eder associates - United States Environmental Protection Agency · 2020-06-11 · e eder associates...

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eder associates ^^vaiievMadison. Wl

consulting engineers, p. c.

December 9, 1991File #497-13

Mr. Michael GiffordRemedial Project ManagerOffice of SuperfundUnited States EnvironmentalProtection Agency

Route 5230 South Dearborn StreetChicago, Illinois 60604

Dear Mike:

Enclosed is one copy of the Phased Feasibility Study Report for theNational Presto Industries, Inc. site. This report includes theminor revisions outlined in your September 18, 1991 letter. Onecopy has been sent to each of the National Presto Superfund SiteInformation Repositories.

Please call if you have any questions or require any additionalcopies.

Very truly yours,

EDER ASSOCIATES/CONSULTING ENGINEERS, P.C.

.E.ident

GAR/llvEncl.cc: J. Boettcher

M. Giesfeldt

LLV1930

48O FOREST AVENUE, LOCUST VALLEY, NEW YORK 11560 • (516) 671-844O • FAX (516) 671-3349

e OFFICES:

eder associates ^^ vaiiev NYMadison. Wl



National Presto Superfund SiteInformation Repository

Chippewa Falls Public Library105 West Central StreetChippewa Falls, Wisconsin 54729

To the Repository:

Pursuant to Michael A. Gifford's direction (United StatesEnvironmental Protection Agency Remedial Project Manager), I haveattached one copy of the Phased Feasibility Study Report preparedby National Presto Industries, Inc., Eau Claire, Wisconsin

This report has been approved by the United States EnvironmentalProtection Agency (USEPA) and the Wisconsin Department of NaturalResources (WDNR) and will be included in the Administrative Record.

Very truly yours,

EDER ASSOCIATES CONSULTING ENGINEERS, P.C.

us,ce President

GAR/llvEncl.cc: M. Gifford

LLV1930

48O FOREST AVENUE. LOCUST VALLEY. NEW YORK 1156O • (516) 671-8440 • FAX (516) 671-3349

e OFFICES

eder associates ^cust vaiiev NYM.idison. Wl



National Presto Superfund SiteInformation Repository

Hallie Town HallRoute 9957 Hagen RoadChippewa Falls, Wisconsin 54729

To the Repository:

Pursuant to Michael A. Giffordf s direction (United StatesEnvironmental Protection Agency Remedial Project Manager), I haveattached one copy of the Phased Feasibility Study Report preparedby National Presto Industries, Inc., Eau Claire, Wisconsin

This report has been approved by the United States EnvironmentalProtection Agency (USEPA) and the Wisconsin Department of NaturalResources (WDNR) and will be included in the Administrative Record.

Very truly yours,

EDER ASSOCIATES CONSULTING ENGINEERS, P.C.

iry A. JJozmus, P'Senior vice President

GAR/llvEncl.cc: M. Gifford

LLV1930

480 FOREST AVENUE, LOCUST VALLEY. NEW YORK 11S6O • (516) 671-8440 • FAX (516) 671-3349

eder associatesconsulting engineers, p.c.

NATIONAL PRESTO INDUSTRIES, INC.EAU CLAIRE, WISCONSIN

PHASED FEASIBILITYSTUDY REPORT

PROJECT #497-13DECEMBER 1991

EDER ASSOCIATESCONSULTING ENGINEERS, P.C.Locust Valley, New York

Madison, WisconsinAnn Arbor, MichiganAugusta, Georgia

LM1006 120591

•ctor associates consulting engineers, p.c.

TABLE OF CONTENTS

Paae

I. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . 1

Purpose and Organization of Report . . . . . . . . . . lBackground Information . . . . . . . . . . . . . . . . 3

Site Description and History . . . . . . . . . . . 3Nature and Extent of Contamination . . . . . . . . . . 4Contaminant Fate and Transport . . . . . . . . . . . . 5

II. IDENTIFICATION OF TECHNOLOGIES . . . . . . . . . . . . 6

Introduction . . . . . . . . . . . . . . . . . . . . . 6Applicable or Relevant and Appropriate Requirements . . 6Eau Claire POTW Pretreatment Standards . . . . . . . . 7Wisconsin Water Quality Standards and Effluent Limits . 8Clean Water Act and Wisconsin Groundwater Discharge

General Permit Requirements . . . . . . . . . . . . 9Wisconsin Preventive Action Limits and Enforcement

Standards . . . . . . . . . . . . . . . . . . . . . 12Wisconsin Air Quality Standards . . . . . . . . . . . . 12Wisconsin High Capacity Well Approvals . . . . . . . . 13Remedial Action Objectives . . . . . . . . . . . . . . 13General Response Actions and Technologies ....... 15

III. DEVELOPMENT, DESCRIPTION AND DETAILED ANALYSIS OFALTERNATIVES . . . . . . . . . . . . . . . . . . . 19

Introduction . . . . . . . . . . . . . . . . . . . . . 19Alternative 1: No Action . . . . . . . . . . . . . . . 22Description . . . . . . . . . . . . . . . . . . . . . . 23Assessment . . . . . . . . . . . . . . . . . . . . . . 23Alternative 2: Pump and Discharge to Sanitary Sewer . 23Description . . .................... 24Assessment . . . . . . . . . . . . . . . . . . . . . . 26Alternative 3: Pump, Aerate, and Discharge to Storm

Sewer . . . . . . . . . . . . . . . . . . . . . . . 29Alternative 3a . . . . . . . . . . . . . . . . . . . . 30Description . . . . . . . . . . . . . . . . . . . . . . 30Alternative 3b . . . . . . . . . . . . . . . . . . . . 31Description . . . . . . . . . . . . . . . . . . . . . . 31Assessment . . . . . . . . . . . . . . . . . . . . . . 32Alternative 4: Pump, Aerate, Direct Discharge to

Surface Water ................... 36Alternative 4a . . . . . . . . * . . . . . . . . . . . . 37Description . . . . . . . . . . . . . . . . . . . . . . 37

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TABLE OF CONTENTS(Continued . . .1

Page

Alternative 4b . . . . . . . . . . . . . . . . . . . . 38Description . . . . . . . . . . . . . . . . . . . . . . 38Assessment . . . . . . . . . . . . . . . . . . . . . . 39Alternative 5: Pump, Air Stripping, On-Site Recharge . 43Description . . . . . . . . . . . . . . . . . . . . . . 44Assessment . . . . . . . . . . . . . . . . . . . . . . 46

IV. COMPARATIVE ANALYSIS OF INTERIM ACTION ALTERNATIVES . . 49

APPENDIX A - NR 106.06 WISCONSIN ADMINISTRATIVE CODE FORMULASTO CALCULATE SURFACE WATER DISCHARGE LIMITATIONS

APPENDIX B - SAMPLE WPDES GENERAL PERMITAPPENDIX C - JULY 11, 1991 LETTER FROM CITY OF EAU CLAIRE

TO EDER ASSOCIATESAPPENDIX D - AUGUST 2, 1991 LETTER FROM CITY OF EAU CLAIRE

TO EDER ASSOCIATESAPPENDIX E - ESTIMATE OF CASCADE AERATION SYSTEM

VOC REMOVAL EFFICIENCY

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LIST OF TABLES

No. Description

1 Summary of VOC Analyses (ug/L) On-Site Monitoring Wells

2 Summary of Inorganic Analyses (ug/L) - April 1991Sampling On-site Monitoring Wells

3 City of Eau Claire POTW Industrial Pretreatment Standards

4 Surface Water Quality Criteria, Discharge Limitation andMaximum Levels Measured 'in On-Site Monitoring Wells

5 Surface Water Criteria and Discharge Limits for Metalsand Maximum Levels Expected in Groundwater Recovered atthe NPI Site

6 Water Quality Standards for VOCs in Groundwater at theNPI Site

7 Alternative 2 Pump and Discharge to Sanitary SewerPreliminary Capital Cost Estimate

8 Alternative 2 Pump and Discharge to Sanitary SewerPreliminary Annual Operating and Maintenance CostEstimate

9 Alternative 3a Pump, Cascade Aeration and Discharge toStorm Sewer Preliminary Capital Cost Estimate

10 Alternative 3a Pump, Cascade Aeration and Discharge toStorm Sewer Annual Operating and Maintenance CostEstimate

11 Alternative 3b Pump, Air Stripping and Discharge to StormSewer Preliminary Capital Cost Estimate

12 Alternative 3b Pump, Air Stripping and Discharge to StormSewer Preliminary Annual Operating and Maintenance CostEstimate

13 Alternative 4a Pump, Cascade Aeration and DirectDischarge to Lake Hallie Preliminary Capital CostEstimate

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LIST OF TABLES(Continued . . .)

