs identified in I identified in identified in Sections 2.8.5 and Sections 2.8.5 and Sections 2.8.5 and Sections 2.8.5 and 2.8.6 2.8.6 2.8.6 2.8.6 I Cost $1,743,000 $3,431,000 $17,697,000 $23,782,000 I I I

I D:IFTMCCOY/IPDCMS/\TAB2-/4. March 1996 I Fort McCay Draft Corrective Measures Study Report

I CL2, CL3, and the GA. Alternative 1 consists of access, land and groundwater use restrictions; CL2 soil cover and erosion protection/slope stabilization; natural attenuation of low-level groundwater I contamination; and groundwater monitoring. Alternative 1 addresses the corrective action objectives for CL2, CL3, and the GA by preventing I access to source material, minimizing the potential for ecological impacts to the La Crosse River, limiting groundwater use, and reducing groundwater concentrations to acceptable levels over time. Given the age and lack of detailed information on the waste material in CL2 and CL3, and the low­ I level sporadic exceedances of PALs in groundwater, it is not possible to accurately predict the time it will take to not have exceedances of the PALs. However, the assumed time period of 30 years should be a conservative estimate. If in the future, the PALs are not exceeded for several consecutive I monitoring events, the 30 year monitoring period may be reduced by way of a permit modification. Alternative 1 would be technically effective, reliable, and implementable at CL2, CL3, and the GA I and would provide short-term and long-term protection of human health and the environment. As presented in Table 2-14, Alternative 1 adequately addresses the human health, environmental, I and institutional control concerns, is readily implementable, provides long-term reliability and is less costly as compared to Alternatives 2, 3, and 4. In addition, compared to the other alternatives, Alternative 1 presents the least potential for adverse impacts to the La Crosse River and adjacent I wetlands. I I I I I I I I I

I D:IFTMCCOYJIPIXMSJISEC170N.2 2-41 March 1996 I Fort McCoy Draft Co"ective Measures Study Report

I 3.0 FIRE TRAINING BURN PIT 1

I 3.1 DESCRIPTION OF FIRE TRAINING BURN PIT 1

Fire Training Bum Pit 1 (FTBP1) is located in the S 1/2 ofthe NW 1/4 of Section 13, T18N, R3W, I Monroe County, Wisconsin. FTBP1 is located within the Equipment Concentration Site (ECS) vehicle parking area approximately 1,500 feet east of Squaw Creek. The pit had a diameter of I approximately 40 feet and was used for training fire fighters. See Figure 3-1 for the location of FTBP1. I 3.2 WASTE MANAGEMENT ACTIVITIES FTBP1 was constructed by excavating soil to a depth of approximately 3 feet and a diameter of I approximately 40 feet. Training activities started with filling the pit with water and fuel.and igniting the fuel layer. Fire fighters would extinguish and reignite the fuel repeatedly until the fuel was I consumed. FTBP1 has not been used since 1987 when it was graded flat. 3.3 PHYSICAL SITE CHARACTERISTICS

I This subsection describes the physical setting ofFTBP1 based on information presented in the RFI report.

I 3.3.1 Site Setting I FTBP1 is located within the ECS at Ft. McCoy. The ECS is relatively flat with a large portion of· the ECS covered with crushed rock. The ECS is fenced with access controlled by Ft. McCoy staff. The location of the pit within the ECS is marked by barrels placed on grade defining a rectangular I area. Figure 3-2 illustrates the immediate site setting ofFTBP1. I 3.3.2 Topography and Drainage The land surface at FTBP1 is relatively flat with a slight slope to the west toward Squaw Creek. The topographic high elevation of the area is west of well OW-132 at 895.0 feet MSL and the low I elevation is west of well OW-134 at 892.0 feet MSL. Topography of the area around FTBP1 is illustrated on Figure 3-2. There is little surface runoff to Squaw Creek due to the flat topography I and high permeability of the surficial soils. 3.3.3 Surficial Soils

I The surficial soil at FTBP1 was the Tarr sand prior to being removed by grading for the ECS. With I the majority of the Tarr sand removed, the Quaternary alluvium is exposed at the ground surface. I

I D:IF1MCCOY/IPOCMS/ISECTION.3 3-1 March 1996 ~~==--~~------~ I ~ ------~~~~~N_ _:~~~y MONROE COUNTY N I I I ., I "'c::r I ~ PESTICIDE DISPOSAL SITE I ....ru FIRE TRAINING I BURN PIT 1

I CLOSED lANDFilL 2 I CLOSED LANDFill. 3 I I I I I

I I

0 1/2 I 2 MILES SCALE I SOURCE: WISCONSIN DEPARTMENT OF TRANSPORTATION ---- MAR. 1996 FIGURE 3-1 18903 FIRE TRAINING BURN PIT I I ...... -ENVIRONMENT & LOCATION MAP I~U~I INFRASTRUCTURE DRAFT CORRECTIVE MEASURES STUDY I FORT McCOY, WISCONSIN I

UJ UJ UJ "'-.. ~-. '~ 0 0 0 ~ .... 0 I 0 0 0 0 0 N fJ) en en ....en en I co co co I ..,) ( Ill 0'> ...... + 0 + I -' ...... 0 ~I~ ~

I ~I H£L=880.79 I~ 1!.7 6.. !l.Z. = OW-137 I ri"\W_IA,., ... ¢ APPROXIMATE I LOCATION OW-141 OF FIRE TRAINING I BURN PIT I I \ ,..._ I N.7133A' \ ,..._ ~~1336 ' I co ' ,..._co I I en 0 L=884.5 co ,..._ co I ~ co co C\1 743400 N N co .... ~ + ---894 I - co 0 N + ~ t-135 en ~ co I ~ oq­ ,..._ .g u... co co co l() <.o co ~ co co II ...... co co I <[ 0

LEGEND I N I ---831----- TOPOGRAPHIC CONTOUR )( )( FENCE

878--- GROUNDWATER CONTOUR NOTES: I I. GROUNDWATER TABLE ELEVATIONS AND CONTOURS -o ARE DERIVED FROM THE RFI PHASE 3 INVESTIGATION. ..; GROUNDWATER FLOW DIRECTION c: 0' 30' 60' ~ GROUNDWATER MONITORING WELL SCALE. I j -+-P-134A ---

~.... EL=BB/.92 GROUNDWATER MONITORING WELL MAR. 1996 FIGURE 3-2 18903 / WITH GROUNDWATER ELEVATION I 0 FIRE TRAINING BURN PIT I .!!. .OW-143 IN FEET ABOVE MEAN SEA LEVEL 0 ..M9ENVIRONMENT & MONITORING WELL & SELECTED BORING ~ SOIL BORING I~U~I INFRASTRUCTIJRE LOCATIONS & WATER TABLE MAP II ~8103 DRAFT CORRECTIVE MEASURES STUDY I i:3 FORT McCOY, WISCONSIN 0~------~------~------~ I Fort McCoy Draft Co"ective Measures Study Report

I 3.3.4 Geology

The only geological unit encountered during drilling to depths of approximately 60 feet at FTBPl I was the Quaternary alluvium. In this area, the Quaternary alluvium consists of fine grained, well sorted sand.

I 3.3.5 Hydrogeology

Hydrogeologic information for FTBPl was obtained during the three phases of the field I investigation for the RFI. Twenty-two wells were installed during the RFI. Well locations are I shown on Figure 3-2. The water table is approximately 12 feet below the ground surface, although it was observed at a depth of approximately 7 feet during 1993 due to a wet year. The average field hydraulic I conductivity value of wells screened in the alluvium is 0.0048 em/sec. The water table gradient is approximately 0.015 ft/ft toward the west with a vertical gradient of0.0042 ft/ft directed upward. I The FTBPl area is a groundwater recharge area. 3.4 SITE CONCEPTUAL MODEL

I Figure 3-3 illustrates the site conceptual model for FTBPl. The primary source of contamination at FTBPl includes burned and unburned fuel residues and chlorinated organics remaining in the soil. Precipitation may infiltrate through contaminated soil to leach and transport contaminants into the I groundwater. Groundwater may then transport contaminants with the regional flow in the direction of Squaw Creek. Transport of contaminants by precipitation runoff is not applicable here due to the I permeable surficial soil and flat topography. I 3.5 NATURE AND EXTENT OF CONTAMINATION Sampling and analysis of soil, soil gas, and groundwater at FTBPl has occurred both during and after the RFI. Description of these activities as well as analytical results are presented in detail in I Section 12.0 of the RFI Report.

Soil contamination appears to be localized to the immediate vicinity of FTBP 1 to depths up to I 11 feet, and limited essentially to VOCs and petroleum hydrocarbons. Soil samples from borings CB-103 and CB-301 (see Figure 3-2) were the only soil samples with significant levels of contamination and the only soil samples with detectable levels of total petroleum hydrocarbons I (TPH). CB-103 soil samples were the only soil samples, with the exception of CB-101-01 (see Figure 3-2), in which 1,2-dichloroethene (1,2-DCE), trichloroethene (TCE), or tetrachloroethene I (PCE) were detected. The primary consistently detected contaminants in groundwater at FTBPl are 1,2-DCE, TCE, and I PCE as found in CB-103 soil samples. These were also the only contaminants, with the exception. of cadmium and lead detected in groundwater at levels exceeding NR 140 PALs. PCE, TCE, and I 1,2-DCE are common solvents with TCE and 1,2-DCE being degradation products ofPCE. The I D:IF1MCCOYJIPDCMSI'SECTION.3 3-2 March 1996 I I

I "0..... rTw 5I Q c. ;,..., I c. ., BARRELS DELINEATING APPROXIMATE tD FORMER PIT LOCATION ------. C'

1'1.1 I sn FENCE AT EAST iD EDGE OF 'ECS <.0 Ol LIGHT POLE I !$ U1 !':> 1'1.1 I U1 I BURN PIT I I

GROUNDWATER I FLOW DIRECTION I I I I

NOTES:

I 1. ECS - EQUIPMENT CONCENTRATION SITE 2. SEE FIGURE 3-2 FOR LOCATION OF I GROUNDWATER MONITORING WELLS. SCALE: NTS MAR. 1996 FIGURE 3-3 18903 & SITE CONCEPTUAL MODEL .....ENVIRONMENT FIRE TRAINING BURN PIT I I ~~~~ INFRASTRUCTURE DRAFT CORRECTIVE MEASURES STUDY I FORT McCOY, WISCONSIN I Fort McCoy Draft Corrective Measures Study Report

I highest levels of groundwater contamination were detected in wells OW-II7 and OW-I29B just west of the former bum pit. ES exceedances in groundwater were detected up to approximately 400 feet west of the former bum pit with PAL exceedances detected up to 700 feet west of the I former bum pit. A summary of groundwater monitoring results is presented in Table 3-I. I 3.6 CONTAMINANT FATE AND TRANSPORT The RFI data demonstrate that chlorinated contaminants (I ,2-DCE, TCE, PCE) apparently moved through the soil to the groundwater. Westerly groundwater flow intercepting the vertically moving I contaminants apparently is providing a migration mechanism for horizontal movement. I Soil contaminated with diesel range organics (diesel fuel related petroleum compounds) and xylene, toluene, and ethylbenzene was also found at FTBPI. Xylene, toluene, and ethylbenzene are VOCs which favor diffusion into the soil atmosphere. As petroleum hydrocarbons detected at CB-30I I weather, many of the lower molecular weight organic compounds will volatilize, leaving a more hydrophobic organic mass. The remaining, more stable hydrocarbons may then sorb other organic compounds from the soil solution resulting in decreased contaminant mobility (Bouchard et al, I I989). This scenario likely exists in the soil at CB-30I and explains why groundwater does not show the presence of these compounds.

I 3.7 DEVELOPMENT OF CORRECTIVE ACTION OBJECTIVES I 3.7.1 Introduction The purpose of this section is to identify potentially applicable soil and groundwater contaminant limits for the chemicals of potential concern (COCs) identified in the RFI Report for FTBPI. These I soil and groundwater contaminant limits are based on public health and environmental criteria, information gathered during the RFI, and applicable WDNR and USEP A regulations. These soil I and groundwater contaminant limits will be considered during the identification and development of appropriate corrective action technologies and alternatives.

I The COCs identified for FTBP I are: I Chemical of Potential Qoncem Tetrachloroethene (groundwater) T richloroethene (groundwater) I I,2-Dichloroethene (trans) (groundwater) Cadmium (groundwater) I Lead (groundwater) I The above compounds were selected as COCs based on one of the following: • COC equals or exceeds an NR I40 PAL in groundwater samples collected from a downgradient I monitoring well. I D:IF1MCCOYJIPDCMSJISEC170N.3 3-3 March 1996 ------Fort McCoy- Draft Corrective Measures Study Report

TABLE3-l

GROUNDWATER QUALITY SUMMARY FIRE TRAINING BURN PIT NO. I FORT MCCOY, WISCONSIN

Weiiii6A Welll168 Well117 Well P-129A Welll298 Well P-129C Well132''' Analytes Detected at Levels Exceeding NR 140 Public RFI Phase TS Monitoring RFI Phase TS Monitoring RFI Phase TS Monitoring RFI Phase TS Monitoring RFI Phase TS Monitoring RFI Phase TS Monitoring RFI Phase TS Monitoring Health Standards I 2 3 T-1 T-2 T-3 I 2 3 T-1 T-2 T-3 I 2 3 T-1 T-2 T-3 I 2 3 T-1 T-2 T-3 I 2 3 T-1 T-2 T-3 I 2 3 T-1 T-2 T-3 I 2 '3 T-1 T-2 T-3 1,2-Dichloroethene ------2 -- 180.0 170 330.0 - 5 - NS ------NS 520.0 2,100.0 540.0 8 2 NS NS - - NS NS NS NS - 27.0 NS NS Tetrachloroethene 12.0 ------13.0 2.0J 13.0 -- 4 - 480.0 860 1,500.0 340.0 6 - NS I.OJ ------NS 1,200.0 760.0 510.0 - - NS NS - - NS NS NS NS - -- NS NS Trichloroethene ------2 - 61.0 87 130.0 90.0 3 - NS ------NS 190.0 280.0 310.0 - - NS NS - - NS NS NS NS - -- NS NS Cadmium ------NS NS - 5.0 -- -- NS NS ------NS NS NS ------NS NS NS - -- - NS NS NS NS -- - NS NS NS NS - - NS NS Lead ------NS NS ------NS NS -- 4.3 6.0 - NS NS NS -- - - NS NS NS ------NS NS NS NS -- -- NS NS NS NS -- -- NS NS

Well P-133A Welll338 Well134 Weiii34A Well135 Well P-135A Well P-136A Welll368 Analytcs Detected at Levels Exceeding NR 140 Public RFI Phase TS Monitoring RFI Phase TS Monitoring RFI Phase TS Monitoring RFI Phase TS Monitoring RFI Phase TS Monitoring RFI Phase TS Monitoring RFI Phase TS Monitoring RFI Phase TS Monitoring Health Standards I 2 3 T-1 T-2T-3 I 2 3 T-1 T-2 T-3 I 2 3 T-1 T-2 T-3 I 2 3 T-1 T-2 T-3 I 2 3 T-1 T-2 T-3 I 2 3 T-1 T-2 T-3 I 2 3 T-1 T-2 T-3 I 2 3 T-1 T-2 T-3

1,2-Dichloroethene NS NS - - NS NS NS NS - -- 120160 NS NS -- -- 7 - NS NS - -- NS NS NS NS -- - NS NS NS NS - -- NS NS NS NS -- - - - NS NS 700.0 330 4 Tetrachloroethene NS NS 0.68 - NS NS NS NS 0.78 -- 8 10 NS NS 3.18 6.8 8 2J NS NS - -- NS NS NS NS- - NS NS NS NS -- -- NS NS NS NS ------NS NS 2.38 120.0 200 -- Trichloroethene NS NS - -- NS NS NS NS -- -- 4 6 NS NS - -- 6 -- NS NS -- - NS NS NS NS -- - NS NS NS NS - - NS NS NS NS ------NS NS - -- 120 -- Cadmium NS NS -- -- NS NS NS NS -- -- NS NS NS NS - - NS NS NS NS -- -- NS NS NS NS -- -- NS NS NS NS - -- NS NS NS NS -- - NS NS NS NS -- -- NS NS Lead NS NS -- -- NS NS NS NS -- -- NS NS NS NS -- -- NS NS NS NS - -- NS NS NS NS- -- NS NS NS NS -- -- NS NS NS NS -- - NS NS NS NS - - NS NS

/J:IF1U'COYJII'IX'AfSJ\TABJ-J Page I o/2 March 1996 ------Fort McCoy Draft Corrective Measures Study Report

TABLE 3-1 (Continued)

GROUNDWATER QUALITY SUMMARY FIRE TRAINING BURN PIT NO. 1 FORT MCCOY, WISCONSIN

Welll37 Welll38 Welll41 Well142 Well143 Well308 Weii308A Analytes Detected PAL ES at Levels Exceeding NR 140 Public RFI Phase TS Monitoring RFI Phase TS Monitoring RFI Phase TS Monitoring RFIPhase TS Monitoring RF1 Phase TS Monitoring RFI Phase TS Monitoring RFI Phase TS Monitoring Health Standards I 2 3 T·l T·2 T-3 I 2 3 T·l T-2 T-3 I 2 3 T-1 T-2 T-3 I 2 3 T-1 T-2 T-3 I 2 3 T-1 T-2 T-3 I 2 3 T·l T-2 T·3 I 2 3 T-1 T-2 T·3 1,2-Dichloroethene NS NS 32.0 - NS NS NS NS - - NS NS NS NS - 9.6 NS NS NS NS - - NS NS NS NS - - NS NS NS NS 110.0 120.0 3 3 NS NS - - NS NS 20.0 100.0 Tetraehloroethene NS NS 110.0 81.0 NS NS NS NS - - NS NS NS NS - 4.7 NS NS NS NS 0.78 - NS NS NS NS 1.88- NS NS NS NS 230.0 220.0 16 19 NS NS - - NS NS 0.5 5.0 Trichloroethene NS NS 17.0 6.5 NS NS NS NS - - NS NS NS NS - - NS NS NS NS -- NS NS NS NS - - NS NS NS NS 33.0 42.0 5 4 NS NS - - NS NS 0.5 5.0 Cadmium NS NS - - NS NS NS NS - - NS NS NS NS - - NS NS NS NS - - NS NS NS NS - - NS NS NS NS - - NS NS NS NS -- NS NS 0.5 5.0 Lead NS NS - - NS NS NS NS - - NS NS NS NS 4.0 - NS NS NS NS - - NS NS NS NS -- NS NS NS NS - - NS NS NS NS -- NS NS I.S 15.0 NOTES:

All values are in ug/1. - Indicate analyte not detected at level exceeding the PAL. NS Well not sampled or analyte not analyzed. T·l samples collected in August 30 and 31/September I, 1994 prior to AS/SVE startup. T-2 samples collected in November 9 and 10, 1995, after the first month of AS/SVE system operation. T-3 samples collected in December 6 and 7, 1995, after the second month of AS/SVE system operation. (I) Well 132 is the upgradient well. J Estimated value. 8 Compound detected in blank sample. TS • AS/SVE Treatability Study

D:\FTMXOY/IPOCMS/\TABJ..I Page2of2 March 1996 I Fort McCoy Draft Corrective Measures Study Report I • COC is a primary contributor to calculated human health risks associated with groundwater exposure pathways under hypothetical future residential use risk scenario at FTBP1.

I • COC is a primary contributor to calculated human health risks associated with soil exposure pathways under hypothetical future residential use risk scenario at FTBP 1.

I 3.7.2 Federal Regulations and Permits I 3.7.2.1 Groundwater Standards The established Safe Drinking Water Act MCLs for COCs at FTBP1 are presented below.

I Federal MCL I Chemical of Potential Concern uWI Tetrachloroethene 5 Trichloroethene 5 I 1,2-Dichloroethene (trans) 100 Cadmium 5 I Lead 15(1) (I) Action Level; no MCL established

I 3. 7.2.2 Soil Standards I There are no federal soil quality standards which apply with respect to soil cleanup objectives. I 3.7.2.3 Surface Water Standards Surface water standards are contained under 40 CFR 122.2 of the Clean Water Act. These standards I address point source discharges and are not directly applicable to measurable surface water quality. 3.7.3 Wisconsin Regulations and Permits

I 3.7.3.1 Groundwater Standards

Wisconsin has implemented the Safe Drinking Water Act under NR 809 WAC and has either I adopted the federal standard or developed a more stringent level. Groundwater quality standards are published in NR 140 WAC. The groundwater quality standards consist of PALs and ESs. The I PALs, ESs, and the Wisconsin MCLs for COCs at FTBP1 are listed below. I I I D:IF1MCCOYJIPOCMSJISEC110N.J 3-4 March 1996 Fort McCoy I Draft Corrective Measures Study Report I Wisconsin PAL ES MCL Chemical of Potential Concern y~ uWI uWI I TeuachJo~ethene 0.5 5 5 I TrichJo~ethene 0.5 5 5 1,2-DichJoroethene (trans) 20 100 100 Cadmium 0.5 5 5 I Lead 1.5 15 N/A NOTES: N/A =No MCL available. I 3.7 .3.2 Soil Quality Standards I WDNR has issued NR 720 regulations which address residual soil contaminant levels. A human health and en~nmental assessment was completed and app~ved for FTBPI during the RFI. The assessment determined existing soil contaminant levels at FTBP I as detected in the RFI do not pose ·I an unacceptable health risk even using the residential scenario. Contaminant concentration limits for soil resulting from that assessment and an evaluation of the NR 720 regulations are discussed in Section 3.7.6. I 3.7.3.3 Surface Water Standards I Surface Quality Standards are contained in WAC NR 102-105. Surface water standards for the COCs were not exceeded. I 3.7.4 Local Regulations and Permits I There are no local regulations or permits which contain soil or groundwater cleanup objectives.

3.7.5 Human Health and Environmental Assessment I

A human health assessment of potential risks was completed for FTBPI using Phase I and Phase 2 RFI data (SEC Donohue, November 1994). As required by USEPA and WDNR, potential exposure I scenarios were evaluated and include scenarios involving hypothetical residents and trespassers at FTBPI. COCs which contribute to excess risk at FTBPI based on hypothetical residents living at FTBPI include the following: I Chemical Media Affected I

TeuachJo~ethene Groundwater TrichJoroethene Groundwater I I ,2-DichJoroethene (trans) Groundwater I

D:IFIMCCOYIIPDCMSIISEC170N.3 3-5 March 1996 I I Fort McCoy Draft Corrective Measures Study Report

I As stated in 40 CFR 300.430(e)(2)(i)(A)(2) of the National Contingency Plan (NCP), "for known or suspected carcinogens, acceptable exposure levels are generally concentration levels that represent an ·excess upper bound lifetime cancer risk to an individual of between 104 (1 in 10,000) and 10"6 I (1 in 1,000,000) using information on the relationship between dose and response." In addition, USEPA's Office of Solid Waste and Emergency Response (OSWER) Directive No. 9355.0-49FS (Presumptive Remedy for CERCLA Municipal Landfill Sites) (see Appendix D), it is stated "that I based on site-specific conditions, an active response is not required if groundwater contaminant concentrations exceed chemical-specific standards but the site risk is within the Agency's acceptable I risk range (104 to 10-6)." Therefore, consistent with Sections 5.1 and 5.2 of the approved human health risk assessment, for the purpose of discussion in the CMS Report, excess risk is defined as total excess cancer risk levels to any population exceeding 104 and noncarcinogenic hazard index I (HI) greater than 1E+OO (1.0). It should be noted that the excess risk identified is based on groundwater contaminant concentrations. at FTBP 1 does not present an excess I health risk. This identification of COCs which contribute to excess risk based on the hypothetical scenario of residents living at FTBP1 is presented since this scenario was one of the criteria used to include a I SWMU in the CMS. This residential scenario assumes both daily contact and consumption of soil and groundwater at the site 350 days per year for a period of 30 years. However, it should be noted that there are several institutional controls that would prevent residential development on FTBP1. I These controls include: I • NR 812.08 prohibits the installation of new water supply wells within 250 feet of a lagoon (FTBP1 would be considered an impoundment/lagoon).

I • FTBP1 is expected to remain the property of the U.S. Army and continue to have associated access restrictions. FTBP 1 is located within a secured, fenced military vehicle parking lot.

I • lfFTBP1 does not remain the property of the U.S. Army, restrictive covenants could be written into a site property deed to notify a prospective purchaser of the location and source of solid I waste/contamination and that groundwater use must be restricted. Therefore, the residential scenario will not be considered applicable to this SWMU. The most likely exposure scenario would be that of a worker at the ECS vehicle parking lot. This scenario assumes I ingestion of and contact with soil at a frequency much less than the residential scenario. Contact with or ingestion of groundwater does not apply to a worker since they do not have access to the I groundwater. Since there was no excess health risk determined in the RFI for the hypothetical 4 residential scenario based on exposure to soil (carcinogenic risk = 2E-05<1 0 ; HI = 1E-0 1<1.0), there is no excess health risk for the worker given a less frequent exposure to the site compared to I a hypothetical resident. Trespassers at the SWMU would also not be exposed to excess health risks 4 (carcinogenic risk= 3£-08<10 ; HI= 6£-04<1.0).

I A qualitative environmental assessment at FTBP 1 revealed that future ecological communities could be affected by contamination if corrective actions were not pursued at this site (SEC Donohue, I November 1994).

I D:IF1MCCOYIIPDCMSIISEC110N.3 3-6 March 1996 Fort McCoy I Draft Corrective Measures Study Report

3.7.6 Soil Objectives I

The human health risk assessment determined existing soil contaminant levels do not pose an unacceptable health risk, even if the residential scenario is used. In addition, the environmental I assessment determined that soil contamination presents only a limited ecological risk. Additional soil sampling and analysis will be performed at the former fire pit during the AS/SVE treatability study as described in Section 3.9. Pending results of that additional sampling, for the purpose of I addressing NR 720.19, it is proposed that existing soil contaminant levels be considered acceptable for residual soil contaminant levels. As discussed in Section 3.9.3, following evaluation of the I AS/SVE treatability study results, a limited amount of contaminated soil remaining at the former fire pit may be removed as a precautionary measure to minimize the potential for the material to act as a source of groundwater contamination. Cleanup goals will be established at that time. I 3.7.7 Groundwater Objectives I Site-specific groundwater objectives identified for FTBP1 were developed by reviewing and evaluating the Federal MCLs, Wisconsin MCLs, and Wisconsin groundwater standards (PALs and ESs). I

The following paragraph is based on excerpts from 57FR31780 and 31797 (pages 31780 and 31797 ofthe July 17, 1992, Federal Register): The Safe Drinking Water Act (SDWA) requires USEPA to I publish maximum contaminant level goals (MCLGs) for contaminants which may have any adverse effect on the health of persons and which are known or anticipated to occur in public water systems. MCLGs are to be set at a level at which no known or anticipated adverse effects on the health of I persons occur and which allows an adequate margin of safety. At the same time the USEPA publishes a MCLG, it must also promulgate a National Primary Drinking Water Regulation which I includes either 1) a MCL, or 2) a required treatment technique. An MCL must be set as close to the MCLG as feasible. Under the SDWA, "feasible" means "feasible with the use of the best technology, treatment techniques, and other means which the Administrator finds, after examination I for efficacy under field conditions and not solely under laboratory conditions (taking cost into consideration)." Other technology factors that are considered in determining the MCL include the ability of laboratories to measure accurately and consistently the level of the contaminant with I available analytical methods.

As presented in 3.7.2 and 3.7.3 above, ESs are generally equal to federal and Wisconsin MCLs. I Since the ESs are generally the same as corresponding MCLs, they inherently represent the lowest possible contaminant concentrations "technically and economically feasible" as required by NR 140.24(2). However, since WDNR interprets State of Wisconsin law to require that PALs be I the goal of groundwater remediation, PALs are proposed as the groundwater objectives which means corrective measures will be developed to attempt to reduce groundwater contaminant concentrations to levels less than the PAL. The selected groundwater objectives for the COCs are presented below. I I I

D:IF1MCCOYJIPDCMSJISEC110N.J 3-7 March 1996 I I Fort McCoy Draft Co"ective Measures Study Report

I PAL Chemical of Potential Concern ~

I TetrachJoroethene 0.5 TrichJoroethene 0.5 1,2-DichJoroethylene( trans) 20 I Cadmium 0.5 I Lead 1.5 The COCs to be addressed in the following technologies and alternatives sections will be those COCs detected in groundwater at FTBPl at levels equal to or exceeding the PAL in downgradient I monitoring wells as shown in Table 3-1. I 3.8 CORRECTIVE MEASURES TECHNOLOGIES 3.8.1 Introduction

I In this section, potentially applicable corrective action technologies are identified for contaminant source material and groundwater based on an evaluation of contaminants detected. Medium-specific corrective action objectives developed in Section 3.7 were evaluated and appropriate general I response actions were identified that satisfy the corrective action objectives. Potentially applicable technologies were then identified for each general response action as listed in Table 3-2 and I discussed in Sections 3.8.2 and 3.8.3. Relevant site-specific conditions were considered in the identification of corrective action I technologies to be retained for consideration in developing corrective action alternatives. Corrective action objectives were reviewed and applicable technologies were selected based on past experience and verified performance information. The identified technologies that have proven effectiveness I for the media and COCs and can be practically implemented, operated, and maintained given site­ specific conditions, are identified as being retained for consideration in developing corrective action alternatives. Table 3-2 identifies which technologies have been retained for consideration in I developing the corrective action alternatives presented in Section 3.9. I 3.8.2 Identification of Applicable Source Material Technologies 3.8.2.1 Source Material Institutional Actions

I Fencing

A chain link fence (6 feet tall) with lockable gates could be constructed around the source area to I restrict site access and disturbance of source material. Fencing would reduce the potential for ingestion of or direct contact with source material. The construction and maintenance costs for I fencing are considered low in comparison to the other technologies evaluated. Fencing will be retained for consideration in developing corrective action alternatives. It should be noted that the I

D:IFTMCCOY IIPDCMSJ\SEC170N.J 3-8 March 1996

I,l I Fort McCoy Draft Corrective Measures Study Report

I TABLE3-2

FIRE TRAINING BURN PIT 1 I CORRECTIVE ACTION OBJECTIVES, GENERAL RESPONSE ACTIONS AND CORRECTIVE MEASURES TECHNOLOGIES I FORT MCCOY, WISCONSIN General Response Corrective Measures Technologies Technologies Retained Corrective Action Objectives Actions Considered for Further Evaluation

I Prevent access to source Institutional . Fencing Yes material . Land Use Restrictions Yes I Reduce potential for Containment . Low Permeability Cap Yes contaminant migration from . Soil Cover Yes source material to groundwater I Removal . Excavation Yes< 1> Treatment • Soil Vapor Extraction Yes< 1> . (on-site or off- site) Yes(l> I . Yes(l> Disposal . Off-site Landfill Yes . Air Sparging!Soil Vapor Extraction Yes< 1> • Chemical Precipitation Yes(l> I • Natural Attenuation Yes Discharge . POTW Yes I • Surface Water Yes NOTE: I (I) These technologies have additional information and illustrations provided in Appendix C in addition to the descriptions presented in Sections 3.8.2 and 3.8.3. I I I

I D:IF1MCCOY/IPOCMSI\TAB3-2. March 1996 I Fort McCoy Draft Co"ective Measures Study Report

I FTBPl source area is already located within the fenced and secured military vehicle parking lot at theECS.

I Land Use Restrictions

Land use restrictions would be implemented to minimize the potential for human contact with source I material. Restrictive covenants could be placed on deeds to the FTBPl property to limit the potential for land development, source material disturbance, and cover (if implemented) intrusions. Restrictive covenants, written into a site property deed, notify any potential purchaser of the property l that contaminated media remain on-site, and that the land use must be restricted. If enforced, deed restrictions would reduce the potential for the ingestion or direct contact with contaminated source material. It is anticipated that deed restrictions at FTBPls would limit excavation. The effectiveness I of deed restrictions depends on continued enforcement. Deed restrictions are subject to changes in political jurisdiction, legal interpretation, and level of enforcement. Administration of land use I restrictions would be the only cost, but would remain perpetually. Land use restrictions will be retained for consideration in developing corrective action alternatives.

I 3.8.2.2 Source Material Containment Actions I Low-Permeability Cap Containment of source material would be implemented to physically minimize the potential for migration of contaminants from, and human access to, source material. Generally, a soil or multi­ I media cap, described below, is placed over source material to achieve this purpose. Capping technologies may be designed to reduce surface water infiltration and possible production of leachates in cases where groundwater is not in direct contact with source material. Capping · I technologies also prpvide a stable outside surface that protects against direct contact with source I material and further isolates and prevents disturbance of the source material. Materials in multi-media capping include natural soil, geotextiles, and geomembranes. Relative capital costs for a multi-media cap are moderate; relative O&M costs are low to moderate. Materials I in a soil cover include only natural soil. Relative capital costs for a soil cover are low; relative O&M costs are low to moderate. Low permeability caps will be retained for consideration in developing I corrective action alternatives . .Soil Cover

I A soil cover would reduce infiltration by promoting surface water runoff. A soil cover would involve adding rooting zone soil, topsoil, and revegetating, as needed. A soil cover is a low-cost technology relative to other source control technologies. Soil cover will be retained for I consideration in developing corrective action alternatives. I

D:IF1MCCOYJIPDCMSIISEC170N.3 3-9 March 1996 Fort McCoy I Draft Co"ective Measures Study Report 3.8.3 Identification of Applicable Groundwater Technologies I 3.8.3.1 Groundwater Institutional Actions I Groundwater Use Restrictions.

Grmmdwater use restrictions would be imposed to prevent the use or installation of new private I wells and public drinking water supply wells within the FTBPl source area (including downgradient contamination). Either voluntary or legal restrictions (or both) on groundwater may apply. Voluntary groundwater use restrictions are restrictive covenants written into a site property deed to I notify any purchaser of the location and source of groundwater contamination and that groundwater use must be restricted. Legal groundwater use restrictions would involve notifying the WDNR Bureau of Water Supply of the groundwater impacts. The Bureau keeps maps and lists of sites with groundwater impacts; however, it is the responsibility of the well driller to be apprised of specially designated areas.

NR 812.08 also prohibits the installation of new water supply wells within 250 feet of a lagoon (FTBPl would be considered an impoundment/lagoon). FTBPl is located outside the zone of contribution of the existing water supply wells. Both voluntary and legal groundwater use restrictions depend on enforcement for their effectiveness. Relative costs for groundwater use restrictions are low. Groundwater use restrictions will be retained for consideration in developing I corrective action alternatives.

GroundwaterAionuoring I

Groundwater monitoring using monitoring wells would be continued at FTBPl to track groundwater quality and the effectiveness of other remediation technologies. Groundwater monitoring is a I commonly used method to determine groundwater quality. Monitoring consists of collecting groundwater samples from monitoring wells and analyzing those samples to defme contaminant I migration or establish increasing or decreasing concentration trends over time. Laboratory analysis detection limits will be set low enough to determine if the PALs have been exceeded. If the PAL is below the lowest detection limit, the lowest detection limit commercially available will be utilized I for evaluating groundwater standard exceedances. Relative capital costs are low; O&M costs are moderate. Groundwater monitoring will be retained for consideration in developing corrective action alternatives. I 3.8.3.2 Groundwater Containment Actions I Low-Permeability Barriers

Low-permeability barriers can be an effective component of a groundwater containment system. The I barriers can consist of a soil, bentonite and water mixture, cement and water mixture, or sheet piling and would probably be located downgradient of the former fire pit. They are most effective if keyed several feet into a low permeability layer such as relatively impermeable bedrock or clay. However, I a low-permeability barrier alone will only divert groundwater flow, it will not contain it. To contain I D:\FTMCCOYJI.PIXMSJ1SEC710N.J 3-12 March 1996 I I Fort McCoy Draft Co"ective Measures Study Report

I groundwater, the groundwater that flows up to and then around or under the barrier must be collected by extraction wells or collection trenches and subsequently treated and discharged. Relative costs for low-permeability barriers would be high given the need for specialized equipment, materials and I procedures to construct a barrier. Given the lack of a low-permeability layer at FTBPl to key into, low-permeability barriers will not be retained for consideration in developing corrective action I alternatives. Hydraulic Barriers

I Hydraulic barriers would be used to minimize migration of contaminated groundwater. A hydraulic barrier would consist of a series of extraction wells or collection trenches. Extracted groundwater I would require treatment or pretreatment prior to discharge. Relative capital costs are moderate, O&M costs (pumping system and well maintenance) are moderate. Hydraulic barriers will be I retained for consideration in developing corrective action alternatives. 3.8.3.3 Groundwater Removal Actions

I Extraction Wells

Extraction wells would be used to collect impacted groundwater. Generally, extraction wells would I be drilled and screened in a highly permeable water-bearing zone. The wells are fitted with a pump to extract groundwater and create a negative pressure zone to promote flow towards the well. Relative capital costs for extraction wells are low to moderate; O&M costs are moderate. Extraction I wells will be retained for consideration in developing corrective action alternatives. I Collection Trenches

Collection trenches may be used in place of extraction wel~s for collecting impacted groundwater I and may be very effective, depending on the hydrogeology of the site. Collection trenches are also used frequently in lowering the local water table and controlling the direction of groundwater flow at a site. Extracted groundwater would require treatment prior to discharge. Relative capital costs I for collection trenches are generally low to moderate; O&M costs are moderate.

Collection trenches will not be retained for developing corrective action alternatives here due to I constructability difficulties in the saturated sandy soils and questionable effectiveness in the high permeability sandy soils. The saturated sandy soils would make construction of a collection trench difficult and costly due to stability/sloughing potential. Even if a trench would be constructed at I FTBP 1, it would have reduced effectiveness since collection trenches operate on the basis of permeability differential. Groundwater generally prefers flow from areas of low permeability (silts, clay) to areas of high permeability (sands, gravels). Since the area at FTBPl already naturally I contains a high permeability material (sands), the effectiveness of a collection trench at FTBPl would be reduced since there would be minimal difference in the permeability of the native material (sands) and the collection trench material (sands). This would result in only partial capture of the I groundwater moving past FTBPl. I I D:\FlMCCOYIIPDCMSJISECTTON.3 3-13 March 1996 Fort McCoy I Draft Co"ective Measures Study Report 3.8.3.4 Groundwater Treatment Actions I Biological Treatment I On-site biological treatment of extracted groundwater may use either an attached or suspended­ growth biological treatment process. In suspended growth systems such as activated sludge processes (ASP}, contaminated groundwater is circulated in a mixing basin where a microbial I population aerobically or anaerobically degrades organic matter and produces new cells. The new cells form a sludge, which is settled out in a clarifier, and a portion of the sludge biomass is recycled to the mixing basin. A portion of the sludge is continuously wasted, to be further treated prior to I solids disposal, generally at a landfill. In attached growth systems, such as rotating biological contactors and trickling filters, microorganisms are established on an inert support matrix to aerobically or anaerobically degrade groundwater contaminants. Attached growth processes produce I less sludge than ASPs. Attached and suspended systems often are used together in series. I' Biological treatment is used primarily to treat nonhalogenated VOCs, SVOCs, and petrolemn hydrocarbons. Halogenated VOCs, SVOCs, and pesticides also can be treated, but the process may be less effective and may be applicable only to some compounds within these groups. Relative I. capital costs for biological groundwater treatment are moderate to high; O&M costs are high. Biological treatment will not be retained for developing corrective action alternatives given that it is less effective than air stripping at removing the low levels of halogenated VOCs detected in the I groundwater.

Air Stripping i

Air stripping would involve pmnping of extracted groundwater into an air stripping vessel which· uses air and water mixing to remove or strip VOCs. Types of aeration methods include packed I towers, diffused aeration, tray aeration, and spray aeration. The treatment system could be located in a building at or adjacent to FTBPI. I The target contaminant groups for air stripping systems are halogenated (1 ,2-DCE, PCE, TCE) and nonhalogenated VOCs. Removal efficiencies around 99 percent can be achieved for these types of I contaminants. The technology can be used, but may be less effective for halogenated and nonhalogenated SVOCs and fuels. Relative capital costs for air stripping are moderate; O&M costs are low, unless vapor-phase carbon is needed (moderate if needed) to treat the exhaust air stream. I Air stripping will be retained for consideration in developing corrective action alternatives.

Carbon Adsorption I

Carbon adsorption would remove organic compounds that preferentially sorb onto carbon versus water. On-site carbon adsorption of extracted groundwater would involve piping extracted I groundwater/leachate through a series of canisters containing activated carbon to which dissolved organic contaminants adsorb with subsequent discharge of the treated water. The technology requires periodic replacement or regeneration of saturated carbon which increases the cost of this I technology. I D:IF7MCCOYJIPDCMSJISEC110N.J 3-14 March 1996 I I Fort McCoy Draft Corrective Measures Study Report

I The target contaminant groups for carbon adsorption are halogenated and nonhalogenated SVOCs. The technology can be used, but may be less effective in treating halogenated VOCs (1,2-DCE, PCE, TCE), fuel hydrocarbons, pesticides, and inorganics. Relative capital costs are moderate to high; I O&M costs are moderate to high. Carbon adsorption will not be retained for developing corrective action alternatives given that it is less effective than air stripping at removing the low levels of I halogenated VOCs detected in the groundwater. I Air Sparging/Soil Vapor Extraction Air would be injected under pressure below the water table to strip VOCs from groundwater/leachate. Air sparging (AS) would be conducted in conjunction with a soil vapor I extraction (SVE) system to remove stripped VOCs from the unsaturated zone. The ease and low cost of installing small-diameter air injection points allows considerable flexibility in the design and construction of a remediation system. Relative capital costs for air sparging are low to moderate; I O&M costs are low unless vapor-phase carbon is needed (moderate if needed) to treat the exhaust air stream. An air sparging treatability study is being conducted at FTBP 1. AS/SVE will be retained I for consideration in developing correction action alternatives. Chemical Precipitation

I On-site chemical precipitation of extracted groundwater/leachate would be used for removing inorganic contaminants as pretreatment for other processes or to address discharge limits for I inorganics. Precipitation is a process by which the chemical equilibrium of a waste stream is altered to reduce the solubility of metals. The metals precipitate out as a solid phase (sludge) and are taken out of the solution by solids removal processes. Metals precipitation is not one unit operation but I a combination of coagulation, flocculation, sedimentation, and, in some cases, filtration processes. · Relative capital costs are moderate; O&M costs are moderate to high due to sludge processing and off-site disposal. The treatment system could be located in a building at or adjacent to FTBPl. I Chemical precipitation will be retained for consideration in developing corrective action alternatives. I Natural Attenuation Natural attenuation would consist of volatilization, biodegradation, recharge and dispersion, t· adsorption, and chemical reactions with subsurface materials to reduce groundwater contaminant concentrations to acceptable levels. Non-destructive attenuation mechanisms include recharge and dispersion, and adsorption. The rest of the attenuation mechanisms are destructive to the contaminants. All of these processes are naturally occurring. Natural attenuation is effective I generally when contaminant concentrations are low, the contaminants have been in place for extended periods, and contaminant concentrations are steady or decreasing over time. Costs for I natural attenuation are low since it is naturally occurring and the only costs associated with it are related to monitoring activities. Once monitoring activities cease, natural attenuation becomes a no­ cost option. Natural attenuation will be retained for consideration in developing corrective action I alternatives. I

I D:IF1MCCOYIIPDCMSIISECnON.3 3-15 March 1996 Fort McCoy I Draft Co"ective Measures Study Report

3.8.3.5 Groundwater Discharge Actions I Publicly/Privately-Owned Treatment Work (POTW) I If groundwater extraction is required, POTW discharge could be implemented for groundwater in conjunction with extraction and, possibly, treatment. Extracted or treated groundwater may be discharged to a POTW including the on-site WWTF via existing or new sewers or force mains. I Pretreatment may be required before discharge to the POTW. Discharge to a POTW will be retained for consideration in developing corrective action alternatives. I Surface Water I If groundwater extraction is required, discharge to surface water would be implemented for groundwater in conjunction with extraction and treatment. Discharge to surface water involves the piping of treated groundwater to an outfall at a surface water body subject to a WPDES permit. The relative capital cost is distance-dependent, and thus would be low to moderate at FTBP 1, while O&M costs are relatively low. Discharge to surface water will be retained for consideration in developing corrective action alternatives. I' 3.9 CORRECI'IVE MEASURES ALTERNATIVES I 3.9.1 Introduction

lh this section, the applicable corrective action technologies identified in Section 3.8 for FTBPl I source material and groundwater are further evaluated and assembled into corrective action alternatives. I Assembling suitable corrective action alternatives was an iterative process that systematically combined the retained technologies into alternatives that meet the corrective action objectives (see I. Sections 3.7.6 and 3.7.7) and are the most practicable for site-specific conditions. The first step of the process consisted of evaluating all pertinent combinations of retained technologies. The preliminary assemblage of alternatives was further evaluated to develop alternatives.that were most I suitable for FTBPl considering the interaction of the selected technologies and site-specific . conditions. Based on this evaluation, the most suitable corrective action alternatives were recommended to be carried forward in the CMS. I 3.9.2 Site-Specific Factors Affecting Development of Alternatives ·I The following factors related to FTBPl were considered the most critical in developing corrective action alternatives: I • The RFI identified no unacceptable human health risks associated with soiVsource material at FTBPl even if the residential scenario is used. I I D:IF1MCCOYIIPOCMSJo.sECTION.3 3-16 March 1996 I. I Fort McCoy Draft Corrective Measures Study Report

I • Current and probable future use of the site is a fenced and secured storage area for military vehicles and equipment.

I • There are no current nor anticipated groundwater receptors downgradient of the site.

• NR 812.08 prohibits the installation of new water supply wells within 250 feet of a lagoon I (FTBP1 would be considered an impoundment/lagoon). FTBP1 is located outside of the zone of contribution of the existing water supply wells.

I • A treatability study is being conducted at FTBP1 to assess the effectiveness of AS/SVE in­ removing VOCs from the soil and groundwater. The treatability study results to date have I shown the potential for AS/SVE to remediate a significant portion of the VOCs in the soil and groundwater at the site.

I • Since the site is relatively flat, there is little potential for soil erosion. Also, due to the permeable sandy soil, rainfall tends to infiltrate rather than drain off the site.

I • The groundwater table is approximately 12 feet below ground surface.

• As discussed in Section 3.5, TCE, PCE, 1,2-DCE and petroleum hydrocarbons were detected I during the RFI at depth in soil only within a limited area in the immediate vicinity of the former burn pit. The highest concentrations of groundwater contaminants are located west of the ,I former burn pit in the direction of groundwater flow. Other compounds in soil were detected sporadically or were attributed to laboratory contamination.

• As discussed in Section 3.5, the only contaminants, with the exception of cadmium and lead,· I detected in groundwater at levels exceeding the PALs are 1,2-DCE, TCE, and PCE. The highest concentrations ofVOCs in groundwater were in the approximate location ofthe AS/SVE system I operated as part of the treatability study. Based on these factors, it is recommended that the three corrective action alternatives identified and I discussed below be carried forward for evaluation in Section 3.9.3. I 3.9.3 Description and Evaluation of Corrective Action Alternatives 3.9.3.1 Introduction

I The following sections describe the three corrective action alternatives proposed for consideration and present an evaluation of the alternatives based on technical, environmental, human health, and institutional criteria as required by Fort McCoy's RCRA Part B Permit. Table 3-3 identifies the I technologies in each of the three alternatives. I 1\

I D:IF1MCCOYJIPDCMSJISEC770N.3 3-17 March 1996 I Fort McCoy I Draft Co"ective Measures Study Report TABLE3-3

I CORRECTIVE MEASURES ALTERNATIVES TECHNOLOGIES FIRE TRAINING BURN PIT 1 I FORT MCCOY, WISCONSIN Alternative #1 Alternative #2 Alternative #3 :.··. ·.·.·. >...... ·... ·. << • < ..\ I •····so~~~~··>·•· ! ..•.••.••.•..•. ·. > < >•······· ~···········...... ····· >.···•·· > ..... Access, Land Use Restrictions· X ·······•> ...... ·······························<···············································X X I Soil Vapor Extraction (AS/SVE X X System) ...... •••• •Gt~~~d~ater .... ) ... ·.·. .·.··· ••• > / .. •••••••••••••••••••••••••••••••• •••••• ········ ······· .. • •••••• •••••••••••• I .•··· ·.. ···········•·····•···•·•· Use Restrictions X X X I Natural Attenuation X X X Monitoring X X X

Air Sparging (AS/SVE System) X X

I ~ andT- X X I I I I I I I I I

I D:'FTMCCOY /IPDCMS/\TABJ-3. March 1996 I Fort McCoy Draft Co"ective Measures Study Report I 3.9.3.2 Corrective Action Alternative 1 I Alternative 1 ASISVE System, Access, Land and Groundwater Use Restrictions, I Natural Attenuation, Groundwater Monitoring

I Alternative 1 consists of AS/SVE for site groundwater; access, land, and groundwater use restrictions; natural attenuation of residual low-level groundwater contamination; and groundwater monitoring. Alternative 1 would have a phased approach. The AS/SVE treatability study (TS) I system would be operated, and then expanded as necessary. The AS/SVE system would be operated for a period of time to be established based on the results of the ongoing AS/SVE TS. These ·t components are described below:

• The AS/SVE TS system includes a series of AS wells that inject air under pressure below the I water table to transfer dissolved VOCs from groundwater to a vapor phase within the unsaturated soil above the water table. A vacuum is applied to a series of SVE wells to induce flow of vapor phase VOCs from the unsaturated zone to the SVE wells. The AS/SVE TS I system consists of8 AS wells and 11 SVE wells installed west ofFTBP1 and one SVE well in the FTBP1 as illustrated on Figure 3-4. The location of the system was based on the highest levels ofPCE detected in groundwater. The AS wells are 2-inch diameter PVC with the top of I a 2-foot screen set approximately 5 feet below the water table. The SVE wells are 4-inch diameter PVC with the bottom of a 5-foot screen set just above the water table. A compressor and blower supply air and vacuum to the AS and SVE wells through underground header pipe I network. The compressor, blower, and ancillary manifold piping, condensate tank and controls are housed in a trailer secured to a concrete slab. The mounting of this equipment in a trailer will allow the major components of the AS/SVE system to be re-used elsewhere following I completion of the treatability study. The AS and SVE wells are flush-mounted in manholes. Typical AS and SVE wells are illustrated in Figures 3-5 and 3-6. Residuals generated by the AS/SVE system include vapor and vapor condensate. Vapor may be treated by carbon I adsorption or thermal oxidation, if necessary' prior to discharge to the atmosphere on-site and condensate would be disposed at an approved licensed facility as described in the .AS/SVE I Work Plan (Rust E&l, April1995). A 4-foot high chain-link fence (approximately 200 feet by 200 feet) with one vehicle/pedestrian gate was installed around AS/SVE TS system (trailer and I wells). • Once the AS/SVE treatability study is complete, it may be necessary to remove a limited amount of contaminated soil (approximately 280 cubic yards per calculations in Appendix A) I from the location of the former fire pit for ex-situ treatment or disposal. This determination will be made following completion of the treatability study.

I • Restrictive covenants would be placed on deeds to the FTBP1 property to restrict land and I groundwater use at FTBPl. I D:IFTMCCOYJIPDCMSJISECTION.3 3-18 March 1996 I ~·~------I

I SVE WELL PROJECTED + RADIUS OF INFLUENCE I .,

H' I -w ~ 0 I 0

·. I / I ...... I / / ...... / I / ...... __ _,.-'" -­ ---- _.,. .... I 743400 N + I I LEGEND: ~ 1995 SOIL BORING -$- PROPOSED SOIL BORING I .. ;!¥{;;;. EXISTING SOIL BORING EXISTING GROUNDWATER -{~~~-- MONITORING WELL I WEST SVE WELL •0 EAST SVE WELL A WEST AS WELL 6 EAST AS WELL I D TEMPORARY VACUUM PROBE I 0' 10' 20' 40' I SCALE ~!"""l~-ril_~~--~1 MAR. 1996 18903 FIGURE 3-4 1111 ...ENVIRONMENT & FIRE TRAINING BURN PIT I I ~~~~ INFRASTRUCfURE AS/SVE WELL LOCATIONS DRAFT CORRECTIVE MEASURES STUDY I FORT McCOY, WISCONSIN I r----FLUSH Ma..NT MAN-IOLE I COI\CRETE CROlNJ SLRFACC. SEAL DETAIL A

(II "0 I Ql ..., I ..., "'a

1'\) ?' 4I 0 U I u; 1.0 PVC PIPE, SCH.40, en .... I\OMINAL 2' DIA. !=? U1 I ~ U1 0 12' 0" I

20'0" ~+------THREADED SCH. 40 PVC RISER PIPE I DI AMETER 2 11\0-1

I :bi------AI\I'LLAR SEAL - ____ y ___ _ TYPE BENTONITE 011PSIPELLETS 23' 0" CRa.NJNATER I LEVEL

I 8'0" I

}41------FILTER PACK I 1' 0" TYPE 40 - 60 SAf'{) --'--,L_~t!--+--+~.:-J----- WlL SCREEN TYPE PVC DIAMETER 2 11\0-1 0" 2' LEI\GTH 2 FEET I •10 SLOT SLOT SIZE

I 1'0" 1------BOREHOLE DIAMETER 6 - 8 II\0-IES I @ GALVANIZED STEEL, SCH. 40, I SOURCE: TWIN CITY ENGINEERING NOMINAL 2" DIA. NOT TO SCALE MAR. 1996 FIGURE 3-5 18903 ftl ...ENVIRONMENT & FIRE TRAINING BURN PIT I I. I~U~I INFRASTRUCTURE TYPICAL AIR SPARGING WELL DRAFT CORRECTIVE MEASURES STUDY I FORT McCOY, WISCONSIN I !"'! I ~-- FLUSH MCLNT MAN-fi_E

I DETAIL A 1" "'0 [ < SMA__ I N:J PeRT -I'D .....::I w/ 1/ 4' Vfl.LVE I c. IC ...-.:1----~~AcE ::I SEfl.L ., 1' 6" I'D 0' 4' D" I N 9" c:c tC I Cl :·:... ~·:\·}::·~ ·~:.-::r~}·· ··_:M~~- !'=? Vfl.LVE -(,J1 HI 4' PVC Slide Gate (,J1w I PVC PIPE, SD-1. 40, NOMINAL 4' DIA. I 2'6"

I /hit----- AN'U..AR SEfl.L Type Bentonite Chi ps!Pe I I ets I 11' D" ~+------Tf-RtADED SD-1. 40 PVC RISER PIPE D i aneter 4 inch I I'D"

,._.______FILTER PACK I Type 16 - 30 Sand I ~1--+------VELL SCREEN Type PVC S'D" Dianeter 4 inch Length 5 feet I Slot Size •20 slot

~-----~~E I D i aneter 8 - 10 inches

I 1'D"

SOURCE: TWIN CITY ENGINEERING NOT TO SCfl.LE

I 18903 MAR. 1996 FIGURE 3-6 .....ENVIRONMENT & FIRE TRAINING BURN PIT I I TYPICAL SOIL VENT CONSTRUCTION I~U~I INFRASTRUCTURE DRAFT CORRECTIVE MEASURES STUDY I FORT McCOY, WISCONSIN I Fort McCoy Draft Corrective Measures Study Report

I • Residual contaminant concentrations of COCs in groundwater would be reduced over time by natural attenuation through volatilization, biodegradation, adsorption and other physical and I chemical reactions within the subsurface environment. • Groundwater monitoring would consist of semi-annual sampling and analysis of 10 of the 22 existing groundwater monitoring wells (1 upgradient, 9 downgradient) at FTBPl. These I groundwater monitoring wells are illustrated on Figure 3-2. Observation wells (OWs) are screened across the water table. Piezometers (Ps) are screened below the water table. The sampling of these observation wells and piezometers should adequately monitor groundwater I quality at FTBPl. However, during the performance of the AS/SVE treatability study, four additional wells (OW-136B, OW-133B, OW-308, and OW-138) and seven additional I piezometers (P-116A, P-129C, P-133A, P-134A, P-135A, P-136A, and P-308A) will be sampled to monitor groundwater quality to help evaluate the effectiveness of AS/SVE.

I Screened Interval Monitorini Well (feet below IW>und surface)

I OW-132 (upgradient) 8-18 OW-129B 10-20 P-129A 34-39 I OW-116B 9-19 OW-134 8-18 OW-135 8-18 I OW-143 8-18 OW-137 8-18 OW-141 9-19 I OW-142 9-19 I Compounds which equaled or exceeded their PALs (VOCs, metals) during previous monitoring events in downgradient monitoring wells would be analyzed for during groundwater monitoring.

I Effectiveness

AS/SVE has been demonstrated to be effective for the removal of VOCs in granular soil and I groundwater. The opemtion ofthe AS/SVE system and removal ofVOCs would effectively mitigate the migration of contaminants from source material to groundwater. Vapor phase treatment by carbon adsorption and/or thermal oxidation (if needed) are proven effective for treatment of organic I vapors.

FTBPl is located within a fenced military vehicle parking area (the ECS) and is expected to remain I the property of the U.S. Army and continue to have associated effective access restrictions. The AS/SVE system perimeter fence and warning signs would provide a further effective access I restriction. I I D:IF1ACCOYIIPIXMSIISEC170N.3 3-19 March 1996 Fort McCoy I Draft Co"ective Measures Study Report

Land and groundwater use restrictions would be effective as FTBP 1 is expected to remain the I property of the U.S. Army. If FTBP1 does not remain the property of the U.S. Army, the effectiveness of deed restrictions would depend on continued enforcement and could be subject to changes in political jurisdiction and legal interpretation. NR 812.08 would supplement groundwater I use restrictions by prohibiting the installation of new water supply wells within 250 feet of FTBP 1.

Assuming the majority of the groundwater contamination would be removed by the AS/SVE system, I as indicated by preliminary AS/SVE TS results, residual groundwater contaminant concentrations would decrease over time to acceptable levels through natural attenuation. I The effectiveness of the AS/SVE system and natural attenuation would be monitored through groundwater monitoring. Semi-annual groundwater sampling and analysis is a proven, effective I means of monitoring groundwater quality. lmplementabUity and Reliability I The AS/SVE system components have been implemented successfully and demonstrated reliability during the ongoing AS/SVE TS and on similar sites. AS/SVE operating and maintenance labor, I equipment and system consumables would be readily available. It is anticipated, based on preliminary results from the AS/SVE TS, that an expansion to the AS/SVE TS system could be constructed in and operated for an approximate one year period to reduce groundwater contaminant I levels to those amendable to natural attenuation. Based on preliminary results from the AS/SVE TS, it is anticipated that an air permit for AS/SVE system emissions would not be required. I Based on the site conditions summarized in Section 3.9.2, access, land and groundwater use restrictions, and natural attenuation in conjunction with groundwater monitoring would be reliable and readily implementable at FTBP 1. I Operation and Maintenance I The operation of the AS/SVE system would require routine monitoring and modifications to operating conditions (based on monitoring), power for blower and compressor, carbon or I supplemental fuel for vapor phase treatment (if needed), disposal/treatment of vapor condensate, vapor sampling and analysis, and engineering review of operational and analytical data. The only other Alternative 1 operational requirement would be semi-annual groundwater monitoring for the I length of time needed to achieve acceptable levels of COCs in groundwater. For cost estimating purposes, this is assumed to be 30 years. I Maintenance of the AS/SVE system would include equipment and controls cleaning, repair and replacement, and potentially minor fence and trailer repair. AS/SVE wells and groundwater monitoring wells may require periodic well screen cleaning and other minor maintenance. It is I anticipated that the useful life of the wells would be at least 15 years. I I D:'F'TMCCOYIIPDCMSJISEC110N.3 3-20 March 1996 I I Fort McCoy Draft Corrective Measures Study Report I Safety

Safety of nearby residents, environments and site workers with regard to physical hazards during I implementation would be addressed by provisions in the construction contractor's SSHP. Potential site safety hazards during construction could include, but not be limited to, heavy equipment operation, chemical exposure, slip/trip/fall hazards, heat/cold stress, wildlife (ticks, snakes, etc.), and I vegetation (poison ivy, etc.). Temporary environmental controls (dust suppression, etc.) and ambient air monitoring would be implemented as needed during installation of the AS/SVE expansion.

I Environmental Evaluation I Implementation of Alternative 1 components would not adversely impact environmentally sensitive areas. An ecological field assessment, included as an appendix to the RFI (SEC Donohue, November 1994), ofFTBP1 concluded that the primary exposure pathway of concern is ingestion I of contaminated subsurface soil by burrowing animals. This soil contamination presents a limited ecological risk. Current and projected future land use as a military vehicle storage area would limit I the potential for proliferation of ecological communities at FTBPl. Human Health Evaluation

I Land use as a fenced military vehicle parking area and access, land use and groundwater use restrictions would prevent residential development at FTBP 1. Therefore, the most likely human health risk exposure scenario for FTBP 1 would be that of ingestion of and direct contact with surface I soil by a worker at the ECS vehicle parking lot. The human health assessment (SEC Donohue, November 1994) concluded that FTBP1 trespassers would not be exposed to excess health risks under current site conditions. The human health assessment also indicated that residents would not I be exposed to excess health risks due to exposure to soil under a residential scenario.