No. Description

14 Alternative 4a Pump, Cascade Aeration and DirectDischarge to Lake Hallie Preliminary Annual Operating andMaintenance Cost Estimate

15 Alternative 4b Pump, Air Stripping, and Direct Dischargeto Lake Hallie Preliminary Capital Cost Estimate

16 Alternative 4b Pump, Air Stripping and Direct Dischargeto Lake Hallie Preliminary Annual Operating andMaintenance Cost Estimate

17 Alternative 5 Pump, Air Strip and On-Site RechargePreliminary Capital Cost Estimate

18 Alternative 5 Pump, Air Strip and On-Site RechargePreliminary Annual Operating and Maintenance CostEstimate

19 Summary of NCP Evaluation

20 Summary of Remedial Alternative Cost Estimates PresentWorth Based on 10% Discount Rate

21 Summary of Remedial Alternative Cost Estimates (PresentWorth Based on 5% Discount Rate)


TABLE OF CONTENTS(Continued . . .)

LIST OF FIGURES

No. Description

1 Location Map2 Buried Valley Map3 Melby Road Site Capture Wells4 Melby Road Site Capture Zone5 Southwest Corner Capture Wells6 Passive Aeration Structure

LIST OF DRAWINGS

No. Description

1 Monitoring Well Locations2 Alternative 2 Piping Layout3 Alternative 3a Piping Layout4 Alternative 3b Piping Layout5 Alternative 4a Piping Layout6 Alternative 4b Piping Layout7 Alternative 5 Piping Layout


I. INTRODUCTION

Purpose and Organization of Report

This Phased Feasibility Study (PFS) report develops, describesand evaluates several alternatives that could be employed as aninterim action operable unit to remediate groundwater at theNational Presto Industries, Inc. (NPI) site located in Eau Claire,Wisconsin. The Remedial Investigation (RI) and Feasibility Study(FS) for the NPI site are being performed under the terms of theAdministrative Order by Consent entered into by NPI, the UnitedStates Environmental Protection Agency (USEPA) and the WisconsinDepartment of Natural Resources (WDNR) effective July 8, 1986. Theconclusions of the RI and FS will be submitted as separatedocuments. This PFS report has been prepared in accordance withguidance set forth in the following USEPA documents:

• Guidance for Conducting Remedial Investigations andFeasibility Studies under CERCLA, Interim Final (RI/FSGuidance Document, October 1988)

• Guidance on Remedial Actions for Contaminated Groundwaterat Superfund Sites, Interim Final (December 1988)

• National Oil and Hazardous Substances PollutionContingency Plan, Final Rule (NCP, March 8, 1990)

In the NCP, USEPA defines operable units as "discrete actionsthat comprise incremental steps toward the final remedy" and which"may include interim actions (e.g., pumping and treating ofgroundwater to retard plume migration) that must be followed bysubsequent actions which fully address the scope of the problem(e.g., final groundwater operable unit that defines the remediation

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level and restoration timeframe)." "USEPA encourages theimplementation of interim action operable units, as appropriate, toprevent exposure or control risks posed by a site." (55 FR 8705)USEPA requires that the selection of operable units be supportedwith sufficient site data that indicate the operable unit willeffectively manage site problems or expedite the reduction of riskposed by the site.

USEPA has not established a specific guidance document thatoutlines information required in a PFS report to evaluate interimaction alternatives. The NCP states (at 55 FR 8705): "The ROD(Record of Decision) for an interim remedy implemented as anoperable unit does not necessarily require a separate RI/FS butinstead can summarize data collected to date that supports thatdecision." Therefore, this PFS report has been prepared accordingto USEPA's RI/FS Guidance Document, using a streamlined approach toexpedite completion of the PFS and implementation of an interimaction.

In step with the RI/FS guidance, Section I of this PFS reportpresents background information collected during the remedialinvestigation that is relevant to on-site groundwatercontamination. The remedial action objectives (RAOs) and thegeneral response actions determined to be appropriate to achievethe RAOs for on-site groundwater are presented in Section II. Thetechnologies employed as components of the PFS alternatives arethen listed. To streamline the PFS process, a general technologyscreening is not appropriate and is not presented. The evaluationis limited to those technologies that would be appropriate toimplement as part of an operable unit (based on the availabledata). Section II also includes a discussion of applicable orrelevant and appropriate requirements (ARARs) as they relate to thealternatives to remediate on-site groundwater. Section IIIdescribes the alternatives developed to achieve the RAOs for on-site groundwater and evaluates them based on the criteria set forth


in the NCP. In order to expedite the PFS process, the remediesconsidered are limited to those that could reasonably be employedat the NPI site, thus an initial alternatives screening is notrequired. Detailed evaluation of these alternatives is supportedby site characterization data collected during the RI. Theselection and detailed evaluation of these alternatives wasconducted in consultation with the USEPA and WDNR and in accordancewith USEPA Guidance documents.

Background Information

Site Description and History

The NPI site is located in- Eau Claire, Wisconsin and iscomprised of approximately 320 acres (see Figure 1, Location Map).The NPI site lies within the City of Eau Claire, except forapproximately nine acres on the eastern portion which are locatedin the Town of Hallie and approximately four acres on the southernportion which are located in the Town of Seymour. The NPI site isnot presently an active manufacturing facility, however, thefacilities are maintained in a high state of readiness forprojectile metal parts production under contracts with theDepartment of Army. The site was originally owned by the UnitedStates Government and was operated between 1940 and 1947 by itscontractors, the U.S. Rubber Company as a small arms gunpowderloading plant and Western Electric as a radar tube manufacturer.NPI purchased the property from the government in 1948. Consumerproducts, Army projectile fuzes and military aircraft parts wereproduced at NPI from 1948 to 1954. Since 1954, the NPI site hasbeen dedicated exclusively to work for the Department of Army, andat times, the site has been inactive. Between 1954 and 1959, theNPI facility produced military aircraft parts and between 1966 and1980, projectile metal parts were produced for the Department ofthe Army.

•etar associates consulting engineers, p.c.

Nature and Extent of Contamination

Formal remedial investigation activity commenced at the NPIsite following the July 1986 issuance of the Administrative Orderby Consent. Since the first RI monitoring wells were installed inNovember 1986, 69 monitoring wells were installed and sampled, 64private wells and 29 pre-RI monitoring wells were sampled and waterlevels were measured in 132 monitoring wells. The locations of themonitoring wells installed on and proximate to the NPI site duringthe RI are presented on Drawing No. 1. Site characterization datacollected prior to and during the NPI site remedial investigationand summarized in the Draft RI Report (Eder Associates, February1991) indicates the presence of groundwater contaminant plumesbeneath and extending significant distances off the NPI site. Theresults of the NPI site RI indicate that volatile organic compounds(VOCs) are the primary groundwater contaminants in the plumes. Themain VOCs detected in on-site samples are 1,1,1-Trichloroethane(TCA), 1,1-Dichloroethane (DCA), 1,l-Dichloroethylene (1,1-DCE),1,2-Dichloroethylene (1,2-DCE), Trichloroethylene (TCE) andTetrachloroethylene (PCE). Table 1 summarizes the individual VOClevels detected in the on-site groundwater samples collected andanalyzed through April 1991. On-site groundwater metalsconcentrations are generally below the levels necessary to maintaindrinking water and surface water quality, however, there areexceedances measured at MW-4B, MW-10A and MW-10B. The most recentgroundwater samples were analyzed for metals in April 1991 andTable 2 summarizes the on-site results.

This PFS report only addresses groundwater beneath the NPIsite along the northern portion of the property at the Melby Roadarea and at the southwest corner of the property. The PFS onlyconsiders remediation of groundwater at these two locations. Off-site groundwater remediation is not a component of this operableunit and will be addressed along with source control in the DraftFS report, to be completed at a later date. It is expected that


the operable unit will beneficially impact off-site groundwaterconditions through plume containment.

Monitoring well data collected during the RI revealed thatgroundwater at the NPI site occurs primarily in the sand and gravelalluvium and, to a lesser extent, in the sandstone bedrock. Theoccurrence of groundwater in the area is also related to a buriedvalley system (see Figure 2). Groundwater at the NPI site flowsgenerally to the northwest in the eastern and extreme southernportions of the property. Groundwater flow in the northwesternpart of the site is more complex because of the combination ofalluvial deposits and the locations of the buried valley and agroundwater divide. This groundwater divide bisects the westernportion of the site in a northwest direction. Located south of thedivide, groundwater from the southwest corner of the NPI propertyflows into the westward trending buried valley which extends to theChippewa River; north of the divide, groundwater from the MelbyRoad area flows into the buried valley that trends northeast andextends to Lake Hallie. Lake Hallie has an inlet and an outlet,and empties to the Chippewa River. The exact location of thedivide could vary depending on seasonal groundwater recharge, theamount of pumping from NPI site wells, and percolation from thelagoon system.

Contaminant Fate and Transport

Groundwater is the significant migration pathway for VOCcontaminants at the NPI site. The primary VOCs identified ingroundwater (TCA, TCE, PCE and 1,1 DCE) migrate in the alluvialaquifer. 1,1 DCA and 1,2 DCE (cis and trans) are also present.They are the breakdown products of TCA and TCE and migrate withgroundwater on-site and off-site. VOCs in groundwater migratetoward areas of discharge at Lake Hallie and the Chippewa River.