I There are no current nor anticipated groundwater receptors downgradient of FTBP 1. The AS/SVE system would mitigate contaminant migration from the source material to groundwater. Human health concerns to site workers during the operation of the AS/SVE system would be addressed by I provisions in a SSHP. I Institutional Evaluation Institutional needs for Alternative 1 would include enforcing existing site access restrictions, maintaining site fences to further restrict site access, enforcing land and groundwater use restrictions I and performing routine groundwater monitoring.

The design and implementation schedule of the three alternatives may be effected by Federal, state, I and local environmental and public health standards, regulations, guidance, advisories, ordinances, or community relations. The following institutional requirements may impact design and I implementation. I • It is anticipated that implementation of Alternative 1 will not require a local construction permit. I D:IF1MCCOYIIPDCMSIISEC110N.J. 3-21 March 1996 Fort McCoy I Draft Co"ective Measures Study Report

• It is anticipated that operation of the AS/SVE system will not require a Wisconsin Air Permit. I The AS/SVE system will be operated to meet NR 419 and NR 445 emissions criteria.

• AS/SVE system residuals (condensate) must be disposed in accordance with applicable I regulations.

The other components of Alternative 1 should not be significantly effected by Federal, state, and I local environmental and public health standards, regulations, guidance, advisories, ordinances, or community relations. · I Cost Evaluation I The cost for Alternative 1 includes capital costs to construct the AS/SVE system and associated trailer, foundation and perimeter fence, and annual operation and maintenance costs associated with AS/SVE system and routine groundwater monitoring. It is assumed that costs for recording deed I restrictions would be negligible. Table 3-4 presents the estimated conceptual capital costs for an assumed expansion of the AS/SVE system by approximately 50 percent. The actual amount of AS/SVE system expansion necessary will be determined following evaluation of the AS/SVE TS I results. The estimated conceptual present worth O&M cost for Alternative 1 is $1,290,000 as presented in Table 3-5. Cost estimate back-up information is presented in Appendix A to this CMSR I 3.9.3.3 Corrective Action Alternative l I Alternative 2

ASISVE System, I Groundwater Extraction and Treatment, Natural Attenuation, I Access, Land and Groundwater Use Restrictions, Groundwater Monitoring I Alternative 2 consists of AS/SVE and extraction and treatment for site groundwater; access, land, and groundwater use restrictions, natural attenuation of residual low-level groundwater contamination, and groundwater monitoring. Alternative 2 would have a phased approach similar I to Alternative 1. The AS/SVE TS system would be operated and then expanded as necessary. The AS/SVE TS system would be operated for a period of time to be established based on the results of . the ongoing AS/SVE treatability study. A groundwater extraction and treatment system would also I be installed downgradient of the AS/SVE system to extract and treat groundwater with contamination still exceeding PALs. These components are described below: I • The AS/SVE TS system includes a series of AS wells that inject air under pressure below the water table to transfer dissolved VOCs from groundwater to a vapor phase within the I unsaturated soil above the water table. A vacuum is applied to a series of SVE wells to induce flow of vapor phase VOCs from the unsaturated zone to the SVE wells. The AS/SVE TS I D:IF1MCCOYJIPDCMSJISECTION.3 3-22 March 1996 I I Fort McCoy Draft Corrective Measures Study Report

I TABLE3-4

ALTERNATIVE l CAPITAL COST I FIRE TRAINING BURN PIT l FORT MCCOY, WISCONSIN I Capital Cost Item Quantity Unit Unit Cost Total Cost< 1> Total Cost <2> I Construction: Air Sparging/Soil Vapor Extraction (AS/SVE): I AS/SVE Treatability 1 LS $280,000 $280,000 $280,000 Study System

AS/SVE System 1 LS $177,000 $177,000 $177,000 I Expansion Limited Soil Removal. 390 Ton $200 -- $78,000 I Construction Subtotal $457,000 $535,000 Construction Global Markups: I Scope Contingency (15%) $69,000 $80,000 Subtotal $526,000 $615,000 I Health and Safety (30%) $158,000 $185,000 Subtotal $684,000 . $800,000 I Permitting (5%) $34,000 $40,000 Engineering (20%) $137,000 $160,000 I Construction-Related Services (15%) $103,000 $120,000 Prime Fixed Fee (5%) $34,000 $40,000 I TOTAL CAPITAL COST $992.000 $1.160 000 Note: Costs without limited soil removal and off-site disposal/treatment <2> Costs with limited soil removal and off-site disposal/treatment I Cost assumptions are presented in Appendix A to CMSR. I I I I

I D:IFTMCCOY JIPDCMSJ\TAB3-I. March 1996 I Fort McCoy Draft Corrective Measures Study Report

I TABLE3-5

ALTERNATIVE 1 O&M COST I FIRE TRAINING BURN PIT 1 I FORT MCCOY, WISCONSIN I O&Mitem Quantity Unit Unit Cost Total Cost AS/SVE System Operation and Maintenance (1 yr): I AS/SVE System 1 YR $126,000 $126,000 Scope Contingency (15%) $19,000 I Subtotal $145,000 Administration (10%) $15,000 I AS/SVE System Annual O&M Subtotal $160,000 I Groundwater Monitoring (30 yrs): Groundwater Sampling and 1 (I) YR $58,000 $58,000 Analysis I Scope Contingency (15%) $9,000 I Subtotal $67,000 Administration (i 0%) $7,000 I Groundwater Monitoring Annual O&M Subtotal $74,000 Total Annual O&M Cost $234,000 I Total Present Worth ofO&M $1.290.000 I NOTES: (I) Includes two sampling events per year at 10 wells. O&M assumptions are presented in Appendix A to CMSR. 1 2 I Present Worth Factors:< > i = 5%; 1 yr = 0.952 :< > i = 5%; 30 yrs = 15.373 I I I

I D:IF1MCCOYJIPDCMSI\TABJ.J. March 1996 I Fort McCoy Draft Corrective Measures Study Report I system consists of 8 AS wells and 11 SVE wells installed west of FTBP 1 and one SVE well in the FTBP1 as illustrated on Figure 3-4. The location of the system was based on the highest levels ofPCE detected in groundwater. The AS wells are 2-inch diameter PVC with the top of I a 2-foot screen set approximately 5 feet below the water table. The SVE wells are 4-inch diameter PVC with the bottom of a 5-foot screen set just above the water table. A compressor and blower supply air and vacuum to the AS and SVE wells through underground header pipe I network. The compressor, blower, and ancillary manifold piping, condensate tank and controls are housed in a trailer secured to a concrete slab. The mounting of this equipment in a trailer will allow the major components of the AS/SVE system to be re-used elsewhere following I completion of the treatability study. The AS and SVE wells are flush-mounted in manholes. Typical AS and SVE wells are illustrated in Figures 3-5 and 3-6. Residuals generated by the AS/SVE system include vapor and vapor condensate. Vapor may be treated by carbon I adsorption or thermal oxidation, if necessary, prior to discharge to the atmosphere on-site and condensate would be disposed at an approved licensed facility as described in the AS/SVE I Work Plan (Rust E&l, April1995). A 4-foot high chain-link fence (approximately 200 feet by 200 feet) with one vehicle/pedestrian gate was installed around AS/SVE TS system (trailer and I wells). • Once the AS/SVE treatability study is complete, it may be. necessary to remove a limited amount of contaminated soil (approximately 280 cubic yards per calculations in Appendix A) I from the location of the former fire pit for ex-situ treatment or disposal. This determination will be made following completion of the treatability study.

I • If required, three groundwater extraction wells would be used to collect groundwater downgradient of the AS/SVE system. The collected groundwater (approximately 15 gpm) would then be treated ex-situ using air stripping and chemical precipitation with discharge I either to the on-site WWTF or surface water. The treatment units would be housed in a building at or adjacent to FTBP 1. The conceptual location of the extraction wells and treatment building are shown on Figure 3-7. The actual location of the wells and building would be determined I during design activities. I • Restrictive covenants would be placed on deeds to the FTBP 1 property to restrict land and groundwater use at FTBP1.

I • Residual contaminant concentrations of COCs in groundwater would be reduced over time by natural attenuation through volatilization, biodegradation, adsorption and other physical and I chemical reactions within the subsurface environment. • Groundwater monitoring would consist of semi-annual sampling and analysis of 10 of the 22 existing groundwater monitoring wells (1 upgradient, 9 downgradient) at FTBP1. These I groundwater monitoring wells are illustrated on Figure 3-2. Observation wells (OWs) are screened across the water table. Piezometers (Ps) are screened below the water table. The sampling of these observation wells and piezometers should adequately monitor groundwater I quality at FTBP 1. However, during the performance of the AS/SVE treatability study, four I additional wells (OW-136B, OW-133B, OW-308, and OW-138) and seven additional I D:IF1MCCOYJIPOCMSJISEC110N.J 3-23 March 1996 I w w w w 0 0 0 Q 0 0 g 0 N <.0 (!) (1) "'(1) I a) a) ~~x-xl 01-~i_,a:> I /'0 ) ~I (/ TB~ / ,,)";'/ Lx-xj '> /, l 5 ~~.3 ~ 5 ~~ I ~ <3 II ClfAfff:> 1\ I I ~ ! '\,\ I ) i I ·.C[~!Ol L==BB5.32 - ! . /+-APPRO X I ~AA TEl I IlL ... / I LOCATION l ' J29tl\ I ,.... / i OF FIRE TRAI~m·.JC ·~ _/ n =ass s·--7~~~r 129-A ' -~-). ,..·;;r I BURN pIT I -=-"'-~!LJ•<.Q_L_/~~f-.1_ \..I.J 'V _, I I * ;------r·-~---·-·----~------·--·-:.r-----

I 1 ·-ar5/.i; : 1 LIGHTI 1 ... j '1_~ 1.Wt'ltl~- ~i l POLE /i ._.,- Sl\o, I 't)W ''- I< ~ ~ '\ ~ ... 1...1 DlO IX. E. - - I i ""' I I ~~ I,/ ~ ) ~ 74340P N A,-,-.l '' I "'0 ~~~~~ <.0 OJ c;2 U'l ~q~f a / co /* 0; / /-rf l c;:· 0) £:! r·- ·::t.: 5 LEGEND I ::::1: i)J .,1 (£) 0) ::> I­ OJ ll -831 LU TOPOGRAPHIC CONTOUR I­ co / <[ C> I FENCE

7 '") 8 t b -----·---· GROUNDWATER CONTOUR N I ______.....,.. GROUNDWATER FLOW DIRECTION

GROUNDWATER MONITORING WELL I -$·P-134A NOTES: EL ==BBl. 92 GROUNDWATER MONITORING WELL "0 I. GROUNDWATER TABLE ELEVATIONS AND CONTOURS WITH GROUNDWATER ELEVATION ARE DERIVED FROM THE RFI PHASE 3 INVESTIGATION. I ..OW-143 IN FEET ABOVE MEAN SEA LEVEL c E 0' 30' 60' -;;; ~:::EH03 SOIL BORING SCALE I t5 --- x--x-- CONCEPTUAL LOCATION OF FENCE ..,.0~ MAR. 1996 FIGURE 3-7 18903 / g @ CONCEPTUAL LOCATION OF EXTRACTION WELL .._..ENVIRONMENT & FIRE TRAINING BURN PIT I I 0._ CONCEPTUAL GROUNDWATER EXTRACTION .!Ji AND TREATMENT SYSTEM LAYOUT .;: CONCEPTUAL LOCATION OF TREATMENT BUILDING ~~~~INFRASTRUCTURE II ~ DRAFT CORRECTIVE MEASURES STUDY I g FORT McCOY, WISCONSIN I Fort McCoy Draft Corrective Measures Study Report

I piezometers (P-116A, P-129C, P-133A, P-134A, P-135A, P-136A, and P-308A) will be sampled to monitor groundwater quality to help evaluate the effectiveness of AS/SVE.

I Screened Interval Monitorina Well (feet below around surface)

I OW-132 (upgradient) 8-18 OW-129B 10-20 I P-129A 34-39 OW-116B 9-19 OW-134 8-18 I OW-135 8-18 OW-143 8-18 OW-137 8-18 I OW-141 9-19 OW-142 · 9-19

I Compounds which equaled or exceeded their PALs (VOCs, metals) during previous monitoring events in downgradient monitoring wells would be analyzed for during groundwater monitoring.

I Effectiveness

AS/SVE has been demonstrated to be effective for the removal of VOCs in granular soil and I groundwater. The operation of the AS/SVE system and removal ofVOCs would effectively mitigate the migration of contaminants from source material to groundwater. Vapor phase treatment by I carbon adsorption and/or thermal oxidation(if needed) are proven effective for treatment of organic vapors.

I FTBP1 is located within a fenced military vehicle parking area (the ECS) and is expected to remain the property of the U.S. Army and continue to have associated effective access restrictions. The AS/SVE system perimeter fence and warning signs would provide a further effective access I restriction.

Land and groundwater use restrictions would be effective as FTBP 1 is expected to remain the I property of the U.S. Army. If FTBP1 does not remain the property of the U.S. Army, the effectiveness of deed restrictions would depend on continued enforcement and could be subject to changes in political jurisdiction and legal interpretation. NR 812.08 would supplement groundwater I use restrictions by prohibiting the installation of new water supply wells within 250 feet of FTBP 1. I If required, three groundwater extraction wells would be used to collect the impacted groundwater downgradient of the AS/SVE system. The collected groundwater would be treated using air stripping and chemical precipitation. Given the sporadic nature of low-level PAL exceedances, the I effectiveness of the treatment units may be reduced due to the sporadic nature of low concentration influent. I

I D:IFIMCCOYIIPIXMSIISEC110N.3 3-24 March 1996 Fort McCoy I Draft Co"ective Measures Study Report

Assuming the majority of the groundwater contamination would be removed by the AS/SVE system I and groundwater extraction and treatment, residual groundwater contaminant concentrations would decrease over time to acceptable levels through natural attenuation. I The effectiveness of the AS/SVE system, groundwater extraction and treatment system, and natural attenuation would be monitored through groundwater monitoring. Semi-annual groundwater sampling and analysis is a proven, effective means of monitoring groundwater quality. I lmplementabUity and ReliabUity I The AS/SVE system and groundwater extraction and treatment system components have been implemented successfully and demonstrated reliability on similar sites. AS/SVE and groundwater I extraction and treatment system operating and maintenance labor, equipment and system consumables would be readily available. It is anticipated, based on preliminary results from the AS/SVE TS, that an expansion to the AS/SVE TS system and a new groundwater extraction and I treatment system could be constructed in one construction season.

Based on the site conditions summarized in Section 3.9.2, access, land and groundwater use I restrictions, and natural attenuation in conjunction with groundwater monitoring would also be reliable and readily implementable at FTBP1. I Based on preliminary results from the AS/SVE TS, it is anticipated that an air permit for AS/SVE system emissions would not be required. It is anticipated that an air permit for the air stripper emissions would not be required. I Operation and Maintenance I The operation ofthe AS/SVE system for approximately 1 year would require routine monitoring and modifications to operating conditions (based on monitoring), power for blower and compressor, I carbon or supplemental fuel for vapor phase treatment (if needed), disposal/treatment of vapor condensate, vapor sampling and analysis, and engineering review of operational and analytical data. The other Alternative 2 operational requirements would be operation of the groundwater I extraction/treatment system, and semi-annual groundwater monitoring. For cost estimating . purposes, it is assumed the groundwater extraction/treatment system will be operated for 5 years and groundwater monitoring performed for 30 years. I

Maintenance ofthe AS/SVE and groundwater extraction/treatment systems would include equipment and controls cleaning, repair and replacement, and potentially minor fence and trailer repair. I AS/SVE wells and groundwater monitoring wells may require periodic well screen cleaning and other minor maintenance. It is anticipated that the useful life of the wells would be at least 15 years. I Safety I Safety of nearby residents, environments and site workers with regard to physical hazards during implementation would be addressed by provisions in the construction contractor's SSHP. Potential I D:IF1MCCOYJ1PDCMSJISEC170N.J 3-25 March 1996 I I Fort McCoy Draft Co"ective Measures Study Report I site safety hazards during construction could include, but not be limited to, heavy equipment operation, chemical exposure, slip/trip/fall hazards, heat/cold stress, wildlife (ticks, snakes, etc.), and vegetation (poison ivy, etc.). Temporary environmental controls (dust suppression, etc.) and ambient I air monitoring would be implemented as needed during installation of the groundwater extraction wells, construction of the groundwater treatment plant, and expansion of the AS/SVE system.

I Environmental Evaluation

Implementation of Alternative 2 components would not adversely impact environmentally sensitive I areas. An ecological field assessment, included as an appendix to the RFI (SEC Donohue, November 1994), ofFTBPI concluded that the primary exposure pathway of concern is ingestion of contaminated subsurface soil by burrowing animals. This soil contamination presents a limited I ecological risk. Current and projected future land use as a military vehicle storage area would limit I the potential for proliferation of ecological communities at FTBP I. HuiiUln Health Evaluation

I Land use as a fenced military vehicle parking area and access, land use and groundwater use restrictions would prevent residential development at FTBPI. Therefore, the most likely human health risk exposure scenario for FTBP 1 would be that of ingestion of and direct contact with surface I soil by a worker at the ECS vehicle parking lot. The human health assessment (SEC Donohue, November 1994) concluded that FTBPI trespassers would not be exposed to excess health risks under current site conditions. The human health assessment also indicated that residents would not I be exposed to excess health risks due to exposure to soil under a residential scenario.

There are no current nor anticipated groundwater receptors downgradient of FTBP 1. The AS/SVE I system and groundwater extraction and treatment system would mitigate contaminant migration from the source material to groundwater. Human health concerns to site workers during the operation of the AS/SVE system and groundwater extraction and treatment system would be I addressed by provisions in a SSHP. I Insntuuona/Evaluauon Institutional needs for Alternative 2 would include enforcing existing site access restrictions, I maintaining site fences to further restrict site access, enforcing land and groundwater use restrictions and performing routine groundwater monitoring.

I The design and implementation schedule of the three alternatives may be effected by Federal, state, and local environmental and public health standards, regulations, guidance, advisories, ordinances, or community relations. The following institutional requirements may impact design and I implementation. I • It is anticipated that implementation of Alternative 2 will not require a local construction permit. I I D:IFTM::COYJIPOCMSIISEC110N.3 3-26 March 1996 Fort McCoy I Draft Corrective Measures Study Report

• It is anticipated that operation of the AS/SVE system and air stripper will not require a ·I Wisconsin Air Permit. The AS/SVE system and air stripper will be operated to meet NR 419 and NR 445 emissions criteria. I • If the extracted groundwater is treated and discharged to the surface, it is anticipated that a WPDES permit will be required. I • AS/SVE residuals (condensate) and grom1dwater treatment system residuals (sludge) must be disposed in accordance with applicable regulations. I The other components of Alternative 2 should not be sigitificantly effected by Federal, state, and local environmental and public health standards, regulations, guidance, advisories, ordinances, or I community relations.

Cost Evaluation I

The cost for Alternative 2 includes capital costs to construct the AS/SVE system and associated trailer, foundation and perimeter fence, groundwater extraction and treatment system, and annual I operation and maintenance costs associated with the AS/SVE and groundwater extraction/treatment systems and routine groundwater monitoring. It is assumed that costs for recording deed restrictions would be negligible. Table 3-6 presents the estimated conceptual capital costs for Alternative 2 I including expansion of the AS/SVE TS system. The actual amount of AS/SVE expansion necessary will be determined following evaluation of the AS/SVE TS results. The estimated conceptual present worth O&M cost for Alternative 2 is $1,762,000 as presented in Table 3-7. Cost estimate I back-up information is presented in Appendix A to this CMSR. I 3.9.3.4 Corrective Action Alternative 3 · Alternative 3 I

Groundwater Extraction and Treatment, Natural Attenuation, I Access, Land and Groundwater Use Restrictions, Groundwater Monitoring I Alternative 3 consists of groundwater extraction and treatment; access, land, and groundwater use restrictions; natural attenuation of residual low-level groundwater contamination; and groundwater monitoring. These components are described below: I

• If required, three groundwater extraction wells would be used to collect groundwater downgradient ofFTBPl. The collected groundwater (approximately 15 gpm} would then be I treated ex-situ using air stripping and chemical precipitation with discharge either to the on-site WWTF or surface water. The treatment units would be housed in a building at or adjacent to I FTBP 1. The conceptual groundwater extraction and treatment layout is presented in Figure 3-7. Actual well and building locations would be determined during design activities. I

D:IF7MCCOYIIPIJCMSIISEC710N.J 3-27 March 1996 I I Fort McCoy Draft Corrective Measures Study Report

I TABLE3-6

ALTERNATIVE 2 CAPITAL COST I FIRE TRAINING BURN PIT 1 FORT MCCOY, WISCONSIN I Capital Cost Item Quantity Unit Unit Cost Total Cost<1> Total Cost<2> I Construction: Air Sparging/Soil Vapor Extraction (AS/SVE): I AS/SVE Treatability I LS $280,000 $280,000 $280,000 Study System

AS/SVE System I LS $177,000 $177,000 $177,000 I Expansion AS/SVE System Subtotal $457,000 $457,000 I Ground Extraction and Treatment: Extraction I LS $40,000 $40,000 $40,000 I Treatment I LS $150,000 $150,000 $150,000 Discharge I LS $64,000 $64,000 $64,000 I Groundwater Extraction and Treatment Subtotal $254,000 $254,000 Limited Soil Removal 390 Ton $200 -- $78,000 I Construction Subtotal $711,000 $789,000 Construction Global Markups: I Scope Contingency (15%) $107,000 $118,000 Subtotal $818,000 $907,000 I Health and Safety (30%) $245,000 $272,000 Subtotal $1,063,000 $1,179,000 I Permitting (5%) $53,000 $59,000 Engineering (20%) $213,000 $236,000 I Construction-Related Services (15%) $159,000 $177,000 Prime Fixed Fee (5%) $53,000 $59,000 I TOTAL CAPITAL COST $1 541.000 $1 710 000 Note: Costs without limited soil removal and off-site disposaVtreatment <2>Costs with limited soil removal and off-site disposaVtreatment I Cost assumptions are presented in Appendix A to CMSR. I

I D:IFTMCCOYIIPIXMS/\TABJ-6. March 1996 I Fort McCoy Draft Corrective Measures Study Report I TABLE3-7 ALTERNATIVE 2 O&M COST FIRE TRAINING BURN PIT 1 I FORT MCCOY, WISCONSIN

I O&Mitem Quantity Unit Unit Cost Total Cost AS/SVE System Operation and Maintenance (1 yr): I AS/SVE System 1 YR $126,000 $126,000

Scope Contingency (15%) $19,000

I Subtotal $145,000 I Administration (10%) $15,000 AS/SVE System Annual O&M Subtotal $160,000 I Groundwater Monitoring (30 yrs): Groundwater Sampling and 1 (I) YR $58,000 $58,000 Analysis

I Scope Contingency (15%) $9,000

Subtotal $67,000

I Administration ( 10%) $7,000

Groundwater Monitoring Annual O&M Subtotal $74,000 I Groundwater Extraction and Treatment (5 yrs): I Groundwater Extraction 1 YR $4,000 $4,000 Groundwater Treatment 1 YR $82,000 $82,000 I Subtotal $86,000 Scope Contingency (15%) $13,000 I Subtotal $99,000 Administration (10%) $10,000 I Groundwater Extraction and Treatment Annual O&M Subtotal $109,000 Total Annual O&M Cost $343,000 I Total Present Worth of O&M $1 762.000 Note:

I (I) Includes two sampling events per year at 10 wells. O&M assumptions are presented in Appendix A to CMSR. I Present Worth Factors: i = 5%; 5 yrs = 4.329 :<3> i=5%; 30 yrs = 15.373

I D:IFTMCCOY /IPDCMSJ\TABJ-7. March 1996 I Fort McCoy Draft Co"ective Measures Study Report

I • Once the ongoing AS/SVE treatability study is complete, it may be necessary to remove a limited amount of contaminated soil (approximately 280 cubic yards per calculations in Appendix A) from the location of the former fire pit for ex-situ treatment or disposal. This I determination will be made following completion of the treatability study. I • Restrictive covenants would be placed on deeds to the FTBP1 property to restrict land and groundwater use at FTBP1. I • Residual contaminant concentrations of COCs in groundwater would be reduced over time by natural attenuation through volatilization, biodegradation, adsorption and other physical and I chemical reactions within the subsurface environment. • Groundwater monitoring would consist of semi-annual sampling and analysis of 10 of the 22 existing groundwater monitoring wells (1 upgradient, 9 downgradient) at FTBP1. These I groundwater monitoring wells are illustrated on Figure 3-2. Observation wells (OWs) are screened across the water table. Piezometers (Ps) are screened below the water table. The sampling of these observation wells and pieZometers should adequately monitor groundwater I quality at FTBP1. However, during the performance of the ongoing AS/SVE treatability study, four additional wells (OW-136B, OW-133B, OW-308, and OW-138) and seven additional piezometers (P-116A, P-129C, P-133A, P-134A, P-135A, P-136A, and P-308A) will be I sampled to monitor groundwater quality to help evaluate the effectiveness of AS/SVE. I Screened Interval Monitorin~ Well (feet below IUJ>Ulld surface) I OW-132 (upgradient) 8-18 OW-129B 10-20 P-129A 34-39 I OW-116B 9-19 OW-134 8-18 OW-135 8-18 I OW-143 8-18 OW-137 8-18 OW-141 9-19 I OW-142 9-19

Compounds which equaled or exceeded their PALs (VOCs, metals) during previous monitoring I events in downgradient monitoring wells would be analyzed for during groundwater monitoring. I Effectiveness If required, three groundwater extraction wells would be used to collect the impacted groundwater I downgradient of FTBP1. The collected groundwater would be treated using air stripping and chemical precipitation. Given the sporadic nature of low-level PAL exceedances, the effectiveness I of the treatment units may be reduced due to the sporadic nature of low concentration influent.

I D:IF1MCCOYIIPDCMSJISEC110N.3 3-28 March 1996 Fort McCoy I Draft Co"ective Measures Study Report FTBP1 is located within a fenced military vehicle parking area (the ECS) and is expected to remain I the property of the U.S. Army and continue to have associated effective access restrictions.

Land and groundwater use restrictions would be effective as FTBP1 is expected to remain the I property of the U.S. Army. If FTBP1 does not remain the property of the U.S. Army, the effectiveness of deed restrictions would depend on continued enforcement and could be subject to changes in political jurisdiction and legal interpretation. NR 812.08 would supplement groundwater I use restrictions by prohibiting the installation of new water supply wells within 250 feet of FTBP1.

Assuming the majority of the groundwater contamination would be removed by the groundwater I extraction and treatment system, residual groundwater contaminant concentrations would decrease over time to acceptable levels through natural attenuation. I The effectiveness of groundwater extraction and natural attenuation would be monitored through groundwater monitoring. Semi-annual groundwater sampling and analysis is a proven, effective I means of monitoring groundwater qwility. lmplementability and ReliabUity I

The groundwater extraction and treatment components have been implemented successfully and demonstrated reliability on similar sites. Groundwater extraction and tr~tment operating and I maintenance labor, equipment and system consumables would be r~ly available.

Based on the site conditions summarized in Section 3.9.2, access, land and groundwater use I restrictions, and natural attenuation in conjunction with groundwater monitoring would be reliable and readily implementable at FTBP1. It is anticipated that an air permit for air stripping emissions would not be required. I ·Opera.tion and Maintenance I The Alternative 3 operational requirements would be operation of the groundwater extraction/ treatment system and semi-annual groundwater monitoring. For cost estimating purposes, it is I assumed the groundwater extraction/treatment system would be operated for 30 years and groundwater monitoring performed for 30 years. I Groundwater extraction wells and groundwater monitoring wells may require periodic well screen cleaning and other minor maintenance. It is anticipated that the useful life of the wells would be at least 15 years. I Safety I Safety of nearby residents, environments and site workers with regard to physical hazards during implementation would be addressed by provisions in the construction contractor's SSHP. Potential site safety hazards during construction could include, but not be limited to, heavy equipment I operation, chemical exposure, slip/trip/fall hazards, heat/cold stress, wildlife (ticks, snakes, etc.), and I D:IF1MCCOY 1\PDCMSJISFXT/ON.J 3-29 March 1996 I I Fort McCoy Draft Corrective Measures Study Report

I vegetation (poison ivy, etc.). Temporary environmental controls (dust suppression, etc.) and ambient air monitoring would be implemented as needed during installation of the groundwater extraction I wells and construction of the groundwater treatment plant. I Environmental Evaluation Implementation of Alternative 3 components would not adversely impact environmentally sensitive areas. An ecological field assessment, included as an appendix to the RFI (SEC Donohue, I November 1994), ofFTBP1 concluded that the primary exposure pathway of concern is ingestion of contaminated subsurface soil by burrowing animals. This soil contamination presents a limited ecological risk. Current and projected future land use as a military vehicle storage area would limit I the potential for proliferation of ecological communities at FTBP1. I Human Health Evaluation Land use as a fenced military vehicle parking area and access, land use and groundwater use restrictions would prevent residential development at FTBP1. Therefore, the most likely human I health risk exposure scenario for FTBP 1 would be that of ingestion of and direct contact with surface soil by a worker at the ECS vehicle parking lot. The human health assessment (SEC Donohue, November 1994) concluded that FTBP1 trespassers would not be exposed to excess health risks I under current site conditions. The human health assessment also indicated that residents would not I be exposed to excess health risks due to exposure to soil under a residential scenario. There are no current nor anticipated groundwater receptors downgradient of FTBP1. The groundwater extraction and treatment system would mitigate contaminant migration from the source I material to groundwater. Human health concerns to site workers during the operation of the groundwater extraction and treatment system would be addressed by provisions in a SSHP.

I Institutional Evaluation

Institutional needs for Alternative 3 would include enforcing existing site access restrictions, I maintaining site fences to further restrict site access, enforcing land and groundwater use restrictions and performing routine groundwater monitoring.

I The design and implementation schedule of the three alternatives may be effected by Federal, state, and local environmental and public health standards, regulations, guidance, advisories, ordinances, or community relations. The following institutional requirements may impact design and I implementation. I • It is anticipated that implementation of Alternative 3 will not require a local construction permit. • It is anticipated that operation of the air stripper will not require a Wisconsin Air Permit. The I air stripper will be operated to meet NR 419 and NR 445 emissions criteria. I

I D:IFTMCCOYIIPDCMSJ\SECTION.3 3-30 March 1996 Fort McCoy I Draft Co"ective Measures Study Report

• If the extracted groundwater is treated and discharged to the surface, it is anticipated that a I WPDES permit will be required.

• Groundwater treatment system residuals (sludge) must be disposed in accordance with I applicable regulations.

The other components of Alternative 3 should not be significantly effected by Federal, state, and I local environmental and public health standards, regulations, guidance, advisories, ordinances, or community relations. I Cost Evaluation I The cost for Alternative 3 includes capital costs to construct the groundwater extraction and treatment system, and annual operation and maintenance costs associated with system and routine groundwater monitoring. It is assumed that costs for recording deed restrictions would be negligible. I

Table 3-8 presents the estimated conceptual capital costs for Alternative 3. The estimated conceptual present worth O&M cost for Alternative 3 is $2,814,000 as presented in Table 3-9. Cost estimate I back-up information is presented in Appendix A to this CMSR.

A summary of the cost estimates for all three alternatives is presented in Table 3-10. I 3.9.4 Recommended Alternative I Based on the site-specific factors identified in Section 3.9.2, the alternatives evaluation performed in Section 3.9.3, and the comparison presented in Table 3-11, Alternative 1 is recommended for I FTBP1.

Alternative 1 consists of AS/SVE for site groundwater; access, land, and groundwater use I restrictions; natural attenuation of residual low-level groundwater contamination remaining after AS/SVE operation; and groundwater monitoring. Alternative 1 would have a phased approach. The AS/SVE treatability study (TS) system would be operated, and then expanded as necessary. The I AS/SVE system would be operated for a period of time to be established based on the results of the ·ongoing AS/SVE TS. I Alternative .1 addresses the corrective action objectives for FTBP1 by reducing potential for contaminant migration to and in groundwater, limiting groundwater use, and reducing groundwater I concentrations for COCs to acceptable levels. Since the complete results of the ongoing AS/SVE TS are not yet available for evaluation, it is not possible to accurately predict the time it will take to not have exceedances of the PALs. However, based on the preliminary results of the AS/SVE TS, I it appears promising that AS/SVE in conjunction with limited soil remediation and natural attenuation will achieve the PALs in groundwater at FTBP 1. Alternative 1 would be technically effective, reliable, and implementable at FTBP1 and would provide short-term and long-term I protection of human health and the environment. I

D:IFTMCCOY 11POCMSIISEC170N.J 3-31 March 1996 I I Fort McCoy Draft Corrective Measures Study Report

I TABLE3-8

ALTERNATIVE 3 CAPITAL COST I FIRE TRAINING BURN PIT 1 FORT MCCOY, WISCONSIN I Capital Cost Item Quantity Unit Unit Cost Total Cost<1> Total Cost<2> I Construction: Ground Extraction and Treatment: I Extraction 1 LS $40,000 $40,000 $40,000 Treatment I LS $150,000 $150,000 $150,000 I Discharge 1 LS $64,000 $64,000 $64,000 Limited Soil Removal 390 Ton $200 -- $78,000 I Construction Subtotal $254,000 $332,000 Construction Global Markups: I Scope Contingency (15%) $38,000 $50,000 Subtotal $292,000 $382,000 I Health and Safety (30%) $88,000 $115,000 Subtotal $380,000 $497,000 I Permitting (5%) $19,000 $25,000 Engineering (20%) $76,000 $100,000 I Construction-Related Services (15%) $57,000 $75,000 Prime Fixed Fee (5%) $19,000 $25,000 I TOTAL CAPITAL COST $551.00_0 $722.000 NOTE: O> Costs without limited soil removal and off-site disposaVtreatment <2>Costs with limited soil removal and off-site disposal/treatment I Cost assumptions are presented in Appendix A to CMSR. I I I I

I D:IF1MCCOYJIPDCMSJ\TABJ-8. March 1996 I Fort McCoy Draft Corrective Measures Study Report

I TABLE3-9

ALTERNATIVE 3 O&M COST I FIRE TRAINING BURN PIT 1 I FORT MCCOY, WISCONSIN I O&Mitem Quantity Unit Unit Cost Total Cost Groundwater Extraction and Treatment Operation and Maintenance (30 yrs): I Groundwater Extraction 1 YR $4,000 $4,000 Groundwater Treatment 1 YR $82,000 $82,000 I Subtotal $86,000 Scope Contingency (15%) $13,000 I Subtotal $99,000 I Administration (1 0%) $10,000 Groundwater Extraction and Treatment Annual O&M Subtotal $109,000 I Groundwater Monitoring (30 yrs): Groundwater Sampling and 1 (I) YR $58,000 $58,000 I Analysis Scope Contingency (15%) $9,000 I Subtotal $67,000 Administration (1 0%) $7,000 I Groundwater Monitoring Annual O&M Subtotal $74,000 Total Annual O&M Cost $183,000 I Total Present Worth of O&M $2.814.000 I NOTE: (I) Includes two sampling events per year at 10 wells. I O&M assumptions are presented in Appendix A to CMSR. I I

I D:IFTMCCOYJIPIXMSJ\TAB3-9. March 1996 I Fort McCoy I Draft Corrective Measures Study Report TABLE3-10

I CORRECTIVE MEASURES ALTERNATIVES COST ESTIMATE SUMMARY FIRE TRAINING BURN PIT 1 I FORT MCCOY, WISCONSIN Alternative #1 Alternative #2 Alternative #3 . ./ ) . ···.· •···•••···••· .•••.•...•••.•.•••••••..•.•• ·. ·•··. •.· < > •.•••. ·. > so-.r(le I/ •. < > .·.·······•·••·•• .··· . I .••••••. .· > .•.•••• <...... \ •••• .· •.. •··.•. > .··. ··••••••••••·•·••·••·• Access, Land Use Restrictions X X X I Soil Vapor Extraction (AS/SVE X X System) .. . ······· -:-::·.; ··.·. :-... ···:·· ... ·.. ·.· .... Groundwater •• ••••••••• ····••·••··• < ••...... ·.•· ... I •••• •••••••••••••••••• .·····.· ..... ····· Use Restrictions X X X I Natural Attenuation X X X Monitoring X X X I Air Sparging (AS/SVE System) X X Extraction and Treatment X X ...... • •• < •.... · ... ··· .· . .. / J . Cost . ·...... ·• ...... ·...... ••...... •. ·.·.· .. . .. ) I >< ··••· i•·· Capital $922,000 $1,541,000 $551,000 ($1,160,000) ($1 '71 0,000) ($722,000) I AnnualO&M $160,000 (AS/SVE) $160,000 --- $74,000 (AS/SVE) (GWMON) $74,000 $74,000 (GWMON) (GWMON) I $109,000 $109,000 (GWE&T) (GWE&T) I *Present Worth O&M $152,000 (1 yr) $152,000 --- $1,138,000 (1 yr) (30 yr) $1,138,000 $1,138,000 (30 yr) (30 yr) I $472,000 $1,676,000 (5 yr) (30 yr) I Total Cost $2,212,000 $3,303,000 $3,365,000 (2,450,000) (3,472,000) (3,536,000) I NOTES: - Costs in parenthesis include costs for limited soil removal and off-site disposal/treatment. *Present Worth Factors (5% rate): I I year= 0.952 5 years = 4.329 I 30 years= 15.373

I D:IFTMCCOYJIPDCMSJ\TABJ-10. March 1996 I Fort McCoy Draft Corrective Measures Study Report

I TABLE3-11

CORRECTIVE MEASURES ALTERNATIVES COMPARISON I FIRE TRAINING BURN PIT 1 FORT MCCOY, WISCONSIN

I Evaluation Criteria Alt#l Alt#2 Alt#3

Effectiveness (performs Should be effective Should be effective Should be effective I intended function) lmplementability and ·lmplementable and lmplementable and lmplementable and Reliability (can be done reliable reliable reliable I and will it last/ perform over the long-term)

Operation and Medium Medium Medium I Maintenance (O&M) Costs I Safety Concerns During Low Low Low Construction! Implementation I Environmental Concerns Adequately addresses Adequately addresses Adequately addresses concerns in Section 3.7.5 concerns in Section 3.7.5 concerns in Section 3.7.5

Human Health Concerns Adequately addresses Adequately addresses Adequately addresses I concerns in Section 3.7.5 concerns in Section 3. 7.5 concerns in Section 3.7.5

Institutional Concerns Addresses institutional Addresses institutional Addresses institutional I control needs identified control needs identified control needs identified in Section 3.7.5 in Section 3. 7.5 in Section 3.7.5 I Cost $2,450,000 $3,472,000 $3,536,000 I I I I I I

I D:IFTMCCOYJIPOCMSJITAB3-//. March 1996 I Fort McCoy Draft Co"ective Measures Study Report

I As presented in Table 3-11, Alternative 1 adequately addresses the human health, environmental, and institutional control concerns, is readily implementable, provides long-term reliability, and is I less costly as compared to Alternatives 2 and 3. I I I I I I I I I I I I I I I

March 1996 I D:IF1MCCOYIIJ'DCMSIISEC110N.3 3-32 I Fort McCoy Draft Co"ective Measures Study Report

I 4.0 FIRE TRAINING BURN PIT 2

I 4.1 DESCRIPTION OF FIRE TRAINING BURN PIT 2

Former Fire Training Burn Pit 2 (FTBP2) is located in the NW 114 of the NE 114 of Section 16, I T17N, R3W, Momoe County, Wisconsin. FTBP2 is located at the Fort McCoy Airport approximately 2,500 feet west of Silver Creek. The pit was used for training fire fighters. See I Figure 4-1 for the location of FTBP2. I 4.2 WASTE MANAGEMENT ACTIVITIES FTBP2 was constructed by excavating soil to a depth of approximately 3 feet and a rectangular shape of approximately 40 by 30 feet. Training activities started with filling the pit with water and fuel I and igniting the fuel layer. Fire fighters would extinguish and reignite the fuel repeatedly until the fuel was consumed. FTBP2 was not used since 1992. As described in Section 4.7.6, the fire pit and I surrounding contaminated soil were removed in late 1994. 4.3 PHYSICAL SITE CHARACTERISTICS

I This subsection describes the physical setting ofFTBP2 based on information presented in the RFI Report.

I 4.3.1 Site Setting

FTBP2 is located in a grassy field east of the north-south runway at the Fort McCoy Airport as I shown on Figure 4-2. Operations buildings and a hangar are located approximately 114-mile northeast of the pit with old fuel product storage sheds located approximately 100 yards southeast I of the pit. Construction of a new engineered FTBP and other structures at the airport has occurred since FTBP2 was removed in 1994.

I 4.3.2 Topography and D.rainage

The land surface at FTBP2 is generally flat as illustrated in Figure 4-2. Ground surface elevations I range from 836 to 840 feet MSL with a general slope toward the west. There is little surface runoff from the area due to the flat topography and permeable surficial soils.

I 4.3.3 Surficial Soils

Soils at FTBP2 are sand of the Impact series. The Impact sand is classified as an acidic soil with pH ranging from 4.5 to 6.0, clay content less than 8 percent, and less than 2 percent organic matter. The soil is sandy with high permeability and conductivity.

D:\FTMXOYJIPDCMSJ'SEC170N.4 4-1 March 1996 I ~~======~-JA:CK~SO~~C~,OL:iNT~,------~ N I

I / I I I PESTICIDE DISPOSAL SITE I I

I CLOSED LANDF1lL 2 I CLOSED LANDFill. 3 I I I I

'l~Q~", ! -~-- .. i \ I FIR~ T~INI~~<--·--,_ \/--'"'--1 -·--) I BURN PIT 2

0 1/2 2 MILES \ SCALE I SOURCE: WISCONSIN DEPARTMENT OF TRANSPORTATION ---- MAR. 1996 FIGURE 4-1 18903 _..ENVIRONMENT & FIRE TRAINING BURN PIT 2 ftll LOCATION MAP I ~~~~ INFRASfRUCTURE DRAFT CORRECTIVE MEASURES STUDY I FORT McCOY, WISCONSIN ~,------~ I / " I I I / ?~200N I I I I I I I I I I I I I I ..., I I -·rD I I i:. I I .... I I ..... I I 3: FORMER ~ I I QJ ..., i I ; I I .... BURN PIT I I .!-'> I I I I I U5 I I 1.0 y C7l I I 0 I !-'? I n.J I I I .... I I .... I I A I I I I I I I I I I I I I I I I I 7l3000N I I I I I I £"I I¥ I I I I I I I I I I I I I I I I I I SS02 'I r I I I I \ \ \ SS03e I " I N SS04;::;-

--838- TOPOGRAPHIC CONTOUR 712800 ....

----829.75 GROUNDWATER CONTOUR I SS05

GROUNDWATER FLOW DIRECTION

GROUNDWATER MONITORING fl =829' 89 I WELL INDICATING THE GROUNDWATER TABLE IN ~WI20 FEET ABOVE MEAN SEA NOTES: LEVEL '·GROUNDWATER TABLE ELEVATIONS AND CONTOURS ARE DERIVED FROM SHALLOW SOIL SAMPLE THE RFI PHASE 3 INVESTIGATION. I LOCATION - PHASE I CHEMICAL BORING 0' IS' 30' 60' I PHASE I AND 2 SCALE ---- MAR. 1996 FIGURE 4-2 18903 FIRE TRAINING BURN PIT 2 IIIII ...ENVIRONMENT & GROUNDWATER MONITORING WELL AND SELECTED I ~~~~ INFRASTRUCTURE SOIL SAMPLING LOCATIONS AND WATER TABLE MAP DRAFT CORRECTIVE MEASURES STUDY I FORT McCOY, WISCONSIN I Fort McCoy Draft Corrective Measures Study Report

I 4.3.4 Geology

The uppermost geologic unit at FTBP2 consists of the Quaternary alluviwn on top of a friable I mediwn-grained Cambrian sandstone bedrock described in Section 2.4.4 of this CMSR. In this area the Quaternary alluviwn consists of fine-grained, well-sorted sand.

I 4.3.5 Hydrogeology

There is one hydrostratigraphic unit at FTBP2 consisting of two parts. The upper part of the unit I consists of the Quaternary alluviwn with the lower part being a friable mediwn grained Cambrian sandstone bedrock. Both parts of the hydrostratigraphic unit have similar hydraulic conductivities I and are relatively permeable. All wells around FTBP2, with the exception of OW-118, are screened in the alluviwn. Well locations are shown on Figure 4-2. The water table gradient is not affected by the transition from one part of the hydrostratigraphic unit to the other as the observed water table I elevations reflect the general topographic trend. The water table, approximately 10 feet below the land surface, has a horizontal gradient at FTBP2 of 0.004 ft/ft toward the north-northwest. The average field hydraulic conductivity is 0.012 em/sec. FTBP2 is located in a groundwater recharge I area. I 4.4 SITE CONCEPTUAL MODEL Figure 4-3 illustrates the site conceptual model for FTBP2. The primary source of contamination at FTBP2 was the burned and unburned fuel residues and chlorinated organics that remained in the I former pit and soil prior to its removal in late 1994. That removal action is described in Section 4. 7 .6. The former barrel storage area, former fuel storage sheds, and areas near the sheds had the potential for soil and groundwater contamination resulting from former barrel loading, I unloading, storage and transport activities, however, none was detected at those areas during RFI activities. Precipitation may have infiltrated through the pit and adjacent contaminated soil to leach I and transport contaminants into the groundwater. Transport of contaminants by precipitation runoff is not applicable here due to the permeable surficial soil and flat topography.

I 4.5 NATURE AND EXTENT OF CONTAMINATION

Sampling and analysis of soil and groundwater at FTBP2 has occurred both during and after the RFI. I Description of these activities as well as analytical results are presented in detail in Section 13.0 of the RFI Report.

I The bum pit source material was not sampled during the RFI, but is considered the primary contaminated area at FTBP1. Based on soil sampling near the bum pit, low levels ofVOCs in subsurface soil are the primary contaminants detected. The VOCs, 1,2-dichloroethene (1,2-DCE), I trichloroethene (TCE), and tetrachloroethene (PCE) were detected at their maximwn depth at boring I CB-106, at depths of3.5 to 5.5 feet. I I D:IFTMCCOYJIPDCMSJISEC170N.4 4-2 March 1996 C""J I ~ ::c 0 c.. m C""J ::?.... 0 I 0 0 U'l

~C""J 3:

'0~ I ..... IVa 0 c. n,.., I c. NORTH 3: SOUTH QJ.., .... ~ I .... U) U)en I Hi IV.... FORMER BURN PIT IREMOVEO}_\ w I en --~--~--~----I ' ., ...... ______.,"" I GROUNDWATER I FLOW DIRECTION I I I I I I NOTE: SEE FIGURE 4-2 FOR LOCATION OF I GROUNDWATER MONITORING WELLS. SCALE: NTS MAR. 1996 FIGURE 4-3 18903 ftll _..ENVIRONMENT & FIRE TRAINING BURN PIT 2 I I~U~I INFRASTRUCfURE SITE CONCEPTUAL MODEL DRAFT CORRECTIVE MEASURES STUDY I FORT McCOY, WISCONSIN I Fort McCoy Draft Corrective Measures Study Report

I Of the primary site contaminants detected in soil, only TCE and PCE were detected in groundwater. TCE was detected only in well OW-130, and PCE was detected in wells OW-118 and OW-130, all I above the respective PALs. A summary of groundwater sampling results is presented in Table 4-1. Based upon a review of Table 4-1, it appears the removal action in late 1994 mobilized some constituents in the subsurface I resulting in an isolated peak of groundwater contamination detected in sampling event No. 5 in 1995. However, as shown in Table 4-1, sampling event No.6 indicates contaminant levels in groundwater have dropped sharply as expected. Future groundwater monitoring results will be evaluated to · I determine if this downward trend continues. I 4.6 CONTAMINANT FATE AND TRANSPORT The RFI data demonstrate that chlorinated contaminants (TCE, PCE) apparently moved from the pit I material, through the soil to the groundwater. Periodic overflow ofthe pit due to excess precipitation reportedly impacted soils immediately surrounding the pit. North-northwesterly groundwater flow intercepting the vertically moving contaminants apparently is providing a migration mechanism for I horizontal movement. As described in Section 4.7.6, the majority ofFTBP2 source material was removed in 1994. This source removal will eliminate the potential for contaminant migration with infiltrating groundwater. Residual low-level concentrations of groundwater contaminants should I naturally attenuate by the processes described in Section 4.8.2.4. I 4.7 DEVELOPMENT OF CORRECTIVE ACTION OBJECTIVES 4.7.1 Introduction

I The purpose of this section is to identify potentially applicable soil and groundwater contaminant limits for the chemicals of potential concern (COCs) identified in the RFI Report for FTBP2. These I soil and groundwater contaminant limits are based on public health and environmental criteria, information gathered during the RFI, and applicable WDNR and USEPA regulations. These soil and groundwater contaminant limits will be considered during the identification and development I of appropriate corrective ~tion technologies and alternatives. I The COCs identified for FTBP2 are: Chemical of Potential Concern

I Bis (2-ethylhexyl) phthalate (groundwater) Chloromethane (groundwater) Tetrachloroethene (PCE) (groundwater) I Trichloroethene (TCE) (groundwater) Arsenic (groundwater) Barium (groundwater) I Chromium (groundwater) I Lead (groundwater) I D:'IF1MCCOYJIPOCMSIISEC710N.4 4-3 March 1996 ...... ------Fort McCoy Draft Corrective Measures Study Report-

TABLE 4-1

GROUNDWATER QUALITY SUMMARY FIRE TRAINING BURN PIT NO. 2 FORT MCCOY, WISCONSIN

Wellll8 Welll19°> Well120(2) Well130 Analytes Detected at Levels Exceeding Sampling Event Sampling Event Sampling Event Sampling Event NR 140 Public Health Standards I 2 3 4 5 6 I 2 3 4 5 6 I 2 3 4 5 6 I 2 3 4 5 6 PAL ES Tetrachloroethene 3.0J I. OJ -- NS -- I ------NS ------NS -- -- NS 5.0 15.0 NS II 5 0.5 5.0 Trichloroethene ------NS ------NS ------NS -- - NS -- 5.5 NS 4 0.6 0.5 5.0 Chloromethane ------NS ------NS I ------NS ------NS -- -- 0.3 3 Bis(2-ethylhexyl) ------NS -- 2JB - -- -- NS -- IJB ------NS 6J IJB -- -- - NS -- 3JB 0.6 6 phthalate Barium ------NS ------NS ------NS ------NS 830 -- 400 2,000 Arsenic ------NS 9.6 ------NS ------NS ------NS 21 -- 5 50 Chromium ------NS 24 ------NS ------NS ------NS 170 24 10 100 Mercury ------NS 0.22 ------NS ------NS ------NS 0.34 -- 0.2 2 Nitrate+Nitrite -- - -- NS ------NS 2,300 2,000 ------NS ------NS -- -- 2,000 10,000 Lead -- -- 7.0 NS 41 3 -- -- 5.0 NS -- 3.1 ------NS -- -- NS -- -- NS 230 33 1.5 15.0 NOTES:

All values are in ugll. ES Enforcement Standard NS Well not sampled due to pit removal activities. PAL Preventive Action Limit (I) Wellll9 is the upgradient well. Sampling Event I - Phase I RFI, April - May 1992 (2) Welll20 is a sidegradient well. Sampling Event 2 - Phase 2 RFI, October - November 1992 -- Analyte not detected at level above PAL. Sampling Event 3 - Phase 3 RFI, May - August 1993 Sampling Event 4 - Interim Monitoring, July 1994 Sampling Event 5 -Interim Monitoring, June 6, 1995 Sampling Event 6 -Interim Monitoring December 5, 1995

D:IFTMCCOYJIPDCMSJITAB4-l. March 1996 I Fort McCoy Draft Corrective Measures Study Report

I Mercury (groundwater) Nitrate+ Nitrite (groundwater)

I The above compounds were selected as COCs based on one of the following: I • COC equals or exceeds an NR 140 PAL in groundwater samples collected from a downgradient monitoring well. I • COC is a primary contributor to human health risks associated with groundwater exposure pathways under hypothetical future residential use risk scenario at FTBP2.

I • COC is a primary contributor to human health risks associated with soil exposure pathways under hypothetical future residential use risk scenario at FTBP2.

I 4.7.2 Federal Regulations and Permits I 4. 7 .2.1 Groundwater Standards The established Safe Drinking Water Act Maximum Contaminant Levels (MCLs) for COCs at I FTBP2 are presented below. Federal MCL I Chemical of Potential Concern uwl Bis (2-ethylhexyl) phthalate 6 I Chloromethane NIA PCE 5 TCE 5 I Arsenic 50 Barium 2,000 Chromium 100 I Lead 15(1) Mercury 2 I Nitrate + Nitrite 10,000

· Notes: (I) No MCL; Federal action level. I N/A =No MCL established I 4. 7 .2.2 Soil Standards There are no federal soil quality standards which apply with respect to soil cleanup objectives. I I

I D:IFTMCCOYIIPDCMSI\SECnON.4 4-4 March 1996 Fort McCoy I Draft Co"ective Measures Study Report

4.7.2.3 Surface Water Standards I

Surface water standards are contained under 40 CFR 122.2 of the Clean Water Act. These standards address point source discharges and are not directly applicable to measurable surface water quality. I 4. 7.3 Wisconsin Regulations and Permits -I 4.7.3.1 Groundwater Standards

Wisconsin has implemented the Safe Drinking Water Act under NR 809 WAC and has either I adopted the federal standard or developed a more stringent level. Groundwater quality standards are contained in NR 140 WAC. The groundwater quality standards consist of PALs and Enforcement I Standards (ESs). The PALs, ESs, and the Wisconsin MCLs for COCs at FTBP2 are listed be~ow. I PAL ES Wisconsin MCL Chemical of Potential Concern uKfl Y&fl uWI I Bis (2-ethylhexyl) phthalate 0.6 6 6 Chloromethane 0.3 3 N/A PCE 0.5 5 5 I TCE 0.5 5 5 Arsenic 5 50 50 Barium 400 2,000 2,000 I Chromium 10 100 100 Lead 1.5 15 N/A Mercury 0.2 2 2 I Nitrate + Nitrite 2,000 10,000 10,000 I Note: N/A =No MCL established

4. 7 .3.2 Soil QualitY, Standards I

WDNR has issued NR 720 regulations which address residual soil contaminant levels. A human health and environmental assessment was completed and approved for FTBP2 during the RFI. I Contaminant concentration limits for soil resulting from that assessment and evaluation ofNR 720 regulations are discussed in Section 4.7.6. I 4.7.3.3 Surface Water Standards

Surface Quality Standards are contained in Wisconsin Administrative Code NR 102-1 05. Surface I water standards for the COCs were not exceeded. This SWMU is approximately 112 mile from the nearest watercourse, Silver Creek. I I

March 1996 D:IFTMCCOYJIPDCMSJ\SEC170N.4 4-5 I I Fort McCoy Draft Co"ective Measures Study Report I 4. 7.4 Local Regulations and Permits I There are no local regulations or permits which contain soil or groundwater cleanup objectives. 4. 7.5 Human Health and Environmental Assessment

I A human health assessment of potential risks was completed for FTBP2 using RFI data (SEC Donohue, November 1994). As required by USEPA and WDNR, potential exposure scenarios were evaluated and include scenarios involving residents and trespassers at FTBP2. There were no COCs I identified which contribute to excess risk at FTBP2 based on RFI sampling results from samples collected from outside the pit. It should be noted that no samples of the pit liner or contents were collected for analysis during the RFI. However, as described in Section 4.7.6 below, the pit and I surrounding contaminated soil were removed in 1994. I As stated in 40 CFR 300.430(e)(2)(i)(A)(2) of the National Contingency Plan (NCP), "for known or suspected carcinogens, acceptable exposure levels are generally concentration levels that represent an excess upper bound lifetime cancer risk to an individual of between l

I As discussed in Section 4.7.5, there were no COCs identified from the samples collected from outside the pit which contribute to excess risk at FTBP2. Therefore, no risk-based soil standards were established for FTBP2. Removal of the majority ofFTBP2 source material (ponded liquids, I liner, and surrounding soil) was performed in late 1994. Approximately 12,700 gallons of water were removed from the pit and disposed at the Fort McCoy Wastewater Treatment Plant. Approximately 610 cubic yards of liner/soil was removed and disposed off-site. Site-specific soil I cleanup levels were established by WDNR and USEPA. Confirmatory soil sampling results indicate that the remaining soil is below the WDNR and USEPA cleanup levels, with the exception of DRO I and GRO which are both amenable to in-situ biodegradation. I I D:IFTMCCOYJIPOCMSJISEC170N.4 4-6 March 1996 Fort McCoy I Draft Co"ective Measures Study Report 4.7.7 Groundwater Objectives I

Site-specific groundwater objectives identified below for FTBP2 were developed from reviewing the Federal MCLs, Wisconsin MCLs, Wisconsin groundwater standards (PALs and ESs). I

The following paragraph is based on excerpts from 57FR31780 and 31797 (pages 31780 and 31797 ofthe July 17, 1992, Federal Register): The Safe Drinking Water Act (SDWA) requires USEPA to I publish maximum contaminant level goals (MCLGs) for contaminants which may have any adverse effect on the health of persons and which are known or anticipated to occur in public water systems. MCLGs are to be set at a level at which no known or anticipated adverse effects on the health of I persons occur and which allows an adequate margin of safety. At the same time the US EPA publishes a MCLG, it must also promulgate a National Primary Drinking Water Regulation which includes either 1) an MCL, or 2) a required treatment technique. An MCL must be set as close to I the MCLG as feasible. Under the SDWA, "feasible" means "feasible with the use of the best technology, treatment techniques, and other means which the Administrator finds, after examination I for efficacy under field conditions and not solely under laboratory conditions (taking cost into consideration)." Other technology factors that are considered in determining the MCL include the ability of laboratories to measure accurately and consistently the level of the contaminant with I available analytical methods.

As presented in 4.7.2 and 4.7.3 above, ESs are generally equal to federal and Wisconsin MCLs. I Since the ESs are generally the same as corresponding MCLs, they inherently represent the lowest possible contaminant concentrations "technically and economically feasible" as required by NR 140.24(2). However, since WDNR interprets State of Wisconsin law to require that PALs be . I the goal of groundwater remediation, PALs are proposed as the appropriate groundwater objectives which means corrective measures will be developed to attempt to reduce groundwater contaminant · concentrations to levels less than the PAL. I

The selected groundwater objectives for the COCs are presented below. In addition, the detections of concentrations of COCs in groundwater samples obtained from monitoring wells equal to or I exceeding the PAL is presented in Table 4-1. I PAL Chemical of Concern ~ I Bis (2-ethylhexyl) phthalate 0.6 Chloromethane 0.3 PCE 0.5 I TCE 0.5 Arsenic 5 Barium 400 I Chromium 10 Lead 1.5 Mercury 0.2 I Nitrate + Nitrite 2,000 I D:IF1M::COYJIPOCMSJISEC710N.4 4-7 March 1996 I I Fort McCay Draft Co"ective Measures Study Report

I The COCs to be addressed in the following technologies and alternatives sections will be those COCs detected in groundwater at FTBP2 at levels equal to or exceeding the PAL in downgradient monitoring wells with the exception of Bis (2-ethylhexyl) phthalate which is a common laboratory I contaminant. I 4.8 CORRECTIVE MEASURES TECHNOLOGIES I 4.8.1 Introduction In this section, applicable corrective action technologies are identified for groundwater based on an evaluation of contaminants detected. Medium-specific corrective action objectives developed in I Section 4. 7 were evaluated and appropriate general response actions were identified that satisfy the corrective action objectives. Potentially applicable technologies were then identified for each I general response action as listed in Table 4-2 and are discussed in Section 4.8.2. Relevant site-specific conditions were considered in the identification of corrective action technologies to be retained for consideration in developing corrective action objectives. Corrective I action objectives were reviewed and applicable technologies were selected based on past experience and verified performance information. The identified technologies that have proven effectiveness for the media and COCs and can be practically implemented, operated, and maintained given site­ I specific conditions are identified as being retained for consideration in developing corrective action alternatives. Table 4-2 identifies which technologies have been retained for consideration in I developing the corrective action alternatives presented in Section 4.9. I 4.8.2 Identification of Applicable Groundwater Technologies 4.8.2.1 Groundwater Institutional Actions

I Groundwater Use Restrictions

Groundwater use restrictions would be imposed to prevent the use or installation of new private I wells and public drinking water supply wells within the FTBP2 source area (including downgradient contamination). Either voluntary or legal restrictions (or both) on groundwater may apply. Voluntary groundwater use restrictions are restrictive covenants written into a site property deed to I notify any purchaser of the location and source of groundwater contamination and that groundwater use must be restricted. Legal groundwater use restrictions would involve notifying the WDNR Bureau of Water Supply of the groundwater impacts. The Bureau keeps maps and lists of sites with I groundwater impacts; however, it is the responsibility of the well driller to be apprised of specially I designated areas. NR 812.08 prohibits the installation of new water supply wells within 250 feet of a lagoon (FTBP2 would be considered an impoundment/lagoon). Both voluntary and legal groundwater use I restrictions depend on enforcement for their effectiveness. Relative costs for groundwater use restrictions are low. I

I D:IF1MCCOYJIPDCMSJISEC170N.4 4-8 March 1996 I Fort McCoy Draft Corrective Measures Study Report

I TABLE4-2

CORRECTIVE ACTION OBJECTIVES, GENERAL RESPONSE ACTIONS I AND CORRECTIVE MEASURES TECHNOLOGIES FIRE TRAINING BURN PIT NO. 2 I FORT MCCOY, WISCONSIN Corrective Measures Technologies Retained I Corrective Action Objectives General Response Actions Technologies Considered for Further Evaluation Reduce concentrations of COCs in Institutional • Groundwater Monitoring Yes groundwater to levels below . Groundwater Use Yes NR 140 PALs, and limit Restrictions I groundwater use Containment . Low-Permeability Barrier No<1> • Hydraulic Barrier Yes I Removal . Extraction Wells Yes . Collection Trenches No

Treatment . Biological Treatment No< 1> I 1 • Carbon Adsorption No< > • Air Stripping Yes <1> . Air Sparging/Soil Vapor No<1> I Extraction . Chemical Precipitation Yes<1> • Natural Attenuation Yes

I Discharge • POTW Yes • Surface Water Yes I NOTE:

(I) These technologies have additional information and illustrations provided _in Appendix C in addition to the descriptions I presented in Section 4.8.2. I I I I I I

I D:IFTMCCOYJIPOCMSJ\TAB4-1. March 1996 I Fort McCoy Draft Co"ective Measures Study Report

I Groundwater use restrictions will be retained for consideration in developing corrective action alternatives.