II. IDENTIFICATION OF TECHNOLQGIES

Introduction

This section presents the remedial action objectives (RAOs)that relate to the on-site groundwater operable unit at the MelbyRoad area and at the southwest corner of the NPI site. Based onthe site characterization data collected during the RI, to date,appropriate general response actions and associated technologies toachieve the RAOs are identified. These technologies are thecomponents of the remedial alternatives developed and evaluated inSection III of the PFS.

Alternative development and evaluation is driven in part byapplicable or relevant and appropriate requirements (ARARs) thatwould impact implementation of the operable unit. The ARARs thathave the greatest impact on on-site groundwater remediation arediscussed in the following subsections.

Applicable or Relevant and Appropriate Requirements

Standards for remedial actions at CERCLA sites are defined bythose public health statutes and environmental regulations that areapplicable or relevant and appropriate requirements (ARARs). Thealternatives and RAOs presented in this PFS have been developedwithin the framework of the ARARs.

USEPA divides ARARs into three types: chemical-specific,action-specific and location-specific. Chemical-specific ARARs areusually health or risk based chemical concentration limits orconcentration ranges in environmental media. Examples of chemical-specific ARARs are the Safe Drinking Water Act Maximum ContaminantLevels (MCLs) and National Ambient Air Quality Standards. Action-

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specific ARARs set performance, design or similar controls onremedial alternatives. Best demonstrated available technology(BOAT) regulations are an example of these ARARs. Location-specific ARARs set limits on activities based on the site location.The Building and Antiquities Act is an example of these ARARs whichcould constrain remedial alternative implementation in an area ofhistorical sites.

The primary ARARs considered in this PFS are:

• Eau Claire POTW Pretreatment Standards

• Wisconsin Water Quality Standards

• Clean Water Act and Wisconsin Groundwater DischargeGeneral Permit Requirements

• Wisconsin Preventive Action Limits and EnforcementStandards and Federal Maximum Contaminant Levels

• Wisconsin Air Quality Standards

• Wisconsin High Capacity Well Approvals

These ARARs have been stressed in recent communicationsbetween NPI, WDNR and USEPA concerning groundwater remediation(i.e. - WDNR letters dated March 7, 1991 and USEPA letter datedJune 4, 1991).

Eau Claire POTW Pretreatment Standards

The City of Eau Claire Publicly Owned Treatment Works (POTW)requires that waters discharged to the sanitary sewer system fromnon-municipal source, contain contaminants at concentrations belowthe POTW's pretreatment standards. The City indicates that it only


limits seven metals under the current pretreatment rules. However,within the next 12 months, the City expects to promulgate morestringent POTW pretreatment regulations that will coversignificantly more pollutants than the current standards. Thecurrent POTW pretreatment standards are presented in Table 3. Itwould be necessary to satisfy the POTW's pretreatment standardsbefore groundwater from the NPI site could be discharged to thesanitary sewer system.

Wisconsin Water Quality Standards and Effluent Limits

Chapters NR 105 (Surface Water Quality Criteria for ToxicSubstances) and NR 106 (Procedures for Calculating Water QualityBased Effluent Limitations for Toxic and Organoleptic SubstancesDischarged to Surface Waters) of the Wisconsin Administrative Codeset forth the WDNR surface water quality criteria and surface waterdischarge limitations.

The Wisconsin Surface Water Quality Standards are based on thehuman threshold criteria for non-carcinogenic compounds (NR 105.08)and the human cancer criteria for carcinogens (NR 105.09). Thesetoxicity based criteria are the allowable in-stream concentrationsestablished to protect public health and welfare and to maintainwater quality. The Wisconsin Pollutant Discharge EliminationSystem (WPDES) program regulates the contaminant concentrationscontained in discharges to surface water. Chapter NR 106,Wisconsin Administrative Code, sets forth procedures forcalculating discharge limitations based on the in-stream waterquality criteria and receiving water flow. The NR 106.06 dischargelimit calculation formulas for rivers and lakes are presented inAppendix A.

Tables 4 & 5 present the Wisconsin surface water criteria forVOCs and metals, respectively, and the water quality-based effluentlimits that would apply to Chippewa River or Lake Hallie

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discharges. These discharge limits are compared to the April 1991maximum concentrations measured in groundwater at the Melby Roadarea and at the southwest corner of the NPI site. According toTable 4, it is expected that untreated groundwater extracted at theNPI site would contain VOCs at levels below the state water qualitycriteria and one to two orders of magnitude below the water qualitybased discharge limits. Similarly, Table 5 indicates that themetals levels expected in groundwater that may be extracted by thisoperable unit would be below the water quality based dischargelimits.

Clean Water Act and Wisconsin Groundwater Discharge General PermitRequirements

The Clean Water Act (Title III) provides for the developmentof effluent limitations for point source discharges to surfacewater or groundwater. Section 301(b)(2) states that effluentlimitations "shall require application of the best availabletechnology economically achievable . . . which will result inreasonable further progress toward the national goal of eliminatingthe discharge of all pollutants". The Wisconsin effluentlimitation regulations are established pursuant to the Clean WaterAct and require that the best available technology that iseconomically achievable (determined by WDNR on a case-specificbasis) be employed for all discharges.

The Wisconsin Pollutant Discharge Elimination System (WPDES)was established under Chapter 147 of the Wisconsin Statutes toregulate discharges to surface water or groundwater. The WDNRBureau of Wastewater Management has developed a general WPDESpermit that applies in certain situations where groundwater isdischarged directly to surface water or indirectly to groundwater.The goal of the general permit is to remove pollutants fromaquifers to prevent their migration. A sample WPDES general permitis presented in Appendix B. The permit only applies touncontaminated or treated groundwater discharges to surface water


or to groundwater where WDNR determines that the discharge will nothave significant receiving waters impacts.

The permit requirements regulate surface water impacts due tothe discharge of groundwater contaminated by petroleum products andvolatile organic compounds. The requirements also regulatepollutants listed in Chapter NR 140 (Wisconsin Administrative Code)for wastewater discharges to groundwaters via infiltration.

WDNR has determined that, based on the levels of VOCscontained in on-site groundwater at the Melby Road area and at thesouthwest corner of the property, the NPI operable unit would besubject to the WPDES general permit requirements for VOCs. Thegeneral permit for discharge to surface water will only be issuedwhen it is confirmed that the permit limits are sufficientlyrestrictive to protect receiving water quality. Treatment isrequired even if the VOC concentrations in the discharge are belowwater quality based levels. WDNR evaluates remedial actiondischarges by comparing the VOC concentrations in the extractedgroundwater with their respective surface water quality standards.The WPDES general permit requirements are restrictive enough tomeet water quality standards using technically and economicallyachievable treatment technologies.

A comparison of the maximum VOC levels measured in the mostrecent (April 1991) groundwater samples collected at the Melby Roadarea and at the southwest corner of the property indicates thatgroundwater extracted at these locations would meet the WisconsinSurface Water Quality Standards for the Chippewa River and LakeHallie without treatment (refer to Table 4) . However, treatment isrequired for all discharges of contaminated groundwater, consistentwith section 30l(b)(2) of the Clean Water Act and the correspondingsection 147.04(2)(b) , Wisconsin Statutes.

WDNR has determined that in the case of VOCs at the NPI sitea passive system such as a cascade would satisfy the Wisconsin best

10


available treatment requirement for groundwater discharges tosurface water.

At facilities that discharge groundwater containing VOCs to aland disposal system, the general permit requires treatment tominimize VOC concentrations to the extent that is technically andeconomically feasible. WDNR compares the expected residual VOCconcentrations in the discharge with the groundwater standards setforth in Chapter NR 140, Wisconsin Administrative Code. These NR140 standards (Preventive Action Limits and Enforcement Standards)for VOCs are discussed in the next section. "Wastewater treatmentwill be required to minimize the level of substances in thegroundwater and to prevent exceedance of the groundwater preventiveaction limits (PAL) contained in Chapter NR 140, WisconsinAdministrative Code, to the extent that it is technically andeconomically feasible." (WPDES General Permit No. WI-0046566-2,Part I, Condition E (1)).

Operable units that discharge groundwater to land via drainageponds, seepage basins, etc. must demonstrate compliance with the NR140 groundwater standards by reporting an analytical result lessthan the PAL or by reporting a result less than the standardanalytical method detection level.

In summary, the WPDES general permit and WDNR Bureau ofWastewater Management policy requires that all groundwater betreated to some specified level prior to discharge. "This permitrequires effective treatment, such as air stripping or activatedcarbon adsorption, for discharges [to surface water] containingvolatile organic chemicals. Some pollutant removal will berequired in all cases, even when the untreated wastewater couldmeet the limits listed above. This requirement for wastewatertreatment will assure compliance with Wisconsin Water QualityStandards in almost all cases." (WPDES General Permit No. WI-0046566-2, Condition D(3)(d)).