I Groundwater Monitoring I Groundwater monitoring using monitoring wells would be continued at FTBP2 to track groundwater quality and the effectiveness of other remediation technologies. Groundwater monitoring is a commonly used method to determine groundwater quality. Monitoring consists of collecting I groundwater samples from monitoring wells and analyzing those samples to define contaminant migration or establish increasing or decreasing concentration trends over time. Laboratory analysis detection limits will be set low enough to determine if the PALs have been exceeded. If the PAL I is below the lowest detection limit, the lowest detection limit commercially available will be utilized for evaluating groundwater standard exceedances. Relative capital costs are low; O&M costs are moderate. Groundwater monitoring will be retained for consideration in developing corrective I action alternatives. I 4.8.2.2 Groundwater Containment Actions Low-Permeability Barriers

I Low-permeability barriers can be an effective component of a groundwater containment system. The barriers can consist of a soil, bentonite and water mixture, cement and water mixture, or sheet piling I and would probably be located downgradient of the former fire pit. They are most effective if keyed several feet into a low permeability layer such as relatively impermeable bedrock or clay. However, a low-permeability barrier alone will only divert groundwater flow, it will not contain it. To contain I groundwater, the grmmdwater that flows up to and then around or under the barrier must be collected by extraction wells or collection trenches and subsequently treated and discharged. Relative costs for low-permeability barriers would be high given the need for specialized equipment, materials and I procedures to construct a barrier. Given the lack of a low-permeability layer at FTBP2 to key into, low-permeability barriers will not be retained for consideration in developing corrective action I alternatives. Hydraulic Barriers

I Hydraulic barriers would be used to minimize migration of contaminated groundwater. A hydraulic barrier would consist of a series of extraction wells or collection trenches. Extracted groundwater would require treatment or pretreatment prior to. discharge. Relative capital costs are moderate, I O&M costs (pumping system and well maintenance) are moderate. Hydraulic barriers will be I retained for developing corrective action alternatives. I I

I D:IFTMCCOYIIPDCMSIISEC770N.4 4-9 March 1996 Fort McCay I Draft Co"ective Measures Study Report 4.8.2.3 Groundwater Removal Actions I Extraction Wells I Extraction wells would be used to collect impacted groundwater. Generally, extraction wells would be drilled and screened in a highly permeable water-bearing zone. The wells are fitted with a pump to extract groundwater and create a negative pressure zone to promote flow towards the well. I Relative capital costs for extraction wells are low to moderate; O&M costs are moderate. Extraction wells will be retained for developing corrective action alternatives. I Collection Trenches I Collection trenches may be used in place of extraction wells for collecting impacted groundwater and may be very effective, depending on the hydrogeology of the site. Collection trenches are also used frequently in lowering the local water table and controlling the direction of groundwater flow I at a site. Extracted groundwater would require treatment prior to discharge. Relative capital costs for collection trenches are generally low to moderate; O&M costs are moderate. I Collection trenches will not be retained for developing corrective action alternatives here due to constructability difficulties in the saturated sandy soils and questionable effectiveness in the high permeability sandy soils. The saturated sandy soils would make construction of a collection trench I difficult and costly due to stability/sloughing potential. Even if a trench would be constructed at FTBP2, it would have reduced effectiveness since collection trenches operate on the basis of permeability differential. Groundwater generally prefers flow from areas of low permeability (silts, I clay) to areas of high permeability (sands, gravels). Since the area at FTBP2 already naturally contains a high permeability material (sands), the effectiveness of a collection trench at FTBP2 I would be reduced since there would be minimal difference in the permeability of the native material (sands) and the collection trench material (sands). This would result in only partial capture of the groundwater moving past FTBP2. I 4.8.2.4 Groundwater Treatment Actions I Biological Treatment

On-site biological treatment of extracted groundwater may use either an attached or suspended­ I growth biological treatment process. In suspended growth. systems such as activated sludge processes (ASP), contaminated groundwater is circulated in a mixing basin where a microbial population aerobically or anaerobically degrades organic matter and produces new cells. The new I cells form a sludge, which is settled out in a clarifier, and a portion of the sludge biomass is recycled to the mixing basin. A portion of the sludge is continuously wasted, to be further treated prior to solids disposal, generally at a landfill. In attached growth systems, such as rotating biological I contactors and trickling filters, microorganisms are established on an inert support matrix to aerobically or anaerobically degrade groundwater contaminants. Attached growth processes produce I less sludge than ASPs. Attached and suspended systems often are used together in series. I D:IF7MCCOY/IPDCMSJISEC770N.4 4-10 March 1996 I I Fort McCoy Draft Co"ective Measures Study Report I Biological treatment is used primarily to treat nonhalogenated VOCs, SVOCs and petroleum hydrocarbons. Halogenated VOCs (PCE, TCE), SVOCs and pesticides also can be treated, but the process may be less effective and may be applicable only to some compounds within these groups. I Relative capital costs for biological groundwater treatment are moderate to high; O&M costs are high. Biological treatment will not be retained for developing corrective action alternatives given that it is less effective than air stripping at removing the low levels of halogenated VOCs detected I in the groundwater. I Air Stripping Air stripping would involve pumping of extracted groundwater into an air stripping vessel which uses air and water mixing to remove or strip VOCs. Types of aeration methods include packed I towers, diffused aeration, tray aeration, and spray aeration. I The target contaminant groups for air stripping systems are halogenated (PCE, TCE) and nonhalogenated VOCs. The technology can be used but may be less effective for halogenated and nonhalogenated SVOCs and fuels. Relative capital costs for air stripping are moderate; O&M costs I are low, unless vapor-phase carbon is needed (moderate if needed) to treat the exhaust air stream. Air stripping will be retained for consideration in developing corrective action alternatives.

I Carbon Adsorption

Carbon adsorption would remove organic compounds that preferentially sorb onto carbon versus I water. On-site carbon adsorption of extracted groundwater would involve piping extracted groundwater/leachate through a series of canisters containing activated carbon to which dissolved organic contaminants adsorb with subsequent discharge of the treated water. The technology I requires periodic replacement or regeneration of saturated carbon which increases the cost of this I technology. The target contaminant groups for carbon adsorption (liquid phase) are halogenated and nonhalogenated SVOCs. The technology can be used, but may be less effective in treating I halogenated VOCs (PCE, TCE), fuel hydrocarbons, pesticides, and inorganics. Relative capital costs are moderate to high; O&M costs are moderate to high. Carbon adsorption will not be retained for developing corrective action alternatives given that it is less effective than air stripping at removing I the low levels of halogenated VOCs detected in the groundwater. I Air Sparging/Soil Vapor Extraction Air would be injected under pressure below the water table to strip VOCs from groundwater/leachate. Air sparging (AS) would be conducted in conjunction with soil vapor I extraction (SVE) to remove stripped VOCs from the unsaturated zone. The ease and low cost of installing small-diameter air injection points allows considerable flexibility in the design and construction of a remediation system. Relative capital costs for air sparging are low; O&M costs I are low unless vapor-phase carbon is needed (moderate if needed) to treat the exhaust air stream. I AS/SVE will not be retained for consideration in developing corrective action alternatives since I D:IFTMCCOYIIPIXMSJISEC170N.4 4-11 March 1996 Fort McCoy I Draft Co"ective Measures Study Report groundwater treatment, if required, may need to be performed ex-situ given the levels of lead and I chromium in groundwater samples from well OW-130.

Chemical Precipitation I

On-site chemical precipitation of extracted groundwater would be used for removing inorganic contaminants as pretreatment for other processes or to address discharge limits for inorganics. I Precipitation is a process by which the chemical equilibrium of a waste stream is altered to reduce the solubility of metals. The metals precipitate out as a solid phase (sludge) and are taken out of the I solution by solids removal processes. Metals precipitation is not one unit operation but a combination of coagulation, flocculation, sedimentation, and, in some cases, filtration processes. Relative capital costs are moderate; O&M costs are moderate to high due to sludge processing and I off-site disposal. Chemical precipitation will be retained for consideration in developing of corrective action alternatives. I Natural Attenuation

Natural attenuation would consist of volatilization, biodegradation, recharge and dispersion, I adsorption, and chemical reactions with subsurface materials to reduce groundwater contaminant concentrations to acceptable levels. Non-destructive attenuation mechanisms include recharge and dispersion, and adsorption. The rest of the attenuation mechanisms are destructive to the I contaminants. All of these processes are naturally occurring. Natural attenuation is effective generally when contaminant concentrations are low, the contaminants have been in place for extended periods, and contaminant concentrations are steady or decreasing over time. Costs for I natural attenuation are low since it is naturally occurring and the only costs associated with it are related to monitoring activities. Once monitoring activities cease, natural attenuation becomes a no­ I cost option. Natural attenuation will be retained for consideration in developing corrective action alternatives. I 4.8.2.5 Groundwater Discharge Actions

Publicly/Privately-Owned Treatment Work (POTW) I

If groundwater extraction is required, POTW discharge would be implemented for groundwater in conjunction with extraction and, possibly, treatment. Extracted or treated groundwater may be I discharged to a POTW including the on-site WWTF via existing or new sewers or force main. Pretreatment may be required before discharge to the POTW. Discharge to a POTW will be retained for consideration in developing corrective action alternatives. I Sulface Water I If groundwater extraction is required, discharge to surface water would be implemented for groundwater in conjunction with extraction and treatment. Discharge to surface water involves the I piping of treated groundwater to an outfall at a surface water body such as the La Crosse River or a tributary to it. The relative capital cost is distance-dependent, and thus would be low to moderate I

D:IF1MCCOYIIPDCMS/L'>EC170N.4 4-12 March 1996 I I Fort McCoy Draft Co"ective Measures Study Report

I at FTBP2, while O&M costs are relatively low. Discharge to surface water will be retained for consideration in developing corrective action alternatives.

I 4.9 CORRECTIVE MEASURES ALTERNATIVES I 4.9.1 Introduction In this section, the applicable corrective action technologies identified in Section 4.8 for FTBP2 I groundwater are further evaluated and assembled into corrective action alternatives. Assembling suitable corrective action alternatives was an iterative process that systematically I combined the retained technologies into alternatives that meet the corrective action objectives (see Sections 4.7.6 and 4.7.7) and are the most practicable for site-specific conditions. The first step of the process consisted of evaluating all pertinent combinations of retained technologies. The I preliminary assemblage of alternatives was further evaluated to develop alternatives that were most suitable for FTBP2 considering the interaction of the selected technologies and site-specific conditions. Based on this secondary evaluation, the most suitable corrective action alternatives were I recommended to be carried forward in the CMS. I 4.9.2 Site-Specific Factors Affecting Development of Alternatives The following factors related to FTBP2 were considered the most critical in developing corrective I action alternatives: • The former bum pit contents, liner, and surrounding contaminated soil were removed in 1994 I and disposed. There were no unacceptable health risks identified for soil or groundwater sampled outside the bermed area during the RFI, even considering the unlikely residential I scenano. • Current and probable future use of the site is a part of the military airport buffer zone area I (currently undeveloped land). • There are no current nor anticipated groundwater receptors downgradient of the site.

I • NR 812.08 prohibits the installation of new water supply wells within 250 feet of a lagoon (FTBP2 would be considered an impoundment/lagoon).

I • Since the site is relatively flat, there is little potential for soil erosion. Also, due to the I permeable soil, rainfall tends to infiltrate rather than drain off the site. • The groundwater table is approximately 10 feet below ground surface.

I • As discussed in Section 4.5, contaminants detected in groundwater at levels exceeding the PAL were arsenic, barium, chromium, lead, mercury, nitrate/nitrite, chloromethane, PCE and TCE. I

I D:IFJMCCOYJIPIXMSJISEC170N.4 4-13 March 1996 Fort McCoy I Draft Co"ective Measures Study Report Based on these factors, it is recommended that the two corrective action alternatives identified and I discussed below be carried forward for evaluation in Section 4.9.3.

4.9.3 Description and Evaluation of Corrective Action Alternatives I 4.9.3.1 Introduction I The following sections describe the two corrective action alternatives proposed for consideration and present an evaluation of the alternatives based on technical, environmental, human health, and institutional criteria as required by Fort McCoy's RCRA Part B Permit. Table 4-3 identifies the I technologies in each of the two alternatives.

4.9.3.2 Corrective Action Alternative 1 I Alternative 1 I Access, Land, and Groundwater Use Restrictions, Natural Attenuation, I Groundwater Monitoring

Alternative 1 consists of access, land and groundwater use restrictions; natural attenuation of low­ I level groundwater contamination; and groundwater monitoring. These components are described below: I • Restrictive covenants would be placed on deeds to the FTBP2 property to restrict land and groundwater use at FTBP2. I • Low and sporadic detections of COCs in groundwater would be reduced to acceptable levels over time by natural attenuation through volatilization, biodegradation, adsorption and other I physical and chemical reactions within the subsurface environment.

• Groundwater monitoring would consist of semi-annual sampling and analysis of three existing I groundwater monitoring wells (1 upgradient and 2 downgradient) located adjacent to FTBP2. The groundwater monitoring well locations are shown on Figure 2-2. Monitoring well OW-120 is proposed to be removed from the monitoring program since it is located sidegradient of the I former fire pit. Observation wells (OWs) are screened across the water table.

Screened Interval I Monitorin~ Well (feet below fUound surface.)

OW-119 (upgradient) 8-18 I OW-118 10-20 OW-130 9-19 I I D:IF1MCCOYJIPDCMSJ'SECTION.4 4-14 March 1996 I I Fort McCoy Draft Corrective Measures Study Report

I TABLE4-3

CORRECTIVE MEASURES ALTERNATIVES TECHNOLOGIES I FIRE TRAINING BURN PIT NO. 2 I FORT MCCOY, WISCONSIN Alternative #1 Alternative #2

.. -.· .·· ... ·.. ··.·.··.· ·.·. I snurc:~ < .. I I Use Restrictions X X Natural Attenuation X X I Monitoring X X Extraction and Treatment X I I I I I I I I I I

I D:IF1MCCOYJIPOCMSI\TAB4-3. March 1996 ·I Fort McCoy Draft Co"ective Measures Study Report

I Compounds which equaled or exceeded their PALs (VOCs, nitrate/nitrite, and metals) during previous monitoring events in downgrad.ient monitoring wells, as shown in Table 4-1, will be I analyzed for during groundwater monitoring. Effectiveness

I FTBP2 is located within Fort McCoy's military airport buffer zone area and is expected to remain the property of the U.S. Army and continue to have associated effective access restrictions.

I Land and groundwater use restrictions will be effective, as F1BP2 is expected to remain the property of the U.S. Army. IfFTBP2 does not remain the property of the U.S. Army, the effectiveness of I deed restrictions will depend on continued enforcement and could be subject to changes in political jurisdiction and legal interpretation. NR 812.08 would supplement groundwater use restrictions by I prohibiting the installation of new water supply wells within 250 feet of FTBP2. Given that the source material has been removed during the 1994 removal action, groundwater contaminant concentrations should decrease over time through natural attenuation. Groundwater I monitoring would be used to measure the effects of source material removal on groundwater contaminant concentrations at FTBP2. Semi-annual groundwater sampling and analysis is a proven, I effective means of monitoring groundwater quality. lmplementability and Reliability

I Based on the site conditions summarized in Section 4.9.2, access, land, and groundwater use restrictions and natural attenuation in conjunction with groundwater monitoring would be reliable I and are readily implementable at FTBP2. Operation and Maintenance I . Semi-annual groundwater monitoring would be the only Alternative 1 opemtional requirement. The operation period for long-term groundwater monitoring will be dependent on the time needed to I achieve acceptable levels for COCs. For cost-estimating purposes, this is estimated to be 3 years.

Monitoring wells may require periodic well screen cleaning and other minor maintenance. It is I anticipated that the useful life of the monitoring wells would be at least 15 years. I Safety Safety of nearby residents, environments and site workers with regard to physical hazards during implementation would be addressed by provisions in the construction contractor's SSHP. Hazards I would be minimal since groundwater monitoring would be the only activities conducted on-site for I Alternative 1. I

March 1996 I D:IFTMCCOYJIPOCMSJ~ON.4 4-15 Fort McCoy I Draft Co"ective Measures Study Report

Environmental Evaluation I

Implementation of Alternative 1 components would not adversely impact environmentally sensitive areas. I

An ecological field assessment (SEC Donohue, November 1994) of FTBP2 concluded that present and future ecological communities could be adversely effected by existing conditions at FTBP2 and I that the exposure pathways of concern are ingestion of source material by burrowing animals and ingestion of contaminated water that pools in the pit by animals. The 1994 interim removal action has mitigated these exposure pathways. I Human Health Evaluation I Land use as a military airport buffer zone area and access, land use and groundwater use restrictions would prevent residential development at FTBP2. Therefore, the most likely human health risk I exposure scenario for FTBP2 is that of ingestion of and direct contact with surface soil by a trespasser. The human health assessment concluded that FTBP2 trespassers would not be exposed to excess health risks under site conditions prior to the 1994 removal action. The human health I assessment also indicated that residents would not be exposed to excess health risks under a residential scenario. The human health assessment did not evaluate risk associated with the source material, as it was assumed that these risks would be mitigated by the 1994 removal action. I There are no current nor anticipated groundwater receptors downgradient ofFTBP2. I Institutional Evaluation

Institutional needs for Alternative 1 would include enforcing existing site access restrictions, I enforcing land use restrictions and performing routine groundwater monitoring. I The design and implementation schedule for Alternative 1 components should not be significantly effected by Federal, state and local environmental and public health standards, regulations, guidance, · advisories, ordinances or community relations. I Cost Evaluation I The cost for Alternative 1 includes operation and maintenance costs associated with routine groundwater monitoring and maintenance. It is assumed that costs for recording deed restrictions· would be negligible. The estimated conceptual present worth O&M cost for Alternative 1 is $85,000 I as presented in Table 4-4. Cost estimate back-up information is presented in Appendix A to this CMSR. I

I D:IF7MCCOYIIPDCMSIISEC770N.4 4-16 March 1996 I I Fort McCoy Draft Corrective Measures Study Report

I TABLE4-4 I ALTERNATIVE 1 O&M COST ESTIMATE FIRE TRAINING BURN PIT NO. 2 I FORT MCCOY, WISCONSIN O&Mitem Quantity Unit Unit Cost Total Cost I Groundwater Monitoring (3 yrs): Groundwater Sampling 1(I) YR $23,000 $23,000 I and Analysis Site Inspection and Maintenance (3 yrs): I Inspection and 1 YR $1,000 $1,000 Maintenance I Groundwater Monitoring and Site Inspection and Maintenance $24,000 Subtotal I Scope Contingency (15%) $4,000 Subtotal $28,000 I Administration (10%) $3,000 Total Annual O&M Cost $31,000 I Total Present Worth ofO&M $85.000 I NOTES: (I) Two sampling events per year at 3 wells. Cost assumptions are presented in Appendix A to CMSR. I Present Worth Factor: i = 5%; 3 years= 2.723 I I I I I

I D:IF7MCCOYJIPDCMSJ\TAB4-4. March 1996 I Fort McCoy Draft Corrective Measures Study Report

I 4.9.3.3 Corrective Action Alternative 2 I Alternative 2 Access, Land, and Groundwater Use Restrictions, I Groundwater Extraction and Treatment, Natural Attenuation, I Groundwater Monitoring Alternative 2 consists of access, land and groundwater use restrictions, groundwater extraction and treatment; natural attenuation of residual low-level groundwater contamination; and groundwater I monitoring.

• Restrictive covenants would be placed on deeds to the FTBP2 property to restrict land and I groundwater use at FTBP2.

• If required, groundwater extraction using three extraction wells would be used to collect I groundwater at the downgradient edge ofFTBP2. The collected groundwater (approximately 15 gpm) would then be treated ex-situ using air stripping and cqemical precipitation with discharge either to the on-site WWTF or to surface water. The treatment units would be housed I in a building at or adjacent to FTBP2. The conceptual location of the extraction wells and treatment building are shown of Figure 4-4. The actual locations would be determined during I design activities. • Residual concentrations of COCs in groundwater would be reduced to acceptable levels over I time by natural attenuation through volatilization, biodegradation, adsorption and other physical and chemical reactions within the subsurface environment.

I • Groundwater monitoring would consist of semi-annual sampling and analysis of three existing groundwater monitoring wells (1 upgradient and 2 downgradient) located adjacent to FTBP2. The groundwater monitoring well locations are shown on Figure 2-2. · Monitoring well OW-120 I is proposed to be removed from the monitoring program since it is located sidegradient of the former fire pit. Observation wells (OWs) are screened across the water table.

I Screened Interval I Monitorini Well (feet below ~Uound surfacw OW-119 (upgradient) 8-18 OW-118 10-20 I OW-130 9-19 Compounds which equaled or exceeded their PALs (VOCs, nitrate/nitrite, and metals) during I previous sampling events in downgradient monitoring wells, as shown in Table 4-1, will be analyzed for during groundwater monitoring. I

I D:IFTMCCOYJIPDCMSJISEC170N,4 4-17 March 1996 Fort McCoy I Draft Co"ective Measures Study Report Effectiveness I

FTBP2 is located within Fort McCoy's military airport buffer zone area and is expected to remain the property of the U.S. Army and continue to have associated effective access restrictions. I

Land and groundwater use restrictions will be effective, as FTBP2 is expected to remain the property of the U.S. Army. IfFTBP2 does not remain the property of the U.S. Army, the effectiveness of I deed restrictions will depend on continued enforcement and could be subject to changes in political jurisdiction and legal interpretation. NR 812.08 would supplement groundwater use restrictions by. prohibiting the installation of new water supply wells within 250 feet of FTBP2. I Groundwater extraction wells would be used to collect the impacted groundwater downgradient of I FTBP2. The collected groundwater would be treated using air stripping and chemical precipitation. Given the sporadic nature of low-level PAL exceedances, the effectiveness of the treatment units may be reduced due to the sporadic nature of low concentration influent. Residual groundwater I contaminant concentrations would decrease over time through natural attenuation. Groundwater monitoring would be used to measure the effects of source material removal and groundwater extraction and treatment, and natural attenuation on groundwater contaminant concentrations at I FTBP2. Semi-annual groundwater sampling and analysis is a proven, effective means of monitoring groundwater quality. I Implementability and Reliability

Based on the site conditions summarized in Section 4.9.2, access, land, and groundwater use I restrictions, groundwater extraction and treatment, and natural attenuation in conjunction with groundwater monitoring would be reliable and are readily implementable at FTBP2. ·Construction of Alternative 2 should be able to be completed in one construction season. I Operation and Maintenance I Semi-annual groundwater monitoring and operation of the groundwater extraction and treatment system would be the Alternative 2 operational requirements. The operation period for long-term I groundwater monitoring will be dependent on the time needed to achieve acceptable levels for COCs. For cost estimating purposes, it is assumed the groundwater extraction and treatment system will be operated for three years with two additional years of groundwater monitoring to verify I effectiveness.

Monitoring and extraction wells may require periodic well screen cleaning and other minor I maintenance. It is anticipated that the useful life of the wells would be at least 15 years.

Safety I

Safety of nearby residents, environments and site workers with regard to physical hazards during implementation would be addressed by provisions in the construction contractor's SSHP. Potential I site safety hazards during construction could include, but not be limited to, heavy equipment I D:IFIMCCOYIIPDCMSJISEC110N.4 4-18 March 1996 I I ~r------~ I I .,-·...., I

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;::u···· .!:..FhJVE Mt· /-..~. SF.'\ !.F.:VE"~ I x-x- CONCEPTUAL LOCATION OF FENCE CONCEPTUAL LOCATION OF EXTRACTION WELL NOTES: !.GROUNDWATER TABLE ELEVATIONS CONCEPTUAL LOCATION OF TREATMENT BUILDING AND CONTOURS ARE DERIVED FROM 0' IS' 30' 60' I THE RFI PHASE 3 INVESTIGATION. SCALE II"'Si I MAR. 1996 FIGURE 4-4 18903 FIRE TRAINING BURN PIT 2 .._..ENVIRONMENT & CONCEPTUAL GROUNDWATER EXTRACTION AND TREATMENT SYSTEM LAYOUT I I~U~I INFRASfRUCTURE DRAFT CORRECTIVE MEASURES STUDY I FORT McCOY, WISCONSIN I Fort McCoy Draft Corrective Measures Study Report

I operation, chemical exposure, slip/trip/fall hazards, heat/cold stress, wildlife (ticks, snakes, etc.), and vegetation (poison ivy, etc.). Temporary environmental controls (dust suppression, etc.) and ambient air monitoring would be implemented as needed during installation of the groundwater extraction I wells and construction of the groundwater treatment plant. I Environmental Evaluation Implementation of Alternative 2 components would not adversely impact environmentally sensitive I areas. An ecological field assessment (SEC Donohue, November 1994) ofFTBP2 concluded that present I and future ecological communities could be adversely effected by existing conditions at FTBP2 and that the exposure pathways of concern are ingestion of source material by burrowing animals and ingestion of contaminated water that pools in the pit by animals. The 1994 removal action has I mitigated these exposure pathways. I Human Health Evaluation Land use as a military airport buffer zone area and access, land use and groundwater use restrictions would prevent residential development at FTBP2. Therefore, the most likely human health risk I exposure scenario for FTBP2 is that of ingestion of and direct contact with surface soil by a trespasser. The human health assessment concluded that FTBP2 trespassers would not be exposed to excess health risks under current site conditions. The human health assessment also indicated that I residents would not be exposed to excess health risks under a residential scenario. The human health assessment did not evaluate risk associated with the source material, as it was assumed that these I risks would be mitigated by the 1994 removal action. I There are no current nor anticipated groundwater receptors downgradient of FTBP2. Institutional Evaluation \

I Institutional needs for Alternative 2 would include enforcing existing site access restrictions, enforcing land use restrictions and performing routine groundwater monitoring.

I The design and implementation schedule for the Alternative 2 component of groundwater extraction and treatment may be impacted by Federal, state, and local permitting requirements.

I • It is anticipated that implementation of Alternative 2 will not require a local construction permit.

• It is anticipated that operation of the air stripper will not require a Wisconsin Air Permit. The I air stripper will be operated to meet NR 419 and NR 445 emissions criteria. I • If the extracted groundwater is treated and discharged to the surface, it is anticipated that a WPDES permit will be required. I I D:IFTMCCOY JIPDCMSJISEC110N.4 4-19 March 1996 Fort McCoy I . Draft Co"ective Measures Study Report

• Groundwater treatment system residuals (sludge) must be disposed in accordance with I applicable regulations.

Cost Evaluation I

The cost for Alternative 2 includes capital costs to construct the groundwater extraction and treatment system and annual operation and maintenance costs associated with the groundwater I extraction and treatment system and routine groundwater monitoring. Costs for recording deed restrictions are assumed to be negligible. I The estimated conceptual capital cost for Alternative 2 is $613,000 as presented in Table 4-5. The estimated conceptual present worth O&M cost for Alternative 2 is $431,000 as presented in I Table 4-6.

A summary of the cost estimates for both alternatives is presented in Table 4-7. I

4.9.4 Recommended Alternative

Based on the site-specific factors identified in Section 4.9.2, the alternatives evaluation performed in Section 4.9.3, and the comparison presented in Table 4-8, Alternative 1 is recommended for FTBP2. Alternative 1 consists of access, land and groundwater use restrictions; natural attenuation I oflow-level groundwater contamination; and groundwater monitoring.

Alternative 1 addresses the corrective action objectives for FTBP2 by reducing potential for I contaminant migration to and in groundwater, limiting groundwater use, and reducing groundwater concentrations for COCs to acceptable levels. Given the 1994 removal action and the monitoring I results in Table 4-1, it is anticipated that PALs will be achieved on a consistent basis Within approximately three years. If PALs are not consistently achieved, additional semi-annual groundwater monitoring will be required until PALs are consistently achieved. Alternative 1 would I be technically effective, reliable, and implementable at FTBP2 and would provide short-term and long-term protection of human health and the environment. I As presented in Table 4-8, Alternative 1 adequately addresses the human health, environmental; and institutional control concerns, is readily implementable, provides long-term reliability, and is less costly as compared to Alternative 2. I I I I I

D:IF1MCCOYIIPDCMSIISEC110N.4 4-20 March 1996 I I Fort McCoy Draft Corrective Measures Study Report

I TABLE4-5 I ALTERNATIVE 2 CAPITAL COST .ESTIMATE FIRE TRAINING BURN PIT NO. 2 I FORT MCCOY, WISCONSIN

I Capital Cost Item Quantity Unit Unit Cost Item Cost Construction: I Groundwater Extraction 1 LS $40,000 $40,000 Groundwater Treatment:

I Air Stripper/Chemical 1 LS $150,000 $150,000 Precipitation I Discharge 1 LS $92,000 $92,000 Groundwater Treatment Subtotal $242,000

I Construction Subtotal $282,000 I Construction Global Markups: Scope Contingency (15%) $43,000 I Subtotal $325,000 Health and Safety (30%) $98,000 I Subtotal $423,000 Permitting (5%) $21,000 I Engineering (20%) $85,000 Construction-Related Services (15%) $63,000 I Prime Fixed Fee (5%) $21,000 I Total Capital Cost St!1~ 1 QQO NOTES:

I Cost assumptions are presented in Appendix A to CMSR. I I

March 1996 I D:~COY/IPOCMS/\TAB4-5. I Fort McCoy Draft Corrective Measures Study Report

I TABLE4-6

ALTERNATIVE 2 O&M COST ESTIMATE I FIRE TRAINING BURN PIT NO. 2 FORT MCCOY, WISCONSIN I O&Mitem Quantity Unit Unit Cost Total Cost I Groundwater Monitoring (5 yrs): Groundwater Sampling and 1(I) YR $23,000 $23,000 I Analysis Site Inspection and Maintenance (5 yrs): Inspection and 1 YR $1,000 $1,000 I Maintenance I Subtotal $24,000 Scope Contingency (15%) $4,000 I Subtotal $28,000 Administration (10%) $3,000 Groundwater Monitoring and Site Inspection and Maintenance $31,000 I Subtotal I Groundwater Extraction and Treatment (3 yrs): Groundwater Extraction 1 YR $4,000 $4,000 I Groundwater Treatment 1 YR $82,000 $82,000 Subtotal $86,000 I Scope Contingency (15%) $13,000 Subtotal $99,000 I Administration (1 0%) $10,000 I Groundwater Extraction and Treatment Subtotal $109,000 Total Annual O&M Cost $140,000 I Total Present Worth ofO&M $431.000 NOTES:

I <1> Includes two sampling events per year at 3 wells. Cost assumptions are presented in Appendix A to CMSR. I Present Worth Factors: (1) i = 5%; 3 years= 2.723; (2) i = 5%; 5 years= 4.329

I D:IF1MCCOYJIPDCMSI\TAB4-6. March 1996 I Fort McCoy Draft Corrective Measures Study Report

I TABLE4-7

CORRECTIVE MEASURES ALTERNATIVES COST ESTIMATE SUMMARY I FIRE TRAINING BURN PIT NO. 2 I FORT MCCOY, WISCONSIN I Alternative #1 Alternative #2 I I Use Restrictions X X Natural Attenuation X X I Monitoring X X Extraction and Treatment X I Construction $0 $613,000 I AnnualO&M $31,000 (GW MON) $31,000 (GW MON) $109,000 (GW E&T) I Present Worth O&M $85,000 (3 yr) $134,000 (5 yr) $297,000 (3 yr) I Total Cost $85,000 $1,044,000 I I I I I I

I D:IFTMCCOY/IPDCMS/\TAB4-7. March 1996 I Fort McCoy Draft Co"ective Measures Study Report

I TABLE4-8

CORRECTIVE MEASURES ALTERNATIVES COMPARISON I FIRE TRAINING BURN PIT NO. 2 FORT MCCOY, WISCONSIN

I Evaluation Criteria Alt#l Alt#2

Effectiveness (performs intended Should be effective Should be effective I function) Implementability and Reliability lmplementable and reliable Implementable and reliable (can be done and will it last/ I perform over the long-term) Operation and Maintenance Low Medium I (O&M)Costs Safety Concerns During Low Low Construction/ Implementation I Environmental Concerns Adequately addresses concerns in Adequately addresses concerns in Section 4.7.5 Section 4.7.5

Human Health Concerns Adequately addresses concerns in Adequately addresses concerns in I Section 4.7 .5 Section 4.7.5

Institutional Concerns Addresses institutional control Addresses institutional control needs I needs identified in Section 4.9.2 identified in Section 4.9.2 Cost $85,000 $1,044,000 I I I I I I I I

I D:IF7MCCOYIIPDCMSI\TAB4..lJ. March 1996 I Fort McCoy Draft Corrective Measures Study Report

I 5.0 CLOSED .LANDFILL 4

I 5.1 DESCRIPTION OF CL4

Closed Landfill4 (CL4) is located in the NW 1/4 of the SW 1/4 of Section 13, Tl8N, R3W, Monroe I County, Wisconsin, adjacent to and east of the Equipment Concentration Site (ECS) and Building 3050 (Figure 5-1). The landfill covers an area of approximately 6 acres and is located I approximately 2,500 feet east of Squaw Creek. I 5.2 WASTE MANAGEMENT ACTIVITIES A Pollution Abatement Survey conducted by the U.S. Army Engineer District (USACE, 1979) reported that CL4 was used from 1951 to 1960. The landfill was used primarily for disposal of food I stuffs, cans, and general kitchen refuse. Broken ceramic cups and plates, broken glass bottles, and rusted cans were observed sparsely distributed over the surface area of the landfill.

I 5.3 PHYSICAL SITE CHARACTERISTICS I 5.3.1 Site Setting CL4 consists of an area of disturbed land as shown on Figure 5-2. To the north of the site predominantly jack pine woodland exists. The northern portions of the Fort's cantonment area I containing several old buildings are several hundred yards south of CL4.

·The Consolidated Maintenance Facility (CMF) has been constructed in the immediate vicinity of I CL4, and an area which includes all of CL4 has been developed into a military vehicle parking lot. The surface of the parking lot is compacted crushed rock. An old asphalt road borders the east edge I of the site. I 5.3.2 Topography and Drainage The land surface of CL4 is relatively flat to gently undulating as shown on Figure 5-2. It slopes towards Squaw Creek to the west at a topographic gradient of 0.009 :ft/ft from a maximum elevation I of905 feet MSL at the east to 896 feet MSL at the west. Mounded areas trending north-south locally modify the overall slope. The SWMU is sparsely vegetated with highly permeable sandy soil landfill cover or sandy native soil exposed at the ground surface. There is little runoff from CL4 due I to the relatively flat land surface and high surface soil infiltration rate. As indicated in Section 5.3 .I I above, the CL4 area has been developed into a parking lot. 5.3.3 Surficial Soils I Surficial soils at CL4 consist of Tarr series soils. The Tarr series is generally found on stream terraces and valley slopes. The natural soils are likely buried or excavated in places where I landfilling has occurred.

I D:IFTMCCOYIIPOCMSJ'SEC110N.$ 5-1 March 1996 I N I I I I I PEST100E DISPOSAL SITE I I

CLOSED Q.OSED LANDFILl. 2 I LANDFILL 4 I CLOSED LANDFILl. 3 I I I I I I --. 0___ 1/2 2 MILES SCALE SOURCE: WISCONSIN DEPARTMENT OF TRANSPORTATION I MAR. 1996 FIGURE 5-I 18903 CLOSED LANDFILL 4 I .._..ENVIRONMENT & LOCATION MAP I~U~I INFRASTRUCTURE DRAFT CORRECTIVE MEASURES STUDY I FORT McCOY, WISCONSIN I ~·r------. •g I + +1'42110GM

I ...... -cr .c, I ..... • 3: 0>.., iU I ::0 • 10 C1l

-p:l I -~ -U1 + I

I I + I

I N ---902- TOPOGRAPHIC CONTOUR 880---- GROUNDWATER CONTOUR ----.J·- GROUNDWATER FLOW DIRECTION NOTES:

I I. GROUNDWATER TABLE ELEVATIONS AND CONTOURS ------· ESTit.tATED POTENTIAL LIMITS OF WASTE ARE DERIVED FROM THE PHASE 2 INVESTIGATION.

2. LIMT!S OF WASTE DETERMINED FROM GEOPHYSfCAL SURVEY QUADRATURE CONTOUR MAP ASSUMING EL =880.19 GROUNDWATER MONITORING WELL WASTE IS INDICATED BY AREAS HAVING WITH GROUNDWATER ELEVATION CONDUCTIVITY OF 5 ,_..HO/lo4 OR MORE OR OF -3 .OWI09 IN FEET ABOVE SEA LEVEL I MMHO/M OR LESS. 3. LIMITS OF WASTE ARE ESTIMATED OUTSIDE OF THE TELEPHONE POLE GEOPHYSICAL SURVEY AREA. • 0' 80' 160' I SCALE ---- I MAR. 1996 FIGURE 5-2 18903 CLOSED LANDFILL 4 .....ENVIRONMENT & GROUNDWATER MONITORING WELL LOCATIONS I AND WATER TABLE MAP I~U~I INFRASTRUCfURE DRAFT CORRECTIVE MEASURES STUDY I FORT McCOY, WISCONSIN ~~~~~~~~~~~~~-~~~~~ Fort McCoy Draft Corrective Measures Study Report

TABLE 5-l

GROUNDWATER QUALITY SUMMARY CLOSED LANDFILL NO.4 FORT MCCOY, WISCONSIN

Well107111 Well108 Well109 Analytes Detected at Levels Exceeding NR 140 Public Sampling Event Sampling Event Sampling Event Health Standards 1 2 3 . 4 5 6 1 2 3 4 5 6 1 2 3 4 5 6 PAL ES Tetrachloroethene -- lJ NS ------l.OJ NS ------lJ NS ------0.5 5.0 Bis(2-ethylhexyl)phthalate 2BJ -- NS -- -- 3BJ -- -- NS -- -- 2BJ -- -- NS -- -- 2BJ 0.3 3.0 Cadmium -- -- NS ------6.0 NS ------NS ------0.5 5.0 Chromium -- -- NS 20.0 ------NS -- 38 95 -- -- NS ------10.0 100.0 Nitrate + Nitrite -- -- NS 8,300 6,600 12,100 6, 700 4,660 NS 4,800 5,900 3,800 5,130 8,350NS 10,300 7,800 7,200 2,000 10,000 Mercury NS 1.2B ------NS 1.9B ------NS l.lB -- -- 0.2 2.0 Antimony -- -- NS ------48 -- NS ------60 -- NS ------1.2 6.0 Nickel -- -- NS ------NS -- 34 76 -- -- NS ------20 100 Arsenic -- -- NS ------NS -- -- 22 -- -- NS ------5 50 NOTES:

All values in ug/1. ES Enforcement Standard NS Well not sampled during Phase 3 ofRFI. PAL Preventive Action Limit (I) Well 107 is the upgradient well. Sampling Event 1 - Phase 1 RFI, April - May 1992 J Estimated value. Sampling Event 2 - Phase 2 RFI, October- November 1992 . B Analyte found in associated blank. Source of mercury was acid used to preserve Sampling Event 3 - Phase 3 RFI, May - August 1993 samples analyzed for metals in Event 4. Sampling Event 4- Interim Monitoring, July 27, 1994 -- Analyte not detected at level above PAL. Sampling Event 5 - Interim Monitoring, June 8, 1995 Sampling Event 6 - Interim Monitoring, December 5, 1995

D:IFTMCCOYJIPDCMSJ\TABS-1. March 1996 I Fort McCoy Draft Co"ective Measures Study Report I 5.6 CONTAMINANT FATE AND TRANSPORT

Soils at CL4 are sandy, with rapid permeability. Sands typically exhibit low cation exchange I capacity, and chemical reduction/oxidation factors are high. Such characteristics are conducive to the dissolution and reprecipitation of buried metals. Given the very low concentrations of organic I compounds detected, it may be prone to degradation by hydrolysis, or from biological activity. 5.7 DEVELOPMENT OF CORRECTIVE ACTION OBJECTIVES

I 5.7.1 Introduction

The purpose of this section is to identify potentially applicable soil and groundwater contaminant I levels for the COCs identified in the RFI Report for CL4. These soil and groundwater contaminant limits are based on public health and environmental criteria, information gathered during the RFI, and applicable WDNR and USEPA regulations. These soil and groundwater contaminant limits will I be considered during the identification and development of appropriate corrective action I technologies and alternatives. The COCs identified for CL4 are:

, I Chemical of Potential Concern

Bis(2-ethyl hexyl) phthalate (groundwater) I Tetrachloroethene (PCE) (groundwater) Antimony (groundwater) Arsenic (groundwater) I Cadmium (groundwater) Chromium (groundwater) Nickel (groundwater) I Nitrate+Nitrite (groundwater) I The above compounds were selected as COCs based on one of the following: • COC equals or exceeds an NR 140 PAL in groundwater samples collected from a downgradient I monitoring well.

• COC is a primary contributor to calculated human health risks associated with groundwater I exposure pathways under hypothetical future residential use risk scenario at CL4.

• COC is a primary contributor to calculated human health risks associated with soil exposure I pathways under hypothetical future residential use risk scenario at CL4. I I I D:IFIMCCOY/IPOCMSIISEC170N.5 5-3 March 1996 Fort McCoy I Draft Co"ective Measures Study Report (1 in 1,000,000) using information on the relationship between dose and response." In addition, I USEPA's Office of Solid Waste and Emergency Response (OSWER) Directive No. 9355.0-49FS (Presumptive Remedy for CERCLA Municipal Landfill Sites) (see Appendix D), it is stated "that based on site-specific conditions, an active response is not required if groundwater contaminant I concentrations exceed chemical-specific standards but the site risk is within the Agency's acceptable risk range (1 0-4 to 10-6)." Therefore, consistent with Sections 5.1 and 5.2 of the approved human health risk assessment, for the purpose of discussion in the CMS Report, excess risk is defined as I total excess cancer risk levels to any population exceeding 10-4 and noncarcinogenic hazard index (HI) greater than 1E+OO (1.0). I This identification of COCs which contribute to excess risk based on the hypothetical scenario of residents living at CL4 is presented since this scenario was one of the criteria used to include a SWMU in the CMS. This residential scenario assumes both daily contact and consumption of soil I and groundwater at the site 350 days per year for a period of30 years. However, it should be noted that there are several institutional controls that would prevent residential development on CL4. I These controls include: • NR 812.08 prohibits the installation of new water supply wells within 1,200 feet of a solid waste I site.

• CL4 is expected to remain the property ofthe U.S. Army and continue to have associated access I restrictions. CL4 has been incorporated into a crushed-rock paved parking lot to be used for the storage of military vehicles. I • IfCL4 does not remain the property of the U.S. Army, restrictive covenants could be written into a site property deed to notify a prospective purchaser of the location and source of solid­ waste/contamination and that groundwater use must be restricted. I

Therefore, the residential scenario will not be considered applicable to this SWMU. The most likely exposure scenario would be that of a worker at the vehicle parking lot. This scenario assumes I ingestion of and contact with soil at a frequency much less than the residential scenario. Contact with or ingestion of groundwater does not apply to a worker. Since there was no excess health risk I determined in the RFI for the hypothetical residential scenario based on exposure to soil, there is no excess health risk for the worker given a less frequent exposure to the site compared to a · hypothetical resident. Trespassers at the SWMU would also not be exposed to excess health risks. I

Field assessment of ecological communities indicate that most communities were removed at CL4 as this site during construction of the Consolidated Maintenance Facility. In addition, it is unlikely I that groundwater contaminants will enter the surface water system (Squaw Creek) due to the distance of approximately 2,500 feet between CL4 and the creek. I I I D:IF1ACCOYIIPOCMSI1SECTION.5 5-6 March 1996 I I Fort McCoy ,, Draft Co"ective Measures Study Report 5.7.6 Soil Objectives

No soil cleanup objectives have been developed for CL4 since no unacceptable human health or I environmental risks associated with soil have been identified. It should be noted, however, that no sampling of soiVsource material was performed at CL4 during the RFI.

I 5.7.7 Groundwater Objectives I Site-specific groundwater objectives identified for CL4 were developed from reviewing the Federal MCLs, Wisconsin MCLs, and Wisconsin groundwater standards (PALs and ESs).

I The following paragraph is based on excerpts from 57FR31780 and 31797 (pages 31780 and 31797 ofthe July 17, 1992, Federal Register): The Safe Drinking Water Act (SDWA) requires USEPA to ,, publish maximum contaminant level goals (MCLGs) for contaminants which may have any adverse effect on the health of persons and which are known or anticipated to occur in public water systems. MCLGs are to be set at a level at which no known or anticipated adverse effects on the health of persons occur and which allows an adequate margin of safety. At the same time the USEPA I publishes a MCLG, it must also promulgate a National Primary Drinking Water Regulation which includes either 1) a MCL, or 2) a required treatment technique. An MCL must be set as close to the MCLG as feasible. Under the SDWA, "feasible" means "feasible with the use of the best I technology, treatment techniques, and other means which the Administrator finds, after examination for efficacy under field conditions and not solely under laboratory conditions (taking cost into consideration)." Other technology factors that are considered in determining the MCL include the I ability of laboratories to measure accurately and consistently the level of the contaminant with I available analytical methods. As presented in 5.7.2 and 5.7.3 above, ESs are generally equal to federal and Wisconsin MCLs. Since the ESs are generally the same as corresponding MC~s, they inherently represent the lowest I possible contaminant concentrations "technically and economically feasible" as required by NR 140.24(2). However, since WDNR interprets State of Wisconsin law to require that PALs be the goal of groundwater remediation, PALs are proposed as the appropriate groundwater objectives I which means corrective measures will be developed to attempt to reduce groundwater contaminant concentrations to levels less than the PAL.

I The selected groundwater objectives for the COCs are presented below. In addition, detections of concentrations of COCs in groundwater samples obtained from monitoring wells equal to or I exceeding the PAL are presented in Table 5-1.

,~ PAL Chemical of Potential Concern !YiLD

Bis(ethylhexyl) phthalate 0.6 I Tetrachloroethene (PCE) 0.5 Antimony 1.2 I Arsenic 5

I D:'IF1MCCOYJIPDCMSJISEC710N.S 5-7 March 1996 Fort McCoy I Draft Co"ective Measures Study Report

Cadmium. 0.5 I Chromium 10 Nickel 20 Nitrate+Nitrite 2,000 I

The COCs to be addressed in the following technologies and alternatives sections will be those COCs detected in groundwater at CL4 at levels equal to or exceeding the PAL in downgradient I monitoring wells. The exception is Bis(2-ethyl hexyl) phthalate which is a common laboratory contaminant. I 5.8 CORRECTIVE MEASURES TECHNOLOGIES

5.8.1 Introduction I In this section, applicable corrective action technologies are identified for contaminant somce I material, groundwater, and landfill gas based on an evaluation of contaminants detected. Medium­ specific corrective action objectives developed in Section 5. 7 were evaluated and appropriate general response actions were identified that satisfy the corrective action objectives. Potentially applicable I technologies were then identified for each general response action as listed in Table 5-2 and are discussed in Sections 5.8.2, 5.8.3, and 5.8.4. I Relevant site-specific conditions were considered in the identification of corrective action technologies to be retained for consideration in developing corrective action alternatives. Corrective action objectives were reviewed and applicable technologies were selected based on past experience I and verified performance information. The identified technologies that have proven effectiveness for the media and COCs and can be practically implemented, operated, and maintained given site-­ specific conditions, are identified as being retained for consideration in developing corrective action I alternatives. Table 5-2 identifies which technologies have been retained for consideration in developing the corrective action alternatives presented in Section 5.9. I 5.8.2 Identification of Applicable Source Material Teehnologies I 5.8.2.1 Source Material Institutional Actions Fencing I

A chain link fence (6 feet tall) with lockable gates could be constructed around the somce area to restrict site access and distmbance of somce material. Fencing would reduce the potential for I ingestion of or direct contact with somce material. The construction and maintenance costs for fencing are considered low in comparison to the other technologies evaluated. Fencing will be retained for consideration in developing corrective action alternatives. It should be noted that the I CL4 somce area is already located within a fenced and seemed military vehicle parking lot at the CMF. I I D:IFTMCCOYJIPDCMSJISEC170N.$ 5-8 March 1996 I I Fort McCoy Draft Corrective Measures Study Report

TABLE 5-2

CORRECTIVE ACTION OBJECTIVES, GENERAL RESPONSE ACTIONS AND CORRECTIVE MEASURES TECHNOLOGIES CLOSED LANDFILL 4 FORT MCCOY, WISCONSIN

Technologies General Response Corrective Measures Retained for Corrective Action Objectives Actions Technologies Considered Further Evaluation

Prevent access to source material. Erosion Control • Soil Cover/Parking Lot Yes I Institutional • Fencing Yes • Land Use Restrictions Yes Reduce potential for contaminant Removal . Excavation Yes Ol I migration from source material to 1 groundwater. Disposal . Off-site Landfill Yes< > I Containment • NR 504 Cover System No Treatment . In-situ Solidification/ Yes<1> Stabilization (S/S) I . Ex-situ SIS No<1> Reduce concentrations of COCs Institutional . Groundwater Use Yes in groundwater to levels below Restrictions I NR 140 PALs, and limit . Groundwater Monitoring Yes groundwater use.

Containment . Low Permeability Barrier No Ol I . Hydraulic Barrier Yes

Removal . Extraction Wells Yes I . Collection Trenches No Treatment . Biological Treatment NoO> I . Carbon Adsorption No Ol . Air Stripping . Yes Ol . Air Sparging/Soil Vapor No Ol Extraction I . Chemical Precipitation Yes<1> . Natural Attenuation Yes I Discharge • POTW Yes . Surface Water Yes Reduce potential for uncontrolled Landfill Gas . Passive Vents No I gas migration from landfill. Management System I NOTE: These technologies have additional information and illustrations provided in Appendix C in addition to the I descriptions presented in Sections 5.8.2, 5.8.3 and 5.8.4.

I D:'!FTMCCOYJIPOCMSJ\TAB5-2. March 1996 I Fort McCoy Draft Co"ective Measures Study Report

I Land Use Restrictions

Land use restrictions would be implemented to minimize the potential for human contact with source I material. Restrictive covenants could be placed on deeds to the CU property to limit the potential for land development, source material disturbance, and cover (if implemented) intrusions. Restrictive covenants, written into a site property deed, notify any potential purchaser of the property I that contaminated media remain on-site, and that the land use must be restricted. If enforced, deed restrictions would reduce the potential for the ingestion or direct contact with contaminated source material. It is anticipated that deed restrictions at CL4 would limit excavation. The effectiveness I of deed restrictions depends on continued enforcement. Deed restrictions are subject to changes in political jurisdiction, legal interpretation, and level of enforcement. Administration of land use I restrictions would be the only cost, but would remain perpetually. Land use restrictions will be retained for consideration in developing corrective action alternatives.

I 5.8.2.2 Source Material Removal Actions I Excavation Excavation could be required in conjunction with any above ground source material treatment or disposal actions. Excavation would involve removal of source material using standard I' excavation/construction equipment or special equipment adapted to minimize disturbances. Relative costs for excavation are low to high depending on excavated volume. Excavation will be retained I for consideration in developing corrective action alternatives. · 5.8.2.3 Source Material Disposal Actions

I Off-Site Landfill t Off-site landfilling would involve the transportation of excavated source material from the site to an appropriate licensed landfill able to accommodate the needed capacity, pending waste testing and WDNR approval per NR 722 for volumes exceeding 250 cubic yards. Disposal in an off-site landfill I, may also require pretreatment of the source material prior to acceptance by the landfill. The disposal of source material in an off-site licensed landfill is an effective means for controlling release of ,, contaminants to the environment. However, off-site disposal could result in additional liability for the Army if the off-site landfill becomes the source of problems in the future. Relative capital costs including transportation, testing and treatment/disposal fees are high. Off-site landfills will be I retained for consideration in developing corrective action alternatives. 5.8.2.4 Source Material Containment Actions

I NR 504 Cover System I The NR 504 cover system is the prescribed cover system by the WDNR solid waste regulations for solid waste sites. The cover system is characterized by a 2-foot thick, natural clay barrier layer I. compacted to a hydraulic conductivity of 1 x 1o·' em/sec. The clay layer is designed and constructed j D:II'7AK:COY /IPIXMSI\SEC710N.5 5-9 March 1996 Fort McCoy I Draft Corrective Measures Study Report to minimize the infiltration of precipitation and must be properly placed and_ protected to ensure long-term performance. The entire configuration of a NR 504 cover system for this site would include the following components, in ascending order: compacted natural clay layer, sand drainage layer, protective soil layer, vegetative layer, and vegetation. The NR 504 cover system has been implemented at many landfills and proven to reduce infiltration I into the landfill contents. The installation of this cover system does not require specialized equipment, but its construction is subject to a rigorous quality assurance/quality control (QA/QC) program. An NR 504 cover system is a moderate to high cost technology. The placement of an I NR 504 cover system on CL4 would prevent the use of the area as military vehicle parking lot. Therefore, the NR 504 cover system will not be retained for consideration in developing corrective action alternatives. I 5.8.2.5 Source Material Treatment Actions I In-Situ Solidification/Stabilization ,. Solidification/stabilization (SIS) reduces the mobility of hazardous substances and contaminants in the environment through both physical and chemical means. Unlike other remedial technologies, SIS seeks to trap or immobilize contaminants within their "host" mediwn (i.e., the soil, sand, and/or building materials that contain them), instead of removing them through chemical or physical I treatment. Leachability testing during laboratory treatability studies or pilot scale testing at the site is typically performed to measure the degree of immobilization of contaminants achieved by the S/S I treatment.

In-situ (in-place) S/S techniques typically use auger systems and injector head systems to apply S/S I treatment agents to in-situ wastes and soils. The augers are typically mounted vertically on crawler cranes and mix the waste/soil with the S/S treatment agents delivered to the augers by the injector head system. The S/S treatment agents are typically liquid based and delivered by pipes or hoses t to the augers from on-site mixing/storage tanks. See Figure 5-4 for a conceptual presentation of the in-situ S/S process. Due to the addition of S/S treatment agents, the resultant volume of treated material is larger by approximately 15 percent to 100 percent depending on the amount of S/S I treatment agent required to achieve satisfactory treatment. This volume increase is termed bulking and could result in an increase of surface elevations by several feet across a treated site. An estimate ,I of the amount of bulking cannot be made until treatability studies are performed in pre-design activities to determine the proper reagent/waste mix. Following treatment, a cover with vegetation is generally placed over the treated mass. I

SIS is used primarily to treat inorganic compounds. Relative capital costs are high given the need for specialized equipment, materials and procedures. Additional costs can also be incurred when the I physical nature of the waste (size, hardness, etc.) prevents adequate mixing, resulting in portions of the waste having to be excavated and disposed off-site. S/S techniques can be used alone or combined with other treatment and disposal methods to yield a product or material suitable for land I disposal or, in other cases, that can be applied to beneficial use. In-situ S/S will be retained for consideration in developing corrective action alternatives. .I

D:IFIMCCOYIIP/XMSI'SECUON.5 5-10 March 1996 I ~' - ../ .... - ...... } ~) .. - .. , ...... -: --

9E :z~ :ao 966l 'El ·JeH SOURCE: REMEDIATION TECHNOLOGIES SCREENING MATRIX AND REFERENCE GUIDE EPA/542/B-94/013 NTIS PB95-104782, OCTOBER 1994

~~ Emissions, ~es Dust Reagent andVOC ancVor ~~ Control Binder ~~ ~ ~ l> :0

lD n ~ 0 0 z ~ :o-n 'Injector ,,""'0:~>zrn --1(/)-j Head ,n-c ·II -4--Caisson ~~c-l l> , -i:o r - rTJ C> ~n Vl C ~~, ""''n::o o~Vl~rrn ;< (/) ~ ::e ~ __. rn (]1 -rn::oz ' ~l;i rn __. ~ 4~1 94P·2110 8/22/94 oc )> )> ~fg -i -i -(1)~- z rna ~7 TYPICAL AUGER/CAISSON AND REAGENTnNJECTOR.HEAD IN SITU Vlzz ~--~ . SOLIDIFICATIONISTABILIZATION SYSTEMS 0 0 -< ,

Ql lD 0 VI I Fort McCoy Draft Corrective Measures Study Report

I Ex-Situ Solidification/Stabilization

Similar to in-situ S/S, ex-situ S/S treated contaminants are physically bound or enclosed within a I stabilized mass (solidification), or chemical reactions are induced by the stabilizing agents to reduce the contaminants mobility (stabilization).

I With ex-situ S/S treatment, however, the waste material must first be excavated and sorted prior to treatment. Treatment components could consist of a waste staging/sorting area, a pug mill mixing I system that mixes the waste and stabilizing agents fed to it by conveyors or augers and a treated wast~ staging/sampling area. The staging, sorting and ex-situ S/S treatment would be performed in an area adjacent to CL4. In addition, following ex-situ S/S treatment, the treated waste would then I need to be disposed of either on-site or off-site.

Expected treatment results are essentially the same as in-situ S/S treatment with the exception that I mixing of the waste and treatment agents can be better controlled ex-situ. However, given the additional costs and safety and environmental concerns associated with the excavation and handling of the untreated waste and subsequent disposal of the treated waste, ex-situ S/S stabilization will not I be retained for consideration in developing corrective action alternatives. I 5.8.2.6 Source Material Erosion Control Actions Soil Cover/Parking Lot

I The area at CL4 is currently used as a military vehicle parking lot. Most of the area is covered with compacted crushed rock. A soil cover/parking lot would minimize erosion potential through I physical means and by virtue of run-on/run-off drainage control. A soil cover/parking lot would also further isolate and prevent disturbance of the source material. It is a low-cost technology relative to other source control technologies. Soil cover/parking lot will be retained for consideration in I developing corrective action alternatives. I 5.8.3 Identification of Applicable Groundwater Technologies 5.8.3.1 Groundwater Institutional Actions

I Groundwater Use Restrictions

Groundwater use restrictions would be imposed to prevent the use or installation of new private I wells and public drinking water supply wells within the source area (including downgradient contamination). Either voluntary or legal restrictions (or both) on groundwater may apply. I Voluntary groundwater use restrictions are restrictive covenants written into a site property deed to notify any purchaser of the location and source of groundwater contamination and that groundwater use must be restricted. Legal groundwater use restrictions would involve notifying the WDNR Bureau of Water Supply of the groundwater impacts. The Bureau keeps maps and lists of sites with groundwater impacts; however, it is the responsibility of the well driller to be apprised of specially '"I designated areas.

I D:IFTMCCOY JIPOCMSI\SEC110N.S 5-11 March 1996 Fort McCoy I Draft Co"ective Measures Study Report

NR 812.08 prohibits the installation of new water supply wells within 1,200 feet of a solid waste I site. Both voluntary and legal groundwater use restrictions depend on enforcement for their effectiveness. Relative costs for groundwater use restrictions are low. Groundwater use restrictions will be retained for consideration in developing corrective action alternatives. I

There are currently three water supply wells within 1,200 feet of CL4, based on a wellhead protection study recently conducted on the Fort McCoy water supply wells (RUST E&l, November I 1994). However, based on groundwater flow modeling conducted as part of the study, CL4 does not appear to be within the normal capture zone of these supply wells. This modeling vvas based on the conservative scenario of simultaneous continuous pumping at the maximum design capacity for I these wells. Based on this modeling, the need to restrict Fort McCoy's use of the supply wells in the vicinity of CL4 is not anticipated. I Groundwater Monitoring I Groundwater monitoring using monitoring wells would be continued at CL4 to track groundwater quality and the effectiveness of other remediation technologies. Groundwater monitoring is a commonly used method to determine groundwater quality. Monitoring consists of collecting I groundwater samples from monitoring wells and analyzing those samples to define contaminant migration or establish increasing or decreasing concentration trends over time. Laboratory analysis detection limits will be set low enough to determine if the PALs have been exceeded. If the PAL I is below the lowest detection limit, the lowest detection limit commercially available will be utilized for evaluating groundwater standard exceedances. Relative capital costs are low; O&M costs are moderate. Groundwater monitoring will be retained for consideration in developing corrective I action alternatives.

5.8.3.2 Groundwater Containment Actions I Low-Permeability Barriers I Low-permeability barriers can be an effective component of a groundwater containment system. The barriers can consist of a soil, bentonite and water mixture, cement and water mixture, or sheet piling I and would probably be located downgradient of CL4. They are most effective if keyed several feet into a low permeability layer such as relatively impermeable bedrock or clay. However, a low­ permeability barrier alone will only divert groundwater flow, it will not contain it. To contain I groundwater, the groundwater that flows up to and then around or under the barrier must be collected by extraction wells or collection trenches and subsequently treated and discharged. Relative costs for low-permeability barriers would be high given the need for specialized equipment, materials and I procedures to construct a barrier. Given the lack of a low-permeability layer at CL4 to key into, low­ permeability barriers will not be retained for consideration in developing corrective action alternatives. I I I

D:IF1MCCOYJIJ'DCMSJISECTION.5 5-12 March 1996 I I Fort McCoy Draft Co"ective Measures Study Report

I Hydraulic Barriers

Hydraulic barriers would be used to minimize migration of contaminated groundwater. A hydraulic I barrier would consist of a series of extraction wells or collection trenches placed downgradient of CL4. Extracted groundwater would require treatment or pretreatment prior to discharge. Relative capital costs are moderate, O&M costs (pumping system and well maintenance) are moderate. I Hydraulic barriers will be retained for developing corrective action alternatives. I 5.8.3.3 Groundwater Removal Actions I Extraction Wells Extraction wells would be used to collect impacted groundwater. Generally, extraction wells would be drilled and screened in a highly permeable water-bearing zone. The wells are fitted with a pump I to extract groundwater and create a negative pressure zone to promote flow towards the well. Relative capital costs for extraction wells are low to moderate; O&M costs are moderate. Extraction I wells will be retained for developing corrective action alternatives. CoUection Trenches

I Collection trenches may be used in place of extraction wells for collecting impacted groundwater and may be very effective, depending on the hydrogeology of the site. Collection trenches are also used frequently in lowering the local water table and controlling the direction of groundwater flow I at a site. Extracted groundwater would require treatment prior to discharge. Relative capital costs for collection trenches are generally low to moderate; O&M costs are moderate.

I Collection trenches will not be retained for developing corrective action alternatives here due to constructability difficulties in the saturated sandy soils and questionable effectiveness in the high permeability sandy soils. The saturated sandy soils would miuce construction of a collection trench I difficult and costly due to stability/sloughing potential. Even if a trench would be constructed at CL4, it would have reduced effectiveness since collection trenches operate on the basis of I permeability differential. Groundwater generally prefers flow from areas oflow permeability (silts, clay) to areas of high permeability (sands, gravels). Since the area at CL4 already naturally contains a high permeability material (sands), the effectiveness of a collection trench at CL4 would be I reduced since there would be minimal difference in the permeability of the native material (sands) and the collection trench material (sands). This would result in only partial capture of the I groundwater moving past CL4. 5.8.3.4 Groundwater Treatment Actions

I Biological Treatment

On-site biological treatment of extracted groundwater may use either an attached or suspended­ I growth biological treatment process. In suspended growth systems such as activated sludge I processes (ASP), contaminated groundwater is circulated in a mixing basin where a microbial I D:IF7MCCOYJIPOCMSllSECTION.5 5-13 March 1996 Fort McCoy I Draft Con-ective Measures Study Report population aerobically or anaerobically degrades organic matter and produces new cells. The new I cells form a sludge, which is settled out in a clarifier, and a portion of the sludge biomass is recycled to the mixing basin. A portion of the sludge is continuously wasted, to be further treated prior to solids disposal, generally at a landfill. In attached growth systems, such as rotating biological I contactors and trickling filters, microorganisms are established on an inert support matrix to aerobically or anaerobically degrade groundwater contaminants. Attached growth processes produce less sludge than ASPs. Attached and suspended systems often are used together in series. I

Biological treatment is used primarily to treat nonhalogenated VOCs, SVOCs, and petroleum hydrocarbons. Halogenated VOCs (PCE), SVOCs, and pesticides also can be treated, but the I process may be less effective and may be applicable only to some compounds within these groups. Relative capital costs for biological groundwater treatment are moderate to high; O&M costs are I high. Biological treatment will not be retained for developing corrective action alternatives g~ven that it is less effective than air stripping at removing low levels of halogenated VOCs. I Carbon Adsorption

Carbon adsorption would remove organic compounds that preferentially sorb onto carbon versus I water. On-site carbon adsorption of extracted groundwater would involve piping extracted groundwater/leachate through a series of canisters containing activated carbon to which dissolved organic contaminants adsorb with subsequent discharge of the treated water. The technology I requires periodic replacement or regeneration of saturated carbon which increases the cost of this technology. The target contaminant groups for carbon adsorption (liquid phase) are halogenated and * nonhalogenated SVOCs. The technology can be used, but may be less effective in treating· halogenated VOCs (PCE), fuel hydrocarbons, pesticides, and inorganics. Relative capital costs are I moderate to high; O&M costs are moderate ·to high. Carbon adsorption will not be retained for developing corrective action alternatives given that it is less effective than air stripping at removing the low levels of halogenated VOCs detected in the groundwater. I Air Stripping I

Air stripping would involve pumping of extracted groundwater into an air stripping vessel which uses air and water mixing to remove or strip VOCs. Types of aeration methods include packed I towers, diffused aeration, tray aeration, and spray aeration. The treatment system could be located in a building at or adjacent to CL4. I The target contaminant groups for air stripping systems are halogenated (PCE) and nonhalogenated VOCs. Removal efficiencies around 99 percent can be achieved for these types of contaminants. The technology can be used, but may be less effective for halogenated and nonhalogenated SVOCs I and fuels. Relative capital costs for air stripping are moderate; O&M costs are low, unless vapor­ phase carbon is needed (moderate if needed) to treat the exhaust air stream. Air stripping will be retained for consideration in developing corrective action alternatives. I I D:IFIMCCOY/1PDCMSJISEC170N.S 5-14 March 1996 I I Fort McCoy Draft Corrective Measures Study Report

I Air Sparging/Soil Vapor Extraction

Air would be injected under pressure below the water table to strip VOCs from groUhdwater. Air I sparging (AS) would be conducted in conjunction with a soil vapor extraction (SVE) system to remove stripped VOCs from the unsaturated zone. The ease and low cost of installing small­ I diameter air injection points allows considerable flexibility in the design and construction of a remediation system. Relative capital costs for air sparging are low to moderate; O&M costs are low unless vapor-phase carbon is needed (moderate if needed) to treat the exhaust air stream. AS/SVE I will not be retained for consideration in developing of corrective action alternatives because it does not provide treatment of inorganic groundwater contaminants which may need to be treated ex-situ.

I Chemical Precipitation

On-site chemical precipitation of extracted groundwater/leachate would be used for removing I inorganic contaminants as pretreatment for other processes or to address. discharge limits for inorganics. Precipitation is a process by which the chemical equilibrium of a waste stream is altered to reduce the solubility of metals. The metals precipitate out as a solid phase (sludge) and are taken I out of the solution by solids removal processes. Metals precipitation is not one unit operation but a combination of coagulation, flocculation, sedimentation, and, in some cases, filtration processes. Relative capital costs are moderate; O&M costs are moderate to high due to sludge processing and I off-site disposal. Chemical precipitation will be retained for consideration in developing corrective action alternatives.

I ·Natural Attenuation

Natural attenuation would consist of volatilization, biodegradation, recharge and dispersion; I adsorption, and chemical reactions with subsurface materials to reduce groundwater contaminant concentrations to acceptable levels. Non-destructive attenuation mechanisms include recharge and I· dispersion, and adsorption. The rest of the attenuation mechanisms are destructive to the contaminants. All of these processes are naturally occurring. Natural attenuation is effective generally when contaminant concentrations are low, the contaminants have been in place for I extended periods, and contaminant concentrations are steady or decreasing over time. Costs for natural attenuation are low since. it is naturally occurring and the only costs associated with it are related to monitoring activities. Once monitoring activities cease, natural attenuation becomes a no­ I cost option. Natural attenuation will be retained for consideration in developing corrective action alternatives.

I 5.8.3.5 Groundwater Discharge Actions I Publicly/Privately-Owned Treatment Work (POTW) If groundwater extraction is required, POTW discharge would be implemented for groundwater in I conjunction with extraction and, possibly, treatment. Extracted or treated groundwater may be discharged to a POTW including the on-site WWTF via existing or new sewers or force main. I.

I D:IF7MCCOYI\PIXMSI1SEC110N.5 5-15 March 1996 Fort McCoy I Draft Co"ective Measures Study Report Pretreatment may be required before discharge to the POTW. Discharge to a POTW will be retained I for consideration in developing corrective action alternatives.

Surface Water I

If groundwater extraction is required, discharge to surface water would be implemented for groundwater/ in conjunction with extraction and treatment. Discharge to surface water involves the I piping of treated groundwater to an outfall at a surface water body such as the La Crosse River or a tributary to it. The relative capital cost is distance-dependent, and thus would be low to moderate at CL4, while O&M costs are relatively low. Discharge to surface water will be retained for I consideration in developing corrective action alternatives.

5.8.4 Identification of Applicable Landfill Gas (LFG) Technologies I LFG is potentially present at CL4, where some putrescible wastes were disposed of. However, it I is anticipated that, due to the age of the landfill (30 to 40 years), the current LFG production rate is very low. Therefore, landfill gas technologies will not be retained for development of corrective action alternatives. I 5.9 CORRECTIVE MEASURES ALTERNATIVES I 5.9.1 Introduction

In this section, the applicable corrective action technologies identified in Section 5.8 for CL4 source I material and groundwater are further assembled into corrective action alternatives.

Assembling suitable corrective action alternatives was an iterative process that systematically I combined the retained technologies into alternatives that meet the corrective action objectives (See Sections 5.7.6 and 5.7.7) and are the most practicable for site-specific conditions. The first step of the process consisted of evaluating all pertinent combinations of retained technologies. The I preliminary assemblage of alternatives was further evaluated to develop alternatives that were most suitable for CL4 considering the interaction of the selected technologies and site-specific conditions. I Based on this evaluation, the most suitable corrective action alternatives were recommended to be carried forward in the CMS. I 5.9.2 Site-Specific Factors Affecting Development of Alternatives

The following factors related to CL4 were considered the most critical in developing corrective I action alternatives:

• There are no current nor anticipated future groundwater receptors located between CL4 and I Squaw Creek. Groundwater flow is toward Squaw Creek. I I D:IF'IAK:COYJIPDCMSJISEC110N.5 5-16 March 1996 I I Fort McCoy Draft Corrective Measures Study Report I • CL4 is expected to remain the property of the U.S. Army and continue to have associated access restrictions. CL4 has been incorporated into a crushed-rock paved parking lot at the I Consolidated Maintenance Facility for the storage of military vehicles. • NR 812.08 prohibits the installation of new water supply wells within 1,200 feet of a solid waste I site. • The landfill contains some putrescible waste. Since the age of waste is 30 to 40 years, a high I percentage of potential LFG would have already been generated and dissipated. • There is currently little runoff from CL4 due to the flat topography and high soil infiltration rate.

I • As discussed in Section 5.5, inorganic contaminants detected in groundwater at levels exceeding PALs include antimony, arsenic, cadmium, chromium, iron, nickel, manganese, and nitrate­ I nitrite. Iron and manganese are generally not considered significant public health concerns. • As discussed in Section 5.5, the only organic contaminants detected in groundwater at levels I exceeding PALs were PCE and bis(2-ethylhexyl)phthalate. However, bis(2-ethylhexyl) phthalate is a common laboratory contaminant. PCE was also detected in the upgradient well.

I Based on the factors identified above, it is recommended that the four corrective action alternatives, identified and discussed below, be carried forward for evaluation in Section 5.9.3. t 5.9.3 Description of Evaluation of Corrective Action Alternatives

5.9.3.1 Introduction

The following sections describe the four corrective action alternatives proposed for consideration t and present an evaluation of the alternatives based on technical, environmental, human health, and institutional criteria as required by Fort McCoy's RCRA Part B Permit. Table 5-3 identifies the technologies in each of the four alternatives.

5.9.3.2 Corrective Action Alternative 1

Alternative 1

Access, Land, and Groundwater Use Restrictions, Natural Attenuation, Groundwater Monitoring

Alternative 1 consists of access, land use and groundwater use restrictions; natural attenuation of low-level groundwater contamination; and groundwater monitoring. These components are described below:

D:IF1MCCOYIIPDCMSJISEC170N.S 5-17 March 1996 Fort McCoy I Draft Co"ective Measures Study Report

lmplementability and Reliability I

Based on the site conditions summarized in Section 5.9.2, access, land, and groundwater use restrictions and natural attenuation in conjunction with groundwater monitoring would be reliable I and readily implementable at CL4.

Operation and Maintenance I

Semi-annual groundwater monitoring would be the only Alternative 1 operational requirement. The operation period for groundwater monitoring will be dependent on the time to achieve acceptable I levels for COCs in groundwater. For cost estimating purposes, it is assumed groundwater monitoring will continue for 30 years. The parking lot would be maintained by Fort McCoy through I routine inspections and maintenance. Monitoring wells may require periodic well screen cleaning and other minor maintenance. It is anticipated that the useful life of the monitoring wells would be at least 15 years. I Safety I Implementation of Alternative 1 components would not pose a threat to the safety of nearby residents and environments or site workers since the only site activities for Alternative 1 consist of groundwater sampling. f Environmental Evt~luation r Implementation of Alternative 1 components would not adversely impact environmentally sensitive areas. r An ecological field assessment (SEC Donohue, November 1994) of CL4 concluded that most of the potential ecological communities would have been removed with the construction of the crushed­ t rock paved parking lot for the Consolidated Maintenance Facility. In addition, the planned land use as a military vehicle parking lot would limit the potential for ecological communities at CL4. { Human Health EVflluation r Land use as a military vehicle parking lot and access, land use and groundwater use restrictions would prevent residential development at CL4. Therefore, the most likely human health risk exposure scenario for the CL4 would be that of ingestion of and direct contact with surface soil by a hypothetical trespasser or a site worker. The human health assessment concluded that site workers at CL4 would not be exposed to excess health risks under this scenario. The human health assessment also indicated that residents would not be exposed to excess health risks under a hypothetical residential scenario. In addition, there are no current nor anticipated future groundwater receptors located between CL4 and Squaw Creek.

D:IF'IU::COYIIPDCMS/1SEC170N.:S 5-19 March 1996 I Fort McCoy Draft Co"ective Measures Study Report

I Institutional Evaluation

Institutional needs for Alternative 1 include enforcing existing site access restrictions, enforcing land I and groundwater use restrictions and performing routine groundwater monitoring.

The design and implementation schedule for Alternative 1 components would not be effected by I Federal, state and local environmental and public health standards, regulations, guidance, advisories, I ordinances or community relations. Cost Evaluation

I The cost for Alternative 1 includes annual operation and maintenance costs associated with routine groundwater monitoring and maintenance. It is assumed that costs for recording deed restrictions would be negligible. The estimated conceptual presnt worth O&M cost for Alternative 1 is $477,000 I as presented in Table 5-4. Cost estimate back-up information is presented in Appendix A to this CMSR.

I 5.9.3.3 Corrective Action Alternative 2 I Alternative 2 Access, Land and Groundwater Use Restrictions, Groundwater Extraction and Treatment, I Natural Attenuation, I Groundwater Monitoring Alternative 2 consists of access, land and groundwater use restrictions; groundwater extraction and treatment; natural attenuation of residual low-level groundwater cont8mination; and groundwater I monitoring.

• Existing access restrictions to CL4 associated with the Fort McCoy facility and the parking lot I would be maintained.

• Restrictive covenants would be placed on deeds to the CL4 property to restrict land and I groundwater use at CL4. I • If required, groundwater extraction using eight extraction wells would be used to collect groundwater at the downgradi~nt edge of CL4. The collected groundwater (approximately 40 gpm) would then be treated ex-situ using chemical precipitation and air stripping with I discharge either to the on-site WWTF or surface water. The treatment units would be housed in a building at or adjacent to CL4. The conceptual location of the extraction wells and building I are shown in Figure 5-5. The actual locations would be determined during design activities. I

I D:IFIMCCOY/IPDCMS/ISEC170N.S 5-20 March 1996 I Fort McCoy Draft Corrective Measures Study Report

I TABLE 5-4

ALTERNATIVE 1 O&M COST ESTIMATE I CLOSED LANDFILL 4 I FORT MCCOY, WISCONSIN O&Mitem Quantity Unit Unit Cost Total Cost I Groundwater Monitoring (30 yrs):

Groundwater Sampling and 1(I) YR $23,000 $23,000 I Analysis Site Inspection and Maintenance (30 yrs): I Inspection and Maintenance 1 YR $1,000 $1,000 Groundwater Monitoring and Site Inspection and Maintenance $24,000 I Subtotal Scope Contingency (15%) $3,600 I Subtotal $28,000 I Administration (1 0%) $2,800 Total Annual O&M Cost $31,000 I Total Present Worth ofO&M $477.000 NOTES:

I (I) Includes two sampling events per year at 3 wells. Cost assumptions are presented in Appendix A to CMSR. I I I I I I

I D:IF1MCCOYJIPDCMSJ\TAB5-4. March 1996 I ~,r------1 I

I ...... -CJ' I 3: "'..., I I I I I I I I

I II

I NOTES; I. GROUNDWATER TABLE ELEVATIONS AND CONTOURS ARE DERIVED F"ROM THE PHASE 2 INVESTIGATION.

2. LU.ATIS OF WASTE DETERMINED FROM GEOPHYSICAL SURVEY QUADRATURE CONTOUR MAP ASSUMING WASTE IS INDICATED BY AREAS HAVING CONDUCTIVITY OF 5 MUHO/M OR MORE OR OF -3 I MMHO/M OR LESS. 3. LIMITS OF WASTE ARE ESTIMATED OUTSIDE OF THE GEOPHYSICAL SURVEY AREA. 0' 80' 160' SCALE CONCEPTUAL LOCATION OF FENCE -- I x-x- -- CONCEPTUAL LOCATION OF EXTRACTION WELL

CONCEPTUAL LOCATION OF TREATMENT BUILDING

I MAR. 1996 FIGURE 5-5 18903 CLOSED LANDFILL 4 .....ENVIRONMENT & CONCEPTUAL GROUNDWATER EXTRACTION I AND TREATMENT SYSTEM LAYOUT ~~~~ INFRASTRUCTURE DRAFT CORRECTIVE MEASURES STUDY I FORT McCOY, WISCONSIN I Fort McCoy Draft Corrective Measures Study Report

I • Residual concentrations of COCs in groundwater would be reduced to acceptable levels over time by natural attenuation through adsorption and other physical and chemical reactions within I the subsurface environment. • Groundwater monitoring would consist of semi-annual sampling and analysis of 3 existing groundwater monitoring wells (1 upgradient and 2 downgradient) located adjacent to CL4. The I groundwater monitoring wells are illustrated on Figure 5-2. Observation wells (OWs) are I screened across the water table. Screened Interval I Monitoring Well (feet below ground surface)

OW-107 (upgradient) 15-25 I OW-108 17-27 OW-109 13-23

I Compounds which equaled or exceeded their PALs (metals, VOCs, and nitrate/nitrite) in previous sampling events in downgradient monitoring wells would be analyzed for during I groundwater monitoring. I Effectiveness A crushed-rock paved parking lot has been constructed on the surface of CL4 for Consolidated Maintenance Facility military vehicle parking and is expected to remain the property of the U.S. I Army and continue to have associated effective access restrictions.

Land and groundwater use restrictions would be effective, as CL4 is expected to remain the property I of the U.S. Army. If the CL4 does not remain the property of the U.S. Army, the effectiveness of deed restrictions would depend on continued enforcement and could be subject to changes in political jurisdiction and legal interpretation. NR 812.08 would supplement groundwater use I restrictions by prohibiting the installation of new water supply wells within 1,200 feet ofCL4.

If required, eight groundwater extraction wells would be used to collect the impacted groundwater I downgradient ofCL4. The collected groundwater would be treated using chemical precipitation and air stripping. Given the sporadic nature of low-level PAL exceedances, the effectiveness of the I treatment units may be reduced due to the sporadic nature of low concentration influent. Given the low concentrations and sporadic detections of COCs, and the age of the landfill, I groundwater concentrations of these compounds are expected to be further reduced over time through natural attenuation.

I The effectiveness of groundwater extraction and treatment and natural attenuation would be monitored through groundwater monitoring. Semi-annual groundwater sampling and analysis is a I proven effective means of monitoring groundwater quality.

I D:IFTMCCOY JIPDCMSIISEC170N.5 5-21 March 1996 Fort McCoy I Draft Corrective Measures Study Report

lmplementability and Reliability I

Based on the site conditions summarized in Section 5.9.2, access, land, and groundwater use restrictions, groundwater extraction and treatment, and natural attenuation in conjunction with I groundwater monitoring would be reliable and readily implementable at CL4. Construction of Alternative 2 should be able to be completed in one construction season. I Operation and Maintenance I' Semi-annual groundwater monitoring and operation of the groundwater extraction and treatment system would be the Alternative 2 operational requirements. The operation period for groundwater extraction and treatment or groundwater monitoring will be dependent on the time to achieve I acceptable levels for COCs in groundwater. For cost estimating purposes, it is assumed the groundwater extraction and treatment system will be operated for 10 years with groundwater monitoring continuing for an additional 20 years. I

The parking lot would be maintained by Fort McCoy through routine inspections and maintenance. Monitoring and extraction wells may require periodic well screen cleaning and other minor I maintenance. It is anticipated that the useful life of the wells would be at least 15 years.

Safety I Safety of nearby residents, environments and site workers with regard to physical hazards during I implementation would be addressed by provisions in the construction contractor's SSHP. Potential site safety hazards during construction could include, but not be limited to, heavy equipment operation, chemical exposure, slip/trip/fall hazards, heat/cold stress, wildlife (ticks, snakes, etc.), and I vegetation (poison ivy, etc.). Temporary environmental controls (dust suppression, etc.) and ambient air monitoring would be implemented as needed during installation of the groundwater extraction wells and construction of the groundwater treatment plant. I Environmental Evaluation I Implementation of Alternative 2 components would not adversely impact environmentally sensitive areas. I An ecological field assessment (SEC Donohue, November 1994) ofCL4 concluded that most of the potential ecological communities would have been removed with the construction of the crushed­ I rock paved parking lot for the Consolidated Maintenance Facility. In addition, the planned land use as a military vehicle parking lot would limit the potential for ecological communities at CL4. I Human Health Evaluation

Land use as a military vehicle parking lot and access, land use and groundwater use restrictions I would prevent residential development at CL4. Therefore, the most likely human health risk exposure scenario for the CL4 would be that of ingestion of and direct contact with surface soil by I

D:IF1MCCOYIIPDCMSI\SEC170N.S 5-22 March 1996 I I Fort McCoy Draft Corrective Measures Study Report

I a hypothetical trespasser or a site worker. The human health assessment concluded that site workers at CL4 would not be exposed to excess health risks under this scenario. The human health I assessment also indicated that residents would not be exposed to excess health risks under a residential scenario. I In addition, there are no current nor anticipated future groundwater receptors located between CL4 and Squaw Creek.

I Institutional Evaluation

Institutional needs for Alternative 2 include enforcing existing site access restrictions, enforcing land I and groundwater use restrictions and performing routine groundwater monitoring.

The design implementation schedule for Alternative 2 may be impacted by federal, state, and local I permitting requirements. I • It is anticipated that implementation of Alternative 2 will not require a local construction permit. • It is anticipated that operation of the air stripper will not require a Wisconsin Air Permit. The I air stripper will be operated to meet NR 419 and NR 445 emissions criteria. • If the extracted groundwater is treated and discharged to the surface, it is anticipated that a · I WPDES permit will·be required.

• Groundwater treatment system residuals (sludge) must be disposed in accordance with . I applicable regulations. I Cost Evaluation The cost for Alternative 2 includes capital costs to construct the groundwater extraction/treatment system and annual operation and maintenance costs associated with groundwater I extraction/treatment, and semi-annual groundwater monitoring. It is assumed that costs for recording deed restrictions would be negligible.

I The estimated conceptual capital construction cost for Alternative 2 is $1,046,000 as presented in Table 5-5. The estimated conceptual present worth O&M cost for Alternative 2 is $1,696,000 as I presented in Table 5-6. Cost estimate back-up information is presented in Appendix A to this CMSR.

I 5.9.3.4 Corrective Action Alternative 3 I Alternative 3 Excavate and Remove CL4, I Transport and Dispose In Off-Site Landfill,

·I D:IF'IA«:COYIIPIXMSJISEC110N.S 5-23 March 1996 I Fort McCoy Draft Corrective Measures Study Report

I TABLE 5-5

ALTERNATIVE 2 CAPITAL COST ESTIMATE I CLOSED LANDFILL 4 I FORT MCCOY, WISCONSIN Capital Cost Item Quantity Unit Unit Cost Item Cost I Construction: Groundwater Extraction 1 LS $104,000 $104,000 I Groundwater Treatment 1 LS $269,000 $269,000 I Discharge 1 LS $92,000 $92,000 Construction Subtotal $465,000 I Construction Global Markups: Scope Contingency (15%) $70,000 I Subtotal $535,000 Health and Safety (30%) $161,000 I Subtotal $696,000 Permitting (10%) $70,000 I Engineering (20%) $140,000 I Construction-Related Services (15%) $105,000 Prime Fixed Fee (5%) $35,000 I Total Capital Cost $1.046.000 NOTES:

I Cost assumptions are presented in Appendix A to CMSR. I I I I

I D:IFTMCCOYIIPDCMSIITAB5-5. March 1996 I Fort McCoy Draft Co"ective Measures Study Report

I TABLE 5-6

ALTERNATIVE 2 O&M COST ESTIMATE I CLOSED LANDFILL 4 I FORT MCCOY, WISCONSIN O&Mitem Quantity Unit Unit Cost Total Cost I Groundwater Monitoring (30 yrs):

Groundwater Sampling and 1(I) YR $23,000 $23,000 I Analysis Site Inspection and Maintenance (30 yrs): I Inspection and Maintenance 1 YR $1,000 $1,000 Groundwater Monitoring and Site Inspection and Maintenance $24,000 I Subtotal Scope Contingency (15%) $3,600 I Subtotal $28,000 Administration (10%) $2,800 I Subtotal $31,000 I Groundwater Extraction and Treatment (10 yrs): Groundwater Extraction 1 YR $10,000 $10,000 I Groundwater Treatment 1 YR $115,000 $115,000 Subtotal $125,000 I Scope Contingency (15%) $19,000 Subtotal $144,000 I Administration (1 0%) $14,000 I Subtotal $158,000 Total Annual O&M $189,000 I Total Present Worth ofO&M ~ 1.f!2~~~~Q NOTES:

I (I) Includes two sampling events per year for 3 wells. Cost assumptions are presented in Appendix A to CMSR. I Present Worth Factors: (1) i = 5%; 10 yrs =7,722; (2) i = 5%; 30 yrs = 15.373

I D:IF7MCCOYJIPDCMSIITAB$4J. March 1996 ------~--- --

I Fort McCay Draft Corrective Measures Study Report

I Backfill Area, Replace Parking Lot, I Groundwater Monitoring Alternative 3 consists of excavation and removal of CL4; transport and disposal of CL4 material in I a licensed off..,site landfill; backfill of the excavated areas and replacement of the parking lot; and groundwater monitoring. These components are described below: I • Excavation and removal of CL4 material would involve the use of standard excavation/ construction equipment.

I • Off-site landfilling of the CL4 material would involve the transport of the material to a licensed landfill.

I • Backfilling of the excavated areas would involve the placement and compaction of these areas with clean soil. The crushed rock parking lot would then be replaced.

I • Groundwater monitoring would consist of semi-annual sampling and analysis of 3 existing groundwater monitoring wells (1 upgradient and 2 downgradient) located adjacent to CL4. The groundwater monitoring wells are illustrated on Figure 5-2. Observation wells (OWs) are I screened across the water table. I Screened Interval I Monitorin~ Well (feet below ~round surface) OW-107 (upgradient) 15-25 OW-108 17-27 I OW-109 13-23

Compounds which equaled or exceeded their PALs (metals, VOCs, and nitrate/nitrite) in I previous sampling events in downgradient monitoring wells would be analyzed for during _ groundwater monitoring.

I Effectiveness I A crushed-rock paved parking lot has been constructed on the surface of CL4 for Consolidated Maintenance Facility military vehicle parking and is expected to remain the property of the U.S. Army and continue to have associated effective access restrictions. This parking lot would be I replaced following the removal of CL4 material.

Land and groundwater use restrictions would be effective, as CL4 is expected to remain the property I of the U.S. Army. If the CL4 does not remain the property of the U.S. Army, the effectiveness of deed restrictions would depend on continued enforcement and could be subject to changes in I

I D:IF1MCCOYJIPDCMSJISEC110N.5 5-24 March 1996 Fort McCoy I Draft Corrective Measures Study Report political jurisdiction and legal interpretation. NR 812.08 would supplement groundwater use I restrictions by prohibiting the installation of new water supply wells within 1,200 feet of CL4.

Excavation and removal of CL4 material would be effective in removing the source of groundwater I contamination and the threat of direct contact with waste material. I Disposal of CL4 material in a licensed off-site landfill is an effective means for controlling the release of contaminants to the environment. I Given the low concentrations and sporadic detections of COCs, and the removal of CL4 material, groundwater concentrations of these compounds are expected to decrease over time through natural attenuation. I

The effectiveness of the removal of CL4 and natural attenuation would be monitored through groundwater monitoring. Semi-annual groundwater sampling and analysis is a proven effective I means of monitoring groundwater quality.

lmplementability and Reliability I

Based on the site conditions summarized in Section 5.9.2, access, land, and groundwater use restrictions, CL4 material removal and off-site disposal in a licensed landfill, replacement of the I parking lot, and natural attenuation in conjunction with groundwater monitoring would be reliable and readily implementable at CL4. Construction of Alternative 3 should be able to be completed I in one construction season.

Operation and Maintenance I

Semi-annual groundwater monitoring would be the only Alternative 3 operational requirement. The operation period for groundwater monitoring will be dependent on the time to achieve acceptable I levels for COCs in groundwater. For cost estimating purposes, given the removal of the waste, it is assumed groundwater monitoring will be performed for five years following waste removal. The parking lot would be maintained by Fort McCoy through routine inspections and maintenance. I Monitoring wells may require periodic well screen cleaning and other minor maintenance. It is anticipated that the useful life of the monitoring wells would be at least 15 years. I Safety I Safety of nearby residents, environments and site workers with regard to physical hazards during implementation would be addressed by provisions in the construction contractor's SSHP. Potential site safety hazards during construction could include, but not be limited to, heavy equipment I operation, chemical exposure, slip/trip/fall hazards, heat/cold stress, wildlife (ticks, snakes, etc.), and vegetation (poison ivy, etc.). Temporary environmental controls (dust suppression, etc.) and ambient air monitoring would be implemented as needed during implementation of Alternative 3. I I

D:IFIMCCOYJIPIXMSJISEC170N.$ 5-25 March 1996 I I Fort McCoy Draft Corrective Measures Study Report

I Environmental Evaluation

I Implementation of Alternative 3 components would not adversely impact environmentally sensitive areas. I An ecological field assessment (SEC Donohue, November 1994) of CL4 concluded that most of the potential ecological communities would have been removed with the construction of the crushed­ rock paved parking lot for the Consolidated Maintenance Facility. In addition, the planned land use I as a military vehicle parking lot would limit the potential for ecological communities at CL4. I Human Health Evaluation Land use as a military vehicle parking lot and access, land use and groundwater use restrictions would prevent residential development at CL4. Therefore, the most likely human health risk I exposure scenario for the CL4 would be that of ingestion of and direct contact with surface soil by a hypothetical trespasser or a site worker. The human health assessment concluded that site workers at CL4 would not be exposed to excess health risks under this scenario. The human health I assessment also indicated that residents would not be exposed to excess health risks under a residential scenario. In addition, there are no current nor anticipated future groundwater receptors I located between CL4 and Squaw Creek. Th~ removal of waste material would minimize risk. I Institutional Evaluation Institutional needs for Alternative 3 include enforcing existing site access restrictions, enforcing land I and groundwater use restrictions and performing routine groundwater monitoring. The design implementation schedule for Alternative 3 may be impacted by federal, state, and local I permitting requirements. Cost Evaluation

I The cost for Alternative 3. includes capital costs to excavate, remove, and dispose CL4 material in an off-site landfill, backfill the area and replace the parking lot, and annual operation and I maintenance costs associated with semi-annual groundwater monitoring. The estimated conceptual capital construction cost for Alternative 3 is $16,399,000 as presented in I Table 5-7. The estimated conceptual present worth O&M cost for Alternative 3 is $134,000 as presented in Table 5-8. Cost estimate back-up information is presented in Appendix A to this I CMSR. 5.9.3.5 Corrective Action Alternative 4

I Alternative 4 I In-situ Stabilization ofCL4,

I D:IFIMCCOY JIPDCMSJISEC770N.5 5-26 March 1996 I Fort McCoy Corrective Measures Study Report

I TABLE 5-7

ALTERNATIVE 3 CAPITAL COST ESTIMATE I CLOSED LANDFILL 4 I FORT MCCOY, WISCONSIN Capital Cost Item Quantity Unit Unit Cost Item Cost I Pre-Design: Site Survey I LS $5,000.00 $5,000 I Limits of Waste Investigation I LS $8,000.00 $8,000 Pre-Design Subtotal $13,000 I Construction: Erosion Control: I Silt Fencing 3,000 LF $1.00 $3,000 Erosion Control Subtotal $3,000 I Excavation/Backfill/Revegetation: Clearing and Grubbing 4.0 AC $6,250.00 $25,000 I Excavation 113,000 CY $2.50 $283,'000 Backfill Soil Borrow, Haul, and 119,000 CY $10.00 $1,190,000 Placement

I Vegetation 1.0 AC $2,000.00 $2,000

Parking Lot ( 6 acres) 1.0 LS $221,000.00 $221,000

I Confirmation Soil Sampling 138 EA $900.00 $124,000

Excavation/Backfill/Revegetation/Parking Lot Subtotal $1,845,000

I Construction Subtotal $1,848,000

Construction Markups:

I Health and Safety (30%) $555,000

Subtotal $2,403,000

I Permitting (5%) $120,000

Engineering (10%) $240,000

I Construction-Related Services (15%) $360,000 I Subtotal $3,123,000 I

I D:IFTMCCOY/IPOCMS/\TABS-7. March 1996 ------

I Fort McCoy Corrective Measures Study Report I TABLE 5-7 (Continued) ALTERNATIVE 3 CAPITAL COST ESTIMATE I CLOSED LANDFILL 4 FORT MCCOY, WISCONSIN

I Capital Cost Item Quantity Unit Unit Cost Item Cost I Disposal Characterization Sample Analysis l,I30 EA $I,200.00 $I,356,000

Hauling I58,000 Ton $30.00 $4,740,000

I Disposal I58,000 Ton $28.00 $4,424,000

Reporting/Documentation I LS $10,000.00 $10,000

I Disposal Subtotal $10,530,000

Subtotal Capital Cost $13,666,000

I Global Markups

Scope Contingency (15%) $2,050,000

I Prime Fixed Fee (5%) $683,000 TOTAL CAPITAL COST S1,;: 'lOO_OOO

I NOTES: I I) Cost assumptions are presented in Appendix A to CMSR. I I I I I I I

I D:IF7MCCOYIIPDCMSI\TA.B5-7. March 1996 I Fort McCoy I Draft Co"ective Measures Study Report TABLE 5-8 I ALTERNATIVE 3 O&M COST ESTIMATE CLOSED LANDFILL 4 I FORT MCCOY, WISCONSIN O&Mitem Quantity Unit Unit Cost Total Cost I Groundwater Monitoring (5 yrs): Groundwater Sampling and 1(1) YR $23,000 $23,000 I Analysis Site Inspection and Maintenance (5 yrs): I Inspection and Maintenance 1 YR $1,000 $1,000

" I Subtotal $24,000 Scope Contingency (15%) $3,600 I Subtotal $28,000 Administration (10%) $2,800 I Total Annual O&M Cost $31,000 Total Present Worth ofO&M $1~4 1 0QO I NOTES:

(1) Includes two sampling events per year at 3 wells. I Cost assumptions are presented in Appendix A to CMSR. I Present Worth Factor: i = 5%; 5 yrs = 4.329. I I I I I

March 1996 I D:IF7MCCOYJIPDCMSJ\TAB~. I Fort McCoy Draft Corrective Measures Study Report

I Access, Land and Groundwater Use Restrictions, Replace Parking Lot, Natural Attenuation, I Groundwater Monitoring. I Alternative 4 consists of in-situ stabilization ofCL4; replacement of the parking lot; access land and groundwater restrictions; natural attenuation; and groundwater monitoring.

I • CL4 material would be stabilized in-situ using specialized equipment to inject and mix stabilizing agents with the waste mass. The effectiveness and cost depends in part on the difficulty of injecting and mixing the stabilizing agents. It is not uncommon to have portions I of material to be . stabilized, excavated and disposed off-site due to the inability of the stabilization equipment to penetrate and mix buried debris.

I • Existing access restrictions to CL4 associated with the Fort McCoy facility would be maintained. The crushed rock parking lot would be replaced if excessive bulking of the treated material does not occur which could prevent the use of the area as a parking lot due to steep I grades.

• Restrictive covenants would be placed on deeds to the CL4 property to restrict land and I groundwater use at CL4. I • Low and sporadic detections of COCs in groundwater would be reduced to acceptable levels over time by natural attenuation through adsorption and other physical and chemical reactions I within the subsurface environment. • Groundwater monitoring would consist of semi-annual sampling and analysis of 3 existing groundwater monitoring wells (1 upgradient and 2 downgradient) located adjacent to CL4. The I groundwater monitoring wells are illustrated on Figure 5-2 .. Observation wells (OWs) are screened across the water table.

I Screened Interval Monitorin~ Well (feet below ~round surface)

I OW-107 (upgradient) 15-25 OW-108 17-27 I OW-109 13-23 Compounds which equaled or exceeded their PALs (metals, VOCs, and nitrate and nitrite) in I previous sampling events in downgradient monitoring wells would be analyzed for during groundwater monitoring. I I

I D:IF7MCCOY IIPOCMSIISEC170N.$ 5-27 March 1996 Fort McCoy I Draft Co"ective Measures Study Report

Effectiveness I

A crushed-rock paved parking lot has been constructed on the surface of CL4 for Consolidated Maintenance Facility military vehicle parking and is expected to remain the property ofthe U.S. I Army and continue to have associated effective access restrictions. The parking lot would be replaced following in-situ stabilization of the CL4 material if excessive bulking of the treated I material does not occur.

Land and groundwater use restrictions would be effective, as CL4 is expected to remain the property I of the U.S. Army. If the CL4 does not remain the property of the U.S. Army, the effectiveness of deed restrictions would depend on continued enforcement and could be subject to changes in political jurisdiction and legal interpretation. NR 812.08 would supplement groundwater use I restrictions by prohibiting the installation of new water supply wells within 1,200 feet of CL4.

In-situ stabilization of the CL4 material would be effective in treating the inorganic contaminants I in the waste material. However, it is not as effective for organic contaminants and is not effective at all if the stabilization equipment is prevented from contacting and mixing waste by buried debris or other obstructions. I

Given the low concentrations and sporadic detections of COCs, and the in-situ stabilization treatment, groundwater concentrations of these compounds would be expected to decrease over time I through natural attenuation. Groundwater data indicate that natural attenuation currently is active at CL4. I The effectiveness of in-situ stabilization and natural attenuation would be monitored through groundwater monitoring. Semi-annual groundwater sampling and analysis is a proven effective I means of monitoring groundwater quality.

Implementability and Reliability I

Based on the site conditions summarized in Section 5.9.2, access, land, and groundwater use restrictions and natural attenuation in conjunction with groundwater monitoring would be reliable I and readily implementable at CL4. However, due to the potential problems noted above with the in-situ stabilization treatment, it may not be readily implementable. Construction of Alternative 4 should be able to be completed in one construction season. I Operation and Maintenance I Semi-annual groundwater monitoring would be the only Alternative 4 operational requirement. The operation period for groundwater monitoring will be dependent on the time to achieve acceptable I levels for contaminants in groundwater. It is assumed for cost estimating purposes that groundwater monitoring will be performed for 30 years to document the long-term effectiveness of the in-situ SIS treatment. I I

D:IFTMCCOY JIPOCMSIISECTION.5 5-28 March 1996 I I Fort McCoy Draft Corrective Measures Study Report

I The parking lot would be maintained by Fort McCoy through routine inspections and maintenance. Monitoring wells may require periodic well screen cleaning and other minor maintenance. It is I anticipated that the useful life of the monitoring wells would be at least 15 years. I Safety Safety of nearby residents, environments and site workers with regard to physical hazards during implementation would be addressed by provisions in the construction contractor's SSHP. Potential I site safety hazards during construction could include, but not be limited to, heavy equipment operation, chemical exposure, slip/trip/fall hazards, heat/cold stress, wildlife (ticks, snakes, etc.), and vegetation (poison ivy, etc.). Temporary environmental controls (dust suppression, etc.) and ambient I air monitoring would be implemented as needed during implementation of Alternative 4. I Environmental Evaluation Implementation of Alternative 4 components would not adversely impact environmentally sensitive I areas. An ecological field assessment (SEC Donohue, November 1994) ofCL4 concluded that most of the potential ecological communities would have been removed with the construction of the crushed­ I rock paved parking lot for the Consolidated Maintenance Facility. In addition, the planned land use I as a military vehicle parking lot would limit the potential for ecological communities at CL4. Human Health Evaluation

I ·Land use as a military vehicle parking lot and access, land use and groundwater use restrictions would prevent residential development at CL4. Therefore, the most likely human health risk exposure scenario for the CL4 would be that of ingestion of and direct contact with surface soil by I a hypothetical trespasser or a site worker. The human health assessment concluded that site workers at CL4 would not be exposed to excess health risks under this scenario. The human health assessment also indicated that residents would not be exposed to excess health risks under a I residential scenario. In addition, there are no current nor anticipated future groundwater receptors located between CL4 and Squaw Creek.

I Institutional Evaluation I Institutional needs for Alternative 4 include enforcing existing site access restrictions, enforcing land and groundwater use restrictions and performing routine groundwater monitoring.

I The design implementation schedule for Alternative 4 may be impacted by federal, state, and local permitting requirements. I I

I D:IF1MCCOY JIPDCMSI\SEC170N.S 5-29 March 1996 I Fort McCoy Draft Corrective Measures Study Report

Cost Evaluation I The cost for Alternative 4 includes capital costs to perform in-situ stabilization of CL4 material, I replace the parking lot, and annual operation and maintenance costs associated with semi-annual groundwater monitoring. It is assumed that costs for recording deed restrictions would be negligible. I The estimated conceptual capital construction cost for Alternative 4 is $21,427,000 as presented in Table 5-9. The estimated conceptual present worth O&M cost for Alternative 4 is $477,000 as presented in Table 5-10. Cost estimate back-up information is presented in Appendix A to this I CMSR.

A summary of the cost estimates for all four alternatives is presented in Table 5-11. I 5.9.4 Recommended Alternative I Based on the site-specific factors identified in Section 5.9.2, the alternatives evaluation performed in Section 3.9.3, and the comparison presented in Table 5-12, Alternative 1 is recommended for CL4. Alternative 1 consists of access, land use and groundwater use restrictions; natural attenuation I of low-level groundwater contamination; and groundwater monitoring. I Alternative 1 addresses the corrective action objectives for CL4 by reducing potential for contaminant migration to and in groundwater, limiting groundwater use, and reducing groundwater concentrations for COCs to acceptable levels. Alternative 1 would be technically effective, reliable, I and implementable at CL4 and would provide short-term and long-term protection of human health and the environment. I As presented in Table 5-12, Alternative 1 adequately addresses the human health, environmental, and institutional control concerns, is readily implementable, provides long-term reliability, and is less costly as compared to Alternatives 2, 3, and 4. I I I , I I I· I

D:IFTMCCOYIIPDCMSIISECTION.5 5-30 March 1996 I I Fort McCoy Draft Corrective Measures Study Report

I TABLE 5-9

ALTERNATIVE 4 CAPITAL COST ESTIMATE I CLOSED LANDFILL 4 FORT MCCOY, WISCONSIN

I Capital Cost Item Quantity Unit Unit Cost Item Cost

Pre-Design: I Site Survey I LS $5,000 $5,000 Limits of Waste Investigation I LS $8,000 $8,000 I Pre-Design Subtotal $13,000 Construction: I Clearing and Grubbing 4.0 AC $6,250 $25,000 Stabilization of Landfill Material: I Bench-Scale Test I LS $100,000 $100,000 Pilot-Scale Test I LS $200,000 $200,000 I Mobilization/Demobilization I LS $160,000 $160,000 Stabilization 113,000 CY $100 $11,300,000 I Subsurface Debris Handling 5,000 CY $10 $50,000 Debris Hauling 7,000 TON $30 $210,000 I Debris Disposal 7,000 TON $28 $196,000 Characterization Sample Analysis 50 EA $1,200 $60,000 I Confmnation Soil Sampling 138 EA $900 $124,000 Stabilization Subtotal $12,425,000 I Cover Stabilized Material: Soil Borrow, Haul, and Placement 17,000 CY $15 $255,000 I Vegetation 1.0 AC $2,000 $2,000 Parking Lot ( 6 acres) I LS $221,000 $221,000 I Cover Stabilized Material Subtotal $478,000 Construction Subtotal $12,903,000 I Construction Global Markups: Scope Contingency (15%) $1,936,000 I Subtotal $14,839,000 Health and Safety (30%) $4,452,000 I Subtotal $19,291,000

I D:IFTMCCOY1\PIXMSJ\TA/JS-9. March 1996 I Fort McCoy I Draft Co"ective Measures Study Report TABLE 5-9 (Continued)

ALTERNATIVE 4 CAPITAL COST ESTIMATE I CLOSED LANDFILL 4 FORT MCCOY, WISCONSIN I Capital Cost Item I Quantity I Unit I Unit Cost Item Cost I Pennitting (1%) $193,000 Engineering (2%) $386,000 I Construction-Related Services (3%) $579,000 Prime Fixed Fee (5%) $965,000 I Construction Total $21,414,000 TOTAL CAPITAL COST $21427.000 I NOTE: 1. Cost assumptions are presented in Appendix A to CMSR. I I I I I I I I I

D:IFTMCCOYIIPIXMSJ\TAB5·9. March 1996 I Fort McCoy Draft Corrective Measures Study Report

I TABLE 5-10

ALTERNATIVE 4 O&M COST ESTIMATE I CLOSED LANDFILL 4 I FORT MCCOY, WISCONSIN O&Mitem Quantity Unit Unit Cost Total Cost I Groundwater Monitoring (30 yrs):

Groundwater Sampling and 1(I) YR $23,000 $23,000 I Analysis Site Inspection and Maintenance (30 yrs): I Inspection and Maintenance 1 YR $1,000 $1,000 Subtotal $24,000 I Scope Contingency (15%) $3,600 I Subtotal $28,000 Administration (10%) $2,800 I Total Annual O&M Cost $31,000

Total Present Worth of O&M $47Z2QOO I NOTES:

(I) Includes two sampling events per year at 3 wells. I Cost assumptions are presented in Appendix A to CMSR. I I I I I I

I D:IFn.K:COYIIPOCMSJ\TABS-10. March 1996 I Fort McCoy Draft Corrective Measures Study Report

I TABLES-11 I CORRECTIVE MEASURES ALTERNATIVES COST ESTIMATE SUMMARY CLOSED LANDFILL 4 I FORT MCCOY, WISCONSIN Alt#1 Alt#2 Alt#3 Alt#4 ...... •• ... I: I<···•·•••············•·· .... .·. ······· ·.. I •••••• I ... .· ·.:. . . S()urce < I> <...... > . ·•···•·•·.. I /····•·•···. ············•····· ·• ..•• .... > Access, X X X I Land Use Restrictions I Excavation and X Disposal In-Situ X I Stabilization ..•.••••.•.•.•••• ! i< .. ..· •·.··· <.••••• .··· ······· Groundwater ·.·. I << Irc• ...... :.:::.:...... ·•··•·•••••·, _:) I • •• ••••••••• ••••••••• I > ••••• Use Restrictions X X X X Natural X X .x X I Attenuation I Monitoring X X X X Extraction and X Treatment .. I .... ·... ·····. < I I•· . .. iCost ? ...... ·.•. •:•. . > •••• ··················.·············· ... ••••••••••••• •• ··········• ...... · ...•.·.·.·.·.···•·• .• :.... ············•········ / .. I Capital $0 $1,046,000 $16,399,000 ·············$21,427,000 AnnualO&M $31,000 $31,000 $31,000· $31,000 (GWMON) I $158,000 (GWE&T) I Present Worth $477,000 $476,000 $134,000 $477,000 O&M (30 yr) (30 yr) (5 yr) (30 yr) $1,220,000 I (10 yr) I Total Cost $477,000 $2,742,000 $16,533,000 $21,904,000 I

I D:\FTMCCOY/IPDCMSI\TABS-11. March 1996 I Fort McCoy Draft Corrective Measures Study Report

I TABLE S-12

CORRECTIVE MEASURES ALTERNATIVES COMPARISON I CLOSED LANDFILL 4 FORT MCCOY, WISCONSIN

I Evaluation Criteria Alt#l Alt#l Alt#3 Alt#4

Effectiveness Should be Should be Only effective if Only effective if all I (performs intended effective effective complete removal of waste mass can function) of waste achieved be satisfactorily (Section 5.9.3.4) treated I (Section 5.9.3.5) Implementability Implementable Implementable May not be fully May not be fully and Reliability (can and reliable and reliable implementable; is implementable; I be done and will it reliable concern with long- last/ perform over (Section 5.9.3.4) term reliability the long-term) (Section 5.9.3.5) I Operation and Low Medium Low Low Maintenance (O&M) Cost

I Safety Concerns Low Low Medium Medium During Construction/ I Implementation Environmental Adequately Adequately Adequately Adequately Concerns addresses addresses addresses concerns addresses concerns concerns in concerns in in Section 5.7.5 in Section 5.7.5 I Section 5.7.5 Section 5.7.5

Human Health Adequately Adequately Adequately Adequately Concerns addresses addresses addresses concerns addresses concerns I concerns in concerns in in Section 5.7.5 in Section 5.7.5 Section 5.7.5 Section 5.7.5 I Institutional Addresses Addresses Addresses Addresses Concerns institutional institutional institutional control institutional control control needs control needs needs identified in needs identified in identified in identified in Sections 5.7.5 and Sections 5.7.5 and I Sections 5.7.5 and Sections 5.7.5 and 5.9.2 5.9.2 5.9.2 5.9.2 I Cost $477,000 $2,742,000 $16,533,000 $21,904,000 I I I

I D:IFTMCCOY/IPDCMSJ\TABS-/2.NEW March 1996 I Fort McCoy Draft Corrective Measures Study Report I 6.3.3 Surfieial Soils ,, Surficial soils in the PDS are of the Tarr series. This is a poorly-graded fine to mediwn sand, mostly derived from outwash, generally found on stream terraces and valley slopes. I 6.3.4 Geology The only geologic unit in the area is the Quaternary alluviwn. In this area, the alluviwn consists of fine to mediwn-grained, poorly-graded stratified sand (SP) that had been transported and deposited I by local meandering streams. Bedrock was not encountered during investigative activities in this area. The depth to bedrock is not known in the area. The sandstone bedroclc overlying Fort McCoy I is described in Section 2.4.4 of this CMSR. 6.3.5 Hydrogeology

I Five wells were installed near the PDS to measure the water table elevation, perform hydraulic conductivity testing, and collect groundwater samples for chemical analysis. Well locations are I shown in Figure 6-2. Wells OW-113, OW-114, OW-115, P-139A, and OW-139B are all screened in the Quaternary alluviwn. The Quaternary alluviwn was the only stratigraphic unit analyzed in I this investigation. The water table, approximately 23 feet below the ground surface, has a hydraulic gradient of approximately 0.005 ft/ft to the west. The mean field hydraulic conductivity (K.) for the alluviwn I is 0.042 em/sec. The PDS is a groundwater recharge area. I 6.4 SITE CONCEPTUAL MODEL Figure 6-3 illustrates the site conceptual model for the PDS. The primary contaminated mediwn in the area was soil potentially contaminated from discharges, container rinsing, or leaking drwns. I Pesticides, solvents, and inorganic compounds in the vadose zone may migrate to the groundwater with infiltrating rainwater. Migration of contaminants from the PDS toward the La Crosse River would be possible, as contaminants, if mobilized, could be transported along the direction of I groundwater movement. I 6.5 NATURE AND EXTENT OF CONTAMINATION Sampling and analysis of soil and groundwater at the PDS have occurred as part of the RFI. I Section 16.0 of the RFI Report describes the details of field activities and results.

Based on RFI Phase 1 soil sampling analytical results and a geophysical survey, it was decided to I conduct an interim removal action. Approximately 1,000 tons of soil and buried containers of various sizes were excavated and disposed in an approved RCRA landfill. After the drwns and containers were removed from the excavation, confirmation samples were collected for laboratory I analysis. Twenty-two samples were collected and analyzed for pesticides and metals. Analytical I results from these samples indicated the presence of pesticides (dieldrin, DDD, DDE, and DDT). I D:IFTMCCOYIIPDCMSIISEC170N.6 6-2 March 1996 Fort McCoy Draft Co"ective Measures Study Report

6.0 PESTICIDE DISPOSAL SITE

6.1 DESCRIPTION OF PESTICIDE DISPOSAL SITE I The Pesticide Disposal Site (PDS) is located in the NE 114 of the NW 114 of Section 14, T18N, R3W, Monroe County, Wisconsin, approximately 1,000 feet west of the La Crosse River, along the southeast perimeter of the North Impact Area (Figure 6-1 ). The PDS is approximately 112 mile I northwest of the northern portion of the cantonment area. I 6.2 WASTE MANAGEMENT ACTIVITIES The site was used as a pesticide burial ground from the mid to late 1940s, sometime after World War II, until1965 when the site was closed. Pesticides typically used during this period were DDT, I Diazinon, 2,4-D, Lindane, and Dieldrin. These pesticides were often applied in solution, with various organic solvents used as carriers. As described in Section 6.5, approximately 1,000 tons of I PDS soil and waste were removed and disposed off-site. 6.3 PHYSICAL SITE CHARACTERISTICS

This subsection describes the physical setting of the PDS based on information presented in the RFI I Report. 6.3.1 Site Setting I The PDS is situated along the southeastern perimeter of the North Impact Area, near an earthen berm which marks the boundary of the impact area (Figure 6-2). The surrounding area is generally flat and dominated by grasses interspersed with scrub oak and jack pine woody vegetation. Grasses I constitute the predominant vegetation. The site was littered with various metal debris and fencing removed for the RFI work. Nearby relic vehicles and piles of debris remain in various stages of I decay. No facilities such as buildings, waste disposal units, or general use areas are near the PDS due to its location within the perimeter of the North Impact Area. The area is generally not used for human I activities. A gravel road near the PDS is an entry point into the impact area. I 6.3.2 Topography and Drainage

The PDS is mainly flat, except for the berm separating it from the area immediately to the southeast, I which lies outside the North Impact Area. The land surface slopes gently to the west-southwest, with a gradient of approximately 0.02 ft/ft as shown in Figure 6-2. The elevation of the area is approximately 878 feet MSL. There is little runoff, due to the high permeability of the surficial I soils, and what runoff there is flows towards the La Crosse River. I • D:IF1MCCOYIV'DCMSIISEC110N.6 6-1 March 1996 ~~==~~------~f -...... jACKSON COU~T!

N

I I

I ~ PESTICIDE ; DISPOSAL SITE I I

CLOSED I..ANDFlU. 2 I a.oseo LANDFILL 4 - ClOSED LANDFILl. 3 'I I I I I I

0 1/2 I 2 MILES \ SCALE SOURCE: WISCONSIN DEPARTMENT OF TRANSPOR;ATION --- I MAR. 1996 FIGURE 6-1 18903 PESTICIDE DISPOSAL SITE .....ENVIRONMENT & LOCATION MAP I I~U~I INFRASTRUCfURE DRAFT CORRECTIVE MEASURES STUDY I FORT McCOY, WISCONSIN . 'C <'D "'.... Q) "';a c. IC I :::1 I

I *EL=B59 D4 lOWIJSfll

OWIJ9B I J PIJtA

SOIL SAMPLES WERE COLLECTED FROM THIS AREA DURING I THE RFI.

I + I

\ I \ \ . \ I \\

I N

LEGEND I -•••--. TOPOGRAPHIC CONTOUR GROUNDWATER CONTOUR 865. so- ~~g~~N9N T~MR~~~~~Wf LEVEL I ------g~~~~f~~~TER FLOW OJEXISTING GROUNDWATER MONITORING WELL INOICAT lNG THE GROUNDWATER TABLE IN -C FEET ABOVE MEAN SEA LEVEL NOTES: 0' 30' 60' I. GROUNDWATER TABLE ELEVATIONS AND CONTOURS *WilSB GROUNDWATER MONITORING ARE DERIVED FROM THE RFI PHASE 3 INVESTIGATION. P1JSA WELL NEST SCALE ------=- -

MAR. 1996 FIGURE 6-2 18903 PESTICIDE DISPOSAL SITE .._..ENVIRONMENT & GROUNDWATER MONITORING WELL LOCATIONS I AND WATER TABLE MAP ~~~~ INFRASTRUCfURE DRAFT CORRECTIVE MEASURES STUDY FORT McCOY, WISCONSIN I I Fort McCoy Draft Co"ective Measures Study Report I 6.3.3 Surficial Soils ,, Surficial soils in the PDS are of the Tarr series. This is a poorly-graded fine to medium sand, mostly derived from outwash, generally found on stream terraces and valley slopes. I 6.3.4 Geology The only geologic unit in the area is the Quaternary alluvium. In this area, the alluvium consists of fine to medium-grained, poorly-graded stratified sand (SP) that had been transported and deposited I by local meandering streams. Bedrock was not encountered during investigative activities in this area. The depth to bedrock is not known in the area The sandstone bedrock overlying Fort McCoy I is described in Section 2.4.4 of this CMSR. 6.3.5 Hydrogeology

I Five wells were installed near the PDS to measure the water table elevation, perform hydraulic conductivity testing, and collect groundwater samples for chemical analysis. Well locations are I shown in Figure 6-2. Wells OW-113, OW-114, OW-115, P-139A, and OW-139B are all screened in the Quaternary alluvium. The Quaternary alluvium was the only stratigraphic unit analyzed in I this investigation. The water table, approximately 23 feet below the ground surface, has a hydraulic gradient of ,, approximately 0.005 ftlft to the west. The mean field hydraulic conductivity (K) for the alluvium is 0.042 em/sec. The PDS is a groundwater recharge area. I 6.4 SITE CONCEPTUAL MODEL Figure 6-3 illustrates the site conceptual model for the PDS. The primary contaminated medium in the area was soil potentially contaminated from discharges, container rinsing, or leaking drums. I Pesticides, solvents, and inorganic compounds in the vadose zone may migrate to the groundwater with infiltrating rainwater. Migration of contaminants from the PDS toward the La Crosse River would be possible, as contaminants, if mobilized, could be transported along the direction of I groundwater movement. I 6.5 NATURE AND EXTENT OF CONTAMINATION Sampling and analysis of soil and groundwater at the PDS have occurred as part of the RFI. I Section 16.0 of the RFI Report describes the details of field activities and results.