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Wisconsin Preventive Action Limits and Enforcement Standards

Chapter NR 140 of the Wisconsin Administrative Codeestablishes Preventive Action Limits (PALs) and EnforcementStandards (ESes), which are public health-related groundwaterstandards for particular contaminants. The ESes are generally setat the Federal Maximum Contaminant Levels (MCLs) which protecthuman health by limiting exposure to particular constituents indrinking water. The MCLs are promulgated under the Safe DrinkingWater Act and are developed using health, cost and technicalconsiderations.

The primary objective of the PFS operable unit is to preventadditional off-site migration of contaminated groundwater from theMelby Road area and the southwest corner of the NPI site.Groundwater concentrations of 1,1,1-TCA, PCE and TCE have exceededtheir respective MCLs and ESes at these areas of the NPI site.

The long-term goal of groundwater remediation at the NPI siteis to reduce VOC levels in groundwater to the PALs using acombination of source control and groundwater actions. Long-termgroundwater remediation and source control will be addressed aspart of the final response action for the site.

Wisconsin Air Quality Standards

Air emissions from groundwater treatment systems that may beemployed as part of an operable unit at the NPI site must satisfythe WDNR Chapter NR 445 Wisconsin Administrative Code regulations.Air emissions from treatment of VOC-contaminated groundwater shallbe evaluated on a case-by-case basis regarding the need for airemission controls and compliance with the substantive requirementsof a WDNR air permit.2

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The WDNR Air Section indicates that emission controls arerequired for sources that emit greater than 5.7 pounds of totalorganics per hour. Sources that emit greater than 3.1 pounds oftotal organics per hour or 15 pounds per day must demonstrate thatthe lowest available emission rates or best available controltechnology (BACT) levels will be achieved and maintained.

Based on the maximum levels of VOCs measured in groundwater atthe Melby Road area and at the southwest corner of the property(approximately 700 ug/L), emission controls would not be requiredfor VOC emissions (less than 3.4 pounds of total organics per day)from a treatment system at the NPI site.

Wisconsin High Capacity Well Approvals

The provisions of Chapter NR 112.26(1) WisconsinAdministrative Code are applied to ensure that groundwaterextraction at a site will not reduce the availability ofgroundwater to public utilities in the area. WDNR has establisheda high capacity well approvals program to regulate sites whereproposed groundwater pumping of a single well or a combination ofwells would withdraw more than 70 gpm from the aquifer. Such sitesmust apply for a high capacity well approval from the WDNR Bureauof Water Supply, which will either grant or deny approval, orimpose conditions on pumping so that the water supply of any publicutility will not be impaired.

Remedial Action Objectives

The remedial action objectives (RAOs) of the operable unit areto protect human health and the environment, and to preventgroundwater degradation by preventing off-site migration ofcontaminated groundwater from the Melby Road area and the southwestcorner of the NPI site where contaminant concentrations haveexceeded their MCLs and ESes. Pursuant to the NCP, the RAOs for

13


the NPI site operable unit specify the contaminants of concern inthe on-site groundwater, and the remediation goals that drive thedevelopment and analysis of alternatives.

The VOCs of concern in on-site groundwater at the Melby Roadarea and at the southwest corner of the NPI site are listed below:

• Trichloroethylene• Tetrachloroethylene• 1,1,1-Trichloroethane• 1,1-Dichloroethane• 1,1-Dichloroethylene• 1,2-Dichloroethylene

A summary of the VOC levels detected in the on-site monitoringwell samples is presented in Table 1. Some of these compounds havebeen detected at levels that exceed the Federal MCLs or EnforcementStandards (ES) presented in Table 6.

Groundwater samples were collected in April 1991 and analyzedto determine metals concentrations in areas likely to be pumped forremedial purposes. Table 2 summarizes the on-site groundwatermetals levels. Exceedances of water quality based discharge limitsfor metals were detected at monitoring wells MW-4B, MW-10A and MW-10B. However, this is not expected to affect the discharge togroundwater of treated groundwater in this operable unit. Themetals data from wells MW-14 and MW-15 characterize the metalsconcentrations that can be expected in groundwater recovered at theMelby Road area. Similarly, the metals data from wells MW-4, MW-23and MW-34 are representative of metals concentrations that can beexpected in groundwater recovered at the southwest corner of theproperty. Table 5 presents the most recent metals results fromthese wells and the associated Wisconsin surface water qualitycriteria (chronic toxicity to aquatic life) and water quality basedlimits on discharges to the Chippewa River and Lake Hallie. Based

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on the Table 5 information, it is not anticipated that metals ingroundwater recovered at the NPI site would impact surface waterquality or public health. Therefore, removal of metals from on-site groundwater is not an RAO of the operable unit.

The primary objective of the PFS operable unit is to preventoff-site migration of VOCs from the Melby Road area and thesouthwest corner of the property. The long-term remedial goal isto restore the on-site aquifer to the Wisconsin PALs. However,this aquifer restoration can only be reasonably achieved, if atall, when a groundwater remedy is combined with source control.This issue will be addressed in the Draft FS Report. The aquiferrestoration RAO has been developed in step with the NCP statementthat USEPA expects "that contaminated groundwaters will be returnedto their beneficial uses wherever practicable, within a timeframethat is reasonable given the particular circumstances of the site"(55 FR 8702) .

General Response Actions and Technologies

General response actions and technologies that may beimplemented as part of the operable unit at the NPI site to achievethe RAOs are as follows.

General Response Action Technology

Pumping/CollectionTreatment

Discharge

Extraction WellsPassive Aeration/CascadeAir StrippingSanitary Sewer System/ POTWStorm Sewer SystemDedicated Pipeline toSurface Water

On-Site GroundwaterRecharge

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Groundtfater extraction wells will create a barrier togroundwater flow and, in effect, will capture groundwater thatcurrently migrates off-site from the Melby Road area and thesouthwest corner of the NPI property. Physical barriers (i.e. -slurry walls or sheet pilings) designed solely to containgroundwater flow are not considered in this PFS; they are notimplementable due to the depth to groundwater and aquiferthickness. Conventional treatment technologies that employaeration, via passive aeration or air stripping, are well provenand are effective at removing low concentrations of VOCs fromgroundwater. Therefore, operable unit remedies that employ pumpinggroundwater from the Melby Road area and the southwest corner ofthe site will prevent off-site migration and will facilitatetreatment to reduce VOC levels to.satisfy WPDES requirements forsurface water discharges or to achieve the PALs if treatedgroundwater is returned to the aquifer.

Three pumping tests were performed on MW-14 at the Melby Roadarea during the period of July 16-19, 1991. The initial testconsisted of a step test during which MW-14 was pumped at 30, 60and 90 gpm for 3 hour steps. The step test was followed by a 24-hour constant rate test at 100 gpm at MW-14. The third test wasperformed by pumping MW-14 and MW-15 at 90 gpm each while recordingwater-level measurements in MW-5A, located half-way between MW-14and MW-15. The results of this two well test are most applicableto determine the pumpage required to capture groundwater flow atboth the Melby Road area and at the southwest corner of the NPIsite.

Pumping MW-14 and MW-15 at 90 gpm each for 6 hours resulted ina measured drawdown of 0.15 feet at MW-5A. Drawdown was continuingat the end of the 6 hour period which indicates that cross-gradientcapture of groundwater was accomplished by pumping MW-14 and MW-15at a maximum rate of 90 gpm each duririg the 6-hour test.

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Figure 3 shows the locations of the spent forge compounddisposal trenches and recovery wells MW-14 and MW-15. Pumpage of.these wells will capture all groundwater passing beneath the MelbyRoad site. The capture zone would include the trenches as well asareas to the east and west of the trenches. The area of capturewas simulated using the Capture™ model. Figure 4 shows theCapture™ plot which predicts the zone of groundwater capture afterone year. A discussion of the modelling parameters is presented inan addendum to this report. Figure 4 shows that the width of thecapture zone after one year would be over 800 feet wide. Thepredicted capture zone provides an effective over-design aspect tothe conceptual plan for prevention of off-site migration of VOCs ingroundwater at the Melby Road site.

Figure 4 shows the conceptual design of a two well groundwatercapture system for the southwest corner. Based on the water tablecontour for this area, groundwater flows west, northwest and northfrom the area of MW-34. This flow pattern is consistent with thedowngradient distribution of TCE at off-site monitoring wells MW-15, MW-38, RW-15, MW-23 and RW-2. The capture well locations arebased on the depicted groundwater flow direction from the vicinityof MW-34 and the width of a capture zone demonstrated during thepumping tests at the Melby Road site. The location and actualwidth of the capture zone will be determined during the remedialdesign phase. For example, if the capture zone width needs to beincreased, it may be necessary to install 3 capture wells.However, the total pumpage in the southwest corner would probablyremain at 200 gpm but distributed between three wells instead oftwo. If the Capture™ model predictions (Figure 4) are accurate,a capture zone width of more than 800 feet would also beaccomplished in the southwest corner, assuming similar hydraulicproperties in the aquifer at both locations.