Based on RFI Phase 1 soil sampling analytical results and a geophysical survey, it was decided to I conduct an interim removal action. Approximately 1,000 tons of soil and buried containers of various sizes were excavated and disposed in an approved RCRA landfill. After the drums and containers were removed from the excavation, confirmation samples were collected for laboratory I analysis. Twenty-two samples were collected and analyzed for pesticides and metals. Analytical I results from these samples indicated the presence of pesticides (dieldrin, DDD, DDE, and DDT). I D:IF1MCCOYJIPDCMSJISECTION.6 6-2 March 1996 I D'r------~ I

I '0 "'Ul ~a Q c. WEST EAST ;,.., I c. X Q.l.., I ~ iO 1.0en

0 I !l? ~ FORMER AND tn PESTICIDE LANDFILL SOIL BERM I GRAVEL ROAD I I I I

ij GROUNDWATER FLOW DIRECT ION I I I I NOTE: SEE FIGURE 6-2 FOR LOCATION OF. GROUNDWATER MONITORING WELLS. SCALE: NTS

I MAR. 1996 FIGURE 6-3 18903 ftll ..._.ENVIRONMENT & PESTICIDE DISPOSAL SITE I I~U~I INFRASTRUCTURE SITE CONCEPTUAL MODEL DRAFT CORRECTIVE MEASURES STUDY I FORT McCOY, WISCONSIN I Fort McCoy Draft Co"ective Measures Study Report I An additional 5 feet of soil was then removed from the excavated area and an additional 15 confirmation samples were collected and analyzed for the same parameters. Analytical results from this second round of confirmation sampling indicated that pesticide contamination was still I present in some areas of the excavation. An additional 2 feet of soil was excavated from the areas where pesticides were detected. Following this additional excavation, to a depth of approximately 12 feet below the natural ground surface, samples were collected at depths of 12 feet, 15 feet, and I 19 feet. Pesticides were still detected at three locations above the approved action level of8.4 mg/kg (dieldrin). The excavation was lined with 6-mil polyethylene sheeting and backfilled with approximately 800 cubic yards of clean soil. Backfill was supplied by Fort McCoy. No seeding of I the area was performed.

Groundwater analytical results both before (Phase 1) and after (Phases 3, 4, and 5) the interim I removal action indicate that PCE and lindane exceed PALs and ESs. PCE was detected above the ES in only well OW-115. Lindane has only been detected in well OW-115. A summary of I groundwater monitoring results is presented in Table 6-1. I 6.6 CONTAMINANT FATE AND TRANSPORT Due to the sandy soil, flat low slope terrain, and lack of vegetation over the PDS, contaminant transport is limited primarily by water solubility. PCE moves readily through soil and groundwater I while lindane is less water-soluble. Based on RFI results, it appears PCE and lindane have migrated through the soil and tothe groundwater at PDS. However, due to the removal of the source material as described in Section 6.5, it is expected that groundwater contaminant concentrations should I decrease over time. With the exception of well OW-115, this is occurring. Additional groundwater sampling at and around OW-115 will be performed to evaluate lindane and PCE concentration I trends. 6.7 DEVELOPMENT OF CORRECTIVE ACTION OBJECTIVES

I 6.7.1 Introduction I The purpose of this section is to identify potentially applicable soil and groundwater contaminant levels for COCs identified in the RFI Report for the PDS. These soil and groundwater contaminant limits are based on public health and environmental criteria, information gathered during the RFI, I and applicable WDNR and USEPA regulations. These soil and groundwater contaminant limits will be considered during the identification and development of appropriate corrective action I technologies and alternatives. The COCs identified in the RFI for groundwater and soil at the PDS are:

I Chemical of Potential Concern

Tetrachloroethene (groundwater) I Trichloroethene (groundwater) I gamma-BHC (lindane) (groundwater) I D:IFIA-K:COYJIPDCMSJISEC170N.6 6-3 March 1996 - .. \_ ...... , ...... ·~ .. ,~ ...... Fort McCoy - -' Draft Corrective Measures Study Report TABLE6cl

GROUNDWATER QUALITY SUMMARY PESTICIDE DISPOSAL SITE FORT MCCOY, WISCONSIN

Well113<'l Analytes Detected at Well114 Well115 Weii139A Weii139B Levels Exceeding NR 140 Public Health Sampling Event Sampling Event Sampling Event Sampling Event Sampling Event Standards I 2 3 4 5 I 2 3 4 5 I 2 3 4 5 I 2 3 4 5 I 2 3 4 5 PAL ES Tetrach loroethene 2J NS ------2J NS 1.2B -- -- 8.0 NS 6.1B 11.0 15 NS NS 0.8B -- NS NS l.IB -- 0.5 5.0 ' -- -- Trichloroethene -- NS -- 3.1 -- -- NS ------NS ------NS NS ------NS NS ------0.5 5.0 Lead -- NS ------NS ------NS ------NS NS -- 4.0 -- NS NS -- 5.0 -- 1.5 15.0 Gamma-BHC -- NS ------NS ------1.90 NS 0.65 2.7 7.3 NS NS ------NS NS ------0.02 0.2 (Lindane) Mercury -- NS -- 1.4B -- -- NS ------NS -- l.IB -- NS NS -- LOB -- NS NS -- LOB -- 0.2 2.0 Nitrate+ Nitrite -- NS ------NS ------NS ------NS NS -- 2,100 -- NS NS -- 2,000 -- 2,000 10,000 NOTES:

All values in ug/1. ES Enforcement Standard NS Well not sampled due to well not installed by the sampling event or access to area was restricted. PAL Preventive Action Limits (I) Wellll3 is the upgradient well. Sampling Event I - Phase I RFI, April- May 1992 J Estimated value. Sampling Event 2 - Phase 2 RFI, October- November 1992 B Analyte detected in field blank. Source of mercury was acid used to preserve samples analyzed for metals in Event 4. Sampling Event 3 - Phase 3 RFI, May - August 1993 D Sample diluted. Sampling Event 4- Interim Monitoring, July 1994 -- Analyte not detected at level exceeding the PAL. Sampling Event 5 - Interim Monitoring, June 1995

/):\FTAJCCOY/II'/X"Jo..JSI\TAB6~1 March 1996 I Fort McCoy Draft Co"ective Measures Study Report

I 4,4 DDT (soil) Lead (groundwater) I Nitrate +Nitrite (groundwater) The above compounds were selected as COCs based on any one of the following:

I • COC equals or exceeds an NR 140 PAL in groundwater samples collected from a downgradient monitoring well.

I • COC is a primary contributor to calculated human health risks associated with groundwater I exposure pathways under hypothetical future residential use risk scenario at the PDS. • COC is a primary contributor to calculated human health risks associated with soil exposure J, pathways under hypothetical future residential use risk scenario at the PDS. 6.7.2 Federal Regulations and Permits

I 6.7~2.1 Groundwater Standards

The established Safe Drinking Water Act Maximum Contaminant Levels (MCLs) for COCs at the I PDS are presented below.

Federal MCL I Chemical of Potential Concern uWJ.

Tetrachloroethene 5 I Trichloroethene 5 gamma-BHC (lindane) 0.2 I 4,4DDT N/A Lead 15(!) I Nitrate + Nitrite 10,000 NOTE: N/A= No MCL available I 0 > No MCL; Federal Action level 6.7.2.2 Soil Standards

I There are no federal soil quality standards that apply with respect to soil cleanup objectives I 6.7.2.3 Surface Water Standards Surface water standards are contained under 40 CFR 122.2 The Clean Water Act. These standards t address point source discharges and are not directly applicable to measurable surface water quality.

D:IFTMCCOY/1PDCMSJISEC170N.6 6-4 March 1996 Fort McCoy l Draft Co"ective Measures Study Report

6. 7.3 Wisconsin Regulations and Permits I 6.7.3.1 Groundwater Standards I Wisconsin has implemented the Safe Drinking Water Act under NR 809 WAC and has either adopted the federal standard or developed a more stringent level. Groundwater quality standards are published in NR 140 WAC. The groundwater quality standards consist of PALs and ESs. The I PALs, ESs, and the Wisconsin MCLs for COCs at the PDS are listed below. I PAL ES Wisconsin MCL Chemical of Potential Concern u~ u~ u~/1 I Tetrachloroethene (PCE) 0.5 5 5 Trichloroethene (TCE) 0.5 5 5 gamma-BHC (lindane) 0.02 0.2 0.2 ,I 4,4 DDT N/A N/A N/A Lead 1.5 15 N/A ,- Nitrate + Nitrite 2,000 10,000 10,000 NOTE: N/A =No standard available 1 6. 7.3.2 Soil Quality Standards I WDNR has issued NR 720 regulations which address residual soil contaminant levels. A human health and environmental assessment was completed and approved for the PDS. Contaminant concentration limits for soil resulting from that assessment and evaluation of the NR 720 regulations I are discussed in Section 6. 7 .6.

6.7.3.3 Surface Water Standards I

Surface Quality Standards are contained in NR 102-105 WAC. Surface water standards for the COCs were not exceeded. This SWMU is over 1,000 feet from the nearest watercourse, the I LaCrosse River.

6. 7.4 Local Regulations and Permits I There are no local regulations or permits which contain soil or groundwater cleanup objectives. I 6. 7.5 Human Health and Environmental Assessment I A human health assessment of potential risks was completed for PDS using Phase 1 and Phase 2 RFI data (SEC Donohue, November 1994). As required by USEPA and WDNR, potential exposure scenarios were evaluated and include scenarios involving residents and trespassers at PDS. An I interim stabilization action resulted in removal of most chemicals at the PDS. COCs which contribute to excess risk based on hypothetical residents living at the PDS include the following: I

D:IF7MCCOYJIPDCMSJISECTJON. 6 6-5 March 1996 Fort McCay Draft Corrective Measures Study Report I Chemical Media Affected I 4,4DDT Soil As stated in 40 CFR 300.430(e)(2)(i)(A)(2) of the National Contingency Plan (NCP), "for known or suspected carcinogens, acceptable exposure levels are generally concentration levels that represent I an excess upper bound lifetime cancer risk to an individual of between 104 (1 in 10,000) and 10-6 (1 in 1,000,000) using information on the relationship between dose and response." In addition, USEPA's Office of Solid Waste and Emergency Response (OSWER) Directive No. 9355.0-49FS I (Presumptive Remedy for CERCLA Municipal Landfill Sites) (see Appendix D), it is stated "that based on site-specific conditions, an active response is not required if groundwater contaminant concentrations exceed chemical-specific standards but the site risk is within the Agency's acceptable I risk range (104 to 10-li)." Therefore, consistent with Sections 5.1 and 5.2 of the approved human health risk assessment, for the purpose of discussion in the CMS Report, excess risk is defined as I total excess cancer risk levels to any population exceeding 104 and noncarcinogenic hazard index (HI) greater than 1E+OO (1.0).

I This identification of COCs which contribute to excess risk based on the hypothetical scenario of residents living at the PDS is presented since this scenario was one of the criteria used to include a SWMU in the CMS. This residential scenario assumes both daily contact and consumption of soil I and groundwater at the site 350 days per year for a period of30 years. However, it should be noted that there are several institutional controls that would prevent residential development on the PDS. I These controls include: • NR 812.08 prohibits the installation of new water supply wells within 1,200 feet of a solid waste I site. • The PDS is expected to remain the property of the U.S. Army and continue to have associated I access restrictions. The PDS is located within Fort McCoy's North Impact Area. • Ifthe PDS does not remain the property of the U.S. Army, restrictive covenants could be written I into a site property deed to notify a prospective purchaser of the location and source of solid waste/contamination and that groundwater use must be restricted.

I Therefore, the residential scenario will not be considered applicable to this SWMU. The most likely exposure scenario would be that of a trespasser at the SWMU. This scenario assumes 16 trespassing events a year to the SWMU for 9 years with ingestion of and contact with soil. Contact with or I ingestion of groundwater does not apply to a trespasser. As concluded in the human health assessment, trespassers at the SWMU are not exposed to excess health risks based upon existing soil 4 contaminant concentrations as detected during the RFI (carcinogenic risk = 2E-06<10 ; HI = I 1E-01 <1.0). .

Field assessment at the PDS indicate that most of the ecological risks were eliminated during the I interirp removal action. I I D:IFTMCCOYJIPIXMSJISFC770N.6 6-6 March 1996 Fort McCoy Draft Co"ective Measures Study Report

6. 7.6 Soil Corrective Action Objectives I

For the purpose of addressing proposed NR 720.19, it is proposed that existing soil contaminant levels be considered acceptable for residual soil contaminant levels. Based on the health assessment I results using the trespasser scenario, existing soil contaminant levels do not create an excess health risk. The actual measured groundwater contaminant concentrations which indicate isolated exceedances of NR 140 groundwater standards (see Table 6-1) preclude the need to calculate I predicted groundwater concentrations. Given the removal of the contents of the PDS, it is expected that groundwater contaminant concentrations should decrease over time. In addition, the environmental assessment did not indicate a presence of an ecological risk due to the existing soil I contaminant levels. I 6.7.7 Groundwater Corrective Action Objectives

Site-specific groundwater objectives identified for the PDS were developed from reviewing the I Federal MCLs, Wisconsin MCLs and Wisconsin groundwater standards (PALs and ESs).

The following paragraph is based on excerpts from 57FR31780 and 31797 (pages 31780 and 31797 I ofthe July 17, 1992, Federal Register): The Safe Drinking Water Act (SDWA) requires USEPA to publish maximum contaminant level goals (MCLGs) for contaminants which may have any adverse effect on the health of persons and which are known or anticipated to occm in public water systems. I MCLGs are to be set at a level at which no known or anticipated adverse effects on the health of perso~s occur and which allows an adequate margin of safety. At the same time the USEPA publishes a MCLG, it must also promulgate a National Primary Drinking Water Regulation which I includes either 1) a MCL, or 2) a required treatment technique. An MCL must be set as close to the MCLG as feasible. Under the SDWA, "feasible" means "feasible with the use of the best · · technology, treatment techniques, and other means which the Administrator finds, after examination I for efficacy under field conditions and not solely under laboratory conditions (taking cost into consideration)." Other technology factors that are considered in determining the MCL include the I ability of laboratories to measure accurately and consistently the level of the contaminant with available analytical methods. I As presented in 6.7.2 and 6.7.3 above, ESs are generally equal to federal and Wisconsin MCLs. Since the ESs are generally the same as corresponding MCLs, they inherently represent the lowest possible contaminant concentrations "technically and economically feasible" as required by I NR 140.24(2). However, since WDNR interprets State of Wisconsin law to require that PALs be the goal of groundwater remediation, PALs are proposed as the appropriate groundwater objectives which means corrective measures will be developed to attempt to reduce groundwater contaminant I r concentrations to levels less than the PAL. The selected groundwater objectives for COCs are presented below. I I I D:1FIMCCOYJIPDCMSJISEC710N.6 6-7 March 1996 I I Fort McCoy Draft Co"ective Measures Study Report

I PAL Chemical of Potential Concern .(yil.U

I Tetrachloroethene(PCE) 0.5 Trichloroethene (TCE) 0.5 Nitrate + Nitrite 2,000 I Lead 1.5 gamma-BHC (lindane) 0.02 I 4,4DDT *

I NOTE: *No PAL or MCL established; no excess risk identified for groundwater exposure. The COCs to be addressed in the following technologies and alternatives sections will be those t· COCs detected in groundwater at the PDS at levels equal to or exceeding the PAL in downgradierit monitoring wells as noted above.

I 6.8 CORRECTIVE MEASURES TECHNOLOGIES I 6.8.1 Introduction In this section, applicable corrective action technologies are identified for contaminant source material and groundwater based on an evaluation of contaminants detected. Medium-specific I corrective action objectives developed in Section 6. 7 were evaluated and appropriate general response actions were identified that satisfy the corrective action objectives. Applicable technologies were then identified for each general response action as listed in Table 6-2 and · I discussed in Sections 6.8.2 and 6.8.3.

Relevant site-specific conditions were considered in the identification of corrective action I technologies to be retained for consideration in developing corrective action alternatives. Corrective action objectives were reviewed and applicable technologies were selected based on past experience I and verified performance information. The identified technologies that have proven effectiveness for the media and COCs and can be practically implemented, operated, and maintained given site­ specific conditions, are identified as being retained for consideration in developing corrective action I alternatives. Table 6-2 identifies which technologies have been retained for consideration in developing the corrective action alternatives presented in Section 6.9.

I 6.8.2 Identification of Applicable Source Material Technologies I 6.8.2.1 Source Material Institutional Actions Fencing

I A chain link fence (6 feet tall) with lockable gates could be constructed around the source area to I restrict site access and disturbance of source material. Fencing would reduce the potential for I D:IFTM::COYJIPDCMSJISECTION.6 6-8 March 1996 I Fort McCoy Draft Corrective Measures Study Report

I TABLE6-2

PESTICIDE DISPOSAL SITE CORRECTIVE ACTION OBJECTIVES, GENERAL RESPONSE ACTIONS I AND CORRECTIVE MEASURES TECHNOLOGIES I FORT MCCOY, WISCONSIN Corrective Measures Technologies Retained Corrective Action Objectives General Response Actions Technologies Considered for Further Evaluation

I Prevent site access to source Institutional . Fencing Yes material . Land Use Restrictions Yes I Reduce concentrations of COCs Institutional . Groundwater Use Restrictions Yes in groundwater to levels below . Groundwater Monitoring Yes NR 140 PALs, and limit groundwater use ' Containment . Low-Permeability Barrier No<'> I . Hydraulic Barrier Yes Removal . Extraction Wells Yes I . Collection Trenches No Treatment . Biological Treatment No O> • Carbon Adsorption Yes<'> • Air Stripping Yes<'> I . Air Sparging!Soil Vapor No<'> Extraction • Chemical Precipitation Yes O> I . Yes 0 > . Natural Attenuation Yes Discharge . POTW Yes I . Surface Water No I NOTE: (I) These technologies have additional information and illustrations provided in Appendix C in addition to the descriptions I presented in Sections 6.8.2 and 6.8.3. I I I I I

I D:IF7MCCOY/IPIXMSJ\TAB6-2 March 1996 I Fort McCoy Draft Co"ective Measures Study Report

I ingestion of or direct contact with source material. nie construction and maintenance costs for fencing are considered low in comparison to the other technologies evaluated. Fencing will be retained for consideration in developing corrective action alternatives. It should be noted that the I source area is already located within the secured North Impact Area. I Land Use Restrictions Land use restrictions would be implemented to minimize the potential for human contact with source I material. Restrictive covenants could be placed on deeds to the SWMU property to limit the potential for land development, source material disturbance, and cover (if implemented) intrusions. Restrictive covenants, written into a site property deed, notify any potential purchaser of the property I that contamina~ media remain on-site, and that the land use must be restricted. If enforced, deed . restrictions would reduce the potential for the ingestion or direct contact with contaminated source material. It is anticipated that deed restrictions at SWMUs would limit excavation. The I effectiveness of deed restrictions depends on continued enforcement. Deed restrictions are subject to changes in political jurisdiction, legal interpretation, and level of enforcement. Administration of land use restrictions would be the only cost, but would remain perpetually. Land use restrictions I will be retained for consideration in developing corrective action alternatives. I 6.8.3 Identification of Applicable Groundwater Technologies 6.8.3.1 Groundwater Institutional Actions

I Groundwater Use Restrictions

Groundwater use restrictions would be imposed to prevent the use or installation of new private · I wells and public drinking water supply wells within the source area (including downgradient contamination). Either voluntary or legal restrictions (or both) on groundwater may apply. I Voluntary groundwater use restrictions are restrictive covenants written into a site property deed to notify any purchaser of the location and source of groundwater contamination and that groundwater use must be restricted. Legal groundwater use restrictions would involve notifying the WDNR I Bureau of Water Supply of the groundwater impacts. The Bureau keeps maps and lists of sites with groundwater impacts; however, it is the responsibility of the well driller to be apprised of specially I designated areas. NR 812.08 prohibits the installation of new water supply wells within 1,200 feet of a solid waste site. Both voluntary and legal groundwater use restrictions depend on enforcement for their I effectiveness. Relative costs for groundwater use restrictions are low. Groundwater use restrictions will be retained for consideration in developing corrective action alternatives.

I Groundwater Monitoring I Groundwater monitoring using monitoring wells would be continued at the PDS to track groundwater quality and the effectiveness of other remediation technologies. Groundwater I monitoring is a commonly used method to determine groundwater quality. Monitoring consists of I D:'IFTACCOYJIPIXMSJISFX:TION.6 6-9 March 1996 Fort McCoy I Draft Co"ective Measures Study Report collecting groundwater samples from monitoring wells and analyzing those samples to. define I contaminant migration or establish increasing or decreasing concentration trends over time. Laboratory analysis detection limits will be set low enough to determine if the PALs have been exceeded. If the PAL is below the lowest detection limit, the lowest detection limit commercially I available will be utilized for evaluating groundwater standard exceedances. Relative capital costs are low; O&M costs are moderate. Groundwater monitoring will be retained for consideration in developing corrective action alternatives. I 6.8.3.2 Groundwater Containment Actions I Low-Permeability Barriers I Low-permeability barriers can be an effective component of a groundwater containment system. The barriers can consist of a soil, bentonite and water mixture, cement and water mixture, or sheet piling and would probably be located downgradient of the PDS. They are most effective if keyed several I feet into a low permeability layer such as relatively impermeable bedrock or clay. However, a low­ permeability barrier alone will only divert groundwater flow, it will not contain it. To contain groundwater, the groundwater that flows up to and then around or under the barrier must be collected I by extraction wells or collection trenches and subsequently treated and discharged. Relative costs for low-permeability barriers would be high given the need for specialized equipment, materials and procedures to construct a barrier. Given the lack of a low-permeability layer at the PDS to key into, I low-permeability barriers will not be retained for consideration in developing corrective action alternatives. I Hydraulic Barriers I Hydraulic barriers would be used to minimize migration of contaminated groundwater. A hydraulic barrier would consist of a series of extraction wells or collection trenches. Extracted groundwater would require treatment or pretreatment prior to discharge. Relative capital costs are low to I moderate, O&M costs (pumping system and well maintenance) are moderate. Hydraulic barriers will be retained for developing corrective action alternatives. I 6.8.3.3 Groundwater Removal Actions

Extraction Wells I

Extraction wells would be used to collect impacted groundwater. Generally, extraction wells would be drilled and screened in a highly permeable water-bearing zone. The wells are fitted with a pump I to extract groundwater and create a negative pressure zone to promote flow towards the well. Relative capital costs for extraction wells are low to moderate; O&M costs are moderate. Extraction I wells will be retained for developing corrective action alternatives. I I

D:IFTMCCOYIIPDCMSJISEC710N.6 6-10 March /996 I I Fort McCoy Draft Corrective Measures Study Report I Collection Trenches

Collection trenches may be used in place of extraction wells for collecting impacted groundwater I and may be very effective, depending on the hydrogeology of the site. Collection trenches are also used frequently in lowering the local water table and controlling the direction of groundwater flow at a site. Extracted groundwater would require treatment prior to discharge. Relative capital co.sts I for collection trenches are generally low to moderate; O&M costs are moderate.

Collection trenches will not be retained for developing corrective action alternatives here due to I constructability difficulties in the saturated sandy soils and questionable effectiveness in the high permeability sandy soils. The saturated sandy soils would make construction of a collection trench difficult and costly due to stability/sloughing potential. Even if a trench would be constructed at the I PDS, it would have reduced effectiveness since collection trenches operate on the basis of permeability differential. Groundwater generally prefers flow from areas of low permeability (silts, I clay) to areas of high permeability (sands, gravels). Since the area at the PDS already naturally contains a high permeability material (sands), the effectiveness of a collection trench at the PDS would be reduced since there would be minimal difference in the permeability of the native material I (sands) and the collection trench material (sands). This would result in only partial capture of the groundwater moving past the PDS.

I 6.8.3.4 Groundwater Treatment Actions I Biological Treatment On-site biological treatment of extracted groundwater may use either an attached or suspended­ growth biological treatment process. In suspended growth systems such as activated sludge I processes (ASP), contaminated groundwater is circulated in a mixing basin where a microbial population aerobically or anaerobically degrades organic matter and produces new cells. The new cells form a sludge, which is settled out in a clarifier, and a portion of the sludge biomass is recycled I to the mixing basin. A portion of the sludge is continuously wasted, to be further treated prior to solids disposal, generally at a landfill. In attached growth systems, such as rotating biological I contactors and trickling filters, microorganisms are established on an inert support matrix to aerobically or anaerobically degrade groundwater contaminants. Attached growth processes produce I less sludge than ASPs. Attached and suspended systems often are used together in. series. Biological treatment is used primarily to treat nonhalogenated VOCs, SVOCs and petroleum hydrocarbons. Halogenated VOCs (PCE, TCE), SVOCs and pesticides also can be treated, but the I process may be less effective and may be applicable only to some compounds within these groups. Relative capital costs for biological groundwater treatment are moderate to high; O&M costs are high. Biological treatment will not be retained for developing corrective action alternatives given I that it is less effective than air stripping at removing low levels of halogenated VOCs. I I I D:IF7MCCOYJIPDCMSJ'SEC170N.6 6-11 March 1996 Fort McCoy I Draft Corrective Measures Study Report Carbon Adsorption I

Carbon adsorption would remove organic compounds that preferentially sorb onto carbon versus water. On-site carbon adsorption of extracted groundwater would involve piping extracted I groundwater/leachate through a series of canisters containing activated carbon to which dissolved organic contaminants adsorb with subsequent discharge of the treated water. The technology requires periodic replacement or regeneration of saturated carbon which increases the cost of this I. technology.

The target contaminant groups for carbon adsorption (liquid phase) are halogenated and I nonhalogenated SVOCs. The technology can be used, but may be less effective in treating halogenated VOCs (PCE, TCE), fuel hydrocarbons, pesticides, and inorganics. Relative capital costs are moderate to high; O&M costs are moderate to high. Carbon adsorption will be retained for I consideration in developing corrective action alternatives due to the presence of pesticides. I Air Stripping

Air stripping would involve pumping of extracted groundwater into an air stripping vessel which I uses air and water mixing to remove or strip VOCs. Types of aeration methods include packed towers, diffused aeration, tray aeration, and spray aeration. The treatment system could be located in a building at or adjacent to the PDS. I

The target contaminant groups for air stripping systems are halogenated (PCE, TCE) and nonhalogenated VOCs. Removal efficiencies around 99 percent can be achieved for these types of I contaminants. The technology can be used, but may be less effective for halogenated and nonhalogenated SVOCs and fuels. Relative capital costs for air stripping are moderate; O&M costs · are low, unless vapor-phase carbon is needed (moderate if needed) to treat the exhaust air stream. I Air stripping will be retained for consideration in developing corrective action alternatives.

Air Sparging/Soil Vapor Extraction I Air would be injected under pressure below the water table to strip VOCs from I groundwater/leachate. Air sparging (AS) would be conducted in conjunction with a soil vapor extraction (SVE) system to remove stripped VOCs from the unsaturated zone. The ease and low cost of installing small-diameter air injection points allows considerable flexibility in the design and I construction of a remediation system. Relative capital costs for air sparging are low to moderate; O&M costs are low unless vapor-phase carbon is needed (moderate if needed) to treat the exhaust air stream. AS/SVE sparging will not be retained for consideration in developing corrective action I alternatives since if groundwater treatment is required, it will probably need to be done ex-situ to address the pesticide and inorganic contaminants. I Chemical Precipitation

On-site chemical precipitation of extracted groundwater would be used for removing inorganic I contaminants as pretreatment for other processes or to address discharge limits for inorganics. I D:IF1MCCOYIIPDCMSJ'SEC170N.6 6-12 March 1996 I I Fort McCoy Draft Co"ective Measures Study Report

I Precipitation is a process by which the chemical equilibrium of a waste stream is altered to reduce the solubility of metals. The metals precipitate out as a solid phase (sludge) and are taken out of the solution by solids removal processes. Metals precipitation is not one unit operation but a I combination of coagulation, flocculation, sedimentation, and, in some cases, filtration processes. Relative capital costs are moderate; O&M costs are moderate to high due to sludge processing and I off-site disposal. Chemical precipitation will be retained for consideration in developing of corrective action alternatives. I Phytoremediation Phytoremediation is the use of plant root systems for subsurface in-situ remediation. I Phytoremediation acts through two fundamental processes; in-situ biodegradation through enhancement of oxidation rates, and phytoextraction (removal of compounds) (Vance, 1996). As presented in the literature included in Appendix C, phytoremediation can remediate soil and I groundwater to depths of 30 feet or more. Inorganic and organic chemicals, including pesticides, can be absorbed through the root system of plants including trees. Planting costs have been estimated to be in the range of $10,000 per acre, with monitoring costs parallel to those associated I with other remediation technologies (Vance, 1996). Phytorernediation at the PDS would consist of planting appropriate species of trees on and downgradient of the PDS. Phytoremediation will be I retained for consideration in developing corrective action alternatives. I Natural Attenuation Natural attenuation would consist of volatilization, biodegradation, recharge and dispersion, adsorption, and chemical reactions with subsurface materials to reduce groundwater contaminant I concentrations to acceptable levels. Non-destructive attenuation mechanisms include recharge and dispersion, and adsorption. The rest of the attenuation mechanisms are destructive to the contaminants. All of these processes are naturally occurring. Natural attenuation is effective I generally when contaminant concentrations are low, the contaminants have been in place for extended periods, and contaminant concentrations are steady or decreasing over time. Costs for natural attenuation are low since it is naturally occurring and the only costs associated with it are I related to monitoring activities. Once monitoring activities cease, natural attenuation becomes a no­ cost option. Natural attenuation will be retained for consideration in developing corrective action I alternatives. I 6.8.3.5 Groundwater Discharge Actions Publicly/Privately-Owned Treatment Work (POTW) I If groundwater extraction is required, POTW discharge would be implemented for groundwater in conjunction with extraction and possibly, treatment. Extracted or treated groundwater may be discharged to a POTW including the on-site WWTF via existing or new sewers or force main. I Pretreatment may be required before discharging to the POTW. Discharge to a POTW will be retained for consideration in developing correction action alternatives. I

I D:\F11.CCOYIIPOCMSIISEX:170N.6 6-13 March 1996 Fort McCoy I Draft Corrective Measures Study Report Surface Water I

If groundwater extraction is required, discharge to surface water would be implemented for groundwater in conjunction with extraction and treatment. Discharge to surface water involves the I piping of treated groundwater to an outfall at a surface water body such as the La Crosse River. The relative capital cost is distance-dependent, and thus would be low to moderate at the PDS, while O&M costs are relatively low. Discharge to the surface water will be retained for consideration in I developing corrective action alternatives.

6.9 CORRECTIVE MEASURES ALTERNATIVES I 6.9.1 Introduction I In this section, the applicable corrective action technologies identified in Section 6.8 for PDS source material and groundwater are further evaluated and assembled into corrective action alternatives. I Assembling suitable corrective action alternatives was an iterative process that systematically combined the retained technologies into alternatives that meet the corrective action objectives (see I Sections 6. 7.6 and 6. 7. 7) and are the most practicable for site-specific conditions. The first step of the process consisted of evaluating all pertinent combinations of retained technologies. The preliminary assemblage of alternatives was further evaluated to develop alternatives that were most I suitable for PDS considering the interaction of the selected technologies and site-specific conditions. Based on this evaluation, the most suitable corrective action alternatives were recommended to be carried forward in the CMS. I 6.9.2 Site-Specific Factors Affecting Development of Alternatives I The following factors related to the PDS were considered the most critical in developing corrective action alternatives: I • A removal action consisting of excavation and off-site removal of 1,000 tons of contaminated soil, drums and containers was performed at the time of Phase 1 of the RFI. I

• PDS is expected to remain the property ofthe U.S. Army and continue to have associated access restrictions. This will also aid in the establishment and enforcement of land use and I groundwater restrictions. The PDS is located within Fort McCoy's North Impact Area.

• Confirmation soil sampling perforqted after the removal action indicated that some limited areas I of residual pesticide (dieldrin, ODD, DOE, DDT and lindane) contamination remained at the PDS. It is estimated that there is relatively small volume of soil remaining containing pesticide concentrations at the PDS. I • PDS is located 1,000 feet west of the La Crosse River. I • Groundwater flow is toward the La Crosse River. I D:IF'IUXOYJ1PDCMSJISEC770N.6 6-14 March 1996 I I Fort McCoy Draft Corrective Measures Study Report I • There are no current groundwater receptors located between the PDS and the La Crosse River. • NR 812.08 prohibits the installation of new water supply wells within 1,200 feet of a solid waste I site.

• There is currently little runoff from PDS due to the flat topography and high soil infiltration I rate.

• Contaminants detected in groundwater at levels exceeding PALs are presented in Table 6-1. I PCE was detected above the ES only in well OW-115. Lindane has been detected only in well OW-115.

I • Pesticides detected in soil are generally insoluble in water and are not expected to be readily I mobile with infiltrating water. Based on these factors, it is recommended that the two corrective action alternatives identified and I discussed below be carried forward for evaluation in Section 6.9.3. 6.9.3 Description and Evaluation of Corrective Action Alternatives

I 6.9.3.1 Introduction

The following sections describe the two corrective action alternatives proposed for consideration and I present an evaluation of the alternatives based on technical, environmental, human health, and institutional criteria as required by Fort McCoy's RCRA Part B Permit. Table 6-3 identifies the I technologies in each of the two alternatives. 6.9.3.2 Corrective Action Alternative 1

I Alternative 1 I Access, Land, and Groundwater Use Restrictions, Natural Attenuation, I Groundwater Monitoring Alternative 1 consists of access, land and groundwater use restrictions; natural attenuation of low­ level groundwater contamination; and groundwater monitoring. These components are described I below:

• Existing access restrictions to PDS associated with the Fort McCoy facility would be I maintained. A chain-link fence could be constructed around the perimeter of the PDS (approximately 400 feet) to further restrict site access if deemed necessary at a later date due I to unauthorized access to and disturbance of the area. I I D:IFIMCCOYIIPOCMSJ'Lme170N.6 6-15 March 1996 I Fort McCoy Draft Corrective Measures Study Report

I TABLE6-3

PESTICIDE DISPOSAL SITE I CORRECTIVE MEASURES ALTERNATIVES COST ESTIMATE SUMMARY FORT MCCOY, WISCONSIN I Alternative #1 I I I I Extraction and Treatment X I I I I I I I I I I

I D:IF1MCCOYJIPDCMSJ\TAB~3 March 1996 I Fort McCoy Draft Co"ective Measures Study Report

I • Restrictive covenants would be placed on deeds to the PDS property to restrict land and groundwater use at the PDS.

I • Isolated detections of COCs in groundwater would be reduced to acceptable levels over time by natuml attenuation through volatilization, biodegradation, adsorption and chemical reactions within the subsurface environment. For a minimal additional cost, phytoremediation could be I implemented to supplement natural attenuation at the PDS. I • Groundwater monitoring would consist of semi-annual sampling and analysis of five existing groundwater monitoring wells (1 upgradient and 4 downgradient) located adjacent to PDS. The groundwater monitoring well locations are shown on Figure 6-2. Observation wells (OWs) are I screened across the water table.

Screened Interval I Monitorin" Well (feet below "round surface.) OW-113 (upgradient) 19-29 OW-114 19-29 I OW-115 19-29 OW-139A 46-51 I OW-139B 16-26 Compounds which equaled or exceeded the PALs (VOCs, metals and pesticides) in previous sampling events in downgradient monitoring wells will be analyzed for during groundwater I monitoring. I Effectiveness The PDS is located within Fort McCoy's North Impact Area (munitions testing impact area) and is I expected to remain the property of the U.S. Army and continue to have associated effective access restrictions. The perimeter fence, if required, would provide a further effective access restriction.

I Land and groundwater use restrictions woUld be effective, as the PDS is expected to remain the property of the U.S. Army. If the PDS does not remain the property of the U.S. Army, the effectiveness of deed restrictions would depend on continued enforcement and could be subject to I changes in political jurisdiction and legal interpretation. NR 812.08 would supplement groundwater use restrictions by prohibiting the installation of new water supply wells within 1,200 feet of the I PDS. Given that the majority of the potential source material was removed during the 1993 interim I removal action and the relatively low concentrations and isolated detections of PCE and lindane, groundwater concentrations of these compounds would be expected to decrease over time through I natuml attenuation. Phytoremediation could be implemented to supplement natural attenuation. I

I D:IF'IMCCOYJIPDCMSJ\SEC170N.6 6-16 March 1996 Fort McCoy I Draft Corrective Measures Study Report

Groundwater monitoring would be used to measure the effects of source material removal and I natural attenuation on groundwater contaminant concentrations at PDS. Semi-annual groundwater sampling and analysis is a proven effective means of monitoring groundwater quality. I Implementability and Reliability I Based on the site conditions summarized in Section 6.9.2, perimeter fencing (if required), land and groundwater use restrictions, and natural attenuation in conjunction with groundwater monitoring would be reliable and are readily implementable within a one-year period at the PDS. I Phytoremediation would also be readily implementable at the PDS.

Operation and Maintenance I

Semi-annual groundwater monitoring would be the only Alternative 1 operational requirement. The operation period for groundwater monitoring will be dependent on the time needed to achieve I acceptable levels ofCOCs in groundwater. For cost estimating purposes, it is assumed groundwater monitoring will be performed for 30 years. I The perimeter fence, if required, would be maintained by Fort McCoy through routine inspections and maintenance. Monitoring wells may require periodic well screen cleaning and other minor maintenance. It is anticipated that the useful life of the monitoring wells would be at least 15 years. I Safety I Implementation of Alternative 1 components would not pose a threat to the safety of nearby residents and environments or site workers since the only Alternative 1 site activities would be groundwater I monitoring.

Environmental Evaluation I

Implementation of Alternative 1 components would not adversely impact environmentally sensitive areas. An ecological field assessment (SEC Donohue, November 1994) of the PDS concluded that I most of the potential ecological communities would have been removed with contaminated soil during the 1993 interim removal action. It is anticipated that because of the small area of the PDS, the fence would have a minor impact to animal migration. Also, current land use as a munitions I testing impact area would limit the potential for ecological communities at the PDS. I Human Health Evaluation

Land use as a munitions testing impact area and access, land use and groundwater use restrictions I would prevent residential development at the PDS. Therefore, the most likely human health risk exposure scenario for the PDS is that of ingestion of and direct contact with surface soil by a trespasser. The human health assessment concluded that PDS trespassers would not be exposed to I excess health risks under this scenario. In addition, there are no current groundwater receptors located between the PDS and the La Crosse River. I

D:IFIMCCOYIIPDCMSIISEC770N.6 6-17 March 1996 I I Fort McCoy Draft Corrective Measures Study Report

I Institutional Evaluation

Institutional needs for Alternative 1 include enforcing existing site access restrictions, maintaining I a site fence to further restrict site access, enforcing land and groundwater use restrictions and I performing routine groundwater monitoring. The design and implementation schedule for Alternative 1 components should not be significantly effected by Federal, state and local environmental and public health standards, regulations, guidance, I advisories, ordinances or community relations. I Cost Evaluation The cost for Alternative 1 includes capital costs to construct the perimeter fence, if required, and annual operation and maintenance costs associated with routine groundwater monitoring and I periodic fence inspection and maintenance. Costs for recording deed restrictions are assumed to be negligible.

I The estimated conceptual capital construction cost for Alternative 1 is $17,000 as presented in Table 6-4. That would also represent a conceptual cost for implementing phytoremediation if the fence is not required. The estimated conceptual present worth O&M cost for Alternative 1 is I $630,000 as presented in Table 6-5. Cost estimate back-up information is presented in Appendix A I to this CMSR. · 6.9.3.3 Corrective Action Alternative 2

I Alternative 2

Access, Land, and Groundwater Use Restrictions, I Groundwater Extraction and Treatment, Natural Attenuation, I Groundwater Monitoring Alternative 2 consists of access, land and groundwater use restrictions; groundwater extraction and treatment; natural attenuation of residual low-level groundwater contamination; and groundwater I monitoring. I • Existing access restrictions to PDS associated with the Fort McCoy facility would be maintained. A chain-link fence could be constructed around the perimeter of the PDS (approximately 400 feet) to further restrict site access if deemed necessary at a later date due I to unauthorized access to and disturbance of the area. • Restrictive covenants would be placed on deeds to the PDS property to restrict land and I groundwater use at the PDS. I

I D:IFTMCCOY JIPDCMSJ'SEC110N.6 6-18 March 1996 I Fort McCoy Draft Corrective Measures Study Report

I TABLE6-4

PESTICIDE DISPOSAL SITE I 1 ALTERNATIVE 1 CAPITAL COST ESTIMATE< > I FORT MCCOY, WISCONSIN Capital Cost Item I Quantity I Unit I Unit Cost Total Cost I Construction: Perimeter Fence I 1 I LS I $8,000 $8,000 I Construction Global Markups: I Scope Contingency (15%) $1,200 Subtotal $9,000 I Health and Safety (30%) $2,700 Subtotal $12,000 I Permitting (5%) $600 Engineering (20%) $2,400

I Construction-Related Services (15%) $1,800 I Prime Fixed Fee (5%) $600 Total Capital Construction Cost $1Z10QO I NOTE: If fence is not required, this estimate represents conceptual cost for phytoremediation. I Cost assumptions are presented in Appendix A to CMSR. I I I I I

I D:IFIMCCOYJIPOCMSI\TABfH. March 1996 I Fort McCoy Draft Corrective Measures Study Report

I TABLE6-5

PESTICIDE DISPOSAL SITE I ALTERNATIVE 1 O&M COST ESTIMATE I FORT MCCOY, WISCONSIN O&Mitem Quantity Unit Unit Cost Total Cost I Groundwater Monitoring (30 yrs): Groundwater Sampling and I (I) YR $3I,OOO $3I,OOO I Analysis Site Inspection and Maintenance (30 yrs):

I Inspection and Maintenance I LS $I,OOO $I,OOO Groundwater Monitoring and Site Inspection and Maintenance $32,000 I Subtotal Scope Contingency (I5%) $4,800 I Subtotal $37,000 Administration (IO%) $3,700 I Total Annual O&M Cost $4I,OOO I Total Present Worth of O&M ~~JQ.ugu NOTES:

I (I) Includes two sampling events per year at five wells. • Cost assumptions are presented in Appendix A to CMSR. I I I I I I

I D:IF1MCCOYIIPOCMSI\TAB6-5. March /996 I Fort McCoy Draft Corrective Measures Study Report

I • If required, groundwater extraction using two extraction wells would be used to collect groundwater at the downgradient edge of PDS. The collected groundwater (approximately 10 gpm) would then be treated ex-situ using air stripping, chemical precipitation, and carbon I adsorption with discharge either to the on-site WWTF or surface water. The treatment units would be housed in a building located at or adjacent to the PDS. The conceptual location of the I wells and building are shown in Figure 6-4. The actual locations would be determined during design activities.

I • Residual concentrations of COCs in groundwater would be reduced to acceptable levels over time by natural attenuation through volatilization, biodegradation, adsorption and chemical I reactions within the subsurface environment. • Groundwater monitoring would consist of semi-annual sampling and analysis of five existing groundwater monitoring wells (1 upgradient and 4 downgradient) located adjacent to PDS. The I groundwater monitoring well locations are shown on Figure 6-2. Observation wells (OWs) are screened across the water table.

I Screened Interval Monitoring Well (feet below ground surface)

I OW-113 (upgradient) 19-29 OW-114 19-29 I OW-115 19-29 OW-139A 46-51 I OW-139B 16-26 Compounds which equaled or exceeded the PALs (VOCs, metals and pesticides) in previous monitoring events in downgradient monitoring wells will be analyzed for during groundwater I monitoring. I Effectiveness The PDS is located within Fort McCoy's North Impact Area (munitions testing impact area) and is expected to remain the property of the U.S. Army and continue to have associated effective access I restrictions. The perimeter fence, if required, would provide a further effective access restriction. I Land and groundwater use restrictions would be effective, as the PDS is expected to remain the property of the U.S. Army. If the PDS does not remain the property of the U.S. Army, the effectiveness of deed restrictions would depend on continued enforcement and could be subject to I changes in political jurisdiction and legal interpretation. NR 812.08 would supplement groundwater use restrictions by prohibiting the installation of new water supply wells within 1,200 feet of the I PDS. Groundwater extraction wells would be used to collect the impacted groundwater downgradient of I PDS. The collected groundwater would be treated using air stripping, chemical precipitation, and

I D:IFTMCCOYIIPDCMSIISEC110N.6 6-19 March 1996 I ~·~------I

I "0 "'en en.... Ql I ....5I I I I I I I I I I I

·$~W139B I P139A X-X- CONCEPTUAL LOCATION OF FENCE CONCEPTUAL LOCATION OF NOTE So EXTRACTION WELL

I. GROUNDWATER TABLE ELEVATIONS AND CONTOURS CONCEPTUAL LOCATION OF I TREATMENT BUILDING 0' 30' 60' ARE DERIVED FROM THE RFI PHASE 3 INVESTIGATION. SCALE~ I I MAR. 1996 FIGURE 6-4 18903 PESTICIDE DISPOSAL SITE ftl _..ENVIRONMENT & CONCEPTUAL GROUNDWATER EXTRACTION I AND TREATMENT SYSTEM LAYOUT ·--~· INFRASTRUCTURE DRAFT CORRECTIVE MEASURES STUDY I FORT McCOY, WISCONSIN I Fort McCoy Draft Corrective Measures Study Report

I carbon adsorption. Given the nature of the residual groundwater contamination, the effectiveness I of the treatment units may be reduced due to the isolated nature of low concentration influent. Given that the majority of the potential source material was removed during the 1993 interim removal action, the implementation of groundwater extraction, and the relatively low concentrations I and isolated detections of PCE arid lindane, residual concentrations of these compounds in groundwater would be expected to decrease over time through natural attenuation.

I Groundwater monitoring would be ·used to measure the effects of groundwater extraction and treatment and natural attenuation on groundwater contaminant concentrations at PDS. Semi-annual I groundwater sampling and analysis is a proven effective means of monitoring groundwater quality. lmplementability and Reliability

I Based on the site conditions summarized in Section 6.9.2, perimeter fencing (if required), land and groundwater use restrictions, groundwater extraction and treatment, and natural attenuation in I conjunction with groundwater monitoring would be reliable and are readily implementable at the PDS. Construction of Alternative 2 should be able to be completed in one construction season. I Operation and Maintenance

Semi-annual groundwater monitoring and operation of the groundwater extraction and treatment I system would be the Alternative 2 operational requirements. The operation period for groundwater extraction and treatment or groundwater monitoring will be dependent on the time needed to achieve acceptable levels of COCs in groundwater. For cost estimating purposes, it is asswned the I groundwater extraction and treatment system will be operated for five years with groundwater · monitoring performed an additional two years to evaluate effectiveness.

I Extraction wells and monitoring wells may require periodic well screen cleaning and other minor maintenance. It is anticipated that the useful life of the wells would be at least 15 years.

I Safety I Safety of nearby residents, environments and site workers with regard to physical hazards during implementation would be addressed by provisions in the construction contractor's SSHP. Potential site safety hazards during construction could include, but not be limited to, heavy equipment I operation, chemical exposure, slip/trip/fall hazards, heat/cold stress, wildlife (ticks, snakes, etc.), and vegetation (poison ivy, etc.). Temporary environmental controls (dust suppression, etc.) and ambient air monitoring would be implemented as needed during installation of the groundwater extraction I ·wells and construction of the groundwater treatment plant. I Environmental Evaluation Implementation of Alternative 2 components would not adversely impact environmentally sensitive I areas.

I D:IF1MCCOYJIPDCMSIISECTION.6 6-20 March 1996 Fort McCoy I Draft Co"ective Measures Study Report

An ecological field assessment (SEC Donohue, November 1994) of the PDS concluded that most I of the potential ecological communities would have been removed with contaminated soil during the 1993 interim removal action. Also, current land use as a munitions testing impact area would limit the potential for ecological communities at the PDS. I Human Health Evaluation I Land use as a munitions testing impact area and access, land use and groundwater use restrictions would prevent residential development at the PDS. Therefore, the most likely human health risk I exposure scenario for the PDS is that of ingestion of and direct contact with surface soil by a trespasser. The human health assessment concluded that PDS trespassers would not be exposed to excess health risks under this scenario. In addition, there are no current groundwater receptors I located between the PDS and the La Crosse River.

Institutional Evaluation I

Institutional needs for Alternative 2 include enforcing existing site access restrictions, enforcing land and groundwater use restrictions, and performing routine groundwater monitoring. I

The design and implementation schedule for the Alternative 2 component of groundwater extraction and treatment may be impacted by Federal, state, and local permitting requirements. I • It is anticipated that implementation of Alternative 2 will not require a local construction permit. I • It is anticipated that operation of air stripper will not require a Wisconsin Air Permit. The air stripper will be operated to meet NR 419 and NR 445 emissions criteria. I • If the extracted groundwater is treated and discharged to the surface, it is anticipated that a WPDES permit will be required. I

• Groundwater treatment system residuals (sludge and spent carbon) must be disposed in accordance with applicable regulations. I Cost Evaluation I The cost for Alternative 2 includes capital costs to construct the groundwater extraction and treatment system, and annual operation and maintenance costs associated with the groundwater I extraction and treatment system and routine groundw~ter monitoring. Costs for recording deed restrictions are assumed to be negligible. I The estimated conceptual capital construction cost for Alternative 2 is $532,000 as presented in Table 6-6. The estimated conceptual present worth O&M cost for Alternative 2 is $735,000 as presented in Table 6-7. Cost estimate back-up information is presented in Appendix A to this I CMSR. I

D:IF1MCCOY JIPIXMSJISFCTION.6 6-21 March 1996 I I Fort McCoy Draft Corrective Measures Study Report

I TABLE6-6

PESTICIDE DISPOSAL SITE I ALTERNATIVE 2 CAPITAL COST ESTIMATE I FORT MCCOY, WISCONSIN Capital Cost Item Quantity Unit Unit Cost Total Cost I Construction: Groundwater Extraction 1 LS $30,000 $30,000 I Groundwater Treatment Metals/Air Stripping/ I GAC 1 LS $205,000 $205,000 Groundwater Extraction and Treatment Subtotal $235,000 I Construction Subtotal $235,000 I Construction Global Markups: Scope Contingency (15%) $36,000 I Subtotal $271,000 Health and Safety (30%) $82,000 I Subtotal $353,000 Permitting (10%) $36,000 I Engineering (20%) $72,000 Construction-Related Services (15%) $53,000 I Prime Fixed Fee (5%) $18,000 I Total Capital Construction Cost ~5~2~QQQ NOTE:

I Cost assumptions are presented in Appendix A to CMSR. I I I

I D:\FIMCCOY/IPDCMS/\TABf>-6. March 1996 I Fort McCoy Draft Corrective Measures Study Report

I TABLE6-7

PESTICIDE DISPOSAL SITE I ALTERNATIVE 2 O&M COST ESTIMATE I FORT MCCOY, WISCONSIN O&Mitem Quantity Unit Unit Cost Total Cost I Groundwater Monitoring (7 yrs): Groundwater Sampling and 1(I) YR $31,000 $31,000 I Analysis Site Inspection and Maintenance (7 yrs): I Inspection and Maintenance 1 YR $1,000 $1,000 Groundwater Monitoring and Site Inspection and Maintenance $32,000 I Subtotal Scope Contingency (15%) $4,800 I Subtotal $37,000 Administration (1 0%) $3,700 I Subtotal $41,000 I Groundwater Extraction and Treatment (5 yrs): Groundwater Extraction 1 YR $3,000 $3,000 I Groundwater Treatment 1 YR $87,000 $87,000 Subtotal $90,000 I Scope Contingency (15%) $14,000 Subtotal $104,000 I Administration (1 0%) $11,000 I Subtotal $115,000 Total Annual O&M $156,000 I Total Present Worth ofO&M ~z~~~QQo NOTE:

I (I) Includes two sampling events per year at five wells. • Cost assumptions are presented in Appendix A to CMSR. I • Present Worth Factors: (1) i = 5%, 7 yrs = 5.786; (2) i = 5%, 5 yrs = 4.329

I D:IF1MCCOYJIPDCMSJ\TAB6-7. March 1996 I Fort McCoy Draft Corrective Measures Study Report

I A summary of the cost estimates for both alternatives is presented in Table 6-8. I 6.9.4 Recommended Alternative Based on the site-specific factors identified in Section 6.9.2, the alternatives evaluation performed I in Section 6.9.3, and the comparison presented in Table 6-9, Alternative 1 is recommended for the PDS. Alternative 1 consists ofaccess, land and groundwater use restrictions; natural attenuation of I low-level groundwater contamination; and groundwater monitoring. Alternative 1 addresses the corrective action objectives for the PDS by reducing potential for contaminant migration to and in groundwater, limiting groundwater use, and reducing groundwater I concentrations for COCs to acceptable levels. Alternative 1 would be technically effective, reliable, and implementable at the PDS and would provide short-term and long-term protection of human I health and the environment. As presented in Table 6-9, Alternative 1 adequately addresses the human health, environmental, and institutional control concerns, is readily implementable, provides long-term reliability, and is less I costly as compared to Alternative 2. I I I I I I I I I I

I D:IF1MCCOY JIPOCMSJISEC170N.6 6-22 March 1996 I Fort McCoy Draft Corrective Measures Study Report

I TABLE6-8

PESTICIDE DISPOSAL SITE I CORRECTIVE MEASURES ALTERNATIVES COST ESTIMATE SUMMARY I FORT MCCOY, WISCONSIN Alternative #1 Alternative #2 ...... C7 ...·•· L < . ······ =...... I I< > .•.••••••.•.••• <. ·• < >········································· Access,S~urce············· Land .· · }Use Restrictions. X X I ·...... ·. ·::::>.·.:::::::::.:·.:.:-·.· .. · .. ··••• ..•....•... ·.·•• •· . .•• < . GroilndWat_,.r··········· · .· ... · .. ········ ...... :.:.:...... ~ \ i········· / L .. ··•·•·• .. :•·•...... <; ... ;. ••• •· ···•·•··· .. ••••·• .·•·• < //:. I Use Restrictions X X Natural Attenuation X X I Monitoring X X Extraction and Treatment X ...,.. .··•··· ...... ·. . .. < I ••••••••••••••••• •••••••••••••••••• ·.···· ) •.·················. }< Capital ~········ $17,000< $532,000 < •·•••••• I AnnualO&M $41,000 (GW MON) $41,000 (GWMON) $ 115,000 (GW E&T) I Present Worth O&M $630,000 (30 yr) $ 237,000 (7 yr) $ 498,000 (5 yr) I Total Cost $647,000 $1,267,000 I I I I I I

I D:IF1MCCOYJIPOCMSJ\TAB6-lJ. March 1996 I Fort McCoy Draft Co"ective Measures Study Report

I TABLE6-9

PESTICIDE DISPOSAL SITE I CORRECTIVE MEASURES ALTERNATIVES COMPARISON FORT MCCOY, WISCONSIN I Evaluation Criteria Alternative 1 Alternative 2

Effectiveness (performs intended Should be effective Should be effective I function) Implementability and Reliability (can Implementable and reliable Implementable and reliable be done and will it last/ perform over I the long-term) Operation and Maintenance ( O&M) Low Medium I Cost Safety Concerns During Low Medium Construction/ Implementation

I Environmental Concerns Adequately addresses concerns in Adequately addresses concerns in Section 6.7.5 Section 6. 7.5 I Human Health Concerns Adequately addresses concerns in Adequately addresses concerns in Section 6.7.5 Section 6.7.5

Institutional Concerns Addresses institutional control Addresses institutional control I needs identified in Sections 6.7 .5 needs identified in Sections 6. 7.5 and6.9.2 and6.9.2 I Cost $647,000 $1,267,000 I I I I I I I

I D:IFTMCCOYJIPDCMSJ\TAB6-9. March 1996 I Fort McCoy Draft Co"ective Measures Study Report I 7.0 REFERENCES

I R.S. Means Company, 1993. Heayy Construction Cost Data. 1994.

Rust E&I, April 1995. Final Work Plan. Air SparKinllfSoil Vapor Extraction Treatability Study. Fire I TraininK Pit 1. Fort McCoy. Wisconsin.

Rust E&I, June 1994. Final Corrective Measures TechnoloKies and Alternatives Report. Fort I McCoy. Wisconsin.

Rust E&I, November 1994. Wellhead Protection Area Study. Fort McCoy. Momoe County. I Wisconsin. I SEC Donohue, November 1994. Final Re,port. RCRA Facility Investiiation. Fort McCoy Military Reservation. Monroe County. Wisconsin.

I SEC Donohue, November 1994. "Final Report, Volume 6 - Appendix R, Human Health Assessment," as an appendix to SEC Donohue, November 1994a.

I USACE, August 1991. Final Scqpe of Services. RCRA Facility InvestiKation/Couectiye Measures Study. Fort McCoy. Sparta, Wisconsin.

I U.S. Army Corps of Engineers, June 1979. Resource Conservation and Recoyery Act (RCRA) Pollution Abatement Suryey. Fort McCoy. Wisconsin. Omaha District, Omaha, Nebraska.

I U.S. Department of Agriculture (USDA), 1976. Soil Survey of Monroe County. Wisconsin, Soils I Conservation Service. USDA, 1984. Soil Survey of Monroe County. Wisconsin, Soils Conservation Service. I I I I I

D:IF1MCCOYIIPDCMSIISEC170N. 7 7-1 March 1996 I I I I I APPENDIX A TO CMSR

I SWMU CORRECTIVE ACTION COST ESTIMATE BACK-UP INFORMATION I I I I I I I I I I I I I - , .. ~.

~ I GUIDANCE DOCUMENT I VERIFICATION OF SOn. REMEDIA·TION I .· I I I I II DNR I

a· ENVJRONMENTAL RESPONSE DIVISION I WASTE MANAGEMENT DIVISION I I I ..... ·. I I

1\ APRIL 1994, Revision 1·· · .·. . , I ..

ESTABLISBJNG GRID INTERVALS I Wbc::n obtaiDiDg samples to ~ tbat soil or wastes bPe beeD adequatdy &auofiatrd, it is important to iDsu&c tbat the aaalytical results obtained will provide an accunaa: repJNI •tarial of the c:llt'R area or volume UDder coasidclatioa. The Jocatim aDd number of samples to be 1akm at a particular remccfiation I site depends on many filcto&s: tbe lc:vel of CODfidencc desired, tbe spaDal aDd teaupoml variability of the media to be sampled, aDd tbe costs illwlwd. An impo&taDt objectiw in any sampling JX0811ID1 is to obtain tbe most accurate data possible wbiJc minimizing the associattJf costs. ODe mc:tbod to accomplish tbis goal I is to USC staristicaJly valid sampling ~- 1h: appropriate sample~ Clll be estimated and the sampling loadioas can~ cbosea without bias.

Such stxategies employ tbe ase of griddiDg to facrlitate tbe 1lllbiased selcaion of sampling poims and I accepted statistical tools for evaluating tbe &eSDitant data. Statistical tbcory allows for tbe sampling of a subset of tbe grid poims to acbic:ve a &diabJc cbalactmizaticm of 1be ciltirc maaedial area or waste. a Subsectioas describe ways to ase sampling grids and statistical tDoJs to evaluale mas ofmardiatim.. The followiDg eqnarions aDd tables pmvidc a simple basis to csrablish a grid systaD to &cititate •mbiatecf I selection of sampling poims aDd sample ccm:rage pmponiaaal to 1be aa:a beiai ve&ified. 1. Basic Strategies. A grid system sbould be established CMr the area beiag ~ Grid point rcpre» mac ion sbould be propmtioaal to the size of the 3ICL For c:xcavatiaa, bach tbe ~ aDd I bottom 8ICIS would be included in tbe derelmination of the area size. It is m:om•'C&'Ird tbat OlD&': of ... the followiDg cqnarions be used to derelmioe grid iDtl:rvals for staricwtina" I SIJIQ/1 site: see Part 1 · I .-··

.JAitc medium site: - GI I 4· I I

WHERE: A = area to be grid ($quare feet) I GI • &rid iar.enal SF = Site Factor, length of area to be grid (unitfess) I I I

I -11- I 'I

A) small: up 1D 0.25 am: I B) JDelljum• 0.25 -3.0 3CftS I C) laiF 3.0 acn:s aad an::a= To simplify tbis app6caDaa, ase 111: fbiJowiDg cbalt based aa aa awrase size nmae of sites I (1 acre = 43.S60 squam feet). The app1o• jmam grid rauges are pmvided as a quick cbeck on mmbc::n pDtimd fir spc:ci6c sitl:s usiag 1b= above finmlas · I •GtitliJIIIIWilllllllga I up 1D 0.25 (smaD) up1D 10,890 See Part 1

0.25-3.00 (JMfinm) 10,890-130,680 lS-SOfa:t I 3.0 aDd cm:r (laqc) 130,680+ 30 feet pllis I • I 2. Selliag tire Grid. Aftl:r 1b= grid iaD:rvaJ. is ralmfated, it is rea "m'"Mird dllt a scalal grid overlay be made 1D supe:ainq-.: aa a map of1b= toeotiatof an:a (tbis an:a iadncfcs bach sidMaJ1s aDd base). ScJmc specified poiat (DSDally 1be soudmcst COI'DI:I') sbould be cfesignatrd as 111= 0,0 c:ooniDate. The I grid CaD.tbc:D be adjusard 1D mujmjm sampliag c:ovaage. Some grid adjuslmr:Dt may be JO:lCSSarf for •mupaally shaped areas. Grid adjustment may also be DCCdaf to aca "utntc a mjujmuna of at least aa'e sample fi'am cada sidr:wall. Plopc.wals fix' difi:atad: grid saaaegics may be submitted fbr DNR I .mew aDd approval aa a c:ase-by-c:asc basis. · · I I I ,,I _.I

•12- I I ...... Rust E & I - - - - -GW MONITORING/SAMPLING-FT- MCOY-- (CL2,CL3,GA) ------S1 - Worksheet Summary Page

Subcontractor Manhours Material Labor Equipment Expenses Subcontractor Markup (10') TOTAL COST Subtask: oo All Subtasks 1A Field Work 118 8,229 2,130 1,080 11,439

1B Laboratory 6 669 23' 04 0 2,304. 26,01~ 1C Database Management 38 2,909 2, 909 1D Data Validation 38 2,909 2,909 1E Reporting 69 5,231 191 5,422

Grand Total: 269 19,947 2,130 1,271 23,040 2,304 48,692

G2 ESTIMATOR (TM) Date: 03/04/96 Time: 10:14 am I

I AREA AND VOLUME OF CL2, CL3, AND THE GA

I CL2: 184,800 sf= 4.2 acres approximately 8 ft to groundwater volume to 8 ft = 54,800 cy I volume to 8 to 10ft= 13,700 cy (assume excavation or treatment will end at 10ft) I CL3: 83,300 sf= 1.9 acres approximately 19 ft to groundwater I volume to 15 ft = 46,300 cy (assume waste depth is 15 ft) Grit Area: 57,000 sf= 1.3 acres approximately 12 ft to groundwater I volume = 4,200 cy (2 ft deep) I Total volume for excavation or treatment= 54,800 + 13,700 + 46,300 + 4,200 = 119,000 cy Backfill= 119,000 cy x 1.2 (bulking factor)= 142,800 cy

I Assume 1.4 ton/cy I I I I I I I I I 0:\FI'MCCOYt\PDCMSt\CAMUCALC.CAZ I I I I I I CL2, CL3, AND THE GA

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I ~~12.000

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I OBJECTIVE

I • Develop costs for treating groundwater with low level VOCs and metals.

• Assume metals removal followed by air stripping and surface water discharge. Discharge I location is approximately 200 ft from treatment plant.

I PROCEDURE I • Assume 10 wells (see attached calculations or radius of influence vs. flow rate) will be installed to minimize inflow from LaCrosse River. Flow rate is 50 gpm.

I • Based on groundwater characterization (see attached), system should be similar to Powell Road "Reasonable-Case Scenario," except that we assume no carbon will be required.

I • Adjust costs for extraction wells based on $/well from Powell Road . I • Adjust costs from Powell Road groundwater treatment system using: 0 6 Metals Removal Cn = r · C where ' and Air Stripping Cn = Ft. McCoy Cost I r = Ft. McCoy Flow Powell Road Flow I C = Powell Road Cost I (Source: Chemical En~ineer's Handbook Perry, Chilton, 1973. McGraw-Hill.) Building Discharge, Sampling and Analysis, Admin., Operating Labor I Based on Estimator Judgement. Sludge Management, Polymer based on flow ratio of 50 gpm/280 gpm = 0.18.

I Power use based on 15 HP of equipment. I Other as shown. I I I

I 0:\FTMCCOYJ\PDCMSI\COSTEST. I

COST BACKUP I GROUNDWATER EXTRACTION SYSTEM I • Use Powell Road estimate of:

$194.000 = $13,000/well x 10 wells= $130,000 I 15 wells I • O&M for maintenance = $2,500/Yr (Est. Judge.) Power (pumps) = $10,000/Yr I GROUNDWATER TREATMENT SYSTEM I Capital:

• Building ($1 00,000) + Metals ($160,000) + Air Strip ($28,000) I + Discharge (20,000) = $308,000

O&M: I Sludge Management $12,000/Yr x 0.18 = $2,000/Yr I Polymer $30,000/Yr x 0.18 = $5,400/Yr I Sampling and Analysis = $40,000/Yr

Power Use = $3,100/Yr I Maintenance @ 3% of Capital = $9,000/Yr I Administration = $36,000/Yr

Miscellaneous @ 2% of Capital = $6,000/Yr I Operating Labor = $25,000/Yr I ANNUAL TOTAL = ~~,~~~QO!Yt· I I I

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It' oF ~t.-l.S : 100 0.. = 2. (. 75) I I 10 I I I I I I I I I I

I CL2, CL3, GA ALTERNATIVE NOS. 3 AND 4

I A. Confirmation Soil Sampling Following Waste Removal: I 1. Analytes- VOCs, SVOCs, Metals 2. Cost per sample analysis:

I VOCs= $225 SVOCs=$400 I Metals=~ I $900 per sample 3. Number of samples from MDNR Guidance (4-94):

I a. Area of CL2 + CL3 + Grit Area: I 4.2 acres+ 1.9 acres+ 1.3 acres= 7.4 acres I 7.4 acres x 43,560 ft2 = 322,344 ft2 (322,344) (1t) GI = ~A 1t = = 38ft I · SF 700 I Use 50 ftto calculate samples. I 2 322,344 jt + (1,400 ft X 10ft) = 135 samples I (50 ft X 50 ft)

I Total including 10 percent duplicates= 149 samples. I I 1 of2 I D:\FfMCCOYI\PDCMSI\CAMUCALC.CAZ I I

B. Landfill Characterization Sampling: I I. Analytes - TCLP hazardous waste characterization. I 2. Cost - $1,200 per sample.

3. Numberofsamples-1 per IOOcy. I

103 600 • cy = 1,036 samples I 1/100 cy I I I I I I I I I I I I 2of2 D:\FlMCCOYI\PDCMSI\CAMUCALC.CAZ I I I ftl lriiENVIRONMENT & CALCULATION SHEET PAGE_I_ oF_L •~u~• INFRASTRucTuRE PROJECT No. 1~o3 I CLIENT /J?Ae...f: SUBJECT ~)(( AV~tO ;J Prepared By~ate J.b -')4- PROJECT F?;ei Mc_(o:r' ....;:U...... :.....~'Tli\:-.....:.fO~e~Ck-=.:;.;.-=2._=---- Reviewed By (a(,{ Date 1o~lo -&f"/ 1 _C:::...... t:lM~S~ _ __.______7~A_;,_..M_v __ N...;;.'o.;..:' I ____ Approved By !rib Date 7-J;-f[') I i ~Obl 0sr R'l:OM ~ (sGe- ATT.4c:f+e.D -~),.

I' • ~M~ T-H€.- ~ppe;~ ~ F"T £Y.CAVA""t~ ~'( v ~~e.- 1 L--O~e'C t)r~\0 -r~~S. (A-Do t$0 /o) I • ~ IN ANOT~ 2D.,k ff9e ~lA-~ ~~ rh'\'\I'J.l)£,r,J(r • Af.:>D 1t-J ~O"i H~ l 0 ")o ~2.. I~Po~'~Y ""' I ACC E.;.> 62-CA-o.>

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44. ______See the Reference Secllon tr nlferlncellllbr klbmalion, Cnlw l.isllrVI n1 Cly Cosllndiii8S.. I I ...... ENVIRONMENT & CALCULATION SHEET PAGE_J_ oF __f CAH v t0o,\ PROJECT No. B:tC3:> I :!~~~~~RASTRUCTURE SUBJECT C:::.I-"Z- ~.,u:.,...-v~\\c:>~ Prepared By AD Date ' 0 -~-9'"1 PROJECT ____..;;;v:>;...... ;""::Sf:;..:....S;;;;...__-....::?P.o==~~'=o..:.."'~~ Reviewed By~ate I o-~~-0-q. 0 I ____..;;;<:...;;.;.M--=~;....______----=~..;;;0....::~..:..TILO....~'-=------Approved By ~ Date 7- ](-~ ~ I C 0 t4-r1'&Q L I or 1\-\€. \....~C:..~o&$E .,...~D t:SI.)'T2.~v'-l't::> ~~~ f::o.~~ ,...\olD -r-o I T"" jio.lf•·l"l'"'"tt-l' 13-~t-J¥. :s"Tf'l~ll.... \ T'f ,.._ LO~~ L'E~ \""\...:I "PO'P-TI Ot-lS O'F 11-\.£.. Lfl'; C.~"!:.~ lit} \Jell. I

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/1'16 ·tAJ..S ,tt~?r 1!. ~S/.1.. 7 St1A o_,_~_·/._LL:J_-:..1______-..J I ~ 10 10 1~~ I 02:11f>M rROM Mc:c I TO

J' ------~~------~~~~ Ca.s T: or &44/.'lal?

l'' I I . __...e?, c· Y""c-'z:= l ~,.,,~..,_,;, ; &;r ~.,.,..: . ' .. : ; · (;., -:- S"' ,_ Co• c;,. ~ J . . i .., •.

, :c:r,~c:, ./Ylq.tJ"~~-z~J-,.·:~ · ' ; .. ,, . ' i' ,f l I l t --- ... ______----- TOTfll P, €33 ...... --~ ...... ~,...... Rust E & I - GROUNDEWATER MONITORING (FTBP1-FT MCCOY) S1 - Worksheet Summary · Page

Subcontractor Manhours Material Labor Equipment -----Expenses Subcontractor Markup (10\) TOTAL COST Subtask: 00 All Subtasks 1A Field Work 166 11,469 2,785 1,493 15.74 7 1B Laboratory 8 892 19,400 1, 94 0 22,232 1C Database Management 64 5,061 5,061 1D Data Validation 64 5,061 5,061 1E Reporting 128 8,883 377 9,260

Grand Total: 430 31,366 2,'785 1,870 19,400 1,940 57,361

G2 ESTIMATOR (TM) Date: 03/04/96 Time: 10:06 am Rust E & I AS/SVE OPERATION COSTS (FTBPl-O&M-FMCOY) Sl - Worksheet Summary Page 1

Manhours Material Labor Equipment Subcontractor Sub task: --- Expenses Subcontractor Markup (lOt) TOTAL COST 00 All Subtasks lA Site Check 1,008 73,344 2,600 25,858 18 Quarterly Status Report 15,600 1,560 118,!162 94 6, 518 222 6,740 Grand Total: --- 1,102 79,862 2,600 26,080 15,600 1,560 125,702

G2 ESciMATOR (TM) Date: 03/04/96 Time: 10:03 am fie liii!Jt ~ ._,.. , ...... ~-- ...... - ...... I .. M9ENVIRONMENT & CALCULATION SHEET PAGE __j_ OF-=­ I~U~I INFRASTRUCTURE PROJECT NO. /89o"l I CLIENT &tz.:C c(?eC.aY SUBJECT FIBPI c.o!:>IS Prepared By qt"TDate#st PROJECT.....l!C~m:...;..;.:,S-'------____.A"'"''""":!;""h..:;6_..v....~£"'-. --:::6::;.,Y,.....:?..::; ...... r:...:E=..;.;m...:... Reviewed By 7111}:1 Date~ I ------____;:c."""A...;..;...P ....rn.._.J9""""""'4- ....C-=D;..o$,z;;.5=--- Approved By ?7T-c Date 7~ /"':, -q)

I OBJEC.:T"/V£ .' C:S-rn'VJATCC c..A PI rA L CON'6/iZ.. t..U-TioN C.o6/~ I FOIL /l:S /.:5 Vl:" 6Y 6rt:m e'"X. J>.Pr /'IS ION .fr/ FTBP /.

I A-A.EA Or pee coN~~~~~nON

.e. c-rt.A/~t;r-1 OW - /3-:;... A-ND Ot.V- 308 II A-riA-CHCD Fl&juRC ),

I A-~j..s.J/C t::.X PA-N61DN tA...:JILL- ce>r/SJ::;.T oF 5 A.S W£-LLS ~JUO 7 ::> Vc -r.vCI-L.S ~

FJ .S j:s. II£""" eX P,AJvi6/0/'I C. A-PITA'- C.O~f> IA-U C..-r]o/'1

cO$~ U-71'-L- BE: pp0P'C>P..:r7o.NAL ON IJ./{5 I' 1 BftS/s oP /VVr->B~.I2 oF t/~~l-s _, ro rrr~ A6)6vt 7'""72--&A r/7-s ;u r'l 6 ru o Y :s y.:> n::-,"1 .

,,. ..46/~ v£ 772-rATfiB/L. J TY ~-r'""VDY ::7Y6TCI"'J ' ' 8 ,4::S ) 12. ~ v~ (,.<.)~ L. L-5 .j. C).~ ·trJ. 000 ( ~M ~ /SvE,. 11611- ,, x frOS 1-T> il\{l.tfe -rn~ ) +o ~s :-: ";).fo.,ooO r<-.?.A'T.t\81 !...11'1' s-r V.!)'{ ,A 6 1~ vc .5 y s -re/'Y? e X?Ft N -G JON c:.o-s-r- I ( /~)?Q JOQ ) (/d.. Wf:LL5) ::: :f 17700 Q I /9 W£LJ_S I I I I ...... 8 ~-304 I !!. I !! !! !i I ~-303 I . I T43600 N I I I + I I + ' .1+ +

,.._ ,.._ Cl) I ~ Cl) ~ ·co N ! Cl) ..,I Cl) m Cl) Cl) + Cl) f~ .;r ,.._ Cl) Cl) Cl) &n CD Cl) Cl) ,;~nMArc;D ~fovc Cl) ~ .S '/6f'err} "PANS JON e;c A?/:~ 'I e:. -r12-"(AT$1>~1\. J-r# AK£A ~U17"i P.l2-~A S A.S WCLLS (C61J~A-TED) 8 A$ fi..JC/..1,~ 7 SVE WCl,LS (ESTIMAnD) 11. :S vt: we us LEGEND ~ GROUNOWATER MONITORING WELL 1. GROUNOWATER TABLE ELEVATIONS ANO CONTOURS 100--- PCE CONCENTRATION CONTOUR INSTALLED DURING PHASE I OR Z ARE DERIVED FROM THE PHASE 3 INVESTIGATION. .PII6A I ~ FENCE GROUNIIWATER MONITORING WELL ~· ·P-134A 878--- GROUNOWA TER CONTOUR _.&._ GROUNDWATER MONITORING WELL AUG. 1994 126&8 f' 'l""ow-143 FIGURE A-1 GROUNOWATER FLOW DIRECTION A SOIL BORING RIJHENVIRONMENT & PCE CONCENTRATION CONTOUR (l ~CBI03 · n.rnn A Prn, GROUNOWA TER "t ~ •ssos SIJIFACE SOIL SAioiPI..E LOCATION U'l.t'~iAUcn.JRE ASISYE TREATABILITY STLOT iill_------.------~------_J~------~------Fmn___ ~ __ o_T~·-•_•~-mG---'"------J~~ I

I FTBPl -LIMITED SOIL REMOVAL

I Volume of soil: Assume 40 ft diameter for former pit. I Assume 6 ft deep excavation 1td2 v =-(6ft) I 4

I = _..;______:____:_...;_1t (40 ft)2 (6 ft) I 4 I V = 7,540 ft3-:- 27 = 280 c.y. Assume 1.4 Ton per c.y.

Weight of soil= 280 c.y. x 1.4 = 390 Ton I'

I' I I I I I t t D:\FTMCCOYI\PDCMSI\CAMUCALC.CAZ I I

.Fire Training Bum Pit 1 - Alternative 1 I Annual AS/SVE O&M Cost Estimate Assumptions I 1. AS/SVE System O&M:

a. Electrical based on experience ($800/month). I b. Bi-weekly site check, 2-day dmation. i c. Condensate disposal based on experience. I d. Miscellaneous repair/replacement at 3 percent of the AS/SVE System Subtotal of$457,000 shown on Table 3-3. I e. Quarterly status reports to WDNR.

f. No system failures accounted for. ·i ' ,,I I I I I I I t

D:IFTMCCOYI\PDCMSIICOSTEST I I

I FTBPl - Alternative 2 Cost Estimate I Groundwater Pump and Treatment Construction

I AS/SVE = $457,000 i Groundwater Extraction I Assume same as CAMU #I with barrier length of250 ft instead of 1,000 ft. # wells - ~ = 3 wells, 5 gpm/well I 2(50) $130.000 (3) 5I! $40,000 j 10 Groundwater Treatment

I 0 6 (15 @00) · $308,000 5I! $150,000 I (50 gpm) Discharge (1,500 ft):

0 6 I 20,000 X (Uill!) · "' $64,000 (200)

I TOTAL GW E&T s $254,000

'I Extraction ($12,500Nr) (3/10) $4,000Nr· I Treatment 1 Sampling/Analysis $40,000Nr Other (126,000- 40,000) (15 ~pm)0 · 6 i (50 gpm) $42.000/Yr I $86,000Nr

I 0:\FfMCCOYI\PDCMSI\COSTEST , ~' ~/ ~ ~ ~.-...... ~ '.~ ~ ...... - --~ ... .. Rust E & I -· - -· - - GROUNDWATER MONITORING (FTBP2-FT MCCOY) Sl - Worksheet summary Page 1

Subcontractor Manhours Material Labor Equipment Expenses Subcontractor Markup (lOt) TOTAL COST Subtask: oo All Subtasks lA Field Work 74 5,259 1,190 344 6,793 lB Laboratory 8 892 7,344 734 8,970 lC Database Management 22 1,872 1,872 lD Data Validation 22 1,872 1,872 lE Reporting 44. 3,082 139 3,221

Grand Total: 170 12,977 1,190 483 7,344 734 22,728

G2 ESTIMATOR (TM) Date: 03/04/96 Time: 09:59 am CLOSED LANDFILL 4 (CL4) ···, ~/ ~' ~\ ~ ~j~.,~ ~ J!l!l, fiJI) ~~ .. \ .. ; ... ·.~ ', .. .. Rust E & I GROUNDWATER MONITORING (CL4-FT MCCOY) - Sl - Worksheet Summary -' Page 1

Subcontractor Man hours Material Labor Equipment Expenses Subcontractor Markup (lOt) TOTAL COST Subtask: 00 All Subtasks lA Field Work 76 5,482 911 296 6,689 lB Laboratory 8 1!92 6,280 628 7,800 lC Database Management 20 1,732 1,732 lD Data Validation 20 1,732 1,732 lE Reporting 60 4,136 164 4,300

Grand Total: 184 13,974 911 460 6,280 628 22,253

G2 ESTIMATOR (TM) Date: 07/31/95 Time: 10:50 am I 1 I I I 1 I PESTICIDE DISPOSAL SITE (PDS) I I I I I I I I ,a I I I . , ...... / -~ ...... Rust E & I - GROUNDWATER MONITORING·- (PDS-FT MCCOY) Sl - Worksheet Summary Page 1

Subcontractor Manhours Material Labor Equipment Expenses Subcontractor Markup (lOt) TOTAL COST Subtask: 00 All Subtasks lA Field Work 100 7,102 1,404 594 9,100 lB Laboratory 8 892 10,948 1,095 12,935 lC Database Management 28 2,292 2,292 lD Data Validation 28 2,292 2,292 lE Reporting 64 4,284 226 4,510

Grand Total: 228 16,862 1,404 820 10,948 1,095 31,129

G2 ESTIMATOR (TM) Date: 07/31/95 Time: 10:49 am ...... ENVIRONMENT& CALCULATIONSHEET..trvPfPAGE-LoF_I_ . I •~u~• INFRASTRUCTURE · ?vv- PROJECTNO. JeCJo3 _ CLIENT IJM!t..£ SUBJECT r;;;;;;--z ~ Prepared By f:t:T Date E!/18)1f PROJECT &r d ·co'( F"£!'<<~ Reviewed By~ Date fi/Jt/

T-C!V'~ O"H3j3.08 jof:,OO .$I{;". ao /tF C.· PDS7S 0 2 8/.308/I I CJO 8S.CJD/Ffl t IJRflC£5 ozBjsOB/ 1300 52. ~o) £ IJ (:pA IE (fl?) 0 28/308) /'10 0 2Z3 .oojc/7 I U,Pr£ (v) 02Bj3o8/ 5o":fo 9os-. oo /£ fJ I I ,...,A.N 6,PT£ (M6) I v E:. 1-1 't i c c..,R rt:. ( \f&) I 1/ t 0 14.""' E" /1. p.o-s.75 I

{ 1/DO LF) (I~ /J..F) ~ I (If C. PD5T5) ( 88/t:A) ~ ( 2. Bi2-A (£.$ x L.f) ( :]"2., !>0)£11) ~ I C' M6i) ( 223. c~) ~ ( I V L..,) ( 9 D "S [ A) =- I I I I I -I I I I I• Fl• mn ~ ~ J

\ \ \ \ \ i \ \ ' \ \ \ \ \ \ ' \ \ \ \ \ \ \

N

~ t --.._ TOPQGRAIIHIC CONTOIII GROUIIIIIATER CONTOUR 865.50 - ~rc.. T~=":t LEVEL t ---- :=rr::TER FLOW 1 EXISTIIIC GROIH)WAT!R IIONITORING WELL IN01CA TING THE GROUNOWA TER TABLE IN c::011115 FEET ABOVE MEAN SEA LEVEL NOTESa 0' 30' 60' L GROUNOIIATER TABLE ELEVAnONS ANO CONTOURS .OVI3'!8 GROIJNOWATER UOI'IITQRroiG I ARE OEIIIYEO FRON THE RFI PHAS£ 3 INVES TICA noN. Pll'IA liEU. NEST SCALE ----

i AUGUST 1994 FIGURE 6-2 18903 PESTICIDE DISPOSAL SITE GROUNDWATER MONITORING WELL LOCATIONS ... _..ENVIRONMENT & AND WATER TABLE MAP PRE-DRAFT CORRECTIVE MEASURES STUDY I~U~I INFRASTRUCTURE FORT McCOY MONROE COUNTY, WISCONSIN I

I PDS - Alternative 2 Cost Estimate Groundwater Extraction and Treatment I Construction I Extraction Assume same as CAMU #1 with barrier length of 150ft instead of 1,000 ft.

# wells - .lj.Q = 2 wells, 5ii2Jll I 2(50) well

$130.000 (2) s $30,000 I 10 I Treatment VOCs, Pesticides, Metals

I -+ Air Stripping/GAC/Chemical Precipitation 10gpm

I use CAMU No. 1 ($308,000 + $90,000 for GAC)/50 gpm

0 6 $398,000 (10 ~m) · Sl $152,000 I (50 gpm)

Discharge $2o,oooA.IQQQ~0 · 6 = $53,000 I \ (200)} I $205,000 TOTALGWE&T = $235,000 I l Extraction ($12,500/Yr) (2/10) s $3,000/Yr I Treatment Sampling/Analysis $50,000/Yr

I Other (136,000 - 40,000) o..mo.6 $37.00QNr (50)

I $90,000/Yr I

I D:IFTMCCOYIIPDCMSIICOSTBST. I I I I I I APPENDIX B TO CMSR REVISED RFI REPORT GROUNDWATER MONITORING RESULTS TABLES I TABLE6-5 TABLE 7-6 I TABLES-1 TABLE 12-4 I TABLE 13-3 I I I I I I I I I I .. .. - ...... ,. .. _ .. Final Report - - -Fort McCoy RFI-

TABLE6-5

CLOSED LANDFILL l GROUNDWATER FORT MCCOY RFI MONROE COUNTY, WISCONSIN (ug/1)

OW-101-01 OW-101-02 OW-102-01 OW-102-02 '

7 Feet• 7 Feet• 7 Feet• 7 Feet•

Regulatory Analyte Phase 1 Phase 2 Phase 3 Phase 1 Phase! Phase2 Phase3 Phase2 Phase 3 Background Threshold2

VOLATILE ORGANIC COMPOUNDS

Acetone <10 16 <10 <10 <10 10 <10 <10 <10 <10

Benzene <5 <5 <0.5 <5 2J <5 <0.5 <5 <0.5 <5 0.067

Methylene Chloride <5 <5 <0.5 1 J 2J <5 <0.5 <5 <0.5 <5 IS

Tetrachloroethylene 2J <5 <0.5 1 J <5 12 <0.5 14 <0.5 <5 0.1

Trichloroethene <5 <5 <0.5 <5 <5 1 J <0.5 1 J 1.6B <5 0.18

SEMI-VOLATILE ORGANIC COMPOUNDS

Di-n-octylphthalate <10 <10 <5.0 <10 <10 <10 <5.0 <10 <5.0 <10

bis(2-Ethylhexyl)phthalate 2BJ <10 <5.0 <10 <10 1 J <5.0 SJ <5.0 <10 0.3

METALS

Antimony 125 <7.0

Arsenic <1.0 <1.0 <10 <1.0 1.4 J <1.0 <10 <1.0 <10 <1.0 5

Barium 28 23 <100 25 70 88 <100 85 <100 14 200

Cadmium <10.0 <5.0 <5 <10 <10 <5.0 <5 <5.0 <5 <10 1

Chromium <20.0 <6.0 <10 <20 123 <6.0 <10 <6.0 <10 <20 5

Iron 147 389 1800 185 4140 3210 J 300 3090J 800 539 ISO

Lead <4.0 1.30 <3 <4.0 <4.0 <1.0 <3 1.9 <3 4.2 5

Manganese 20 14 30 18 125 129 20 124 20 23 25

Nickel 29 <11.0 <40 35 61 11 <40 <11 <4.0 <20 ··--

D'IF1MCCOYJ'IU'IJITA/16-S Page I of6 February /995 ...... ,,- .. - ...... ,...... Final Report ------Fort McCoy RFI

TABLE 6-5 (Continued)

CLOSED LANDFILL 2 GROUNDWATER FORT MCCOY RFI MONROE COUNTY, WISCONSIN (ug/1)

OW-101-01 OW-101-02 OW-102-01 OW-102-02

7 Feet' 7 Feet' 7 Feet' 7 Feet'

Regulatory Analyte Phase 1 Phase2 Phase3 Phase 1 Phase I Phase2 Phase3 Phase 2 Phase3 Background Threshold2 J

Selenium 6.4 <2.0

Chemical Oxygen <8000 <8000 <8000 <8000 <8000 <8000 <8000 Demand

Fluoride <100 llO <100 220 220B 240B 120 440

Nitrate + Nitrite 17701 1070 17401 25201 43501 41901 780 2000

Sulfate ll900 147001 12200 8510 86800 91800 7880

Total Dissolved Solids 50000 51000 53000 269000 303000 292000 12900

Total Phosphate <100 <100 <100 <100 <100 <100 <100

METALS, DISSOLVED

Antimony, Dissolved 109 52 <40 <40 Arsenic, Dissolved <1.0 <1.0 1.51 <1.0 s

Barium, Dissolved 23 26 69 13 200 Chromium, Dissolved <20 <20 <20 <20 s Copper, Dissolved 60 28 <20 <20 500

Iron, Dissolved 83

Magnesium Dissolved 2070 1970 860Q____ .______------681_0 - --

D;IJ"1K:COY J'JU'II\TAB6·J Page2of6 February 1995 ...... -Final-- Report ------Fort McCoy RFI-

TABLE 6-S (Continued)

CLOSED LANDFILL 2 GROUNDWATER FORT MCCOY RFI MONROE COUNTY, WISCONSIN (ug/1)

OW-101-01 OW-101-02 OW-102-01 OW-102-02

7 Feet1 7 Feet1 7 Feet1 7 Feet1

Regulatory Analyte Phase I Phase 2 Phase 3 Phase I Phase I Phase2 Phase 3 Phase2 Phase 3 Background Threshold2

Manganese, Dissolved 17 17 120 17 25

Nickel, Dissolved 28 39 <20 21

Potassium, Dissolved 751 610 2710 <500

Selenium, Dissolved 6 5.8 9.3 5.4 I

Vanadium, Dissolved <5 <5 14

Zinc, Dissolved 100 16 450 20 2500

D'IFTKCOTIW111TAB6-$ Page 3 of6 February 1995 .. .. ., .. ---Final Report .. - - - -·- - - - - .. Fort- McCoy RFI

TABLE 6-S (Continued)

CLOSED LANDFILL 2 GROUNDWATER FORT MCCOY RFI MONROE COUNTY, WISCONSIN (ug/1)

OW-103-01 OW-121-01 OW-122-01

7 Feet1 7 Feet1 7 Feet1

Regulatory Analyte Phase I Phase 2 Phase 3 Phase 2 Phase 3 Phase 2 Phase 3 Background Threshold2

VOLATILE ORGANIC COMPOUNDS

Acetone <10 <10 <10 <6.0 <10 <10 <10 <10

Benzene <5 <5 <0.5 <5 <0.5 <5 <0.5 <5 0.067

Methylene Chloride 41 3 81 <0.5 <5 <0.5 <5 <0.8 <5 IS

Tetrachloroethylene <5 <5 <0.5 <5 <0.5 <5 <0.5 <5 0.10

Trichloroethene <5 <5 <0.5 <5 <0.5 <5 <1.2 <5 0.18

SEMI-VOLATILE ORGANIC COMPOUNDS

Di-n-octylphthalate <10 <10 <5.0 <10 <5.0 <10 <5.0 <10

bis(2-Ethylhexyl)phthalate 2B1 <10 <5.0 51 <5.0 21 <5.0 <10 0.3

METALS

Antimony <40 <7.0 <50 <7.0 <50 <7.0 <50 <40

Arsenic 1.11 <1.0 <10 <1.0 <10 31 <10 <1.0 5

Barium 59 45 <100 35 <100 83 <10() 14 200

Cadmium <10 <5.0 <5 5 <5 <5.0 <5 <10 l

Chromium 221 <6.0 <10 <6.0 <10 <6.0 <10 <20 5

Iron 8421 122 600 915 llOO 2120 900 539 ISO

Lead <4.0 <1.0 10 <1.0 29 1.61 <3 4.2 5

Magnesium 1200 ll400 8000 7310 <5000 10800 <5000 6840

Manganese 375 231 190 57 20 227 80 23 25

Dc\F1UXOY/I/IRI\TAB6J Page4of6 February /995 ...... -Final -Report ------Fort --McCoy RFI

TABLE 6-5 (Continued)

CLOSED LANDFILL 2 GROUNDWATER FORT MCCOY RFI MONROE COUNTY, WISCONSIN (ug/1)

OW-103-01 OW-121-01 OW-122-01

7 Feet' 7 Feet' 7 Feet'

Regulatory Analyte Phase 1 Phase 2 Phase 3 Phase2 Phase 3 Phase2 Phase3 Background Threshold1

Nickel 27 <11.0 <40 13 <40 11 <40 <20

Selenium 11 <2.0

Vanadium 34.9 <15.0

Zinc 231 926J 2300 211 J 3000 542 670 31 2SOO

MUSCELLANEOUSP~ETERS

Chemical Oxygen Demand 18000 <8000 <8000 16000 <8000

Fluoride 180 180B 1108 lSOB 120 440

Nitrate+ Nitrite 7570J 4510 540 2940 780 2000

Sulfate 129000 88000 J 132000 J 60100 J 7880

Total Dissolved Solids 733000 236000 J 269000J 201,000 J 129000

Total Phosphate 330 300 <100 410 <100

METALS, DiSSOLVED

Antimony, Dissolved <40 <40

Arsenic, Dissolved l.lJ <1.0 5

Barium, Dissolved 57 13 200

Chromium, Dissolved 24J <20 5 Copper, Dissolved <20

Mrumesium Dissolved 1200 6870

D'\FV.CCOYI'JIFIJ\TAB6·S Page 5 of6 February 1995 .. .. -Final- Report ------Fort- McCoy RFJ-

TABLE 6-S (Continued)

CLOSED LANDFILL 2 GROUNDWATER FORT MCCOY RFI MONROE COUNTY, WISCONSIN (ug/1)

OW-103~01 OW-121-01 OW-122-01

7 Feet1 7 Feet1 7 Feet1

Regulatory Analyte Phase I Phase2 Phase 3 Phase2 Phase 3 Phase2 Phase 3 Background Threshold2

Manganese, Dissolved 383 17 25

Nickel, Dissolved 28 21

Potassium, Dissolved 3850 <500

Selenium, Dissolved 10 5.4 I

Vanadium, Dissolved 36.3

Zinc, Dissolved 224 20 2500

NOTES:

I Approximate depth. 2 Preventive Action Limits (PALs) from NR140 Wisconsin Administrative Code. OW-104 Phase 1 results were used as the background sample forCL2. Results are shown for all samples if, for any phase, the analyte is above background or the background sample has a "U" qualifier for that analyte. Blanks indicate compound was either not analyzed or has no PAL. Results below detection limits are shown as less than detection limit for than analyte.

J Estimated B Indicates that analyte was detected in associated blank.

D,117MfXQY/liiFII\TA/16-S Page 6 of6 February /995 ~ .. .. - -Final Report- -- - .. -- - .. - --Fort McCoy RFI- -

TABLE7-6

CLOSED LANDFILL 3 GROUNDWATER FORT M:CCOY RFI MONROE COUNTY, WISCONSIN (ug/1)

OWIOS-01 OWI06-0I OWI31-0I OW-104

22 Feet' 25 Feet' 23 Feet' 23 Feet'

Phase Regulatory Analyte Phase I Phase 2 3 Phase I Phase 2 Phase 3 Phase 2 Phase 3 Phase 2 Phase 3 Background Threshold2

VOLA TILE COMPOUNDS

I ,2-Dichloroethene <5 <5 <0.5 <5 <0.5 0.7 <5 <0.5 <5 <0.5 <5 20

I, I ,2,2-Tetrachloroethane <5 <5 <0.5 <5 I 1 <0.5 <5 <0.5 <5 <0.5 <5

Tetrachloroethylene 31 21 <0.5 31 I 1 0.6 I 1 <0.5 21 <0.5 <5 0.1

METALS

Aluminum <15 3061 100 <15 5391 200 1061 300 552 200 332

Antimony 49 <7.0

Barium 23 14 <100 19 IS <100 56 <100 II <100 14 200

Copper 48 21 <20 46 <17 <20 <17 <20 <17 <20 <20 500

Iron 1081 1,470 200 911 437 200 123 200 331 200 539 ISO

Magnesium 10,800 5,210 8,000 6,610 5,600 6,000 3,840 <5,000 2,580 <5,000 6,840

Manganese <10 10 <10 <10 6 <10 62 30 7.0 <10 23 25 - Nickel 27 14 <40 28 12 <40

Potassium 2,030 1,430 <5,000 1,390 1,550 <5,000 2,830 <5,000 790 <5,000 872

Selenium 7.3 <2 <5 6.5 <2 <5 <2 <5 <2 <5 5.5 I

Zinc 4971 209 540 307 239 220 283 210 30 <20 31 2,500

Total Alkalinity 61,800 39,000 39,400 43,000 11,000 19,000 22,500

Chloride 7,540 1,940 7,710 8,610 25,700 22,400 51,700

Fluoride 120 120 <1,000 110 120 100 120

D:IFTMXOYJIRF/J\TAB7-6 Page 1 of2 February 1995 - --Final Report ------...... - .. --Fort McCoy RFI-- TABLE 7-6 (Continued)

CLOSED LANDFILL 3 GROUNDWATER FORT MCCOY RFI MONROE COUNTY, WISCONSIN (ug/1)

OWIOS-01 OW106-0l OW131-0l OW-104

22 Feet1 25 Feet1 23 Feet1 23 Feet1

Phase Regulatory Analyte. Phase 1 Phase 2 3 Phase 1 Phase 2 Phase 3 Phase2 Phase 3 Phase 2 Phase3 Background Threshold1

WATER QUALITY PARAMETERS

Chemical Oxygen Demand <8,000 11,000 <8,000 <8,000 <8,000 8,000 <8,000

Nitrate + Nitrite 2,920 1,170 1,460 1,110 2,080 520 780 2,000

Sulfate 10,7000 55,800 J 79,000 69,000] 25,500] 8,690 7,880

METALS, DISSOLVED

Antimony, Dissolved 71 65 <40

Barium, Dissolved 25 19 13 200

Copper, Dissolved 47 55 <20 500

Iron, Dissolved 160 J '78 J

Magnesium, Dissolved 10,700 6,500 6,870

Nickel, Dissolved 24 30 21

Potassium, Dissolved 2,380 1,350 <500

Selenium, Dissolved 6.9 6.6 5.4 1

Zinc, Dissolved 490] 315 J 20 2,500

NOTES:

1Approximate depth. 'Preventive Action Limits (PALs) from NR140 Wisconsin Administrative Code. J = Estimated Blanks indicate sample was not analyzed or that no PAL exists for that parameter. OW-l 04 Phase I results were used as the background sample for CL3. Results are shown for all samples if, for any ph-, the analyte is above background or the background sample has a •u• qualifier for that analyte, or the result is above PALs.

D:IF1ACCOYIIRFIJITAB7-6 Page2of2 February 1995 I Final Report Fort McCoy RFI

I TABLE 8-1

CLOSED LANDFILL 4 I GROUNDWATER FORT MCCOY RFI MONROE COUNTY, WISCONSIN I (ug/1)

OW-107 OW-108 OW-109 I Back- Regulatory Analyte Phase I Phase 2 Phase I Phase 2 Phase I Phase 2 ground Threshold I VOLATILE ORGANIC COMPOUNDS Acetone 2J <10 <10 16 <10 <10 2J I I ,2-Dichloroethylene <5 <5 <5 <5 9 <5 <5 20 Tetrachloroethylene <5 I J <5 I J <5 I J <5 0.1 I SEMI-VOLA TILE COMPOUNDS Bis(2-ethylhexyl) 2BJ <10 <10 <10 <10 <10 2BJ phthalate I METALS-TOTAL Aluminum 839 69 J 237 41J 110 84J 839 I Antimony <40 <7 48 <7 60 <7 <40 Arsenic

I D:IFTMCCOY/IRFIJITABB-1. Page 1 of2 February 1995 I Final Report Fort McCoy RFI I TABLE 8-1 (Continued) CLOSED LANDFILL 4 GROUNDWATER I FORT MCCOY RFI MONROE COUNTY, WISCONSIN I (ug/1) OW-107 OW-108 OW-109 Back- Regulatory I Analyte Phase 1 Phase 2 Phase 1 Phase 2 Phase 1 Phase 2 ground Threshold P04 <100 <100 <100 <100 <100 <100 <100 I so4 10,300 75,600 51,600 65,100 73,600 56,000 10,300 125,000 Total Dissolved 56,000 35,000 184,000 241,000 286,000 190,000 56,000 I Solids NOTES:

J = Estimated I B=Indicates only analyte was detected in associated blank. Results below detection limits are shown as less than detection limit for that analyte. I Blanks indicate compound has no PAL or was not analyzed. I I I I I I I I I

I D:IFTMCCOY /IRFIJITA/JIJ-1 Page2 of2 February 1995 ------

Final Report Fort McCoy Rf

TABLE 12-4

FIRE TRAINING BURN PIT I GROUNDWATER FORT MCCOY RFI MONROE COUNTY, WISCONSIN (ug/1)

OW-116A OW-116B OW-117 P-129A OW-1298 P-129C OW-132 P-133A OW-1338

40 Feet<" 20Feet 20 Feet 40 Feet 20 Feel 60 Feet 20 Feet 40 Feet 18 Feet

Analyte Plwe I "'-2 , ... , Phase I Plwe2 Plwel Plwe I Plwe2 Plwel "'-2 Pt.uel Plwe2 Pt.asel Phase 1 Pt.uel Plwel Phase J

VOLA TILE ORGANIC COMPOUNDS

Tetrachloroethylene 12.0

Trichloroethylene

1,2 Dichloroelhylene

Methylene Chloride 38 28

Methyl Ethyl Ketone <10 <10 <10 <10 <10 <10 <100 <100

METALS

Arsenic, Total <1.0 <10 <1.0 <10 <2 <10 <1.0 <10

Barium, Total 32.0B <100 108B <100 139B 200 349 <100 28 8 200 <100 100 <100 200 Cadmium, Total

Lead, Total 1.4B <3 <4.0 <1.0 <3 43 6.0 I.IB <3

D:lH'A«'COYIIRFIIITAHI2·J Page I ofl February 1995 ------

Final Report Fort McCoy RFI TABLE ll-4 (Continued)

FIRE TRAINING BURN PIT I GROUNDWATER FORT MCCOY RFI MONROE COUNTY, WISCONSIN (ug/1)

OW-134 OW-134A OW-135 P-13SA P-136A OW- OW-137 OW-138 OW-141 OW-142 OW-143 OW-308 P-308A 1368

18 Feet 40Feet 18 Feet 40 Feet 40Feet 18 Feet 18 Feet 18Feet 19Feet 19Feet 19Feet 18 Feet 40 Feet Regulatory Analyte Pbasel Plwel PbiiC] Phase] Phase] Pb ... ] Phase] Plwel Phase] Pbue] Plwel Phase] Plwel Background Threshold'

VOLATILE ORGANIC COMPOUNDS

Tetrachloroethylene 3.1 B

Trichloroethylene <0.5

1,2 Dichloroethylene

Methylene Chloride

Methyl Ethyl Ketone <10 <10 <10 <10 <10 <100 <10 <10 <10

METALS

Arsenic, total <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 <10 5

Barium, total 100 <100 <100 <100 <100 100 100 <100 <100 <100 100 <100 <100 100 200

I Cadmium, total

Chromium, total <10 <10 <10 <10 <10 <10 <10 <10 <10

Lead, total <3 <3 <3 <3 <3 <3 <3 <3 4 <3 <3 <3 <3 <3 s NOTES:

I Approximate depth. ' Preventive Action Limits (PALs) from NR 140 Wisconsin Administrative Code. J Estimated B Indicates analyte present in associated blank. Results below detection limits are shown as less than detection limit for that analyte. OW-116B total and dissolved metals analyzed. Dissolved metals below detection limits. OW-132 is the background sample for FTBPI. Results are shown if, for any phase, the analyte is above background or the background sample has a "U" qualifier for that analyte. Blanks indicate compound either was not analyzed or has no PAL. I

/):1Fl'A'K.l'f)YIIRHIITABI1·J Page 2 of2 February 1995 - -Final Report------Fort- McCoy RFI- - TABLE 13-3

FIRE TRAINING BURN PIT 2 GROUNDWATER FORT MCCOY RFI MONROE COUNTY, WISCONSIN (ug/1)

OW-ll8 OW-ll9 · OW-120 Regulatory Analyte Phase I Phase 2 Phase 3 Phase I Phase 2 Phase 3 Phase I Phase 2 Phase 3 Phase 2 Phase 3 Background Threshold 1

Methylene Chloride 4J

J Estimated. B Indicates analyte was detected in associated blank. Blanks indicate compound not analyzed. Results below detection limits are shown as less than detection limit for test analyte. OW-119 and OW-120 were averaged for background atFfBP2. 1Preventive Action Limits (PALs) from NRI40 Wisconsin Administrative Code.

D;'FTMCCOYJIRF/JITABIJ-J Page 1 of 1 February 1995 I I I I I I APPENDIXC

I SELECTED REMEDIATION TECHNOLOGIES I DESCRIPTIONS AND ILLUSTRATIONS I I I I I I I I I I I I EP A/542/B-94/013 NTIS PB95-104782 I October 1994 Remediation Technologies .I- Screening Matrix I and Reference Guide I Second Edition I I I I I Federal Remediation I Technologies I Roundtable I I I I I Prepared by the DOD Environmental Technology I J Transfer Committee I I 4.28 EXCAVATION, RETRIEVAL, AND OFF-SITE DISPOSAL I Description: Contaminated material is removed and transported to permitted off-site treatment and/or disposal facilities. Some pretreatment of the contaminated I media usually is required in order to meet land disposal restrictions. I I I I I I 4-28 94P-33 8126/94 I 4-28 TYPICAL CONTAMINATED SOIL EXCAVATION DIAGRAM

Applicability: Excavation and off-site disposal is applicable to the complete range of I contaminant groups with no particular target group. Although excavation and off-site disposal alleviates the contaminant problem at the site, it does I not treat the contaminants. Limitations: Factors that may limit the applicability and effectiveness of the process I include: • Generation of fugitive emissions may be a problem during operations . I • The distance from the contaminated site to the nearest disposal facility will affect cost.

I • Depth and composition of the media requiring excavation must be considered. I • Transportation of the soil through populated areas may· affect community acceptability. I • Disposal options for certain waste (e.g., mixed waste or transuranic waste) may be limited. There is currently only one licensed disposal I facility for radioactive and mixed waste in the United States.

I MK01\RPI':02281012.009\comppe.428 4-113 101l7194 . OTHER SOIL TREATMENT TECHNOLOGIES I I Data Needs: A detailed discussion of these data elements is provided in Subsection 2.2.1 (Data Requirements for Soil, Sediment, and Sludge). I The type of contaminant and its concentration will impact off-site disposal requirements. Soil characterization as dictated by land disposal restrictions (LDRs) are required. Most hazardous wastes must be treated to meet either I RCRA or non-RCRA treatment standards prior to land disposal. Radioactive wastes would have to meet disposal facility waste form requirements based on waste classification. I

Performance Data: Excavation and off-site disposal is a well proven and readily implementable I technology. Prior to 1984, excavation and off-site disposal was the most common method for cleaning up hazardous waste sites. Excavation is the initial component in all ex situ treatments. As a consequence, the I remediation consulting community is very familiar with this option.

The excavation of 18,200 metric tons (20,000 tons) of contaminated soil I would require about 2 months. Disposal of the contaminated media is dependent upon the availability of adequate containers to transport the hazardous waste to a RCRA-permitted facility. I

CERCLA includes a statutory preference for treatment of contaminants, and excavation and off-site disposal is now less acceptable than in the past. The I disposal of hazardous wastes is governed by RCRA (40 CFR Parts 261-265), and the U.S. Department of Transportation (DOT) regulates the transport of hazardous materials (49 CFR Parts 172-179,49 CFR Part 1387, and DOT-E I 8876). DOE has demonstrated a cryogenic retrieval of buried waste system, which I uses liquid nitrogen (LNJ to freeze soil and buried waste to reduce the spread of contamination while the buried material is retrieved with a series of remotely operated tools. Other excavation/retrieval systems that; DOE is I currently developing include a remote excavation system, a hydraulic impact end effector, and a high pressure waterjet dislodging and conveyance end effector using confined sluicing. I Cost: Cost estimates for excavation and disposal range from $300 to $510 per metric ton ($270 to $460 per ton) depending on the nature of hazardous materials and methods of excavation. These estimates include excavation/ I removal, transportation, and disposal at a RCRA permitted facility. Excavation and off-site disposal is a relatively simple process, with proven procedures. It is a labor-intensive practice with little potential for further I automation. Additional costs may include soil characterization and treatment to meet land ban requirements. I I

MK01\RPI":02281012.009\compade.428 I 4-114 101271114 I 4.28 EXCAVATION AND OFF-SITE DISPOSAL

I' References: Church, H.K., 1981. Excavation Handbook, McGraw Hill Book Co., New I York. NY. EPA, 1991. Survey of Materials-Handling Technologies Used at Hazardous I Waste Sites, EPA, ORD, Washington, DC, EPA/540/2-911010. EPA, 1992. McColl Superfund Site - Demonstration of a Trial Excavation, EPA RREL, series include Technology Evaluation EPA/S401R-92/015, PB92- I 226448; Applications Analysis, EPA/540/AR-92/015; and Technology Demonstration. Summary, EPA/540/SR/-92/015. I Points of Contact: Contact Government Agency Phone Location

Jaffer Mohiuddin DOE Program (301) 903-7965 EM-552, Travion II I Manager Washington, DC 20585 Technology USAEC (410) 671-2054 SFIM-AEC-ETD Demonstration and Fax: (410) 612-6836 APG, MD 2101o-5401 I Transfer Branch I I I I I I I I I I

I MK01\RPT:02281012.0091compgde.428 4-115 10127194 I 4.7 SOLIDIFICATION/STABILIZATION {IN SITU) I Description: Solidification/stabilization (SIS) reduces the mobility of hazardous substances and contaminants in the environment through both physical and chemical I means. Unlike other remedial technologies, SIS seeks to trap or immobilize contaminants within their "host" medium (i.e., the soil, sand, and/or building materials that contain· them), instead of removing them through chemical or physical treatment. Leachability testing is typically performed to measure I the immobilization of contaminants. In situ SIS techniques use auger/caisson I systems and injector head systems to apply SIS agents to in situ soils.

I Emissions, Reagent Dust ancVor andVOC I Control Binder ~ I I 'Injector Head I ~caisson

I 4·7 94P-2110 8122/94

4-7 TYPICAL AUGER/CAISSON AND REAGENTnNJECTOR HEAD IN SITU I SOLIDIFICATION/STABILIZATION SYSTEMS SIS techniques can be used alone or combined with other treatment and I disposal methods to yield a product or material suitable for land disposal or, in other cases, that can be applied to beneficial use. These techniques have I been used as both final and interim remedial measures. ~pplicability: The target contaminant group for in situ SIS is inorganics (including radionuclides). The technology has limited effectiveness against SVOCs and pesticides and no expected effectiveness against VOCs; however, systems I designed to be more effective in treating organics are being developed and tested.

I Limitations: Factors that may limit the applicability and effectiveness of the process include:

I • Depth of contaminants may limit some types of application processes. I

I MKOl \RPI":02l81012.009\o:ompp.47 4-27 10127194 IN SITU SOIL TREATMENT TECHNOLOGIES I I • Future usage of the site may "weather'' the materials and affect ability to maintain immobilization of contaminants. I • Some processes result in a significant increase in volume (up to double the original volume). I • Certain wastes are incompatible with variations of this process . Treatability studies are generally required. I • Reagent delivery and effective mixing are more diffiailt than for ex situ applications.

• Like all in situ treattnents, confirmatory sampling can be more I difficult than for ex situ treattnents.

Data Needs: A detailed discussion of these data elements is provided in Subsection 2.2.1 I (Data Requirements for Soil, Sediment, and Sludge). Data needs include particle size, Atterberg limits, moisture content, metal concentrations, sulfate content, organic content, density, penneability, unconfined compressive I strength, leachability, pH, and miaostructure analysis.

Performance Data: SIS technologies are well demonstrated, can be applied to the most common I site and waste types, require conventional materials handling equipment, and are available competitively from a number of vendors. Most reagents and additives are also widely available and relatively inexpensive industrial I commodities. In situ SIS processes have demonstrated the capability to reduce the mobility I of contaminated waste by greater than 95%.The effects, over the long term, of weathering (e.g., freeze-thaw cycles, acid precipitation, and wind erosion), groundwater infiltration, and physical disturbance associated with uncontrolled future land use can significantly affect the integrity of the I stabilized mass and contaminant mobility in ways that cannot be predicted by laboratory tests. I Cost: .Costs for cement-based stabilization techniques vary widely according to materials or reagents used, their availability, project size, and chemical nature of contaminants (e.g., types and concentration levels for shallow I applications). The in situ soil mixing/auger techniques average $50 to $80 per cubic meter ($40 to $60 per cubic yard) for the shallow applications and $190 to $330 per cubic meter ($150 to $250 per cubic yard) for the deeper I applications.

The shallow soil mixing technique processes 36 to 72 metric tons (40 to 80 tons) per hour on average, and the deep soil mixiilg technique averages 18 I to 45 metric tons (20 to 50 tons) per hour.

The major factor driving the selection process beyond basic waste I compatibility is the availability of suitable reagents. SIS processes require that potentially large volumes of bulk reagents and additives be transported to project sites. Transportation costs can dominate project economics and I

MKOI\RPI':02281012.009\compade.47 4-28 10127194 I I 4.7 SOLIDIFICATION/STABILIZATION (IN SITU) I can quickly become uneconomical in cases where local or regional material I sources are unavailable. References: EPA, 1989. Chemfix Technologies, Inc.- Chemical Fixation/Stabilization, EPA RREL, series includes Technology Evaluation, Vol I, EPA/540/5- I 89/0lla, PB91-127696, and Technology Evaluation, Vol II, EPA/540/5- 89/011b, PB90-274127.

EPA, 1989. Hazcon - Solidification, EPA RREL, series includes I Technology Evaluation, Vol. I, _EPA/540/5-89/001a, PB89-158810; Technology Evaluation, Vol. II, EPA/540/5-89/001b, PB89-158828; Applications Analysis, EPA/540/AS-89/001; and Technology Demonstration I Summary, EPA/540/S5-89/001.

EPA, 1989. IWI'/GeoCon In-Situ Stabilization, EPA RREL, series includes I Technology Evaluation, Vol. I, EPA/540/5-89/004a; Technology Evaluation, Vol. II, EPA/540/5-89/004b, PB89-194179; Technology Evaluation, Vol Ill,· EPA/540/5-89/004c, PB90-269069; Technology Evaluation, Vol IV, EPA/540/5-89/004d, PB90-269077; Applications Analysis, EPA/540/ AS- I 89/004; Technology Demonstration Summary, EPA/540/S5-89/004; Technology Demonstration Summary - Update Report, EPA/540/S5- I 89/004a; and Demonstration Bulletin, EPA/540/MS-89/004. EPA, 1989. SrrE Program Demonstration Test International Waste Technologies In Situ Stabilization/Solidification Hialeah, Florida, I Technology Evaluation Report, EPA RREL, Cincinnati, OH, EP A/540/5- 89/004a. I EPA, 1989. Soliditech, Inc. -Solidification, EPA RREL, series includes Technology Evaluation, Vol I, EPA/540/5-89/005a; Technology Evaluation, Vol II, EPA/540/5-89/005b, PB90-191768; Applications Analysis, EPA/540/ AS-891005; Technology Demonstration Summary, EPA/540/S5- I 89/005; and Demonstration Bulletin, EPA/540/M5-89/005.

EPA, 1989. Stabilization/Solidification of CERCLA and RCRA Wastes: I Physical Tests, Chemical Testing Procedures, Technology Screening, and Field Activities, EPA, CERL, Cincinnati, OH, EPA/625/6-89/022. I EPA, 1990. International Waste Technologies/Geo-Con In Situ Stabilization/ Solidification, Applications Report, EPA, ORO, Washington, DC, EPA/540/ AS-891004.

I EPA, 1993. Solidification/Stabilization and Its Application to Waste Materials, Technical Resource Document, EPA, ORO, Washington, DC, I EPA/530/R-93/012. EPA, 1993. Solidification/Stabilization of Organics and lnorganics, I Engineering Bulletin, EPA, ORD, Cincinnati, OH, EPA/540/S-92/015. Wiles, C.C., 1991. Treatment of Hazardous Waste with Solidification/ I Stabilization, EPA Report EPA/600/D-91/061.

I MK01\RPI":02281012.009\compgde.47 4-29 10127/94 IN SITU SOIL TREATMENT TECHNOLOGIES I I Site Information: Beginning Levels Site Name Contact SUmmary Levels Attained Coats I Hialeah, FL Jeff Newton Deep soil mixing using $111-$194/ lntemational Waste drive auger to inject ton Technologies additive slurry and water I 150 North Main Street, into in-place soil. NA NA Suite 910 Wichita, KS 67202 (316) 269-2660 Geo-Con I Dave Miller (817) 383-1400

Note: NA • Not Available. I

Points of Contact: I Contact Government Agency Phone Location

Mary K. Stinson EPA RREL (908) 321-6683 2890 Woodbridge Avenue (MS-104) Fax: (908) 321-6640 Edison, NJ 08837-3679 I Patricia M. Erikson EPA RREL (513) 569-7884 26 West M.L. King Drive Fax: (513)569-7676 Cincinnati, OH 45268 Edward R. Bates EPA RREL (513) 569-7774 26 West M.L. King Drive I Fax: (513) 569-7676 Cincinnati, OH 45268 John Cullinane USAE-WES (801) 836-3111 ATTN: LEWE8-EE·S 3909 Halls Ferry Road Vicksburg, MS 39180-6199 I Technology USAEC (410) 671-2054 SFIM·AEC-ETD Demonstration and Fax: (410) 612·6836 APG, MD 21010.5401 Transfer Branch I I I I I I I ( I

MK01\RPI':02281012.()()9\a)mpsdeA7 4-30 10/l7194 I I I 4.19 SOLIDIFICATION/STABILIZATION (EX SITU) Description: As for in situ solidification/stabilization (SIS) (see Technology Profile No. 4. 7), ex situ SIS contaminants are physically bound or enclosed within a I stabilized mass (solidification), or chemical reactions are induced between the stabilizing agent and contaminants to reduce their mobility (stabilization). I Ex situ SIS, however, typically requires disposal of the resultant materials. I Waste Material I Weight Feeder Dry Reagent Sfto

I Auger I Water Supply (if required)------')lo...,.l Homogenizer' Dry Reagent Feeder I I Pug Mill I

I Chute to Truck Loading Area 4-19 94P·2199 1on194 I 4-19 TYPICAL EX SITU SOLIDIFICATION/STABILIZATION PROCESS FLOW DIAGRAM

Applicability: The target contaminant group for ex situ SIS is inorganics, including I radionuclides. The technology has limited effectiveness against SVOCs and pesticides; however, systems designed to be more effective against organic I contaminants are being developed and tested. Limitations: Factors that may limit the applicability and effectiveness of the. process I include: • Environmental conditions may affect the long-term immobilization of I contaminants. • Some processes result in a significant increase in volume ·(up to I double the original volume). • Certain wastes are incompatible with different processes. Treatability I studies are generally required. • VOCs are generally not immobilized.

I MKOl\RYf:02281012.009\compgdeA19 4-77 10/27194 EX SITU SOIL TREATMENT TECHNOLOGIES I I • Long-term effectiveness has not been demonstrated for many contaminant/process combinations. I Data Needs: A detailed discussion of these data elements is provided in Subsection 2.2.1 (Data Requirements for Soil, Sediment, and Sludge). Soil parameters that must be determined include particle size, Atterberg limits, moisture content, I metal concentrations, sulfate content, organic content, density, permeability, unconfined compressive strength, leachability, microstructure analysis, and physical and chemical durability. I

Performance Data: Depending upon the original contaminants and the chemical reactions that I take place in the ex situ SIS process, the resultant stabilized mass may have to be handled as a hazardous waste. For certain types of , the stabilized product must be capable of meeting stringent waste form I requirements for disposal (e.g., Class B or Class C low level materials). Remediation of a site consisting of 18,200 metric tons (20,000 tons) could require less than 1 month, depending on equipment size and type and soil I properties (e.g., percent solids and particle size). DOE has demonstrated the Polyethylene Encapsulation of Radionuclides and I Heavy Metals (PERM) process at the bench scale. The process is a waste treatment and stabilization technology for high-level mixed waste. Specific targeted contaminants include radionuclides (e.g., cesium, strontium, and I cobalt), and toxic metals (e.g., chromium, lead, and cadmium). The process should be ready for implementation in FY95. I Cost: Ex situ solidification/stabilization processes are among the most mature remediation technologies. Representative overall costs from more than a dozen vendors indicate an approximate cost of under $110 per metric ton ($100 per ton), including excavation. I

References: Bricka, R.M., et al., 1988. An Evaluation of Stabilization/Solidification of Fluidized Bed Ash (K048 and K051 ), USAE-WES Technical I Report EL-88-24.

EPA, 1989. Chemjix Technologies, Inc.-Chemical Fixation/Stabilization, I EPA RREL, Technology Evaluation Vol. I, EPA/540/5-89/011a, PB91-127696; and Technology Evaluation Vol. n, EPA/540/5-89/0llb, PB90-274127. I

EPA, 1989. Harcon--Solidification, EPA RREL, series includes Technology Evaluation Vol. I, EPA/540/5-89/00 1a, PB89-158810; Technology Evaluation I Vol. U, EPA/540/5-89/001b, PB89-158828; Applications Analysis, EPA/540/A5-89/001; and Technology Demonstration Summary, EP A/540/S5-89/001. I

EPA, 1989. Solidtech, Inc.-Solidification, EPA RREL, series includes Technology Evaluation Vol. I, EPA/540/5S-89/005a; Technology Evaluation I Vol. n, EPA/540/5S-89/005b, PB90-191768; Applications Analysis,

MK01\RPJ':02281 012.009\comp&dcA19 4-78 10127194 I I 4.19 SOLIDIFICATION/STABILIZATION I EPA/540/ AS-89/005; Technology Demonstration Summary, EPA/540/S5- I 89/005; and Demonstration Bulletin, EPA/540/MS-89/005. EPA, 1989. Stilbilization/Solidification of CERCLA and RCRA Wastes­ Physical Tests, Chemical Testing Procedures, Technology Screening and I Field Activities, EPA, ORO, Washington, DC, EPA/625/6-89/022.

EPA, 1992. Silicate Technology Corporation-Solidification/Stabilization of I Organic/Inorganic Contaminants, EPA RREL, Demonstration Bulletin, EPA/540/MR-92/010; Applications Analysis, EPA/540/AR-92/010, PB93- I 172948. . EPA, 1993. Solidification/Stilbilization and Its Application to Waste Materials, Technical Resource Document, EPA, ORO, Washington, DC, I EPA/530/R-93/012. EPA, 1993. Solidijication/Stilbilization of Organics and Inorganics, I Engineering Bulletin, EPA, ORO, Cincinnati, OH, EPA/540/S-921015. DOE, 1993. Technology Name: Polyethylene Encapsulation, Technology Infonnation Profile (Rev. 2) for ProTech, DOE ProTech Database, TIP I Reference No. BH-321201. I I I I I I I I I

10127194 I MKOl\RPI':~l012.CXl9'colllpldeA19 4-79 EX SITU SOIL TREATMENT TECHNOLOGIES I

/' I ( Site Information: Beginning Levels I Site Name Cont.ct Sununary Levels Attained Coats Portable Edwin Barth· EPA Dry alumina, calcium, and 93.2 to $80/metric Equipment CERI silica blended in reaction >99.9% ton . Salvage vessel. reduction of ($73/ton) I Clackamas, OK NA CU,Pb,and Zn TCLP levels Naval NFESC Code 411 Spent blasting abrasives <5ppm $94/metric I Construction Port Hueneme, CA 93043 screened and mixed with · TCLP ton Battalion Center (614) 424-5442 portland cement and NA ($85/ton) Port Hueneme, soluble silicates. CA I RobinsAFB Terry Lyons Addition of pozzolonic Macon, GA EPARREL cementitioua matlriala. 26 West M.L King Dr. NA NA NA Cincinnati, OH 45268 I (513) 569-7589 Note: NA •. Not Available. I Points of Contact: Cont.ct Government Agency Phone Location I Edwin Barth EPACERI (513) 569·7669 26 West M.L King Dr. Fax: (513) 569-7585 Cincinnati, OH 45268 Mark Bricka USAE·WES (601) 634-3700 CEWES.EE·S 3909 HaDa Feny Road I Vicksburg, MS 39180-6199 ~atricia M. Erikson EPARREL (513) 569-7884 26 West M.L. King Dr. Fax: (513) 569-7676 Cincinnati, OH 45268 I Technology USAEC (410) 671-2054 SFIM·AEC·ETD Demonstration and Fax: (410) 612-6836 APG, MD 21 01 0.5401 Transfer Branch I Sherry Gibson DOE (301) 903-7258 EM-552, Tnwion II Washington, DC 20585 I I I I I ( I.