Upon recovery and treatment of groundwater extracted fromwells located at or near the NPI property line at the Melby Road

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area and at the southwest corner, the groundwater can be dischargedin a number of ways. Existing hookups to the City of Eau Clairesanitary sewer and storm sewer systems are located on-site. Thesanitary sewer line connects to the City's Publicly Owned TreatmentWorks (POTW), which is located southwest of the NPI site (underthis alternative, treatment is not required). On-site storm sewersdrain in a southwesterly direction and eventually discharge to theChippewa River. Two additional discharge options, direct pipedischarge to surface water or on-site groundwater recharge are alsoconsidered in this PFS. In discussions regarding the operable unitat the NPI site, the City of Eau Claire has indicated (letter datedJuly 11, 1991 - see Appendix C) that sanitary sewer discharge isnot acceptable, however, discharge of treated groundwater to thestorm sewer system would be acceptable (letter dated August 2, 1991- see Appendix D).

The operable unit alternatives developed in Section III willcombine the technologies listed above as necessary to achieve theRAOs and to comply with the ARARs.

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III. DEVELOPMENT. DESCRIPTION ANDDETAILED ANALYSIS OF ALTERNATIVES

Introduction

The general response actions and applicable technologiesidentified in Section II were combined to form remedialalternatives to achieve the operable unit remedial actionobjectives within the framework of the ARARs.

The remedial alternatives presented in this section wouldprevent off-site contaminant migration and begin to restore theaquifer at the Melby Road area and the southwest corner of the NPIsite.

The revised NCP states that "focusing the development ofalternatives only on those that show promise in achieving the goalsof the Superfund program is a significant means by which theprogram can streamline the process and achieve more rapid cleanup"(55 FR 8714). The Feasibility Study "shall include an alternativescreening step, when needed, to select a reasonable number ofalternatives for detailed analysis" (55 FR 8848). The alternativespresented in this PFS are limited to the most appropriate remediesbased on available site characterization information in order toexpedite implementation of the operable unit. This PFS documentsinformation that supports an operable unit and presents andevaluates a number of potential remedial options.

The detailed descriptions include process design criteria andcertain specifications, flow diagrams, advantages anddisadvantages, personnel and equipment requirements, costestimates, etc. When evaluating alternatives, SARA emphasizes thestatutory preference for permanent solutions and use of treatment

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technologies. SARA also requires that the calculation of cost-effectiveness include the long-term costs (i.e. - operating andmaintenance costs) associated with the alternatives.

USEPA incorporated the SARA 121(b) criteria into nineevaluation criteria presented in the NCP (Part 300.430) and asrequired, each operable unit remedial alternative is assessedagainst these criteria in this section. The nine NCP evaluationcriteria are summarized below.

Overall Protection of Human Health and the Environment — Thedegree to which unacceptable site risks posed through exposure tothe contaminants are eliminated, reduced or controlled by theremedial alternative.

• Compliance with ARARs — Whether requirements that areapplicable or relevant and appropriate to a given alternative aresatisfied by the alternative or whether there is sufficientjustification for a waiver.

Lona-Term Effectiveness and Permanence — The magnitude of riskremaining after remedial activities are complete. Potential risksrelate to untreated or residual contaminants and the ability ofcontrols to provide sufficient protection from hazardous residuals.

Reduction of Toxicitv. Mobility or Volume Through Treatment —The ability of the alternative to reduce threats at a site bydestroying toxic contaminants, reducing the total mass ofcontaminants, reducing the volume of toxic contaminants, and/orreducing contaminant mobility. This operable unit does not addressreduction of toxicity, mobility or volume. Because this interimaction does not constitute the final remedy for the NPI site, thestatutory preference for a remedy that employs treatment to reducetoxicity, mobility or volume as a principal element will beaddressed by the final response action.

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Short-Term Effectiveness - Health and environmental impactsduring implementation including the need to protect the communityand workers during the remedial action, environmental impactsduring implementation and the time required to achieve the remedialaction objectives.

Implementability — The technical and administrativefeasibility of implementing an alternative including thereliability of the technology, technical difficulties encounteredin construction and operation of the technology, and the ease ofimplementing additional remedial actions that might be necessary inthe future.

Cost — The capital cost, annual operation and maintenance costand present worth of the alternative. Capital costs includeexpenditures for the equipment, labor, materials, transportationand disposal necessary to implement the remedial actions, as wellas expenditures for engineering, legal, financial and othernecessary services. Annual operation and maintenance (O&M) costsare required to ensure the continued effectiveness of a remedialaction and include maintenance, materials, labor, disposal andenergy costs, insurance, taxes, licensing and administrative costs.The present worth analysis discounts all future cost streams to acommon year, usually the current year. The NCP recommends using adiscount rate of ten percent (40 CFR 300, 55 FR 8722) before taxesand after inflation in the analysis of present worth with a plannedremedial lifetime for costing purposes not to exceed 30 years. TheRI/FS guidance document (USEPA, October 1988) recommends that afive percent discount rate be used to determine present worth.This PFS presents estimated remedial alternative costs as ranges(present worth calculated at 10% to present worth calculated at 5%)to reflect the NCP and RI/FS guidance recommendations.

State Acceptance — The technical and administrative concernsthe State may have regarding the alternative.

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Community Acceptance — Public concerns regarding thealternatives.

The State and Community Acceptance criteria will be addressedby USEPA after the PFS report and proposed operable unitremediation plan have been reviewed by the public. USEPA willsolicit public comments on the PFS Report in accordance with therevised NCP (55 FR 8730), which states: "CERCLA calls formeaningful state and community involvement in selecting theremedial action . . . USEPA notes, however, that information onstate and community acceptance generally will not be complete untilcomments are received on the proposed plan. Once all comments areevaluated, state and community acceptance may prompt modificationsto the preferred remedy and are thus designated modifyingcriteria."

Five remedial alternatives that may be implemented are listedbelow and are described and evaluated in this section. Allalternatives, except the No Action alternative, would pumpgroundwater from the Melby Road area and the southwest corner anddischarge the recovered groundwater with or without treatment.

1. No Action2. Pump, Discharge to Sanitary Sewer3a. Pump, Cascade Aeration, Discharge to Storm Sewer3b. Pump, Air Stripping, Discharge to Storm Sewer4a. Pump, Cascade Aeration, Direct Discharge to Surface Water4b. Pump, Air Stripping, Direct Discharge to Surface Water5. Pump, Air Stripping, On-site Recharge

Alternative 1: No Action

The purpose of the No Action alternative is to provide abaseline against which other remedial alternatives can be compared.

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Description

The NCP requires that a No Action alternative be consideredwhen evaluating remedial alternatives. The No Action alternativewould be limited to long-term groundwater monitoring which will bedeveloped in detail as part of the FS for the NPI site.

Assessment

Overall Protection of Human Health and the Environment - TheNo Action alternative would not achieve the RAOs developed in thisPFS. The off-site migration of VOCs in groundwater from the MelbyRoad area and the southwest corner of the property would not beprevented.

Compliance with ARARs - The No Action alternative would relyon natural attenuation to achieve the groundwater remedial goals.This alternative would not comply with ARARs.

Lono-Term Effectiveness and Performance - The No Actionalternative would not prevent off-site migration of VOCs from theMelby Road area or the southwest corner of the property.

Short-Term Effectiveness - This alternative would provide noshort term effectiveness.

Implementability - This alternative is readily implementable.

Cost - There would be no capital or O&M costs for thisalternative.

Alternative 2: Pump and Discharge to Sanitary Sewer

This alternative would pump groundwater from the Melby Roadarea and the southwest corner to prevent off-site contaminant

23


migration and to reduce the levels of VOCs in the grouhdwater. Theproposed pumping locations and rationale for selecting theselocations is presented in Section II (General Response Actions andTechnologies). Recovered groundwater would be discharged directlyto existing sanitary sewers on-site. Based on available samplingdata from representative wells, contaminant concentrations inuntreated groundwater recovered at the NPI site would be below theCity of Eau Claire POTW pretreatment standards (see Table 3).

Description

Groundwater would be pumped from two wells along the northernproperty line at the Melby Road area and from wells to beconstructed at the southwest corner. Two recovery wells, MW-14 andMW-15 (see Figure 3), at the Melby Road area are constructed of 5-inch diameter carbon steel with 40 feet of screen installed fromthe water table to the top of the bedrock formation. The wells areequipped with submersible pumps and each would be pumped at a rateof approximately 100 GPM. Preliminary calculations predict thatthese two wells pumping at a combined rate of 200 GPM will preventoff-site migration of contaminated groundwater from the Melby Roadarea. More accurate pumping rates will be determined based onaquifer tests that will be completed prior to the detailed remedialdesign phase. Groundwater recovered by capture wells MW-14 and MW-15 would be pumped approximately 1,000 feet to a manhole on-sitewhere the discharge pipe can be connected to an 8-inch sanitarysewer line.

Two recovery wells would be installed at the southwest cornerat the approximate locations shown in Figure 5. The actual numberand locations of these wells will be determined during the remedialdesign phase. These wells would be constructed of 8-inch carbonsteel screened from the water table to the bedrock. The pumpingrates for these wells would be approximately 100 GPM each.Groundwater recovered at the southwest corner would be pumped

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approximately 600 feet where the discharge would be connected to a15-inch sanitary sewer line on-site. The locations of the recoverywells and piping for this alternative are shown in Drawing No. 2.