MK01\RPI':02281012.009\ccmpgdc.419 4-80 1M7194 I I 4.24 LOW TEMPERATURE THERMAL DESORPTION I Description: Low temperature thermal desorption (LTID) systems are physical separation processes and are not designed to destroy organics. Wastes are heated to I between 90 and 320 °C (200 to 600 °F) to volatilize water and organic contaminants. A carrier gas or vacuum system transports volatilized water and organics to the gas treatment system. The bed temperatures and I residence times designed into these systems will volatilize selected contaminants but will typically not oxidize them. LTID is a full-scale technology that has been proven successful for remediating petroleum I hydrocarbon contamination in all types of soil. Contaminant destruction efficiencies in the afterburners of these units are greater than 95%. The same equipment could probably meet stricter requirements with minor I modifications, if necessary. Decontaminated soil retains its physical properties and ability to support biological activity. I ;,. Clean Afterburner I I I Offgas I' I Baghouse

I H I ... Material Excavate ,. ,..... Desorber Handling '-- I ~OVersized Rejects ... Treated I Medium I 4-24 94P-2220 9/12194 I 4-24 TYPICAL SCHEMATIC DIAGRAM OF THERMAL DESORPTION PROCESS Two common thermal desorption designs are. the rotary dryer and thermal screw. Rotary dryers are horizontal cylinders that can be indirect- or direct­ I fired. The dryer is normally inclined and rotated. For the thermal screw units, screw conveyors or hollow augers are used to transport the medium through an enclosed trough. Hot oil or steam circulates through the auger .I to indirectly heat the medium. All thermal desorption systems require treatment of the off-gas to remove and contaminants. Particulates are removed by conventional particulate removal equipment, I such as wet scrubbers or fabric filters. Contaminants are removed through

I MK011RPI':02281012.009\compgdc.424 4-97 10127194 EX SITU SOIL TREATMENT TECHNOLOGIES I I condensation followed by carbon adsorption, or they are destroyed in a secondary chamber or a catalytic oxidizer. Most of these units i are transportable. I

Applicability: The target contaminant groups for L TID systems are nonhalogenated VOCs and fuels. The technology can be used to treat SVOCs at reduced I effectiveness.

Limitations: Factors that may limit the applicability and effectiveness of the process include: I

• There are specific feed size and materials handling requirements that . can impact applicability or cost at specific sites. I

• Dewatering may be necessary to achieve acceptable soil moisture content levels. I • Highly abrasive feed potentially can damage the processor unit I • Heavy metals in the feed may produce a treated solid residue that requires stabilization. I Data Needs: A detailed discussion of these data elements is provided in Subsection 2.2.1 (Data Requirements for Soil, Sediment, and Sludge). In addition to identifying soil contaminants and their concentrations, information necessary I for engineering thermal systems to specific applications include soil moisture content and classification, texture, mercury content, pH, and presence of high or low volatility compounds. I Performance Data: Most of the hardware components for L TID systems are readily available I off the shelf. Many vendors offer L TID units mounted on a single trailer. Soil throughput rates are typically 13 to 18 metric tons (15 to 20 tons) per hour for sandy soils and less than 6 metric tons (7 tons) per hour for clay soils when more than 10% of the material passes a 200-mesh screen. Units with capacities ranging from 23 to 46 metric tons (25 to 50 tons) per hour require four or five trailers for transport and 2 days for setup. ... All ex situ soil thermal treabnent systems employ similar feed systems consisting of a screening device to separate and remove materials greater than 5 centimeters (2 inches), a belt conveyor to move the screened soil from I the screen to the first thermal treatment chamber, and a weight belt to measure soil mass. Occasionally, augers are used rather than belt conveyors, but either type of system requires daily maintenance and is subject to failures I that shut the system down. Soil conveyors in large systems seem more prone to failure than those in smaller systems. Size reduction equipment can be incorporated into the feed system, but its installation is usually avoided I to minimize shutdown as a result of equipment failure. I

MKOl \RPI':02281012.009\oompgde.424 4-98 10127194 I I 4.24 LOW TEMPERATURE THERMAL DESORPTION I Soil storage piles and feed equipment are generally covered as protection from rain to minimize soil moisture content and material handling problems. I Soils and sediments with water contents greater than 20 to 25% may require the installation of a dryer in the feed system to reduce the energy cost to heat the soil. Some volatilization of contaminants occms in the dryer, and I the gases are routed to a thermal treatment chamber.

Cost: Rates charged to remediate petroleum hydrocarbon contaminated soil range I from $45 to $110 per ~etric ton ($40 to $100 per ton) of soil. Costs for remediating clay soils may approach $220 per metric ton ($200 per ton) because of the reduced throughout resulting from the small soil particle size. I Of this cost, approximately $20 to $35 per metric ton ($15 to $30 per ton) is required for direct operating costs such as utility consumption and repair. Vendors typically perform preventive maintenance, such as lubrication, on I a daily basis. Unit transportation and setup costs are typically $3.30 to $5.50 per metric ton ($3 to $5 per ton), seldom exceeding a mobilization cost of $200,000. Excavation of contaminated soil and the replacement of the I treated soil costs approximately $6 to $11 per metric ton ($5 to $10 per ton). References: EPA, 1992. A Citizen's Guide to Thermal Desorption, EPA, OSWER, ,I Washington, DC, EPA/542/F-92/006.

EPA, 1992. Low Temperature Thermal Treatment (LT 3®) System, I Demonstration Bulletin, Washington, DC, EPA/540/MR-92/019. EPA, 1992. Roy F. Weston, Inc.-Low Temperature Thermal Treatment (LT3) System, EPA RREL, Demonstration Bulletin, EPA/540/MR-921019; I and Applications Analysis, EPA/540/AR-92/019.

EPA, 1993. Low Temperature Thermal Aeration (LITA) System, Canonie I Environmental Services, Inc., EPA RREL, Demonstration Bulletin, EPA/ 540/MR-93/504.

I EPA, 1994. Thermal Desorption System. Clean Berkshires, Inc., EPA RREL, Demonstration Bulletin, EPA/540/MR-94/507; and Capsule, EPA/ I 540/R-94/507a. EPA, 1994. Thermal Desorption Treatment, Engineering Bulletin, I EPA/540/5-94/50 1. EPA, 1994. Thermal Desorption Unit, EcoLogic Intemationa~ Inc., EPA I RREL, Demonstration Bulletin, EPA/540/MR-94/504. Lighty, J., et al., 1987. The Cleanup of Contaminated Soil by Thermal Desorption, Presented at Second International Conference on New Frontiers I for Hazardous Waste Management, EPA Report EPA/600/9-87/018. U.S. Anny, August 1990. The Low Temperature Thermal Stripping Process, I USATHAMA, APG, MD, USATHAMA Cir. 200-1-5.

I MK01\RPT:0228101l.009'\o:ompple.424 4-99 10fl7194 EX SITU SOIL TREATMENT TECHNOLOGIES I I Site Information: Beginning Levels Site Name Contact Summary Levels Attained Costa I Tinker AFB Michael G. Cosmos Low temperature thermal 99.9% BTEX $410 to Oklahoma City, Roy F. Weston, Inc. treatment (L T ~ - 3,000 removal $798/metric OK One Weston Way ydl treated - VOCs, ton West Chester, PA 19380 SVOCs, TP-4 NA ($373- I (610) 701-7423 $725/ton) based on soil moisture I Letterkenny AD Michael G. Cosmos USAEC's Holo-Aite screw Various VOCs up 99.95% voc $81 to Chambersburg, Roy F. Weston, Inc. thermal processor to 20,000 ppm removal $176/metric PA One Weston Way ton West Chester, PA 19380 ($74- (610) 701-7423 $160/ton) I + $410 to $798/metric ton ($87- I $184/ton) soil for gas treat- ment Letterkenny AD Michael G. Cosmos LT' - TCE, DCE, PCE, Various VOCs up Up to 1.8 $410 to I Chambersburg, Roy F. Weston, Inc. xylene to 27,000 ppm ppm $798/metric PA One Weston Way ton West Chester, PA 19380 ($373- (610) 701-7423 $725/ton) I based on soil moisture Note: NA • Not Available. I Points of Contact: Contact Government Agency Phone Location I Michael Gruenfeld EPA RREL (908) 321-6625 2890 Woocl:uidge Ave. Releases Control Building 10 (MS-104) Branch Edison, NJ 08837 t Paul dePercin EPA (513) 569-7797 26 West M.L. King Dr. Cincinnati, OH 45268 Daniel E. Averett USAE-WES (601) 634-3959 Attn: CEWES.EE-S 3909 HaUs Ferry Road I Vicksburg, MS 3918Q-6199 Technology USAEC (410) 671-2054 SFIM-AEC·ETD Demonstration and Fax: (410) 612-6836 APG, MD 21010.5401 Transfer Branch I I I. I I

MK01\RPT:02281 012.009\compgde.424 4-100 I I I 4.41 SLURRY WALLS Description: Slurry walls are used to contain contaminated groundwater, divert contaminated groundwater from the drinking water intake, divert I uncontaminated groundwater flow, and/or provide a barrier for the groundwater treatment system. I I I I I I I I 94P-2350 8/26/94 I 4-41 TYPICAL KEYED-IN SLURRY WALL (CROSS SECTION)

These subsurface barriers consist of a vertically excavated trench that is filled I with a slurry. The slurry hydraulically shores the trench to prevent collapse and forms a filter cake to reduce groundwater flow. Slurry walls often are used where the waste mass is too large for treatment and where soluble and I mobile constituents pose an imminent threat to a source of drinking water. Slurry walls are a full-scale technology that have been used for decades as I long-term solutions for controlling seepage. They are often used in conjunction with capping. The technology has demonstrated its effectiveness in containing greater than 95% of the uncontaminated groundwater; however, I in contaminated groundwater applications, specific contaminant types may degrade the slurry wall components and reduce the long-term effectiveness. I Most slurry walls are constructed of a soil, bentonite, and water mixture; walls of this composition provide a barrier with low permeability and chemical resistance at low cost Other wall compositions, such as sheet I piling, cement, bentonite, and water, may be used if greater s~ctural

I MK01\RPI":OZ211012.009\compsde.441 4-165 10fZ7/9ol IN SITU WATER TREATMENT TECHNOLOGIES I I strength is required or if chemical incompatibilities between bentonite and site contaminants exist I Slurry walls are typically placed at depths less than 15 meters (50 feet) and are generally 0.6 to 1.2 meters (2 to 4 feet) in thickness. The most effective application of the slurry wall for site remediation or pollution control is to I base (or key) the slurry wall 0.6 to 0.9 meters (2 to 3 feet) into a low permeability layer such as clay or bedrock, as shown in the preceding figure. This "keying-in" provides for an effective foundation with minimum leakage I potential. An alternate configuration for slurry wall installation is a "hanging" wall in which the wall projects into the groundwater table to block the movement of lower density or floating contaminants such as oils, fuels, I or gases. Hanging walls are used less frequently than keyed-in walls.

Applicability: Slurry walls contain the groundwater itself, thus treating no particular target I group of contaminants. They are used to contain contaminated groundwater, divert contaminated groundwater from drinking water intake, divert uncontaminated groundwater flow, and/or provide a barrier for the I groundwater treatment system.

Limitations: Factors that may limit the applicability and effectiveness of the process include: I • 1be technology only contains contaminants within a specific area. I • Soil-bentonite backfills are not ·able to withstand attack by strong acids, bases, salt solutions, and some organic chemicals. Other slurry mixtures can be developed to resist specific chemicals. I

• There is the potential for the slurry walls to degrade or deteriorate over time. I

Data Needs: A detailed discussion of these data elements is provided in Subsection 2.2.2 (Data Requirements for Groundwater. Surface Water, and Leachate). I

The following factors. at a minimum, must be assessed prior to designing effective soil-bentonite slurry walls: maximum allowable permeability, I anticipated hydraulic gradients, required wall strength, availability and grade of bentonite to be used, boundaries of contamination, compatibility of wastes and contaminants in contact with slurry wall materials, characteristics (i.e., I depth, permeability, and continuity) of substrate into which the wall is to be keyed, characteristics of backfill material (e.g .• fines content), and site terrain and physical layout I Performance Data: Slurry walls have been used for decades, so the equipment and methodology are readily available and well known; however, the process of designing the I proper mix of wall materials to contain specific contaminants is less well developed. Excavation and backfilling of the trench is critical and requires experienced contractors. I

MK01\RPI':02281012.0091compp.441 4-166 10127194 I I 4.41 SLURRY WALLS I Cost: Costs likely to be incurred in the design and installation of a standard soil­ bentonite wall in soft to medium soil range from $540 to $750 per square I meter ($5 to $7 per square foot) (1991 dollars). These costs do not include variable costs required for chemical analyses, feasibility, or compatibility I testing. Testing costs depend heavily on site-specific factors. Factors that have the most significant impact on the final cost of soil­ I bentonite slurry wall installation in~lude: • Type, activity, and distribution of contaminants. I • Depth, .length, and width of wall. • Geological and hydrological characteristics.

I • Distance from source of materials and equipment I • Requirements for wall protection and maintenance. • Type of slurry and backfill used.

I • Other site-specific requirements as identified in the initial site assessment (e.g., presence of contaminants or debris).

I References: Goldberg:-Zoino and Associates, Inc., 1987. Construction Quality Control and Post-Construction Performance for the Gilson Road Hazardous Waste I Site Cutoff Wall, EPA Report EPA/6CYJ/2-87/065. McCandless, R.M. and A. Bodocsi, 1987. InvestigatioTJ of Slurry Cutoff Wall Design and Construction Methods for Containing Hazardous Wastes, I EPA Report EPA/600/2-87/063.

Miller, S.P., 1979. Geotechnical Containment Alternatives for Industrial I Waste Basin F, Roclcy Mountain Arsenal, Denver, Colorado: A Quantitative Evaluation, USAE-WES Technical Report GL-79-23. I Spooner, P.A., et al., 1984. Slurry Trench Construction for Pollution Migration Control, EPA Report EPA/540/2-84/001. · I USACE, 1986. Civil Works Construction Guide Specification for Soil­ Bentonite Slurry Trench Cutoffs, National Institute of Building Sciences, Construction Criteria Base, CW-02214. ·

I Zappi, M.E., D.O. Adrian, and R.R. Shafer, 1989. "Compatibility of Soil­ Bentonite Slurry Wall Backfill Mixtures with Contaminated Groundwater," I in Proceedings of the 1989 Superfund Conference, Washington, DC. t

I MKOl \RPI':02281012.009\almpade.441 4-167 10/l7194 IN SITU WATER TREATMENT TECHNOLOGIES I I Zappi, M.E., R.A. Shafer, and D.D. Adrian, 1990. Compatibility of Ninth Avenue Superfund Site Ground Water with Two Soil-Bentonite Slurry Wall Backfill Mixtures, WES Report No. EL-90-9. I Site Information: I Site Name Contact Summ•ry Co•• Hazardous Waste Landfill GEO-CON,Inc. Bentonite altemative used beCause of saltwater environment I and pnasence of incompatible NA organic compound. Sanitary Landfill GEO-CON, Inc. Limited working area. NA I, Coal Tar Disposal Pond Cireumfenantial containment of NA leachate from pond with metals NA and phenols. Keyed to impervious till. I Note: NA • Not Available. I Points of Contact: Contact Government Agency Phone Location Jesse Oldham USAE-WES (601) 634-3111 Attn: cewes-ee-s I or Mark E. Zappi (601) 634-2856 3903 Halls Feny Road Vicksburg, MS 39180-6199 Technology USAEC (410) 671-2054 SFIM-AEC-ETO { Demonstration and I Fax: (410) 612-6836 APG, MD 2101o-5401 Transfer Branch I I I I I I I ( t

MK01\RPT:02281012.009\colllplde.441 4-168 I I I. , 4.43 BIOREACTORS

Description: Bioreactors degrade contaminants in water with microorganisms through I attached or suspended biological systems. In suspended growth systems, such as activated sludge, fluidized beds, or sequencing batch reactors, I contaminated groundwater is circulated in an aeration basin where a microbial population aerobically degrades organic matter and produces C02, H20, and new cells. The cells form a sludge, which is settled out in a clarifier, and is either recycled to the aeration basin or disposed of. In I attached growth systems, such as upftow fixed film bioreactors; rotating biological contactors (RBCs), and trickling filters, microorganisms are established on an inert support matrix to aerobically degrade water J, contaminants.

,, Off gas Treatment Off gas t I Treatment I

I' I ABC Units ' I Solids Sludge I Disposal' Disposal' 94P·2352 8126194 I 4-43 TYPICAL ROTATING BIOLOGICAL CONTACTOR (ABC)

One promising methodology includes the use of active supports (such as I activated carbon, which adsorbs the contaminant and slowly releases it to the microorganisms for degradation). The microbial population may be derived either from the contaminant source or from an inoculum of organisms I specific to a contaminant. Other applications include wetland ecosystems and column reactors. t

I MK01\RPT:02281012.009\compgde.443 . 4-173 10f27194 EX SITU WATER TREATMENT TECHNOLOGIES I I Applicability: Bioreactors are used primarily to treat SVOCs, fuel hydrocarbons, and any biodegradable organic material. The process may be less effective for some pesticides. Successful pilot-scale field studies have been conducted on some I halogenated compounds, such as PCP and chlorobenzene and dichloro­ benzene isomers. I Limitations: The following factors may limit the applicability and effectiveness of the process: I • Residuals from sludge processes require treatment or disposal.

• Very high contaminant concentrations may be toxic to I microorganisms.

controls may need to be applied if there is volatilization I from activated sludge processes. • Low ambient temperatures significantly decrease biodegradation rates, I resulting in longer cleanup times or increased costs for heating.

• Nuisance microorganisms may preferentially colonize bioreactors, I leading to reduced effectiveness.

Data Needs: A detailed discussion of these data elements is provided in Subsection 2.2.2 (Data Requirements for Groundwater, Surface Water, and Leachate). Data requirements include contaminants and their concentrations, soil ''I classification, texture, pH, presence of compounds toxic to microorganisms, contaminant biodegradability, tlow rate, temperature, and nutrient levels.

Performance I Data: This is a well developed technology that has been used for many decades in the treatment of municipal wastewater. Equipment and materials are readily I available. As with other pump-and-treat technologies, time needed to clean up is dependent upon subsurface conditions and the rate of desorption of contaminants from subsurface materials, but it is typically faster than in situ bioremediation. I

Startup time can be slow if organisms need to be acclimated to the wastes; however, the existence of cultures that have been previously adapted to I specific hazardous wastes can decrease startup· and detention times.

DOE has demonstrated another biological process, biological destruction of I tank waste (BD1W), on the laboratory scale. This process is a separation and volume--reduction process for supernatant and sluiced salt cake waste from underground storage tanks. These wastes are usually composed of I various radionuclides and toxic metals concentrated in a nitrate salt solution. The bacteria act as metal and radionuclide adsorbers and also as denitrification catalysts that reproduce themselves at ambient temperature and • MK01\RPI':0228101l.009\tompgde.443 4-174 1007194 I I 4.43 BIOREACTORS I pressure. Some degradation of organic contaminants may also occur during I the process. The field demonstration bioreactor tank size is about 100 cubic meters, which corresponds to a waste treannent rate of 2 gpm, sufficient to treat a I !-million gallon tank in 1 year. At the 2-gpm size, the BD1W system is transportable. The current bioreactor is able to process salt solutions having nitrate concentrations up to 300,000 ppm. The maximum salt tolerance is I being explored. Power usage is estimated at 20 kW for pumping and agitation.

I Cost: Costs are highly dependent on the contaminants and their concentrations in the influent stream. Biological treannent has often been found to be more I economical than carbon adsorption. Staging will vary from site to site depending on the wastestream. The cost to install a single unit with a protective cover and a surface area of 9,300 to I 13,900 square meters (100,000 to 150,000 square feet) ranges from $80,000 to $85,000.

I References: DOE-ID, 1993. Technology Name: Biological Destruction of Tank Wastes, Technology Information Profile (Rev. 2) for ProTech, DOE ProTech I Database, TTP Reference No.: ID-121204. EPA, 1980. Innovative and Alternative Technology Assessment Manual, I EPA, Office of Water Program Operations, EPA/430/9-78/009. EPA, 1984. Design Information on Rotating Biological Contactors, EPA/600/2-84/106.

I EPA, 1987. Rotating Biological Contactors: U.S. Overview, EPA/600/D- 87/023.

I EPA, 1991. BioTrol- Biotreatment of Groundwater, EPA RREL, series includes Technology Evaluation, EPA/540/5-91/001, PB92-110048; Applications Analysis, EPA/540/AS-91/001; Technology Demonstration I Summary, EPA/540/S5-91/001; and Demonstration Bulletin, EPA/540/M5- 91/001.

I EPA, 1993. BioTrol, Inc. - Methanotrophic Bioreactor System, EPA RREL, series includes Emerging Technology Bulletin; EPA/540/F-93/506; Emerging Technology Summary, EPA/540/SR-93/505; and Journal Article, I AWMA, Vol. 43, No. 11, November 1993.

Opatken, E.J., H.K. Howard, and J.J. Bond, 1987. Biological Treatment of I Hazardous Aqueous Wastes, EPA Report EPA/600/D-87/184.

Opatken, E.J., H.K. Howard, and J.J. Bond, 1989. "Biological Treatment of I Leachate from a Superfund Site," Environmental Progress, Vol. 8, No. 1.

I MK01\RFI':02281012.009Icompgde.443 4-175 10127194 EX SITU WATER TREATMENT TECHNOLOGIES I I Stinson, M., H. Skovronek, and T. Chresand, 1992. "EPA SITE Demonstration of BioTrol Aqueous Treatment System," Journal of the Air I Waste Management Association, Vol. 41, No.2, p. 228. Site Information: I Beginning Levels Site Name Contact Summary Levels Attained Costs Hanscomb AFB, Alison Thomas Testing of constitutive 550 ppbTCE About MA USAF TCE-clegJading microbe 85ppb NA I Tyndall AFB, FL {904) 283-6303 Mac:Gillis& Dennis Chilcote SiTE demo at Superfund 45 ppm PCP <1 ppm in <$0.92/1,000 L I Gibbs BioTrol, Inc. site- BioTIOI ~· one pass (<$3.5011,000 New Brighton, 10300 Valley V18W Rd. Treatment Sy8tem gallons) MN Eden Pnlirie, MN 55344- (BATS) 3456 I (612) 942-8032 TCE Site Ronald Lewis SITE demo of TCE >100 ppm Lowppbs St. Joseph, Ml EPA RREL immobilized cell 26 West M.L King Dr. bioraactor (ICB) I Cincinnati, OH 45268 . biotreatment system, NA (513) 569-7856 aerobic/anaerobic fixed Fax: (513) 569-7620 fdm bioraactor Burteigh Tunnel Rick Brown Manmade wetland 50-60 ppm zinc 99% I Silver Plume, CO Colorado Dept of Health ecosystem-baaed reclJction in 421 o East 11th Ave. tnlatment 3 months NA Room 252 (303) 692-3383 I Fax: (303) 759-5355 Dow Chemical Alison Thomas Chlorobenzene 140 ppm <5ppb Site, TX USAF degradation in a fluid bed chlorobenzene chloro- NA Tyndall AFB reactor benzene I

Note: NA • not available Points of Contact: I Contact Government Agency Phone Location Edward Bates EPA RREL (513) 569-7774 26 West M.L King Dr. I Fax: (513) 569-7676 Cincinnati, OH 45268 David Smith EPA, Region VIII (303) 293-1475 999 181h St. Fax: (303) 294-1198 Denver, CO 80202 I Edward J. Opatken EPA RREL (513) 569-7855 26 West M.L King Dr. Cincinnati, OH 45268 Alison Thomas USAF (904) 283-6303 ALJEQW Tyndall AFB, FL 32403 I Sherry Gibson DOE (301) 903-7258 EM-552, Trevion II Washington, DC 20585 Mary K. Stinson EPA RREL (908) 321-6683 2890 Woodbridge A'le. I M8-104 Edison, NJ 08837-3679 Technology USAEC (410) 612-2054 SFIM-AEC-ETD Demonstration and Fax: (410) 612-6836 APG, MD 2101o-5401 I Transfer Branch ( I

MKOl\RPl':0%181012.009\compadeM3 4-176 10117194 I I 4.47 LIQUID PHASE CARBON ADSORPTION I Description: liquid phase carbon adsorption is a full-scale technology in which groundwater is pumped through a series of vessels containing activated I carbon to which dissolved contaminants adsorb. When the concentration of contaminants in the effluent from the bed exceeds a certain level, the carbon can be regenerated in place; removed and regenerated at an off-site facility; I or removed and disposed of. Carbon used for explosives- or metals­ contaminated groundwater probably cannot be regenerated and should be removed and properly disposed of. Adsorption by activated carbon has a I long history of use in treating municipal~ industrial, and hazardous wastes. I I I I Carbon Bed I I Particulate FiHer Influent ~======-...,.. ~ Effluen I (Treated Water)

I Spent Carbon -47 94P-3314 8/25194

I 4-47 TYPICAL FIXED-BED CARBON ADSORPTION SYSTEM

I The two most common reactor configurations for carbon adsorption systems are the fixed bed (see figure) and the pulsed or moving bed. The fixed-bed configuration is the most widely used for adsorption from liquidS. Suspended solids in a liquid stream may accumulate in the column, causing I an increase in pressure drop. When the pressure drop becomes too high, the accumulated solids must be removed, for example, by backwashing. The solids removal process necessitates adsorber downtime and may result in I carbon loss and disruption of the mass transfer zone. Pretreatment for I

I MKOl \RPI':0228l Ol2.009\compp!e.447 4-189 l0/l7194 EX SITU WATER TREATMENT TECHNOLOGIES I I removal of solids from streams to be treated is, therefore, an important design consideration. I Carbon can be used in conjunction with the steam reforming. Steam reforming is a technology designed to destroy halogenated solvents (such as carbon tetrachloride, CC14, and chloroform, CHC13) adsorbed on activated I carbon by reaction with superheated steam in a commercial reactor (the Synthetica Detoxifier). I Applicability: The target contaminant groups for carbon adsorption are SVOCs and explosives. Limited effectiveness may be achieved on halogenated VOCs, fuels, and pesticides. Liquid phase carbon adsorption is effective for I removing contaminants at low concentrations (less than 10 mg!L) from water at nearly any flow rate, and for removing higher concentrations of contaminants from water at low flow rates (typically 2 to 4 liters per minute I or 0.5 to 1 gpm). Carbon adsorption is particularly effective for polishing water discharges from other remedial technologies to attain regulatory compliance. Carbon adsorption systems can be deployed rapidly, and contaminant removal efficiencies are high. Logistic and economic I disadvantages arise from the need to transport and decontaminate spent carbon. I Limitations: The following factors may limit the applicability and effectiveness of the process: !

• The presence of multiple contaminants can impact process performance. Single component isotherms may not be applicable for ' mixtures. Bench tests may be conducted to estimate carbon usage for I mixtures. j • Metals can foul the system.

• Costs· are high if used as the primary treatment on wastestreams with high contaminant concentration levels. I

• Type and pore size of the carbon, as well as the operating temperature, will impact process performance. Vendor expertise for I carbon selection should be consulted.

• Carbon used for explosives-contaminated groundwater is not I regenerated; it must be properly disposed of. • Water-soluble compounds and small molecules are not adsorbed well. I

Data Needs: A detailed discussion of these data elements is provided in Subsection 2.2.2 (Data Requirements for Groundwater, Surface Water, and Leachate). I I

MK01\RPT:02281012Jl091compgde.447 4-190 10127194 I I 4.47 LIQUID PHASE CARBON ADSORPTION I The major design variables for liquid phase carbon applications are empty bed contact time (EBCI), usage rate, and system configuration. Particle size I and hydraulic loading are often chosen to minimize pressure drop and reduce or eliminate backwashing. System configuration and EBCT have an impact on carbon usage rate. When the· bed life is longer than 6 months and the

I treatment objective is stringent (C/C0<0.05), a single adsorber or a combination of single beds operating in parallel is preferred. For a single adsorber, the EBCI' is normally chosen to be large enough to minimize I carbon usage rate. When less stringent objectives are required (C/C0<0.3), blending of effluents from partially saturated adsorbers can be used to reduce carbon replacement rate. When stringent treatment objectives are required (C/C <0.05) and bed life is short (less than 6 months), multiple beds in I 0 series may be used to decrease carbon usage rate. I Performance Data: Adsorption by activated carbon has a long history of use as a treatment for municipal, industrial, and hazardous wastestreams. The concepts, theory, and engineering aspects of the technology are well developed. It is a proven technology with documented performance data. Carbon adsorption is a relatively nonspecific adsorbent and is effective for removing many organic, 'I explosive, and some inorganic contaminants from liquid and gaseous streams. Cost: Costs associated with GAC are dependent on wastestream flow rates, type I of contaminant, concentrations, and site and timing requirements. Costs are lower with lower concentration lev~ls of a contaminant of a given type. Costs are also lower at higher flow rates. At flow rates of 0.4 million liters per day (0.1 mgd), costs increase to $0.32 to $1.70 per 1,000 liters ($1.20 I to $6.30 per 1,000 gallons) treated.

References: EPA, 1986. Mobile Treatment Technologies for Superfund Wastes, I EPA/54012·86/003.

EPA, 1990. Innovative and Alternative Technology Assessment Manual, I EPA, Office of Water Program Operations, EPA/430/9·78/009.

EPA, 1993. Approaches for the Remediation of Federal Facility Sites Contaminated with Explosive or Radioactive Wastes, EPA/625/R.·93/013.

Zappi, M.E., B.C. Fleming, and C.L. Teetar, 1992. Draft- Treatability of 'I Contaminated Groundwater from the Lang Sup~rfund Site, USAE-WES.

Zappi, M.E., C.L. Teeter, B.C. Fleming, and N.R. Francingues, 1991. I Treatability ofNinth A venue Superfund Site Groundwater, WES Report EL- 91-8. I. I

I MKOt\RPJ':onatot2.0091compgdc.447 4.191 10127194 EX SITU WATER TREATMENT TECHNOLOGIES I

{ I Site lnfonnation: Beginning Levels I Site Name Contact SUmmary Levels Attained Costs Verona WeUfield Superfund • GAC as 12,850 ppb 11 ppb Battle Creek, Ml NA pl'8traatment.for air TVOC NA stripper. I U.S. Coast Guard NA Pump/treat and cischarge 10,329 ppb <10 ppb NA Traverse City, Ml to municipal aewer. Toluene Love Canal NA GAC system.for leachate 28,000 ppb <10 ppb NA Niagara Falls, NY treatment Benzene I Milan AAP USAECETD Pilot scale study of GAC 1.0 - 2.0 mgiL NO (<10 Milan, TN (410) 671-2054 for explosives- total explosives ppb) for all 9 · NA contaminated groundwater. explosives I Note: NA • Not Available. I Points of Contact: Cof!laCt Government Agency Phone Location Dr. James Heidman EPA RREL FTS 684-7632 26 West M.L. King Dr. I (513) 569-7632 Cincinnati, OH 45268 David Biancosino DOE (301) 903-7961 EM-551, Trevion II Washington, DC 20585 I Technology USAEC (410) 671-2054 SFIM-AEC·ETD Demonstration and Fax: (410) 612-6836 APG, MD 21010.5401 Transfer Branch (. I I I I I I I I ( .. .. _ I

MKOl \RI'l':0228101l.009\compade.447 4-192 10/27194 i I 4.44 AIR STRIPPING

I Description: Air stripping is a full-scale technology in which volatile organics are partitioned from groundwater by greatly increasing the surface area of the contaminated water exposed to air. Types of aeration methods include I packed towers, diffused aeration, tray aeration, and spray aeration. I I I Packing Clean Out I Air Stripping I Tower I ___ ,I Water Inlet Une --..+ I I 4-44 94P-3312 9113194 SOURCE: RECOVERY EQUIPMENT SUPPLY, INC. I 4-44 JYPICAL AIR STRIPPING SYSTEM Air stripping involves the mass transfer of volatile contaminants from water to air. For groundwater remediation, this process is typically conducted in I a packed tower or an aeration tank. The typical packed tower air stripper includes a spray nozzle at the top of the tower to distribute contaminated water over the packing in the column, a fan to force air countercurrent to the I water flow, and a sump at the bottom of the tower to collect decontaminated water. Auxiliary equipment that can be added to the basic air stripper includes an air heater to improve removal efficiencies; automated control I systems with sump level switches and safety features, such as differential pressure monitors, high sump level switches, and explosion-proof components; and air emission control and treatment systems, such as I activated carbon units, catalytic oxidizers, or thermal oxidizers. Packed tower air strippers are installed either as permanent installations on concrete I pads oi: on a skid or a trailer. I

I MK01\RPT:02281012.009\compgde.444 4-177 10127194 EX SITU WATER TREATMENT TECHNOLOGIES I I Aeration tanks strip volatile compounds by bubbling air into a tank through which contaminated water flows. A forced air blower and a distribution manifold are designed to ensure air-water contact without the need for any I packing materials. The baffles and multiple units ensure adequate residence time for stripping to occur. Aeration tanks are typically sold as continuously operated skid-mounted units. The advantages offered by aeration tanks are I considerably lower profiles (less than 2 meters or 6 feet high) than packed towers (5 to 12 meters or 15 to 40 feet high) where heigl)t may be a problem, and the ability to modify performance or adapt to changing feed I composition by adding or removing trays or chambers. The discharge air from aeration tanks can be treated using the same technology as for packed tower air discharge treatment I

Air strippers can be operated continuously or in a batch mode where the air stripper is intermittently fed from a collection tank. The batch mode ensures I consistent air stripper performance and greater energy efficiency than continuously operated units because mixing in the storage tanks eliminates any inconsistencies in feed water composition. I Applicability: Air stripping is used to separate VOCs from water. It is ineffective for inorganic contaminants. Henry's law constant is used to determine whether I air stripping will be effective. Generally, organic compounds with constants greater than 0.01 atmospheres- m3/mol are considered amenable to stripping. Some compounds that have been successfully separated from water using air I stripping include BlEX, chloroethane, TCE, DCE, and PCE. Limitations: The following factors may limit the applicability and effectiveness of the I process: • The potential exists for inorganic (e.g., iron greater than 5 ppm, I hardness greater than 800 ppm) or biological fouling of the equipment, requiring pretreatment or periodic column cleaning.

• Consideration should be given to the Henry's law constant of the I VOCs in the water stream, ·and the type and amount of packing used in the tower. I • Compounds with low volatility at ambient temperature may require preheating of the groundwater. I \ • Off-gases may require treatment based on mass emission rate.

Data Needs: A detailed discussion of these data elements is provided in Subsection 2.2.2 I (Data Requirements for Groundwater, Surface Water, and Leachate).

Vendors require the following information to select the properly sized tower I for a specific application: range of feedwater flow rates; range of water and I MK01\RPT:02281 012.(Xl91compgde.444 4-178 101Z7/94 I I 4.44 AIR STRIPPING I air temperatures; whether the tower will operate continuously or intennittently; tower feed and discharge systems (gravity feed or type and I location of pumps); height restrictions on the tower; influent contaminant identification and concentrations; mineral content; pH; requirements for effluent water contaminant concentrations; and restrictions on air discharge I from the tower. Performance Data: Removal efficiencies around 99% are typical for towers that have 4.6 to 6 I meters (15 to 20 feet) of packing and are removing compounds amenable to stripping. Removal efficiencies can be improved by adding a second air stripper in series with the first, heating the contaminated water, increasing I the airmquid ratio, or heating the air. Thermal units for treating air stripper emissions can be used as a source of heat. The performance of aeration tanks can be improved by adding chambers or trays, or by increasing the air I supply, depending on the design of the tank.

The major problem encountered with packed tower air strippers is fouling of I the packing, which reduces the air flow rate. Fouling is caused by oxidation of minerals in the feed water, such as iron and magnesium, by precipitation I of calcium, and by biological growth on the packing material. Cost: A major operating cost of air strippers is the electricity required for the groundwater pump, the sump discharge pump, and the air blower. The I power rating of the groundwater pump and discharge pump depends on the pressure head and pressure drop across the column and should be obtained from pump curves. A$ a generalized rule, pumps in the 4 to 80 liters per I minute (1 to 20-gpm) range require from 0.33 to 2 HP; from 80 to 290 liters per minute (20 to 75 gpm) power ratings are 1 to 5 HP; and from 380 to 2,270 liters per minute (100 to 600 gpm), power ratings range from 5 to 30 I HP. A crude method of estimating blower motor power assumes that each foot of air stripper diameter requires 1.5 HP.

I References: Dietrich, C., D. Treichler, and J. Armstrong, 1987. An Evaluation of Rotary Air Stripping for Removal of Volatile Organics from Groundwater, USAF I Environmental and Service Center Report ESL-TR-86-46. Elliott, M.G. and E.G. Marchand, 1990. "USAF Air Stripping and Emissions Control Research," in Proceedings of the 14th Annual Army Environmental I Symposium, USATHAMA Report CErnA-lE-TR-90055. Shukla, H.M. and R.E. Hicks, 1984. Process Design .Manual for Stripping of Organics, Water General Corporation for EPA, EPA/600/12-841139, NTIS I PB 84 232628.

Singh, S.P., 1989. Air Stripping of Volatile Organic Compounds from I Groundwater: An Evaluation of a Centrifugal Vapor-Liquid Contractor, USAF Environmental and Service Center Report ESL~ TR-86-46. I

I MK01\RPT:02281012.009\compade.444 4-179 10117194 EX SITU WATER TREATMENT TECHNOLOGIES I I

Wilson, J.H., R.M. Counce, A.J. Lucero, H.L. Jennings, and S.P. Singh, 1991. Air Stripping and Emissions Control Technologies: Field Testing of I Counter Cu"ent Poclcings, Rotary Air Stripping, Catalytic Oxidation, and Adsorption MateritJls, ESL TR 90-S 1. I Site Information: Beginning Levels I Site Name Contact Summary. Levels Attained Costa 9th Ave. Beth Fleming Bench scale unit to treat Superfund Site USAE-WES VOCs in groundwater Gary, IN Attn: CEWES-EE·S I 3909 HaUs Ferry Road NA NA NA Vicksburg, MS 39180· . 6199 (601) 634-3943 I Englin AFB Edward G. Marchand Field testing of rotary air >99% HQ AFCESAIRAVW stripper- high iron removal Tyndall AFB, FL 32403- content NA NA 5319 I (904) 283-6023 DOE - Savannah 5()()-gpm air stripper, 11 15-ppm TCE, Less than 1 $0.20/1,000 L River Site NA wells 6.7-ppm PCE TCE and ($0. 75/1,000 I PCE gallons) Note: NA • Not Available. i ' Points of Contact: I Contact Government Agency Phone Location Capt. Edward G. USAF (904) 283-6023 HQ AFCESAIRAV I Marchand Tyndall AFB, FL 32403-5319 Or. James Heidman EPARREL FTS 684·7632 26 West M.L. King Or. {513) 569-7632 Cincinnati, OH 45268 I Technology USAEC {410) 671·2054 SFIM·AEC·ETD Demonstration and Fax: {410) 612-6836 APG, MD 21010.5401 Transfer Branch I I I I I ( I

MK01\RF1':02281012.009\compp.444 4-180 10117194 I I 4.34 AIR SPARGING · I Description: Air sparging is an in situ technology in which air is bubbled through a contaminated aquifer. Air bubbles traverse horizontally and vertically I through the soil column, creating an underground stripper that removes contaminants by volatilization. These air bubbles carry the contaminants to a vapor extraction system. Vapor extraction is implemented in conjunction I with air sparging to remove the generated vapor phase contamination. This technology is designed to operate at high flow rates to maintain increased contact between groundwater and soil and strip more groundwater by I spar ging.

Vent Gas I Air Collection Channels Blower To Further r------i~Treatment I or Discharge

I Groundwater Extraction Vadose f Wells Zone

-----~ -- I Injection ------0 -- Well 0 0 Contaminated Saturated 0 Groundwater I 0 Zone I

4-34 94P-3316 8/26194

I 4-34 TYPICAL AIR SPARGING SYSTEM

I Applicability: The target contaminant groups for air sparging are VOCs and fuels. Only li~ted information is available on the process. I Limitations: Factors that may limit the applicability and effectiveness of the process include: I • Depth of contaminants and specific site geology must be considered. • Air injection wells must be designed for site-specific conditions . I • Air flow through the saturated zone may not be uniform . I

I MK01\RPI':02281012.0091<:ompadeA34 4-137 101271114 IN SITU WATER TREATMENT TECHNOLOGIES I I Data Needs: A detailed discussion of these data elements is provided in Subsection 2.2.2 (Data Requirements for Groundwater. Surface Water. and Leachate). Characteristics that should be determined include vadose zone gas I permeability. groundwater flow rate. aquifer permeability. presence of low permeability layers. presence of DNAPLs. depth of contamination. and contaminant volatility and solubility. I Performance Data: This technology will be demonstrated over the next 2 to 3 years at DOE's Hanford Reservation as part of the agency's Integrated Technology I Demonstration Program for Arid Sites. Air sparging has demonstrated sensitivity to minute permeability changes. which can result in localized stripping between the sparge and monitoring wells. I

Cost: One estimate, $371,000 to $865,000 per hectare ($150,000 to $350,000 per acre) of groundwater plume to be treated. was available. I

References: Hildebrandt, W. and F. Jasiulewicz. 1992. "Cleaning Up Military Bases." The Military Engineer. No. 55, p. 7. September-October 1992. I I I I I I I I I • I I

MK01\RP1':02l81012.009'compade.434 4-138 J0/1.7194 I I 4.34 AIR SPARGING I Site Information: Beginning Levels I Site Name Contact Summary Levels Attained Costs Savannah River, NA NA PCE 3-124 <184 ppb NA IL TCE 10-1,031 <1.8 ppb I Conservancy BTX 49-60% Site NA NA reduction NA Belen, NM I Note: NA • Not Available. Points of Contact: I Contact Government Agency Phone Location Steve Stein Environmental (206) 528-3340 4000 N.E. 41st St1'88t Management Seattle, WA 98105 Organization, Pacific I Northwest Division Steven M. Gorelick Stanford University (415) 725-2950 Stanford, CA 94305-2225 Dept. of AppUed Earth ·a Sciences Technology USAEC (410) 671-2054 SFIM-AEC-ETO Demonstration and Fax: (410) 612-6836 APG, MD 2101Q-5401 I Transfer Branch I I I I I I I I I

I MK01\RPT:02281012.009\compp.434 4-139 10/27194 I 4.6 SOIL VAPOR EXTRACTION (IN SITU}

I Description: Soil vapor extraction (SVE) is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile and some semivolatile I contaminants from the soil. The gas leaving the soil may be treated to recover or destroy the contaminants, depending on local and state air discharge regulations. Vertical extraction vents are typically used at depths I of 1.5 meters (5 feet) or greater and have been successfully applied as deep as 91 meters (300 feet). Horizontal extraction vents (installed in trenches or horizontal borings) can be used as warranted by contaminant zone geometry, I drill rig access, or other site-specific factors. I Moisture Separator Inlet I Gas Discharge I Fume Incineration I Catalytic Oxidation I I I I 4-6 94P-3306 8126194 I 4-6 TYPICAL IN SITU SOIL VAPOR EXTRACTION SYSTEM

Groundwater depression p~ps may be used to reduce groundwater I upwelling induced by the vacuum or to increase the depth of the vadose zone. Air injection is effective for facilitating extraction of deep contamination, contamination in low permeability soils, and contamination I in the saturated zone (see Treatment Technology Profile 4.34, Air Sparging).

Applicability: The target contaminant groups for SVE are VOCs and some fuels. The I technology is typically applicable only to volatile compounds with a Henry's law constant greater than 0.01 or a vapor pressure greater than 0.5 mmHg I (0.02 inches Hg). Other factors, such as the moisture content, organic I MK01\RPT:02281012.009\compgde.46 4-23 10127194 IN SITU SOIL TREATMENT TECHNOLOGIES I

content, and air penneability of the soil, will also affect SVE' s effectiveness. I SVE will not remove heavy oils, metals, PCBs, or dioxins. Because the process involves the continuous flow of air through the soil, however, it often promotes the in situ biodegradation of low-volatility organic I compounds that may be present.

Limitations: Factors that may limit the applicability and effectiveness of the process I include:

• Soil that is tight or has high moisture content (>50%) has a reduced I penneability to air, requiring higher vacuums (increasing costs) and/or hindering the operation of SVE. I • Large screened intervals are required in extraction wells for soil with highly variable penneabilities or horizonation, which otherwise may result in uneven delivery of gas flow from the contaminated regions. I • Soil that has high organic content or is extremely dry has a high sorption capacity of VOCs, which results in reduced removal rates. I • Air emissions may require treatment to eliminate possible harm to the public and the environment I • As a result of off-gas treatment, residual liquids and spent activated carbon may require treatment/disposal. I • SVE is not effective in the saturated zone; however, lowering the water table can expose more media to SVE (this may address concerns regarding LNAPLs). I

Data Needs: A detailed discussion of these data elements is provided in Subsection 2.2.1 (Data Requirements for Soil, Sediment, and Sludge). Data requirements I include the depth and areal extent of contamination, the concentration of the contaminants, depth to water table, and soil type and properties (e.g., structure, texture, permeability, and moisture content). I

Pilot studies should be pedormed to provide design information, including extraction well, radius of influence, gas flow rates, optimal applied vacuum, I and contaminant mass removal rates.

Performance I Data: A field pilot study is necessary to establish the feasibility of the method as well as to obtain infonnation necessary to design and configure the system. During full-scale operation, SVE can be run intermittently (pulsed operation) I once the extracted mass removal rate has reached an asymptotic level. This pulsed operation can increase the cost-effectiveness of the system by facilitating extraction of higher concentrations of contaminants. ·. After the I contaminants are removed by SVE, other remedial measures, such as I MK01\RFI':02281012.009\compple.46 4-24 1007194 I I­ 4.6 SOIL VAPOR EXTRACTION (IN SITU) I biodegradation, can be investigated if remedial action objectives have not I been met. SVE projects are typically completed in 18 months. Cost: The cost of SVE is site-specific, depending on the size of the site, the nature and amount of contamination, and the hydrogeological setting (EPA, July 1989). These factors affect the number of wells, the blower capacity and I vacuum level required, and the length of time required to remediate the site. A requirement for off-gas treatment adds significantly to the cost Water is also frequently extracted during the process and usually requires treannent I prior to disposal, further adding to the cost. Cost estimates for SVE range between $10 and $50 per cubic meter ($10 and $40 per cubic yard) of soil. I Pilot testing typically costs $10,000 to $100,000. References: EPA, 1989. Terra Vac, In Situ Vacuum Extraction System, EPA RREL, Applications Analysis Report, Cincinnati, OH, EPA Report EPA/540/AS- I 89/003.

EPA, 1989. Terra Vac- Vacuum Extraction, EPA RREL, series includes I Technology Evaluation, Vol. I, EPA/540/5-89/003a, PB89-192025; Technology Evaluation, Vol. II, EPA/540/ A5-89/003b; Applications Analysis, EPA/540/ AS-89/003; Technology Demonstration Summary, EPA/540/SS- I 89/003; and Demonstration Bulletin, EPA/540/MS-89/003.

EPA, 1990. State of Technology Review: Soil Vapor Extraction System I Technology, Hazardous Waste Engineering Research Laboratory, Cincinnati, OH, EPA/600/2-89/024.

I EPA, 1991. AWD Technologies, Inc. -Integrated Vapor Extraction and Stream Vacuum Stripping, EPA RREL, series includes Applications Analysis, EPA/540/ A5 -91/002, PB89-192033.. and Demonstration Bulletin, I EP A/540/MS-89/003. EPA 1991. Guide for Conducting Treatability Studies Under CERCLA: Soil I Vapor Extraction, OERP, Washington, DC, EPA Report EPA/540/2- 91/019A.

EPA, 1991. In-Situ Soil Vapor Extraction Treatment, Engineering Bulletin, I RREL, Cincinnati, OH, EPA/540/2-91/006.

EPA, 1991. Soil Vapor Extraction Technology Reference Handbook, EPA, I RREL, Cincinnati, OH, T.A. Pederson and J.T. Curtis, Editors, EPA/540/2- I 91/003. I I I M KOl \RPI':02281 Oll.00911:ompp.46 4-25 10127194 IN SITU SOIL TREATMENT TECHNOLOGIES I ·I Site Information: Beginning Levels Site Name Contact Summary Levels Attained Costs I DOE, Savannah Brian B. Looney Horizontal wells are 1,800 ppb TCE 30 ppb TCE Demo- River, Aiken, SC Westinghouse Savannah concu11'81\tly used to $44Jkg River Co. ramec:liUt soils and Prep- P.O. Box 616 groundwater. $300,000· I Aiken, sc 29802 $450,000 (803) 725-3692 Groveland Wells Mary Stinson Pilot system 3-350 ppm TCE Non-detect $30 to $75 Superfund Site EPA Technical Support to 39 ppm per metric I Groveland, MA Branch, RREL TCE ton ($30 to 2890 Woodbridge Ave. $70 per ton) Builcing 10 of soil Edison, NJ 08837-3679 I (908) 321-6683 Terra Vac (714) 252-8900 Hill AFB, UT Major Mart< Smith Full-scale aystem at JP-4 I USAF jet "-' spil alta NA NA NA Letteri50 vents) > 1,000 ppm total $2M design, Chambersburg, Bldg. 4435 pilot system. 1,530 m1 VOCs NA install, and I PA APG, MD 21010 (2,000 ~ traat8d. operation. (410) 671-2054 Note: NA • Not Available. I

Points of Contact: Contact Government Agency Phone Location I Mike O'Rear DOE Savannah River (803) 725-5541 Aiken, SC Ramon Mendoza EPA Region IX (415) 744-2410 75 Hawthome Street San Francisco, CA 94105 I Arthur L. Baehr USGS (609) 771-3978 810 Bear Tavern Rd., Suite 206 West Trenton, NJ 08628 Michael Gruenfeld EPA Releases Control (906) 321-6625 2890 Woodbridge Ave. I Branch, RREL MS.104 Edison, NJ 08837-3679 Stacy Erikson EPA (303) 294-1084 One Denver Place I 999 18th Street Denver, CO 80202·2466 Major Mart< Smith USAF (904) 283-6126 AUEQW Tyndall AFB, Fl 32403 I Technology USAEC (410) 671·2054 SFIM·AEC-ETD Demonstration and Fax: (410) 612-6836 APG, MD 21010.5401 Transfer Branch I Mary K. Stinson EPA Technical (908) 321-6683 2890 Woodbridge Ave Support Branch, 'MS-104 RREL Edison, NJ 08837-3679 I I ( I MKOI \RPI':0228! 0!2.009\c:ompgde.46 4-26 10127194 I I I 4.48 PRECIPITATION Oescription: Precipitation of metals has long been the primary method of treating metal­ laden industrial wastewaters. As a result of the success of metals I precipitation in such applications, the technology is being considered and selected for use in remediating groundwater containing heavy metals, including their radioactive isotopes. In groundwater treatment applications, I the metal precipitation process is often used as a pretreatment for other treatment technologies (such as chemical oxidation or air stripping) where I the presence of metals would interfere with the other treatment processes. I

Effluent ...... ,. "·.,...... I Oxidation! •"·"· ...... Reduction ••• ••• ••• ...... h "'· "'· ~.... "'· "· "· ... "'· "'· (for Hydroxide ...... h "• "'• process) ...... •"·"· "· ·"·"'· I pH Adjustment Flocculation and Reagent Addition . I .------f-J Ground Water I • . I Th"~eener k I OVerflow 1---...;,_---1 I L.-- I l Filtrate I I I Solids to Sludge Sludge Disposal Dewatering

I 4-48 94P·2726 8125194 Source: Arthur D. Litle. Inc. I 4-48 TYPICAL METALS PRECIPITATION PROCESS Metals precipitation from contaminated water involves the conversion of soluble heavy metal salts to insoluble salts that will precipitate. The I precipitate can then be removed from the treated water by physical methods such as clarification (settling) and/or filtration.

I This process transforms dissolved contaminant into an insoluble solid, facilitating the contaminant's subsequent removal from the liquid phase by sedimentation or filtration. The process usually uses pH adjusbllent, addition I of a chemical precipitant, and flocculation. Typically, metals precipitate from the solution as hydroxides, sulfides, or carbonates. The solubilities of the specific metal contaminants and the required cleanup standards will I dictate the process used. I Applicability: Precipitation is used mainly for metals.

I MKOJ\RP1':0221JOJ2.009\comp&cleA48 4-193 JM7J94 EX SITU WATER TREATMENT TECHNOLOGIES I I Limitations: Disadvantages of metals precipitation may include:

• As with any pump and treat process, if the source of contamination is I not removed (as in metals absorbed to soil), treatment of the groundwater may be superfluous. I • The presence of multiple metal species may lead to removal difficulties as a result of amphoteric natures of different compounds (i.e., optimization on one metal species may prevent removal of I another) ..

• As discharge standards become more stringent, further treatment may I be required.

• Metal hydroxide sludges must pass TCLP prior to land disposal. I • Reagent addition must be carefully controlled to preclude unacceptable concentrations in treatment effluent. I • Efficacy of the system relies on adequate solids separation techniques (e.g., clarification, flocculation •. and/or filtration); I • Process may generate toxic sludge requiring proper disposal.

• Process can be costly, depending on reagents used, required system I controls, and required operator involvement in system operation.

• Dissolved salts are added to the treated water as a result of pH I adjustment

• Polymer may be added to the water to achieve adequate settling of .I solids.

• Treated water will often require pH adjustment I

Data Needs: A detailed discussion of these data elements is provided in Subsection 2.2.2 (Data Requirements for Groundwater, Surface Water, and Leachate). I

Bench-scale treatability tests should be conducted to determine operating parameters and characteristics [i.e., reagent type and dosage, optimum pH, I retention time, flow rate, temperature, mi~g requirements, flocculent (polymer) selection, suspended solids, precipitate settling and filtration rates, and sludge volume and characteristics]. I Performance Data: Precipitation of heavy metals as the metal hydroxides or sulfides has been I practiced as the prime method of treatment for heavy metals in industrial wastewater for many years. More recently, precipitation (usually as the -I

MK01\RPT:02211012.009\compgdc.448 4-194 1007194 I I 4.48 PRECIPITATION I metal hydroxides) has been used in the electronics and electroplating industries as a pretreatment technology for wastewater discharge to a I publicly owned treatment works (POTW). Metals precipitation is widely used to meet NPDES requirements for the treatment of heavy metal­ I containing wastewaters. Because of its success in meeting requirements for discharge of treated wastewater, metals precipitation is recognized as a proven process for use in I remedial activities such as groundwater treatment Precipitation (combined with sedimentation, and/or flocculation and filtration) is becoming the most widely selected means for heavy metals removal from groundwater in pump I and treat operations. Cost: The primary capital cost factor is design flow rate. Capital costs for 75- and 250-liters-per-minute (20-gpm and 65-gpm) packaged metals precipitation I systems are approximately $85,000 and $115,000, respectively.

The primary factors affecting operating costs are labor and chemical costs. I Operating costs (excluding sludge disposal) are typically in a range from $0.08 to $0.18 per 1,000 liters ($0.30 to $0.70 per 1,000 gallons) of I groundwater containing up to 100 mg/L of metals. For budgetary purposes, sludge disposal may be estimated to increase operating costs by approximately $0.13 per 1,000 liters ($0.50 per 1,000 I gallons) of groundwater treated. Acrual sludge disposal costs (including fixation and transportation) have been estimated at approximately $330 per I metric ton ($300 per ton) of sludge. Costs for performing a laboratory treatability study for metals precipitation may range from $5,000 to $20,000. Depending on the degree of uncertainty I or other requirements, a pilot or field demonstration may be needed. Associated costs may range from $50,000 to $250,000 (depending on scale, I analytical requirements, and duration). References: Balaso, C.A., et al., 1986. Soluble Sulfide Precipitation Study, Arthur D. Little, Inc., Final Repon to USA THAMA, Report No. AMXTH-TE-CR- I 87106. Bricka, R. Mark, 1988. Investigation and Evaluation of the Perfonnance of I Solidified Cellulose and Starch Xanthate Heavy Metal Sludges, USACE­ WES Technical Report EL-88-5. I EPA, 1980. Control and Treatment Technology for the Metal Finishing Industry: Sulfide Precipitation, EPA/625/8-80/003.