Groundwater recovered at the NPI site would be discharged tothe sanitary sewers without treatment because the contaminantconcentrations are below the Eau Claire POTW pretreatment standardspresented in Table 3.

Groundwater samples will be taken from several wells in thevicinity of both the Melby Road area and the southwest corner ofthe NPI site during the operable unit design phase. These sampleswill be analyzed for TCL/TAL compounds to determine if any non-VOCcompounds (i.e. - PAHs or metals) would be a concern in groundwaterrecovered by the on-site operable unit.

After start-up, a groundwater monitoring program will beinitiated to evaluate the effectiveness of this remedial action.Existing monitoring wells MW-5A, MW-5B, MW-6, MW-9A and MW-9B willmonitor groundwater at the Melby Road area. Groundwater at thesouthwest corner will be monitored by wells MW-23A, MW-23B, and twoadditional wells that will be installed during construction of thisremedial action. Monitoring well locations will be refined duringdesign and additional monitoring wells may be provided, ifnecessary. For the first two sampling rounds, groundwater will bemonitored for all TCL/TAL compounds. After this, these wells willbe monitored for trichloroethylene, tetrachloroethylene, 1,1,1-trichloroethane, 1,1-dichloroethane, l,1-dichloroethylene and 1,2-dichloroethylene, and any additional parameters determined to benecessary during the des ign phase sampling and the f irst twosampling rounds. Water table levels will also be measured in thesemonitoring wells to confirm the ability of the operable unit toprevent off-site groundwater migration.

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*

Groundwater monitoring will be conducted quarterly for thefirst year. Pumping rates may be adjusted during this "start-up"performance. After overall system performance has been accuratelydetermined, monitoring will be conducted semi-annually. Themonitoring program proposed for Alternative 2, and each of theremaining alternatives considered in this PFS, is the basis forestimating costs for the respective alternatives. The finalmonitoring program, including number of monitoring points, samplingfrequency and analytical parameters will be approved by USEPA aspart of the remedial design.

As recommended in USEPA's "Guidance on Remedial Actions forContaminated Groundwater at Superfund Sites", an extensiveperformance evaluation will be conducted every five years. Theseevaluations will be used to determine whether remedial goals havebeen or can be achieved. If the performance evaluation indicatesthe remedial alternative is not progressing towards the remedialgoals, the following options will be considered:

• Discontinue operation.

• Modify the RAOs and continue remediation, if appropriate.

• Upgrade or replace the remedial action to achieve theoriginal RAOs or modified RAOs.

Groundwater discharged to the sanitary sewer system would bemonitored to verify that the POTW pretreatment standards are met.This monitoring will be conducted quarterly for the first yearduring start-up and semi-annually thereafter.

Assessment

Overall Protection of Human Health and the Environment - Thisalternative would achieve the operable unit RAOs established in

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this PFS. Pumping wells MW-14 and MW-15 would recover groundwateralong the width of the Melby Road area and prevent off-sitemigration of contaminants at this location. Similarly, pumpingwells located at the southwest corner would recover groundwater toprevent off-site migration of contaminants.

This alternative would reduce the" VOC levels in the extractedgroundwater due to treatment at the City of Eau Claire POTW.Information published by USEPA indicates that POTWs have achievedPCE removals of approximately 96% (source: Fate of PriorityPollutants in Publicly Owned Treatment Works, 1982) and TCA and TCEremovals of >98% and >94%, respectively (source: DevelopmentDocument for Effluent Limitations, Guidelines and Standards for theOrganic Chemicals, Plastics and - Synthetic Fibers Point SourceCategory, 1987). Continued implementation of this alternativewould achieve the PALs in groundwater at the NPI site or theminimum level technically and economically feasible over time. TheDraft FS Report will address source control and the remedialtimeframes predicted by groundwater modeling.

This alternative would improve off-site groundwater qualitysince contaminants would be prevented from migrating off-site fromthe areas addressed by this operable unit. This issue will beaddressed in detail in the Draft FS Report.

Compliance with ARARs - This alternative would comply with allARARs. Groundwater recovered on-site contains contaminants atlevels below the POTW pretreatment standards, thus groundwatertreatment prior to sanitary sewer discharge is not necessary. NPIwould comply with WPDES permit requirements to discharge theextracted groundwater to the sanitary sewer on-site.

Lona-Term Effectiveness and Permanence - Periodic review ofdata generated from the groundwater monitoring well network wouldbe evaluated to determine the effectiveness of the monitoring well

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network and the groundwater recovery system. Changes will be madeto ensure the effectiveness of the remedy, if needed. Thegroundwater monitoring program would reliably track the reductionof VOC concentrations in on-site groundwater in relationship toachieving the remedial goal.

Pursuant to USEPA guidance, an extensive review of operableunit performance would be conducted after 5 years of operation todetermine this alternative's effectiveness in achieving the RAOs.

If the data suggests that the remedial action has beeneffective in reducing the concentration of a contaminant, but thata PAL does not appear to be achievable, an alternativeconcentration limit (ACL) may be- issued. If the data gatheredshows that a remedial action has been ineffective or that furthercleanup is possible, additional remedial actions may be required.(WDNR letter to USEPA, March 7, 1991).

Short-Term Effectiveness - The recovered untreated groundwaterwould meet the POTW pretreatment standards and this would beverified by short-term monitoring.

On-site workers responsible for installing, operating andmaintaining the groundwater recovery system could be exposed toVOCs (i.e. - via inhalation) and any risks would be controlled bythe Health and Safety Plan. The approximate remedial timeframerequired to reduce VOC levels in groundwater to the PALs or to thelowest level technically and economically feasible will bedetermined through modeling to be presented in the Draft FS Report.

Implementabilitv - This alternative is technically feasibleand could be implemented with little difficulty since connectionsto the City sanitary sewer system exist on-site. However, the Cityof Eau Claire has indicated it will not allow NPI to dischargeextracted groundwater to the sanitary sewer system. In a letter

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dated July 11, 1991 (see Appendix C), the City indicated that NPIgroundwater discharge to the sanitary sewer/POTW system during fullscale remedial operation is not acceptable. Clearly, thisadministrative issue is a significant constraint on theimplementability of this alternative.

Cost - The estimated capital cost of this alternative is$164,000. The estimated annual O&M cost of this alternative is$73,000. The present worth of the annual O&M cost ranges from$761,000 to $1,191,000 (based on 30 year timeframe and discountrates of 10% and 5%, respectively).

The total estimated cost of this alternative ranges from$925,000 to $1,355,000 (based on 10% and 5% discount rate,respectively). Tables 7 and 8 present the cost assumptions andcalculations.

Alternative 3: Pump. Aerate, and Discharge to storm Sewer

This alternative would recover groundwater at the Melby Roadarea and the southwest corner to prevent off-site contaminantmigration and to restore on-site groundwater. The proposed pumpinglocations and the rationale for selecting these locations ispresented in Section II (General Response Actions andTechnologies). The levels of VOCs in the recovered groundwaterwill be significantly lower than the WDNR surface water criteria,as discussed in Section II. However, in accordance with WisconsinStatutes, Section 147.04 (2)(b) and Section 301(b)(2) of the CleanWater Act, the ground water will be pumped and treated to reduceVOC levels by passive aeration, alternative 3a, or air stripping,alternative 3b, prior to discharge. This treated groundwater wouldthen be discharged to on-site storm sewers which discharge to theChippewa River.

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On-site groundwater metals concentrations are below MCLsexcept for exceedances measured at MW-4B, MW-lOA and MW-lOB. Theseexceedances are not expected to be found in the pumpage due todilution, however, additional sampling during the design phase andthe first two quarters after start-up will verify the metalsconcentrations in the pumping wells and determine the need for anyadditional pretreatment of extracted groundwater.

Alternative 3a

Description

Groundwater would be pumped from recovery wells as describedin Alternative 2. The two wells - located at the Melby Road area(see Figure 3) would pump a combined flow rate of 200 GPH. Therecovered groundwater would be pumped approximately 1500 feet to acascade-type passive aeration unit located on-site (shown in Figure6) to reduce VOC concentrations by approximately 50% during thesummer months (see Appendix E for calculations). During the winterthe removal efficiency of the cascade will drop to approximately40%. The cascade will be partially above grade and although someicing can be expected, the groundwater which will be 55°F, will beonly briefly exposed to freezing temperatures, and will not freezesolid. All piping, including the storm sewer, will be locatedbelow the frost line, which is approximately 4 feet below grade.Following cascade aeration, the treated groundwater will bedischarged on-site to an existing 12-inch concrete storm sewerlocated south of Building 135 which conveys storm water southwestto the corner of Hallie Lane and Locust Lane and eventually to theChippewa River. Some on-site sewer retrofitting will be necessaryto clear the storm sewer lines, which have been blocked off and/orredirected in several locations.

Two wells located at the southwest corner (see Figure 5) wouldpump a combined flow rate of approximately 200 GPM. This recovered

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groundwater would be pumped approximately 600 feet to a second on-site cascade aeration unit and then discharged on-site to a 24-inchstorm sewer 400 feet from the corner of Hallie Lane and LocustLane. This water also eventually discharges to the Chippewa River.The piping layout for this alternative is shown in Drawing No. 3.

Groundwater monitoring would be conducted, as described inAlternative 2, to determine the effectiveness of this alternativein achieving the operable unit remedial action objectives. Theactual number and location of monitoring wells will be refinedduring design. It is assumed that monitoring wells MW-5A, MW-5B,MW-6, MW-9A, MW-9B, MW-23A, MW-23B, and two additional wells to beinstalled at the southwest corner would be monitored quarterly forthe first year during start-up, and semi-annually thereafter.Performance evaluations would be conducted every five years todetermine the nature and extent of additional remedial efforts, ifnecessary, as described in Alternative 2.

Effluent sampling would be conducted in addition togroundwater monitoring to monitor compliance with WPDES permitrequirements. Treated groundwater would be discharged to theChippewa River via on-site storm sewers. The discharge would besampled and analyzed for trichlorethylene, tetrachloroethylene,1,1,1-trichloroethane, 1,1-dichloroethane, 1,1-dichloroethene, and1,2-dichloroethene, and any additional parameters determined to benecessary during design phase sampling. Samples would be takenweekly for the first four weeks, every two weeks after the firstmonth, monthly after three months, and quarterly after one year.

Alternative 3b

Description

Under this alternative, groundwater would be recovered,treated in an on-site air stripping tower, and discharged to the

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on-site storm sewer system. The groundwater would be pumped fromrecovery wells as described in Alternatives 2 and 3a. The proposedrecovery well locations are shown in Figures 3 and 5. Airstripping would reduce VOC levels in the recovered groundwaterprior to storm sewer discharge.

The Melby Road area and the southwest corner recovery wellsare 5,000 feet apart and two options exist for treatment anddischarge. The first option is to employ two air strippers, one atthe Melby Road area and one at the southwest corner, and theeffluent from each stripper would be discharged to the nearest on-site storm sewer. The second option is to pump the groundwaterrecovered at the Melby Road area approximately 5,000 feet to thesouthwest corner where one air stripper would treat the combinedflow (approximately 400 gpm) prior to discharge to the nearest on-site storm sewer. Employing one air stripper would be more cost-effective. The capital cost of a second air stripper, combinedwith additional operating and maintenance costs would be at leasttwice the cost of a single, larger air stripper and the cost toinstall approximately 3500 feet of associated piping, which wouldbe required for the single stripper option. The piping layout forthis alternative is shown in Drawing No. 4.

Groundwater and effluent discharge monitoring would beconducted as described in Alternatives 2 and 3 a to determinewhether remedial action objectives are being met and to satisfyWPDES requirements.

Assessment

Overall Protection of Human Health and the Environment - Thisalternative would achieve the operable unit RAOs established inthis PFS. Pumping wells MW-14 and MW-15 would recover groundwateralong the width of the Melby Road area and prevent of f-sitemigration of contaminants at this location. Similarly, pumping

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wells located at the southwest corner of the site would recovergroundwater to prevent off-site migration of contaminants.

This alternative would reduce the extracted groundwater VOCconcentrations either by cascade aeration (alternative 3a) or airstripping (alternative 3b). These treatment options are equallyprotective of human health and the environment. VOC concentrationswould be reduced initially due to dilution during pumping, aspumpage from the recovery wells is combined. Then, on-sitetreatment of the extracted groundwater (either cascade or airstripping) would further reduce VOC levels before groundwater isdischarged to the storm sewer and conveyed off-site to the ChippewaRiver. Therefore, leaks of treated groundwater from the stormsewers, if any, are expected to be minor and of no significance.

The Draft FS Report will address source control and theremedial timeframes predicted by groundwater modeling.


Compliance with ARARs - This alternative (3a and 3b) wouldcomply with all ARARs. NPI would comply with WPDES permitrequirements to discharge the recovered groundwater to the on-sitestorm sewers after cascade aeration or air stripping. Treatment ofall groundwater discharges to surface water is required, even ifuntreated groundwater VOC concentrations meet water quality-basedlevels. WDNR has determined that cascade aeration prior to stormsewer discharge would satisfy its requirement for treatment. Bothsubalternatives 3a (cascade) and 3b (air stripping) would complywith the WPDES permit requirements. VOC emissions from an on-siteair stripper or cascade aeration system would be minimal (less than

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3.4 pounds per day) and emission controls would not be required foreither treatment option.

Lona-Term Effectiveness and Permanence - Periodic review ofdata generated from the groundwater monitoring well network wouldbe evaluated to determine the effectiveness of the monitoring wellnetwork and the groundwater recovery system. Changes would be madeto ensure the effectiveness of the remedy, if needed. Thegroundwater monitoring program would reliably track the reductionof VOC concentrations in on-site groundwater in relationship toachieving the remedial goal.


If the data suggests that the remedial action has beeneffective in reducing the concentration of a contaminant, but thata PAL does not appear to be achievable, an alternativeconcentration limit (ACL) may be issued. If the data gatheredshows that a remedial action has been ineffective or that furthercleanup is possible, additional remedial actions may be required.(WDNR letter to USEPA, March 7, 1991).

Short-Term Effectiveness - Implementation of this alternative(3a or 3b) would not pose risks to the community. There would beno significant change in the quality of the Chippewa River as aresult of groundwater discharge from the NPI s ite. Treatmenteither by cascade aeration (alternative 3a) or air stripping(alternative 3b) would effectively reduce VOC levels in thegroundwater recovered on-site that is discharged to the City stormsewer system. VOC emissions from either treatment option would beminimal, would not require emission controls and would not posehealth risks to area residents.

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On-site workers responsible for installing, operating andmaintaining the groundwater recovery and treatment system could beexposed to VOCs (i.e. - via inhalation) and any risks would becontrolled by the Health and Safety Plan. The approximate remedialtimeframe required to reduce VOC levels in groundwater to the PALsor to the lowest level technically and economically feasible willbe determined through modeling to be presented in the Draft FSReport.

Implementabilitv - Wells MW-14 and MW-15 at the Melby Roadarea are equipped with pumps to recover groundwater at thislocation. Extraction wells can be installed at the southwestcorner of the property with little difficulty. The City of EauClaire has indicated that it will allow recovered groundwater to bedischarged to the city storm sewer (see August 2, 1991 letterpresented in Appendix D). The groundwater extraction wells wouldbe equipped with shut-off devices to stop discharge during stormevents of a magnitude to be determined during the design phase.Eau Claire indicated that it would probably be necessary to shutdown the system only a few days per year. This alternative' seffectiveness in preventing off-site contaminant migration wouldnot be impacted by ceasing groundwater recovery for several daysseveral times per year, as may be necessary to avoid storm seweroverload. The on-site storm sewer lines would be cleared andrerouted at some locations in order to implement this alternative.

The cascade aeration systems shown on Figure 6 can beconstructed on-site with materials and labor available from localcontractors. The alternative 3a cascade system would requireminimal maintenance. The length of piping required to conveygroundwater to the on-site storm sewers (approximately 2100 feet)can be minimized by installing a cascade aeration system at thestorm sewers closest to the two groundwater recovery locations.

Implementation of the air stripper alternative (3b) wouldrequire much more operator attention, maintenance and piping

35


(approximately 5000 feet) than the cascade treatment option.Installation of the piping and air stripper equipment and start-upof the system would require a longer lead time than the cascadesystem.

Cost, Alternative 3a - The estimated capital cost of thisalternative is $215,000. The estimated annual O&M cost of thisalternative is $80,000. The present worth of the annual O&M costranges from $828,000 to $1,300,000 (based on 30 year timeframe anddiscount rates of 10% and 5%, respectively).

The total estimated cost of this alternative ranges from$1,043,000 to $1,515,000 (based on 10% and 5% discount rate,respectively). Tables 9 and 10 present the cost assumptions andcalculations.

Cost. Alternative 3b - The estimated capital cost of thisalternative is $305,000. The estimated annual O&M cost of thisalternative is $100,000. The present worth of the annual O&M costranges from $1,019,000 to $1,608,000 (based on 30 year timeframeand discount rates of 10% and 5%, respectively).


Alternative 4: Pump. Aerate. Direct Discharge to Surface Water

This alternative would recover groundwater at the Melby Roadarea and the southwest corner to prevent off-site contaminantmigration and to reduce the levels of VOCs in the groundwater. Theproposed pumping locations and the rationale for selecting theselocations is presented in Section II (General Response Actions andTechnologies). The recovered groundwater would be pumped througha new dedicated pipe installed to discharge to surface water. The

36


water would be treated for VOCs by passive aeration (alternative4a) or air stripping (alternative 4b) prior to discharge. On-site.groundwater metals concentrations are below MCLs except forisolated exceedances measured at MW-4B, MW-10A and MW-10B. Theseexceedances are not expected to be found in the pumpage due todilution, however, additional sampling during the design phase andthe first two quarters after start-up will verify the metalsconcentrations in the pumping wells and determine the need for anyadditional pretreatment of extracted groundwater.