EPA, 1990. Innovative and Alternative Technology Assessment Manual, I EPA, Office of Water Program Operations, EPA/430/9-78/009. I

10127194 I MK01\RFf:Ol281012.00911:ompp.448 4-195 EX SITU WATER TREATMENT TECHNOLOGIES I I Site Information: Beginning Levels Site Name Contact Summary Levels Attained Costa I Coakley Landfill Pretreatment of Cr- 330 ppb Cr· 50 ppb New Hampshire groundwater by hydroxide Ni • 122·200 ppb Ni • 100 ppb NA precipitation with lime, A$ • 10-90 ppb A$. 50 ppb NA I then air stripping for removal of VOCs Stringfellow Acid Pnttreatmant for the Cr • 1.5·270 ppm Cr·O.S ppm Pit Site NA ramoval of metals and Cd • 0.32-9.3 ppm Cd • 0.11 ppm I California organlca, then POlW Zn • 2.2-300 ppm . Zn • 2.81 ppm NA Cu. 1.7-20 ppm Cu·2ppm Winthrop Landfill Pilot test of metals from A$ • 0.1..0.8 ppm A$ ·0.05 ppm Winthrop, ME NA the groundwater by Ni • 0.04 ppm Ni • 0.04 ppm NA I precipitation Zn • 0.2..0.6 ppm Zn • 0.18 ppm Note: NA .. Not Available. I

Points of Contact: Contact Government Agency Phone Location I Dr. D.B. Chan NFESC (805) 982-4191 Code 411 Port Hueneme, CA 93043 Mark Bricka USAE-WES (801) 834-3700 CEWES.EE·S I 3909 Hafts Ferry Road Vicksburg, MS 39180-8199 R.L Biggers NFESC (805) 982·2640 Code 414 Port Hueneme, CA 93043 I Technology USAEC (410) 871-2054 SFIM-AEC·ETD Demonstration and Fax: (410) 812-8836 APG, MD 21010.5401 Transfer Branch I I I I I I I I

MKOl \RPT:OZ2810ll.009\compsde.448 4-196 10fl7194 I . saturnted zone .. . . . to the processes de:scribed above it is not uncommon to fnli'liimnnluof c.irbonace'ous . · find bcl~terlal populations in the rhizosh­ •stl'ate.anlftJIXV:I!en tia.nSfer. Rhizod~~ 'perd'~f~yated t(!a level an order of mag­ .the result of the ·.. nitud~1'~r more above surrounding, .· ....::.:~u ''uu"' and root hairs. Also' undeveloped soils . ·importan{aiecarbonaceous root exuda­ Theprimary in-situ remediation poten­ tio~·such'a's)eakage. from epidermal tial.ofplants for hydrocarbons lies in c~lls; secretionS resulting from metabolic ·. theii capacitY to enhance oxidation rates · in the subsurface and provide cometa­ • '-·~·· ;··:-';), r· ?'- ·::~~~:~~(.':\'.~;,~ ~· !- - . ·: ': , ' actiyity;' mucilages from root tips (which ;p· hytoremediation is the ·use of . ·:a:e:·r as lubricants for root penetration); bolic 'substrate. However, plants also . ,~, yla~t root sy~te~s for subsurfac_e .· ···and lysates from sloughed cells. Exudates · have the ability to remove compounds, a · ; m-s1tu remediation. Phytoremed1-. are composed of a wide range of chemi- · process termed phytoextraction, which I ation acts through two fundamental cals that include sugars, amino acids, can be applied to organic or metal conta­ processes, · in-situ biodegradation organic acids and fatty acids. It is esti- minants. In the case of hydrocarbons, the through enhancement of oxidation rates . mated that 7 to 27 percent of the total compound must be water soluble and I and phytoextraction (removal of com­ plant mass is annually deposited as car­ have a moderate degree of lipid solubil­ pounds). A previous column (July I bonaceous material in the rhizoshpere, ity. Lipid solubility is a function of the

August 1995) discussed in-situ mecha­ amounting to 85 to 155 tons per acre. This octanol-water partition coefficient (K0w) nisms responsible for natural attenua­ carbonaceous material stimulates overall for the compound. The compounds most I tion of organic contaminants in bacterial activity, while providing sub­ readily mobilized by plants have log Kow groundwater and the rates of degrada- strate to support cometabolic degrada­ values in the range of 1 to 3. Compounds tion that could be expected under those tion of xenobiotic hydrocarbons. with values of Kow in this range include 1 conditions. This column focusses on The capability to support oxygen BTEX hydrocarbons and chlorinated sol­ phytoremediation as a method to proac- transfer can be divided into three cate­ vents. Once in the interior of the plant the tively enhance those degradation rates, gories of plants: nonwetland herbaceous adsorbed hydrocarbons may be stored 1 as well as provide mechanisms for the and woody plants with poor oxygen via lignification, volatilized, partially

'"r1. "' ,. degraded through metabolization or trees are capable of depressing the water a ted with other remediation technolo- I completely mineralized. Compounds table through transpiration, up to the gies. Total phytoremediation costs are with values of log K.,w higher than three, equivalent of 3 feet of rainfall per year. estimated to range from $60,000 to such as polynuclear aromatics (PNAs), In tight soils, root penetration can $100,000 per acre. The potential of phy- I are incapablP of entering the root; those improve the overall mass transport toremediation is significant, given with log Kow values lower than 1 are properties. Plants can also aid in the sur­ proper design for its application. Conta­ rejected by the root membranes. It is also face stabilization of soils, preventing the minant type and distribution, soil chem- important to remember that as with any windblown migration of soil with istry and climate are all important I in-situ biodegradation process, the des­ adsorbed contaminants. factors which must be considered. orption and mass transfer of contaminant Planting costs have been estimated to For more information, contact the author, David hydrocarbons from the geologic matrix B. Vance, KTR Environmental, 1776 Montano Rd. I may be the rate-limiting step in the reme­ be in the range of $10,000 per acre, with N.W., Bldg. 3, Albuquerque, NM 87109; phone: diation process. monitoring costs parallel to those associ- 505-344-1776. Q In the instance of the phytoremedia­ tion of metals, the dominant active mechanism is phytoextraction and I accumulation in the tissues of the plant. This is a process that has long been familiar to exploration geologists in the mining industry. Geobotany is con­ We give you I cerned with the identification of plants or plant conditions common to metal rich soils, and biogeochemistry is con­ more for less. I cerned with actual metal concentrations in parts of plants. Other companies price their environmental and safety regulatory databases The mechanisms for metal accumula­ modularly-with separate pricing for EPA, OSHA and DOT CFRs, as well •as tion include chelation, precipitation, com­ for the Federal Register and state coverages. I partmentalization and translocation. The FESA Regulatory Compliance CD-ROM from CPI puts everything you These same mechanisms often contribute need into one CD-ROM. to the metal tolerance of the plant. To r-;o surprises. No extra charges. One CD-ROM, one price. I date, accumulators of lead, cadmium, chromium, nickel, cobalt, copper, zinc Everything you need from EPA, OSHA, and selenium have been identified. To DOr-and more I successfully apply this technology to a FESA gives you the full-text Federal Register, including Final and Proposed Rules, I metal-contaminated site, it is important Notices, Preambles and Consent Decrees, plus a minimum 18 months of archived FR data that pH, organic complexes and interfer­ -cross-referenced with multiple CFR tides (10, 21, 29, 30, 33, 40,49 and others). ing elements be assessed and that plant If it's in the Federal Register, you'll find it in FESA! I species with the appropriate metal selec­ FESA also contains state coverages, and over 40 regulatory compliance tivity be utilized. In some instances, it manuals, including those for OSHA, EPA, RCRA, TSCA, SW-846. Quarterly, bimonthly may be necessary to apply soil amend­ and monthly subscriptions include CPI's biweekly EH&S newsletter at no extra cost. ments to enhance to process. And NIOSH and AP-42 CD-ROMs are now available. I A key part of the metal extraction process is phytochelatins. These are low No otlter data•ase is as easy to use • molecular weight peptides that have the FESA allows you to automatically import all data-text and tables-into any I capability to bind metals. Their presence popular wordprocessing software, with no refonnatting. And with keyword searching, in plants has likely evolved because toxi­ hypertext linking and WYSIWYG viewing, access to FESA data is quick and easy. city to the plant is reduced by having the No rislc 30.day trial metals bound by the phytochelatins. Cur­ I Try FESA for 30 days. If you're not fully satisfied, just return the CD-ROM, rently there are several hyperaccumulat­ with the invoice marked "canceled," with no obligation. ing plants that have been discovered, such as Indian Mustard and Pennycress. I However, these plants are small and slow growing, thus lacking enough biomass to remove significant amounts of metals. Current research is working to identify I plants that are resistant to heavy metals, have the capacity to hyperaccumulate those metals, have high growth rates and I are easy to harvest. DOS • WINDOWS • WINDOWS 95 • NETWORK Lastly, plants have other properties 800·808·3372 with potential remediation applications. Citation Publishing, Inc. • 1435 N. Hayden Rd. • Scottsdale, AZ 85257 • 602.994.4560 • Fax 602.994.4456 I In semiarid climates sufficient numbers CIRCLE 217 ON CARD FOR FREE INFO.

The National Environmental Journal• January/February 1996 31 1 I 09:52 !IN PCA PUBLIC ItflR'IATIDN CFFICE I I I Vegeta~ve Re~ediation Process Offers Advantages I over. Traditional. Punl.p-and-Treat I Technologies: I I '

I • .,. of~itm t«bnofosts 10 d«m I4P c:cm.tamina.i soli! ....a &III'(D; 8.Q. , ,_,*Ill qfANJIW' aridgrounduJt:#ertsliu:nlasblgb'whmin&favtWfJI.IermOrecostlytmdoften.: Ntllflrrll ,...., IIEr ,. tnejfec11w mecbantcaJfl/JJ1rOtM:bss. One new IJIPe cf~cm pro­ I ..,... ~,., ...... CIIlJ, ltirl.nunas n..Medtalton•, useslrriiGrmdolbervegetatkmto~lll soli by aalfll·• .a nalurtllpump to e:x.tTIIt;l. and remedkltll con~~~mtnated ; g~ m aquifm lesr man !JOfeet deep. 7bts twtlcle tJescribes tbts I tn1JOUtltlDe ti'MimBnt melbod, .tbow.r us ~es OfX!I' lrad1tlonal pu.mp , antJ..bwu tecbniqull, and a:plains bow ~em Is being Wid to · o:Jrwct. nitrate and ammomum c;onklmt7UIIton.ftom an aqutftr tn New I .J--y.

Bio.remecUalioD merhodologles have become tnaeasingly Important as a means ol cleaning up envirOnmeneal amm.mlnants. These methods · I take advantase of naa.ua1 biological processes to teduee or cUminate risks to health and the environment. posed by ~ic or hazardous substances. I Most bloremedJadon memod8 use microo.lp.ntsms tO metabolize or ...... ,, odtetwJse ehemlca1ly baQ$furm ba:zardous or toXJc substances. Another • .,..,..,.. _. elrla,Jtw merbod eDlJsrs rhe aid of plant specieS to assimilate c:onmmlnants or to JNeJI...... ~..,.,. I create envtromnenrs conducive to the degradation of contaminanrs ...... ,. tluoush natural biochemical processes (Erickson et al.r 1994). These ~ methods IJC o&cn menecs to as phytolemc:dfadon, a~tion, ot . I samply, vepra1:1Ye .ranec:Uauon. P1am species can be ~ ro exuac:t and assiiDiJatc: or e:xtraa and : chcmir;ally decompose laJXet conDliDinan\S. Many lnorpnlc chemicals . consldeted environrnenad cont.amimUlw an; In fact, vll.al pJant nutrlenm · that can. be a'baotbed dli'OUgb lhc rooc sy-=m lot use in p.::JWth and , deYelopmeat. Heavy meulla can be taken up and bloa.t"CUmulated In plant . t1Bsues. Organ~ 'chctnic:als, noaably pesdddcs, can be abswbed and ! cetabolJzed by pknta, Jndudlng uces. TreeMedlatlon"' takes veptat~ n=medlatlon a step further by" using • trees u an akanative to StOUndwaLer 111pump4nd-trcat• technology. ~ ' TreeMcdiatio~ pmcess ta.lces advanmse of the extensive root I)'Btems of ·

~/SUMJ&D.l994 M~! 21/£ 'd 1£9£'0N NV1£:6 9661 '£1 ·qa~ 021'131'96 89:53 1-H PCA PUB..IC Itt=CRIATitli CFFICE 003 I ~ JIDwAD G. &m. 'I I ... 'j.. I. trees ad. otba-~ D.eiii'&CZ waa=r from aquifer ')'Stems sha1lowef ~~k : I 'lbe uprake 01 waleS' by U'CCS can .sub6taradally IDfluence the locaj · hydra\lllas ot a Aallow. aquifer, lbus controUinS the mlption of ~ eontamlnaocplua& 1bls "'.pumpiDI'" elfect flushes water upwud ~ I the IDil columil and can be much more elf'ecttve at remedlltlon thari tNdJdaaaJ Pump411ckteat syscems by 1lmUing additionaJ 1each1Dg at c:omamlnants into the aquJfer.11'1e beneftrs ofTreeMediatlon are: I • ID-sllu remediation • lavJroamalual ~ I • lfidmat lcJw.rccb dcmaUYe • tow~ ..... •I Low eapllal cosr . I AIIICIJONOI' DBBMED1AD0N l'OilA CONl"AMil'iATED AQtDPIJl : In 1990, we went coaJionfed ~the msk of c1eaninS up a ntuogen-: CODtlminau:d aqulter Jn New Jersey lbat could not be pumped etriclendy.i I Sc8 coadJtio.ns were ·JUCb that the aquifer coukl be conak1c:red ani aqu~er that 15 held very d8fuly by the aquifer medium.i StDI, ~tJahdf the srounclwarer'WI$l*ng held. It W86 also m.ovinSI I F aF-sAte IIAd bad to be conWoed. Various rtcaunent akematives were! ~ coaaldend. iftdudiDa muldplc pwDp1lll wells and a collection trendl.j "nleee popoala WC11e UlllllJ&t"aclor due 10 rhe Uncerrainty of., their! I !I ell"ealv.n• ID rbJs lillUildcm. as wen as their cost. lftl:erceptlon and i 'I' c:ioftventlonal tleaUDent wculd have .required .sJplfk:aDt long.term expen-: : ditures. TreeMediatiou,.,.. uldmately chosen as a COSt-effective method o1 · I •I \ . treamumt. Pdor 1t0 this, our cxpedencc had been with lhe use of crops, such as ! allalla, co.n, and other ~. ro etfect reinediatlon of surficial soil : I condltions. Mea crops eflecdvely roo1: In me top 3 ro4 .feet of the soli. Many pJanre arc capable ofmotin& subsramfally deeper but soU conditions, such . - bpotmeablc layas. often set In their "WBJ· I At tblssi1e, the IIOil eanditioas wen: very much a po=Nlal impedlmeftt : for deep 1001 peD~J~CaE~Do. In add'Uon, the aquifer at thiS sJte was located · at about 1' teet below the~ push for IM!D a deep-rooted crop : I Bke alfalfa. Spcd&any, &he pmblem. was to obtain rootin& aaMty to a : depth ol161eetm a •Light' .oil.~ bec:am& the focus of attention. That i J'ocu&wutwtbernanowedwpbreatophyres--ueesthatare lmownforfast . I growth and hlab water usaae rateot-U> ensure that the problem would be : tdcheaect ~ a re1advely shott time span. Cmn.mon phreatophytes ; Jrdude COtto4WOOd and wUlow aees. . I :~Men with trees, hotue'lrer, there are no NSUrances that rooUDa ac:tl¥fty ! 'llr1ll a:rcnd below the 1.0p 3 or 4 feet ol .IOJI. ~ actMiy of : phn.tophydc ncs bu be:cD clemoDsrraled ro readily oceut at depths of 1 I 20 teet or more m scmJadd or arid climates whae root1aa to lhe aquJfer ; Js • matter of IUIVMl. To expect this depth of toOdftg ro occur naturally : Jn a rcsJoA wbeR aanual ~alnfall Is moderate to heavy II quite another . I

M4 BDIDtAUOif/SU.NM¥-1994 ; .'· I I I• WV1£:6 9661 '£1 ·qal ...' Zl/t 'd l £9£ 'ON I ~ PCA PUBLIC UFCRMATICH a=FICE I . .. I matter. In a hwnld dJmate, nees are provided Vlith more than enoup! warer arid nutrients tn lhe swf'ac:e few feet of soD not only to survtw, bur : to t:brlve. I Plams wm naturally c:onsQve thelrre.sollrces and wDl typlallly expend: oDiy the: enersr negessaay to maintain reasonable viability •.Ar. this slr.e.dUs : aansJatcsintoJOodns actlvltybefns contaJned ID.Iheaurface few feet of8011 i -where s.oll pbyalcal. co.odidons sro favo.rable and water and nuaients are, I adequate for J""M'Mble powth. Thus, plamlns a uee and waking for .It: possibly to devdop IOCXIna activity LO tJ1e aqWter 16 feet below the sudace : I was not an t.ocep~BbJc alternative. '.' TR'BDOD)IA.'110N.'YDStJS ~'DUL\T ~Is demo.osEratlng tbataandard puanp-aniR.reat tecbnolo&Y 1 I is often tallins shottu a ~l opdoD.lkla wberc ~ble. pu~ tn:at red\nology ,_y bec:ost-proh!bldve. Water in m aquifer preferentially · f'oDows du: path of least reslllanc:c. Jf some or aB ofa contamiDant.QCQIIS l I In a section of the aquifer where watet Is more dPdY held (apc:dally 1n : capiDary pozes), tbJs water wlU noL be=me a algnlflaw pan ot me . ,..,.,...,.,., pump!Dg .stJeam. 'l1lJs problem "Undoulxedly demonstrates one of the I ~ pdmary r.JJac:lea ot using 5tanda.rd pump-t.nd-treat systems lO adckas tbe ,.,.__.,.root =anup of contamlnall:d zones of an •quJfer, .,..,....,. •. TreeMediaElcn IB a locall~ and sready proce6$ that is even capable I ..,.,..,..,·~,~ ot ez&laalng capJDary water. Properly desJgned. TmeMcdladoo. irlfluences _,_,_,..., &he rocx ")''ltem to develop to the aquifer. drawJnS water and c:omam~Dants 1Aro'U6l .,.,,.,.... up thn;q:b soil pores. Many contaminants will then be absoabed imo the I planl or affeaed by the snicrobial populations associated with the l'hlzosph~e bloJogtcal1y ac:r.lve iiOile SUIJO\Indlng tbe I'OOl ~ TbJe ptOCe.S8 JeD10YC5 c:.oncaaninam.s froln me ar:ounclwatcr or limits I c::oftl:ai'Dbvlnr migration 10 the p>Undwater.

Pllm..... '.l\ut CapahiiWa ofPhn:atDph'f'CI I Xt ha• loca been JVCOpized that ptuatoph)'lk cmp• and tree~ are eflecdve at rootins wtr deeply-tO 100 feet and more. In faa, phrc!ato­ pbya ~been &nld1ccl aa a n\lllancc In· &he aemlarid to arid .repms ot : I the wearem UAired Slates where watw 18 ~. 'nJese plants aro known · tD affoct water availabilky by slpl8c:andy JoweriDs aroundwater levels. Diumal ft"Uaua'doN of weDs -were~ In the 19401 aDd mrtbured to I a povc of ncalby coupn1VOOc1 uees (USDA, l,S). AqUifer leVals at other .locatioM~ ~ 10 have dJopped 5 tea durJnsthc srowtns season due to warer CODSWnpLiOn by phreatophytc$. 11. bas been reported that a : lln8lc willow tree "u.es and IORS over 5,000 pllODS of W8let .In one · I suGamcrday" CM".amj OonsetvancyDJsr:rla, 1991). 'lbJs 5Cei'DinsJ.yphenOm­ CD811lsun= 1s CDll'lp8I'Bblc 110 what 0.6 atres of me phreatoph)'le aJfaJra can traoBpJa: iri one day (Schwab et aL, 1957) and Is plauSible when the leaf I wrtacc ara of a fairly larp: 'Wil1aw ll1:e AI ~klered. At. a eo m 10\lthwestem Ohio, ~ tm=s clemoDstrated considerable pumping capacity, even In a Nladvely humid enWonment. 1-- A taJdy Ideal alt\lallon wu avadable where twO 40-looMID cotton1I'OOd.

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819.50 I 819.00 g 818.50 I 1118.00 i I 816.50 II= 816.00 I 815.50 iii I

DA1'E AT END OP 1o-DAY AYERAGI! I

---~- - - - -___.~...._~- - - -~~- - -- ____ _. ------~ -- - I •• ana could be llolaled and evaluated. MODkorJns weUs ~ pJKCc:l aJOUDd the couonwood ~tees and .monllcxed lor an entltc scason.lxblblt 1 deady denOlel the OJlleE or uansplratlon, the dtawdown of tho aquifer I during lbe ~ and the rbc In the elc:YatlOft of the aquifer as me ttc:cs •pproacbed dormancy. Addilionally, dtere was a downgradient tl'O\Igh, •• demonma.Sby~ctifl'erence betweentheupgra~icntand dow~dleat I. woU elevadotat. Otbet wd clevadons ..-e nat presented for Ulusaation efl"ecl.t hOWt:vet, dlq" did parallel and deviate only slipdy but appsopri­ a&ely fiOID \he UP8f'ldlen!. elevation$. Cllculationt based on rhc .rare of I dtawdown auaa- dac pumping '* Cot each ccxtonwood tree ranged bentccn 50 IDd '50 pllone • day.

Tn:e Growth ..t Coatam1n.aat Ba~Mm~~Stu&U.a I Ast.udylOcvaluatethedl'eaofneplaccmemln.rdatlontorheaqulfcr was amduaed at the New Jersey site. Pow'leen-fooc mil ballcd.-at.ld­ burlappecl ~poplar treeS were cased and plamecl at depths poarcs-­ I slW.Iy closer to me aquifer. Bxhlhlls 1 aDd 5 IUumare me posldve ertca of~ ba1l placelnonl on eady powth and nl.a'opft accumuladon by the uees. Buk:ally, rho c1ofertho t.rees were plaDt.ed to tbe punct.w.ca-. tbc I ..-d1elr pmcNctMty In &hac fitst two yean. It bas been ckcermincd dmsurface-plalltedueesbavenow~rootcdtotbaaqulfer, whkh 5houkluans1a&clmoCIIDimptodualvlcy~e~tbecleep--planred I trees. Hkropn ac:cumula11on Ia c:xpec:ted to lftcn:aiJo JUbalant1allyu thetn=ea "''· mal~. 'lbese ~ of nltJ'oaen ~ should appmacb \'haw or ~non:- I

H5 BmAIIDIATJONfSmoaa 1994: I Zl/9 'd 1£9£ 'ON rrvz£:6 9661 '£1 ·qa! 1212/13196 09: 55 11-1 PCA PUILIC I~ICN CFFICE la06 -..~~.!'H..... • ••••• • .,.. I ' • • •• ...... l ...,._ ...... I

I o I lhrhiW.t: z. .Method c~ PJantln.s nee. 10 Atfea: RooEtna ACCMty. I HeJabt: In Sec:oud Yea,. aAer TzansplandnS I I I

At In CapUivy I ~ l'dap I I Bxhlblt '· Method. ot P1aDring Trees to Affect Rooting Aalvky.

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~~-~--­ ------~- I. I tJmetJ the 1evds mfleaed .In b.blb1t 5 CcaJifomJa Fert.Wzet Association, I 1975). W.bJie Dlcroac::n 15 used .tn plant pmduCUOD 111 mJadvely hfgh ra~es, other ~ conrammams could accumulate at comparable rate& but wUI depend on seve.ral. Catton. such as solubility, co.mpadbJllty for plant I ~ and srowtnB condilions.

Blrecrs QQ A4alfc:r OOD.tamlnallta • ·I.· Dowmpdieftt giOUJ).(lwater samples were coJlecr.ecl at the beginning· of the 1992 JtO'tl'iDs 8Ca$0D and after lhe 1993 growing sea.son at rhe New

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I Jersey Ike, ropraemlng two ieasons or remedial acttvity. &eb boring I · loau.lon 'IIVU 8\U'VC)'ed ro eliSW'C repl!c:adon of between-year samples. "l'bough limited, these clala penuJE a prelJmiDary evaluatiOn of the effects ot T.leeMedladaa. on· the nitrogen eonramJDadon in the cloWDgradient I aqW(et. Two liOW'CeS ot comamlnadon are suspected ancln graphically ~ble. bblbJU 4 and 5 shew anapperem.contractlOD of both COD"'miDam pJu.c.IIDd provide JDusuadons ofthe potential effectiveness I oiTreeNedlatloq, ad rbc pumptDg capadly of me trees. Botb nla'atc and llftVI\Oalum COIICelllmiJOnS ~ n:duced to leas than 10 mstlln 1"' at locations .FartheaE .from each 10\ltCC' I cosr mMPABJSON IU a site In llllaois, TteeMedJaLion ,..... coupJed wJlh • pump-aDd-treat I S)'StctD to mlrfptc an lmi'D8dia1e •ata.dsk" SIEI.Iatlon, In r.be in1Ual phastt of . this remedtaJacdvlty, TJCeMedJatlon will function primarily u the •uac• . mem- phJSe otrhe pump-ancJ..Insat8)'5te11l. EvenwaDy, TreeMedlation wm I

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'Bzlalblt5. Chanaes 1JJ the.AmmoDlUm COncamtnantPlume'Two Years after J.n1rJadna t1u: TleeMedJatlon Proca$.

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----~ --~------~------~-

usume both phases of abe l~JB~ll· fonunately, thJs Situadon provides a unique opportUnity to compaR the costS oflhe twO sysr.ems. 1beestJmated · costs provided below wt:JC developed basecl on dUs experleAce and are lnlended tor mustrat~on pwposea oo1y. Pump-anckrea~: and Tleebdecliadon ClOirS were esdmated m round .nurnben Cora 1-.c:re&ite wb:b &.R aquifer 20 feet deep. Costs common to both app!Oichc:.s were not lncluded. a~ch u meer1np Witb reguJatom and laboratory aoat,s~s. PDibl& 6 pathe t«ms and COD CODSidered for the pump-and-treat ')'Item and the T.reeMeditadon system. Jt was assumed that \he pump--aDCI-tteal syaem could funaJon wlrh three pumping 1lle1ls and ll Je9Cl'8C osmosis spl:eol for ueaaneDL As hbfbtr 6 shows, the ettlmatcd costs torthc:TreeMedJaUon JMOPftl are considerably low'erthan lh.oac £or the purrlp40d.l!e8L system. Obviously, theac coats c:.n vary widely depe:ndlDJ on JPCCiflc drc:um­ caances. However, when tbe ua of TaeeModiadon Js a viable option, tr. mould be a more COit-df'c:cdvc approach dum pWl'lp-&IK'lo.b'Cit. There 16 . . ~19M 349 Gl/6 'd l £9£ 'ON WV££:6 9661 '£1 ·qa~ B5h!!57 I"H PCA Pl.I8LIC I~TI~ CFFICE I .. I

------~ Bahlblc '· Estimated o- 1·Aae Stm with ZO..Foot·Deep AqUifi:r. I Pomp41ML'I'I:eal• P.quipma $100,00 I ConsU1tlna 'JS,CXJ') """""*""G:In!lnXtlan 100,000 s,mrCXIill )lahe•:nance ios,ooo I OperllfoD 50,000 ...... 180,000 Walle dJspcaJ llabllly 100,000 I

. . . • ...... ,CI6d.....,..ecpllpolln. dUIDCpumplas-=lls...... ~ I .,.,.. .· TNeJtledlaHcm I Tacdfedialbl pcpm design and fmp1emenatiDn $50,000 .McallcdafJ equipment ~ 10.000 IMaladm 10,000 I ~ 5,000 s.,...~ .. Tr.rtlellftd meetJnss 50.000 I '• .. Data (OJJeafcft so.ooo ADnuallepodS 25,000 50,000 I ~ISICIIIrll'J£

------~~~------1: ------~-~-- 1: ancxber Jmponmc c:oatldaa1lon: addltlonal dilpolal of pumpaand-oeat Rl1clua can .ault In addiUonal replatory problems. Ue\lally, treatmenl with ~Jer.lldOft _..b Ia no disposable sesidue. I OON'DMINANI' usr GllOWS Vqewive rc:medJatloA bas ptoVen 110 be efkalYe at remecliad.ns pesdddes and leftlllzers tn son 81\d grounciwatet (Nair et al., 1W3 and I Juerpna.Gsdlwlnd, 1S'B9). However, like pum.p41ld-aeat redmoloClcs, ¥0plallve remec:llatloll medlocb, such U TrocMediarJon, wJJl DOC treat d c»m:amlnuats. ,_. more Js learned about rbc abllilT for vegetadve I rc:mediadoo of lpeclftc contaminante. tho mcxe wpted me remcdlation ell'cxt Clll be. I Barty lldllll TrocMecUa&lon bat polCDda1 for removal oc mldpion olhaavy =--•· c &om. conram~Dated 10!1 and .son soludoRS, thereby prc:w:nllDc their I :a.aaranow/SUJDIR 19H I Zl/01 'd 1£9£ 'ON 1\V££:6 9661 '£1 ·qa~ PH PCA PUBLIC I~TIQ.I CFFICE 1211121

. . contamination ofaquJfers. Due to the low solublllty ot most heavy mel3ls, they an= nearly Jm.pols.lbtl: 10 extriiU vlll.llallclard pump-anc:kteat method­ ologies. .Akhousb It 1s true lbat planrs seneraDYdo not uptake heavy metals to any patdqree, tbJa.l$ somewhat dependent on their lack ofava&abJiiiy · tO the plant Oackson imd AUoway, 1"2). • Hell"f ~ availab:illtymay explafn me folknvt.n; dala. An evaluation of heavy metal uptake by several hybdd poplar &rea revealed a um.-lold or more Increase In rbe :tine co.nlelll: of affected uees. Zinc conc:e.ntrations won: as blab as 2.900 IDIIJcB Jn dJy leaf dssue of selected uees and as low as 170 mallcB lot other uca. Alrhou&h lJJe~e data.~ ncx the leSUk ot a· COi1tlollecl aperimem, lhey WustraEe me porenm1.fo1: heavy meral Up18ke and tbc f""CDUIJ flit tiat 'rn!eMedJai.IOn baa frL lhC remedlarJon of heavy ~-This .Is espcda11y true where 1t Is accepcable to con'faJn the problem . and 11mlt or eJ.ltn~Mtc mlpdon. oC heavy. meals to tbe. srouncJwau:r. Otpllla . Organic: CIOI1StlNeNS am be adsorbed by vegetation and metabolized or otherwiJe cfearacled. ot they can be affected by contact 1llkh r:he plant · 0.0.,. ..,.,_, ..uA l'OQ[8 (Shimp a al., 15)!15). Plant roots are exueme1y valuable to a 'Wiele Map,.,.. root., mnge of nalaobJal pOpuiatloDs that rhriVe, often In a 5)'lDblotic: reladon· ,.,.,. .,.,..., ship. mabe area immediately surrounding d1c rootS (the rhlze&phtle). "l'he ,.,..,... 6e rhtzosphcrc pmvtdes much of the food, moisture, and oxygen needed by .,.,., to •fc:rolllcd mlaobes to swviYe In "'stons of the 1011 where they would not n.ormal1y ...... Of" be lou.nd (Le .• ln the rqion ofa deep aquifer) (A,nderson etaL, 1993). Once -~ In conaaa. with the plantS' 1001:5, many organic moleeules can be subjected to mlcmblal degradation or mecaboltlm.

CONa..tJSION SineeJri~ID 1990,me~on poc:ashaabeenappJJed attll:skes in 'F.ISCOniJn, JUinois. NonhandSoulh Carolina, and NewJersey. Appll.aldeft ar: the New Jersey site wa5 dae main focus of thll discussion. Ill Illinois. T.ree.Mediation was coupled with • staGCiard pump-and-treat .,stem to alleviate an ilnmaJiate pmblem of oft-&~re movement of a ~rw" plume c»ntalofnJ n11r0sen and peatlddes. Anodler site Jn DliAom l.s ~ treated tor cqanic: and lnOrpniC asrtcultural cbemlcal.s; dmaadc~u have been n:allzedlorpesddde levels in theiOilCftom 1,000 mslkB 10 less ~han 10 mslkl thus far). In WjJCQnsjn, nSUopn and pesddda are beJns =nedJated ustng TrceMedJatlOn lAnd swfac:e vegebl­ tlon. An aquifer ill sandy coastal soil fn ~ C.rolJna Is being treated with ~dlattoo for ~raJ Jncxpntc agdculaual dlemic:a1l as a c:oa­ cft'cc.ttve altematlYe to a pwnp-and..uc:aL ~ FIDally, TreeMediadon Js beloa eppllcd ID mitigate dle ruiSratton ot heavy metals to an ~qqffer In • weatell) South Cuollna. Bach lite posed diffe.rent pi'Oblema and, ~Ior~e New Jersey and Soum Oa'l'OIIDa alta, atandard pwnp-and-tn:at typk:allT 'WO\Jid have been dle process ot chok:e. TleeMedladon, ho-wewr, was chosen for these sireS bac:aluse of fls superior capabilillcs arid much lower c:osta than tradttlGI..aJ pump-ancl-tleac. •

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,JidceOft,U. llld IJ.AIIowly, 1~. ""l'bB 'l'rmlllu'~Qidmlum liom ~SOliS 10 lbe-.. Food O.ID.•m ~,.,of"Jhft:~Mitllll, edbd by Milano. Wllhln&• tOn, DC lftiJ Publllr'bect. ~ s. ue. .iomuad ,... NJ&nna 1n ·ewer n.w~ Coullldel Olaalopr) H•lvA.... tO r..l \Ill! Palalml.• Ill •....,....~ tDIIl ~ ...,.,..,.a. »o ..._. br .... ~ ..._. Yada llllll:¥klrlehlnalt ~ ~~DIAikl.199l.~~ ND.ls\. ' "*• DJL, a IL J$P5. "MAAIeeiUzadCC and Upra1c1: or ~ J'Ciddde tn SoD-I'Wn. ~·,/Mniiii'I/IJRDUSM__,.,., 11~ &cbwJb. G.0:. •aL lt57. n ~$ollllrltl ...... ,..,. 2d &d. NcwYuduJubn 'Reya:SGQL lblmp. , ..... IlL ., "'Inef".cld l!fl'el:lf ot P1anG Ia 1he Blunedlatlon or Sod and • GtoundM1er a..rrtiiJIIed Wllh Otpll.lc Naal:tlals." Crtlltalf lta1lnls ,. ~ ...,.,,. :nd,.,.,uw.41•77.

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I I I I Zl/Zl 'd l£9£ 'ON TreeMediation project uses naturalfunction of tree roots to pull contamination up from shallow aquifers. Say it with trees Lowly tree root may be natures champ at cleaning up groundwater By Edward Gatliff, Ph.D. any people only think in terms of ENVIRONMENTAL FATE & M microbes to _ bioremediate a contaminated site. TREATABILITY LABORATORY There is another bioremediation The Dragun Corporation can: approach that enlists the aid of plants to assimilate contaminants. Known as • Determine the environmental mobility and phytoremediation or agroremediation, degradation of chemicals and/or wastes residing at your one company is taking it one step site using bench-scale testing. further by using trees as an alternative to pump and treat technology. I • Select appropriate environmental fate and The TreeMediation™ process, engineering treatability test methods for your specific developed by Bowser-Momer, Inc., needs. Dayton, Ohio, takes advantage of the extensive root systems of trees and I • Determine feasibility, evaluate performance, and other vegetation to extract water from develop design parameters for pilot and full-scale shallow aquifer systems. Plant species treatment processes for surface water, ground-water, can be selected to extract and I industrial process wastewater, soils, and sediments. assimilate-or extract and chemically decompose target contaminants. For more information on how you can save time and Many inorganic chemicals considered money, and avoid generating bad data, please contact. environmental contaminants are in fact I vital plant nutrients that can be Christopher Englert, P.E. absorbed through the root system for The Dragun Corporation I 30445 Northwestern Hwy., Suite 260 Edward Gatliff, Ph.D., is director of Farmington Hills, MI 48334 the Analytical Sciences Division of (313) 932-0228 Bowser-Morner, In~. .• Dayton, Ohio 1-· Wnte tn 2'!1ti 16 October 1993 Soils use in growth and development. Heavy at least three years for the process to pesticides. Pesticide degradation is a I metals can be taken up and function aggressively, it is apparent that well-documented process whereby • bioaccumulated in plant tissues. Organic the system is already remediating, even plants and other organisms chemicals, notably pesticides, can be in the first year. biochemically alter or degrade certain I absorbed and metabolized by trees. The All the current projects are at locations pesticides. At one of the sites, surface uptake of water can also substantially contaminated with chemicals from soil with herbicide concentrations influence the local hydraulics of a fertilizer handling and processing. Some exceeding I ,000 ppm was reduced to shallow aquifer, thus controlling the of the sites also have pesticide and less than lO ppm using these principles. I migration of a contaminant plume. This heavy metal problems. Tests are An obvious limitation to developing a pumping effect flushes water upward determining the effectiveness of the system using plants to remediate heavy through the soil column and can be trees in assimilating the nutrients and metals is that most vegetation won't I much more effective at remediation than metals, and in metabolizing the Continues on page 18-+ traditional pump and treat systems. To date, TreeMediation bas been used I in aquifers up to 20 feet deep. Shallow, low yielding aquifers are particularly suited for this methodology. Traditional pump and treat systems for this type of I condition are often ineffective. The ideal mechmucal pumping system is one in which a large number of very small I wells are closely spaced and draw water upward through a soil column. 'fhh; is what trees do. Mechanical pumping appears to be I effective in controlling the migration of contaminants in groundwater, but is unable to clean up the water to a pristine I condition. One reason is that in pumping, channeling occurs, where groundwater moves into the well preferentially through higher I permeability sediments, thus having little effect on contaminants in less permeable soils. Another reason is soil I bonding, in which the contaminants chemically bond to constituents in soils. 1 00' X 200' cover used on thermal treatment project. TreeMediation is ideal for applications For over thirty five years Griffolyn's durable plastic sheeting has where these conditions exist._ I represented superior quality. UV inhibitors allow Griffolyn covers to weather Techniques have been developed to up to four years, which in tum saves labor and material replacement costs. force rooting activity into a desired Griffolyn is nylon reinforced to prevent punctures and tears, yet it is portion of the soil column to maximize lightweight and easy to install. Large sheets are available and can be manufac­ I remediation effectiveness. tured to your exact specifications. TreeMediation projects have been Griffolyn covers protect and control contaminated soil. Griffolyn is implemented at sites in five states. used during these types of soil remediation processes: I Regulators in New Jersey and North • Bioremediation • Landfarming • Soil Vapor Extraction Carolina have been particularly • Vitrification • Thermal Desorption • Thermal Treatment supportive of this technology. QUICK DELNERY As a passive method to control I contaminant migration in shallow, low Super Size Sheets Up To 200' X 200' Available yield aquifers, TreeMediation is a low Stock Sizes Available For Immediate Shipment tech, environmentally compatible For more information on Griffolyn Call Toll Free. I approach that requires very little maintenance. The fall of 1993 represents the second complete year of a TreeMediation I project at the first site. Other sites will have completed one year of the process. While it is expected to generally require I Write In 218 October 1993 Soils 17 I & GEOTECHNICAL Say it with trees, :~~~~~ SERVICES from page 17 ENVIRONMENTAL & GROUNDWATER INSTRUMENTATION

COMPLETION PRODl'Crs INSfRUl\!ENTA TION & TESTING Flush ttueaded casing and screen Water level meters P.V.C. Stainless I Teflon Oil interface meters Well covers Organic vapor analyzers Sand , Cement I Benton1te Gas chromatographs Packe~ Area monitors, LEL meters Lockins caps PH I Conductivity meters Chemical Test Kits SAMPLVOG EOUIPME:\1 Dosimeter Tubes Baiters Pipe locators Rapid Reels I Tripods Bladder pumps Peristaltic pumps Pneumatic displacement pumps RECOyERy SYSTEMS Submerstble pumps 3• & 4 • Water treatment Piston pumps Air stripping Lysimeters Carbon filtration Soil samplers I Augers Oil recovery Sample wbes, Brass I SS Vapor Racovery Teflon Jape I Rounds 5ample Bottles ROCK & SOD INSIRI!MENIAIION Data Logger SPEO.\IIIES Transducers Tubing-Tygon 10 Teflon Inclinometer Casing Drums Pressure cells Health & Safety Equipment

EQUIPMENT REPAIR RENTAL EQUIPMENT

IAN FRANCISCO LOS ANGELES PHOENIIVrUCSON PORTLAND 800-524-9111

Write in 391 Weather station at TreeMediation site provides site condition information via modem/computer Operate any type of 3-Phase network. Computer commands control irrigation. Soil Remediation Equipment from a 1-Phase Utility Supply - appreciably accumulate the metals in its tissues. At sites where heavy metals are a concern, TreeMediation is intended to function as a hydraulic barrier to leaching and off site ~ PHASEMASTER• Rotary Phase Converter migration. A secondary function is the uptake and 1-500 HP, 230/460V for accumulation of soluble metals in the tissues of the trees. A all motor loads, heaters and rectifier loads including: benefit of the long tenn focus of TreeMediation is that the low rate of uptake and accumulation of heavy metals is offset. It is • Regenerative Blowers irrelevant whether the process takes I 00 days or I 00 years • Soil Feeders when dealing with relatively immobile hea,·y metals. This • Scrubbers • Conveyors does not mean that plant remediation cannot uptake • Pumps appreciable quantities of heavy metals in a short time. • Compressors Research shows that careful selection of plant species can result in effective and relatively rapid metals remediation. At The~ expensive way to deliver sites where no immediate threat to human health and the 3-phase power to ~ jobsite environment exists, TreeMediation is an economical II' Approved by Utilities alternative to excavation and disposal. II' CSA or UL Listed II' Meets 1993 Nat'/ Elec Code An important component in TreeMediation is remote II' Easy to Install, Quiet Running monitoring and data acquisition equipment. Weather. II' Highly Efficient, Trouble-Free groundwater and soil moisture data are used to assess the II' Expert Application Assistance II' Money-Back Guarantee water usage of the vegetation and the effect of water uptake II' Two Year Warranty on groundwater gradients. Real time changes in groundwater II' One Million HP in Service chemistry can be measured with the potential for reducing periodic sampling and analysis costs. As with the verdict on nearly all remediation technologies, not all the results are in. But for certain sites. this conservative, workable approach is a functional alternative.l Write in 771 for more information Write in 420 18 October 1993 Soils I I I I I APPENDIXD

I USEP A OSWER DIRECTIVE NO. 9355.0-49FS I I I I I I I I I I I I I Directive No. 9355.0-49FS United States Office of EPA 54Q-F-93-035 Environmental Protection Solid Waste and PB 93-963339 Agency Emergency Response September 1993 I &EPA Presumptive Remedy for CERCLA Municipal Landfill I Sites

I Office of Emergency and Remedial Response Quick Reference Fact Sheet Hazardous Site Control Division 5203G

I Since Superfund's inception in 1980, the remedial and removal programs have found that certain categories of sites have similar characteristics, such as types of contaminants present, types of disposal practices, or how environmental media are affected. Based on information acquired from evaluating and cleaning up these sites, the Superfund program is undertaking an initiative to develop presumptive remedies to accelerate future cleanups at these types of sites. The I presumptive remedy approach is one tool of acceleration within the Superfund Accelerated Cleanup Model (SACM).

Presumptive remedies are preferred technologies for common categories of sites, based on historical patterns of remedy selection and EPA's scientific and engineering evaluation of performance data on technology implementation. The I objective ofthe presumptive remedies initiative is to use the program's past experience to streamline site investigation and speed up selection of cleanup actions. Over time presumptive remedies are expected to ensure consistency in remedy selection and reduce the cost and time required to clean up similar types of sites. Presumptive remedies are expected to I be used at all appropriate sites except under unusual site-specific circumstances. This directive establishes containment as the presumptive remedy for CERCLA municipal landfills. The framework for th~ presumptive remedy for these sites is presented in a streamlining manual entitled Conducting Remedial Investiga­ I tions/Feasibility Studies for CERCLA Municipal lAndfill Sites, February 1991 (OSWER Directive 9355. 3-11). This directive highlights and emphasizes the importance of certain streamlining principles related to the scoping (planning) stages of the remedial investigation/feasibility study (RI/FS) that were identified in the manual. The directive also I_ provides clarification of and additional guidance in the following areas: ( 1) the level of detail appropriate for risk assessment of source 'areas at municipallaildfills and (2) the characterization of hot spots. I BACKGROUND Since the manual's development, the expectation to contain wastes at municipal landfills has evolved into a 2 I Superfund has conducted pilot projects at four municipal presumptive remedy for these sites. lmplementation of landfill sites• on the National Priorities List (NPL) to the streamlining principles outlined in the manual at the evaluate the effectiveness of the manual Conducting four pilot sites helped to highlight issues requiring Remedial Investigations/F easibiliry Studies for CERCLA further clarification, such as the degree to which risk I Municipal Landfill Sites (hereafter referred to as "the assessments can be streamlined for source areas and the manual") as a streamlining tool and as the framework for characterization and remediation of hot spots. The the municipal landfill presumptive remedy. Consistent pilots also demonstrated the value of focusing I with the National Oil and Hazardous Substances Pollution streamlining efforts at the scoping stage, recognizing Contingency Plan (or NCP), EPA's expectation was that that the biggest savings in time and money can be containment technologies generally would be appropriate realized if streamlining is incorporated at the beginning for n:tunicipal landfill waste because the volume and of the RifFS· process. Accordingly, this directive I heterogeneity of the waste generally make treaunent addresses those issues identified during the pilots and impracticable. The results of the pilots support this highlights streamlining opportunities to be considered expectation and demonstrate that the manual is an during the scoping component of the Rl/FS. effective tool for streamlining the Rl/FS process for I municipal landfills. 2Sec EPA Publication 9203.1-021, SACM Bulletins, Presumptille Remedies for Municipal Landfill Sites. Aprill992, Vol. I, No. I. and 1 TD Mwlicipallandfill sites typically contain a combination of principally February 1993. Vol. 2, No.I, and SACM Bulletin Presumpti~·e I 795.7 mwlicipal and to a lesser extent hazardous wastes. Remedies, August 1992, Vol.l. No.3. • ENV I 1993 Finally, while the primary focus of the municipal landfill manual is on streamlining the RIIFS, Superfund's goal Highlight 1: Components of under SACM is to accelerate the entire clean-up process. the Presumptive Remedy: Other guidance issued under the municipal landfill Source Containment presumptive remedy initiative identifies design data that I may be collected dming the RI/FS to streamline the • Landfill cap; overall response process for these sites (see Publication No. 9355.3-lSFS, Presumptive Remedies: CERCLA • Source area ground-water control I Landfill Caps Data Collection Guide, to be published in to contain plume; October 1993). • Leachate collection and treatment; CONTAINMENT AS A PRESUMPTIVE • Landfill gas collection and I REMEDY treatment; and/or • Institutional controls to supplement Section 300.430(a)(iii)(B) of the NCP contains the engineering controls. I expectation that engineering controls, such as containment,willbeusedforwastethatposesarelatively low long-term threat or where treatment is impracticable. The preamble to the NCP identifies municipal landfills The EPA (or State) site manager will make the initial I as a type of site where treatment of the waste may be decision of whether a particular municipal landfill site impracticable because of the size and heterogeneity of is suitable for the presumptive remedy or whether a the contents (55 FR 8704 ). Waste in CERCLA landfills more comprehensive RI/FS is required. Generally, this I usually is present in large volumes and is a heterogeneous determination will depend on whether the site is suitable mixture of municipal waste frequently co-disposed for a streamlined risk evaluation, as described on page with industrial and/or hazardous waste. Because 4. The community, state, and potentially responsible treatment usually is impracticable, EPA generally parties (PRPs) should be notified that a presumptive I considers containment to be the appropriate response remedy is being considered for the site before worlc on action, or the "presumptive remedy," for the soun:e the RIJFS work plan is initiated. The notification may areas of municipal landfill sites. take the form ofa fact sheet, a notice in a local newspaper, and/or a public meeting. I The presumptive remedy for CERCLA municipal landfill sites relates primarily to containment of the Use of the presumptive remedy eliminates the need for landfill mass and collection and/or treatment of landfill the initial identification and screening of alternatives I gas. In addition, measures to control landfill leachate, during the feasibility study (FS). Section 300.430(e)(l) affected ground water at the perimeter of the landfill, of the NCP states that," ... the lead agency shall include and/or upgradientground-waterthat is causing saturation an alternatives screening step, when needed, (emphasis of the landfill mass may be implemented as pan of the added) to select a reasonable number of alternatives for I presumptive remedy. detailed analysis." The presumptive remedy does not address exposure EPA conducted an analysis of potentially available I pathways outside the source area (landfill), nor does it technologies for municipal landfills and found that include the long-term ground-water response action. certain technologies are routinely and appropriately AdditionalRI/FSactivities,includingariskassessment, screened out on the basis of effectiveness, feasibility, or will need to be performed, as appropriate, to address cost(NCP Section 300.430(e)(7)). (See Appendix A to I those exposure pathways outside the source area. It is this directive and "Feasibility Study Analysis for expected that RIJFS activities addressing exposure CERCLA Municipal Landfills," September 1993 pathways outside the source generally will be conducted available at EPA Headquarters and Regional Offices.) concurrently with the streamlined RIIFS for the landfill Based on this analysis, the universe of alternatives that I source presumptive remedy. A response action for will be analyzed in detail may be limited to the exposure pathways outside the soun:e (if any) may be components of the containment remedy identified in selected together with the presumptive remedy (thereby Highlight 1, unless site-specific conditions dictate I developing a comprehensive-site response), or as an otherwise or alternatives are considered that were not operable unit separate from the presumptive remedy. addressed in the FS analysis. TheFS analysis document, together with this directive, must be included in the Highlight 1 identifies thecomponentsofthepresumptive administrative record for each municipal landfill I remedy. Response actions selected for individual sites presumptive remedy site to suppon elimination of the will include only those components that are necessary, initial identification and screening of site-specific based on site-specific conditions. alternatives. Funhef" detailed and compreocnsive I 2 I suppoiJ.ing materials (e.g., FS repons included in ~.. areas should be developed early (i.e., during the scoping I analysis, technical reports) can be provided by phase of the Rl/FS). Headquarters, as needed. 1. Characterizing the Site I While the universe of alternatives to address the landfill source will be limited to those components identified in The use of existing data is especially important in Highlight l, potential alternatives that may exist for each conducting a streamlined RI/FS for municipal landfills. component or combinations of components may be Characterization of a landfLil' s contents is not necessary I evaluated in the detailed analysis. For example, one or appropriate for selecting a response action for these component of the presumptive remedy is source area sitesexceptinlimitedcases;rather,existingdataareused ground-water control. If appropriate, this component to determine whether the containment presumption is may be accomplished in a number of ways, including appropriate. Subsequent sampling efforts should focus I pump and treat, slurry walls, etc. These potential on characterizing areas where contaminant migration is alternatives may then be combined with other components suspected, such as leachate discharge areas or areas of the presumptive remedy to develop a range of where surface water runoff has caused erosion. It is I containment alternatives suitable for site-specific important to note that the decision to characterize hot conditions. Response alternatives must then be evaluated spots should also be based on existing information, such in detail against the nine criteria identified in Section as reliable anecdotal information, documentation, and/or 300.430(e)(g) of the NCP. The detailed analysis will physical evidence (see page 6). I identify site-specific ARARs and develop costs on the basis of the panicular size and volume of the landfill. In those limited cases where no information is available for a site, it may not be advisable to initiate use of the I EARLY ACTION AT MUNICIPAL presumptive remedy until some data are collected. For LANDFILLS example, if there is extensive migration of contaminants from a site located in an area with several sources, it will EPA has identified the presumptive remedy site categories be necessary to have some information about the landfill I as good candidates for early action under SACM. At source in order to make an association between on-site municipal landfills, the upfrontknowledge that the source and off-site contamination. area will be contained may facilitate such early actions as installationofalandfLilcaporaground-watercontainment Sources of information of particular interest during I system. Depending on the circumstances, early actions scoping include records of previous ownership, state may be accomplished using either removal authority files, closure plans, etc., which may help to determine (e.g., non-time-critical removal actions) or remedial types and sources of hazardous materials present In. I authority. In some cases, it may be appropriate for an addition, a site visit is appropriate for several reasons, Engineering Evaluation/Cost Analysis to replace pan or including the verification ofexisting data, the identifiCation all of the RI/FS if the source control component will be a of existing site remediation systems, and to visually non-time-critical removal action. Some factors may affect characterize wastes (e.g., leachate seeps). Specific I whether a specific response action would be better information to be collected is provided in Sections 2.1 accompliShed as a removal or remedial action including through 2.4 of the municipal landfill manual. the size of the action, the associated state cost share, and/ I or the scope of O&M. A discussion of these fa:tors is 2. Defining Site Dynamics contained in Early Action and J:.ong-term Action Under SACM -Interim Guidance, Publication No. 9203.1-051, .The collected data are used to develop a conceptual site December 1992. model, which is the key component of a streamlined I RI/FS.,The conceptual site model is an effective tool for SCOPING A STREAMLINED RI/FS defining the site dynamics, streamlining the risk UNDER THE PRESUMPTIVE REMEDY evaluation, and developing the responsea:tion. Highlight FRAMEWORK 2 presents a generic conceptual site model for municipal I landfills. The model is developed before any RI field activities are conducted, and its purpose is to aid in The· goal of an RI/FS is to provide the information understanding and describing the site and to present necessary to: (l) adequately characterize the site; (2) hypotheses regarding: I define site dynamics; (3) defme risks; and (4) develop the response action. As discussed in the following sections, The suspected sources and types of the process for achieving each of these goals can be contaminants present; I streamlined for CERCLA municipal landfill sites because of the up front: presumption that landfill contents will be Contaminant release and transport I contained. The strategy for streamlining each of these mechanisms; 3 I I Highlight 2: Generic Conceptual Site Model I CONrAil INA NT CONrAIIIIIANT AI'I'ECTID SECONDARY SOURCE RILIASEmiANSPORT IIIDIA RECEPTOR I I I IIUNICINL, INDUS'niiAL, I HAZARDOUS WASTES I I I I Rate of contaminant release and transport 3. Defining Risks (where possible); The municipal landfill manual states that a streamlined or I • Affected media; limited baseline risk assessment will be sufficient 10 and initiate response action on the most obvious problems at .•. . andKnown potential routes of mi'"""tion·00..... a municipal landfill (e.g .• ground water.leachate. landfill I ~nten~ and landfill~)- One method for establishing • Known and potential human and nsk usmg a streamlined approach is 10 compare environmental recepiOrS. contaminant concentration levels (ifavailable) 10 standards that are potential chemical-specifJC applicable or relevant I After the ~ta are evaluated and a site visit is completed. and appropriate requirements (ARARs) for the action. thecontammantreleaseandtransportmechanismsrelevant ·· The manual states that where established standards for 10 the s!te should be determined. The key element in one or more contaminants in a given medium are clearly .developmg the conceptual site model is 10 identify those exceeded. remedial action generally is warranted. 3 I aspects of the model that req"tiinf'inore information 10 make_ a decision about response measures, Because It is important 10 note, however, that based on site­ contammen~ of the landfill's contents is the presumed specific conditions.. an active response is not regujred if reswnse acuon, the conceptual site model will be of most ground-water contaminant concentrations exceed I use in identifying areas beyond the landfill source itself · chemical-specifac standards bu1 the site risk is within the . that will require further study. thereby focusing site - Agency's acceptable risk range (10"' 10 1~).. For characterization away from the source area and on areas example • .if. .it· is .determined that the release of. · of potential contaminant migration (e.g •• ground water or I contaminated sediments). · 'See also OSWER Directive 9355.0-30, Rolt of IM Baseline Rislc Asstssnwfll ita Superfund Rtnwdy StltclilHI DtcisiotU, April 22, 1991, which states that if MCL.s ornon-zcroMCLGsan:cxcecded, (a I n:sponse I action generally is wam~med. 4 I ~----- 1 contaminants from-~ particular landfill is declining, and concentrationsofoneormoreground-watercontaminants Highlight3: Source Contaminant are at « barely exceed chemical-specific standards., the Exposure Pathways Addressed I Agency may decide not to implement an active response. by Presumptive Remedy Such a decision might be based on the understanding that the landfill is no longer acting as a source of ground-warer 1. Direct contact with soil and/or contamination, and that the landfill does not present an debris prevented by landfill cap; I uruK:Ceplable risk from any other exposure pathway. 2. ,Exposure to contaminated ground A site generally will not be eligible for a streamlined risk water. within the landfill area I evaluation if ground-water contaminant concentrations .. P.revented by ground-water do not clearly exceed chemical-specific standards or the control;· Agency's accepted level of risk, or other conditions do 3. Exposure to contaminated I not exist that provide a clear justification for action (e.g., leachate prevented by leachate · direct contact with landfill contents resulting from unstable collection and treatment; and slopes). Under these circumstances, a quantitative risk assessment that addresses all exposure pathways will be 4. Exposure to landfill gas necessary to determine whether action is needed. addressed by gas collection and I treatment, as appropriate. Ultimately, it is necessary to demonstrate that the final remedy addresses all pathways and contaminants of remedy, since such contamination will require a I concern, not just those that ttiggered the remedial action. conventional investigation and a risk assessmenL As described in the following sections, the conceptual . site model is an effective tool for identifying those . Stteamlining the risk assessment of the source area pathways and illustrating that they have been addressed eliminates the need for sampling and analysis to support I by the containment remedy. the calculation of current or potential future risk associated with directconta::L It is important to note that because the Streamlined Risk Evaluation Of The Landfill . continued effectiveness of the containment remedy I Source depends on the integrity of the containment system, it is Experience from the presumptive remedy pilots supports likely that institutional controls will be necessary to . the usefulness of a stteamlined risk evaluation to initiate resttict future activities at a CERCLA municipal landfill an early response action under certain circumstances. As . _afterconsuuction of the cap and associated systems. EPA I a matter of policy, for the sowce area of municipal has thus detennined that it is not appropriate or necessary landfills, a quantitative risk assessment that considers all to estimare the risk associated with future residential use chemicals, their potential additive effec~ etc., is not of the landfill source, as such use would be incompatible I necessary to establish a basis for action if ground-warer with the need to maintain the integrity of the containment dataareavailable to demonstrate thatcontaminantsclearly system. (Long-term waste management areas, such as exceed established standards or if other conditions exist municipal landfills, may be appropriate, however,· for that provide a clear justification for action. recreational or other limited uses on a site-specific basis.) I The availability and efficacy of institutional controls should be evaluated in the FS. Decision documents A quantitative risk assessment also is not necessary to evaluate whether the containment remedy addresses all should include measures such as institutional controls to ensure the continued integrity ofsuch containment systems I pathways and contaminants of concern associated with thesource. Rather,allpotentialexposurepathwayscanbe whenever possible. identified using the conceQtuaJ site model and compared to thepathwavs adclrr§sedby the containment presumptive Areas or Contaminant Migration I ~- Highlight3 illustratesthalthecontainmentremedy Almost every municipal landfill site has some characteristic addresses all exposure palhways associated with the that may require additional study, such as leachate somce at municipal landfill sites. . discharge to a wetland or significant surface water run-off caused by drainage problems. These migration pathways, I Finally, a quantitative risk assessment is not required to as well as ground-water contamination that has migrated determine clean-up levels because the type of cap will be , away from the source, ·generally will require determined by closure ARARs, and ground water that is chamcterizationandamorecomprehensiverislcassessment I exiJ'aCted as a component of the presumptive remedy will to detennine whether action is warranted beyond the be required to meet discharge limits, or other standards for source area and, ifso, the type ofaction that is appropriate. its disposal. Calculation of clean-up levels for ground­ warer contamination that has migrated away from the While future residential use of the landfill source area I source will not be accomplished under the presumptive itself is not considered appropriate, the land adjacent to I 5 I

landfills is frequently used for residential purposes. the decision to characterize and/or treat hot spots. The I Therefore, based on site-specific circumstances, it may be overriding question is whether the combination of the appropriate to consider future residential use for ground waste's physical and chemical characteristics and volume water and other exposure pathways when assessing risk is such that the integrity of the new containment system from areas of contaminant migration. will be threatened if the waste is left in place. This I question should be answered on the basis of what is 4. Developing the Response Action .k~Jmmaboutasite(e.g.,fromoperatingrecordsorother reliable information). An answer in theaffumative to all I As a frrst step in developing containment alternatives, of the questions listed in Highlight4 would indicate that ~response action objectives should be developed on the it is likely that the integrity of the containment system basis of the pathways identified for action in the would be threatened, or that excavation and treatment of conceptual site model. Typically, the primary response hot spots would be practicable, and that a significant I action objectives for municipal landfill sites include: reduction in risk at the site would occur as a result of treating hot spots. EPA expects that few CERCLA Presumptive Remedy municipal landfills will fall into this category; rather, based on the Agency's experience, the majority of sites I • Preventing direct contact with landfill are expected to be suitable for containment only·, based contents; on the heterogeneity of the waste, the lack of reliable information concerning disposal history, and the I Minimizing infiltration and resulting problems associated with excavating through refuse. contaminant leaching to ground water; The volume of industrial and/or hazardous waste co­ • Controlling surface water runoff and disposed with municipal waste at CERCLA municipal I erosion; landfills varies from site to site, as does the amount of Collecting and treating contaminated information available concerning disposal history. It is ground water_and leachate to contain impossible to fully characterize, excavate, and/or treat I the contaminant plume and prevent the source area of municipal landfills, so uncertainty further migration from source area; about the landfill contents is expected. Uncertainty by and itself does not call into question the containment approach. However, containment remedies must be I • Controlling and treating landfill gas . designed to take into account the possibility that hot spots are present in addition to those that have been . identified and characterized. The presumptive remedy I Non-Presummive Remedy must be relied upon to contain landfill contents and prevent migration of contaminants. This is accomplished • Remediating ground water; by a combination of measures, such as a landftll cap combined with a leachate collection system. Monitoring I Remediating con~minated surface will further ensure the continued effectiveness of the water and sediments; and remedy. • Remediating contaminated wetland The following examples illustrate site-specific decision I areas. making and show how these factors affect the decision As discussed in Section 3, "Defining Risks," the whether to characterize and/or treat hot spots. containment presumptive remedy accomplishes all but I the last three of these objectives by addressing all Examples or Site-Specific Decision Making pathways associated with the source. Therefore, the Concerning Hot Spot Characterization/ focus of the RIIFS can be shifted to characterizing the Treatment media addressed in the last three objectives I (contaminated ground water, surface water and sediments, and wetland areas) and on collecting data to suppon design of the containment remedy. There is anecdotal information that approximately 200 drums of hazardous waste were disposed of at this 70- I Treatment or Hot Spots acre former municipal landfill, but their location and contents are unknown. The remedy includes a landfill cap The decision to characterize and/or lreat hot spots is a and ground-water and landfill gas treatment I site-specific judgement that should be based on the consideration-of a standard set of factors. Highlight 4 A search for and characterization of hot spots is not lists questions that should be answered before making supponed at Sire A based on the questions listed i., I 6 I I re.maining landfill contents, including passive gas Highlight 4: Characterization collection and flaring. I of HotSpots Treatment of landfill contents is supponed at Site B becauseallofthequestionsinHighlight4canbeanswered If all of the following questions can be in the affll1llative: (1) existing evidence from previous I answered in the affirmative, it is likely investigations and sampling conducted by the state (prior that characterization and'or treatment to the RI) in

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2. The new response action constitutes disposal under 5 I RCRA (i.e., disposal back inro the originallandfill).

The decision about whether a Subtitle C closure requirement is relevant and appropriate is based on a I variety of factors, including the nature of the wasae and its hazardous properties, the date on which it was disposed. and the nature of. the requirement itself. For more information on RCRA Subtitle C closure requirements, I see RCRA ARARs: Focus on Closure Requirements, Directive No. 9234.2-04FS. Ocrober 1989. I

'N01e that disposal of only small quantity hazardous waste llld household hazardous waste does not make Subtitle C applicable. I I I

Notice: I

The policies set out in this document are intended solely as guidance to the U.S. Environmental Protection Agency (I;PA) personnel: they are not final EPA actions and do not constitute rulemaking. These policies are not intended, nor c;an they be relied upon, to create any rights enforceable by any party I in litigation with the United States. EPA officials may decide to follow the guidance provided in this document, or to act at variance with the guidance, based on an analysis of specific site circumstances. EPA also reserves the right to change the guidance at any time without public notice. I I I I I I

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