For the purpose of the PFS, it is assumed that this operableunit would discharge treated groundwater to Lake Hallie because theLake is the most accessible area for discharge. Treatedgroundwater could also be discharged directly to the Chippewa Rivereither to the west or to the north of the NPI site. However,constructing a pipeline to the west is impractical because it wouldrequire over three miles of piping through residentialneighborhoods, and constructing a pipeline to discharge to thenorth would require approximately twice as much piping thandischarging into Lake Hallie.

Direct discharge to the Chippewa River is a contingent optionthat can be evaluated in detail during design if discharge to LakeHallie is not feasible.

Alternative 4a

Description

Groundwater would be pumped from the recovery wells describedin Alternative 2 and shown in Figures 3 and 5. The groundwaterrecovered from the southwest corner would be pumped approximately5,000 feet to the Melby Road area. The recovered groundwater fromall wells would then be pumped approximately 5500 feet through adedicated 6-inch pressure line to Lake Hallie.

37


The recovered groundwater would be treated on-site using acascade-type aerator as described in Alternative 3a and shown inFigure 6. A pump station would be installed to pump the waterapproximately 5500 feet from the cascade to the Lake. There isapproximately a 100-foot drop to the Lake at the proposed pipeoutfall location. Thus, it is likely that the discharge pipe wouldextend down the steep banks and into the water to avoid erosionthat would occur if the outfall was 100 feet above the shoreline.This issue would be addressed during design.

The dedicated pipeline would be installed through lands ownedby the City of Eau Claire and the Town of Hallie, as well asprivately owned properties. Easements would be obtained and/orland would be purchased to install-the pipeline. In addition, theLake Hallie shoreline is privately owned at the proposed outfalllocation, therefore it would also be necessary to obtain rights tothe shoreline.

The pipeline to Lake Hallie would have to cross a railroad,Highway 53, and several smaller roads. The railroad and highwaycrossings would need to be bored and jacked. The piping layout forthis alternative is shown in Drawing No. 5.

Groundwater and effluent discharge monitoring would beconducted as described in Alternatives 2 and 3 to determine whetherremedial action objectives are being met and to monitor compliancewith WPDES permit requirements.

Alternative 4b

Description

Groundwater would be recovered, treated in an on-site airstripper and discharged directly to Lake Hallie through thededicated pipe described under alternative 4a. The groundwater

38

eder associates consulting engineers, p.e,

would be pumped from recovery wells as described in Alternatives 2and 3. The groundwater recovered at the southwest corner would bepumped approximately 5,000 feet to the Melby Road area as describedin Alternative 4a. The combined flow from all wells would betreated in an on-site air stripper, then pumped through a dedicatedpipe and discharged to Lake Hallie. The piping layout for thisalternative is shown in Drawing No. 6. Locating the air stripperon-site would require installation of a pump station to convey thetreated water to the Lake, however, an off-site air stripper wouldrequire significantly more security. Therefore, the air stripperwill be located on-site.

Groundwater and effluent discharge monitoring would beconducted as described in Alternatives 2 and 3 to determine whetherthe remedial action objectives are being met and to monitorcompliance with WPDES permit requirements.

Assessment

Overall Protection of Human Health and the Environment - Thisalternative would achieve the operable unit RAOs established inthis PFS. Pumping wells MW-14 and MW-15 would recover groundwateralong the width of the Melby Road area and prevent of f-sitemigration of contaminants at this location. Similarly, pumpingwells located at the southwest corner of the site would recovergroundwater to prevent off-site migration of contaminants.

This alternative would reduce the extracted groundwater VOCconcentrations either by cascade aeration (alternative 4a) or airstripping (alternative 4b). VOC concentrations would be reducedinitially due to dilution during pumping, as pumpage from therecovery wells is combined. Then, on-site treatment of theextracted groundwater (either cascade or air stripping) wouldfurther reduce VOC levels before groundwater is discharged to thepipeline and conveyed off-site to Lake Hallie. Therefore, leaksfrom this dedicated pipeline, if any, are expected to be minor andof no significance. The Draft FS Report will address source

39


control and the remedial timeframes predicted by groundwatermodeling.

This alternative would improve off-site groundwater qualitysince contaminated groundwater would be prevented from migratingoff-site from the areas addressed by this operable unit. Thisissue will be addressed in detail in the Draft FS Report.

Compliance with ARARs - This alternative (4a and 4b) wouldcomply with all ARARs. The untreated groundwater would notsignificantly change surface water quality, however, NPI wouldcomply with WPDES permit requirements to discharge the recoveredgroundwater to Lake HaHie via dedicated pipeline after on-sitecascade aeration or on-site air stripping. WDNR has determinedthat cascade aeration prior to surface water discharge wouldsatisfy its requirement for treatment of VOCs. Bothsubalternatives 4a (cascade) and 4b (air stripping) would complywith the WPDES permit requirements. VOC emissions from an on-siteair stripper or cascade aeration system would be minimal (less than3.4 pounds per day) and emission controls would not be necessaryfor either treatment option.

Long-Term Effectiveness and Permanence - Periodic review ofdata generated from the groundwater monitoring well network wouldbe evaluated to determine the effectiveness of the monitoring wellnetwork and the groundwater recovery system. Changes would be madeto ensure the effectiveness of the remedy, if needed. Thegroundwater monitoring program would reliably track the reductionof VOC concentrations in on-site groundwater in relationship toachieving the remedial goal.


40


If th£ data suggests that the remedial action has beeneffective in reducing the concentration of a contaminant, but thata PAL does not appear to be achievable, an alternativeconcentration limit (ACL) may be issued. If the data gatheredshows that a remedial action has been ineffective or that furthercleanup is possible, additional remedial actions may be required.(WDNR letter to USEPA, March 7, 1991).

Short-Term Effectiveness - Implementation of this alternative(4a or 4b) would not pose health risks to the community, however,area residents may be inconvenienced and exposed to noise and dustduring installation of the dedicated pipeline from the NPI site toLake Hallie. Surface water quality of Lake Hallie (and theChippewa River downstream of the Lake) would not be significantlychanged by groundwater discharge from the NPI site. Treatmenteither by cascade aeration (alternative 4a) or air stripping(alternative 4b) would effectively reduce VOC levels in thegroundwater recovered on-site that is discharged to Lake Halliethrough the dedicated pipeline from the NPI site. VOC emissionsfrom either treatment option would be minimal, would not requireemission controls and would not pose health risks to arearesidents.

On-site workers responsible for installing, operating andmaintaining the groundwater recovery and treatment system could beexposed to VOCs (i.e. - via inhalation) and any risks would becontrolled by the Health and Safety Plan. The approximate remedialtimeframe required to reduce VOC levels in groundwater to the PALsor to the lowest level technically and economically feasible willbe determined through modeling to be presented in the Draft FSReport.

Implementabilitv - Wells MW-14 and MW-15 at the Melby Roadarea are equipped with pumps to recover groundwater at this

41


location. Extraction wells can be installed at the southwestcorner of the property with little difficulty.

The on-site cascade system can be constructed with materialsand labor available from local contractors. The alternative 4acascade system would require minimal maintenance, whereas thealternative 4b on-site air stripper would require considerablygreater attention. Both alternatives 4a and 4b require the samelength of piping, totalling approximately 2 miles on-site and off-site.

Opposition to construction of the off-site pipeline throughportions of Eau Claire and the Town of Hallie may occur. Inaddition, technical constraints may be associated with installationof the dedicated pipeline, which would cross a railroad, a highwayand several local roads, and thus require boring and jacking.

Construction of a dedicated/pipeline through portions of theTown of Hallie and the City of Eau Claire would require cooperationfrom many different parties including the State of Wisconsin,Chippewa County, the Town of Hallie, the City of Eau Claire,private land owners and any utilities that have easements along theproposed path of the pipeline. In addition, the land along theLake Hallie shoreline at the proposed outfall location is privatelyowned and it would be necessary to obtain rights to or to purchasethis property.

Acquiring property rights and permission from the appropriateauthorities and private land owners, as well as the riparian rightsfor Lake Hallie could be a lengthy process. Negotiating propertyrights and access to easements could take several years and coulddouble or triple the cost of this alternative.

Cost. Alternative 4a - The estimated capital cost of thisalternative is $473,000. The estimated annual O&M cost of this

42


alternative is $117,000. The present worth of the annual O&M costranges from $1,180,000 to $1,870,000 (based on 30 year timeframeand discount rates of 10% and 5%, respectively).


Cost. Alternative 4b - The estimated capital cost of thisalternative is $538,000. The estimated annual O&M cost of thisalternative is $130,000. The present worth of the annual O&M costranges from $1,303,000 to $2,070,000 (based on 30 year timeframeand discount rates of 10% and 5%, respectively).


Alternative 5: Pump, Air Stripping. On-Site Recharge

This alternative would recover groundwater at the Melby Roadarea and the southwest corner to prevent off-site contaminantmigration and to reduce the levels of VOCs in on-site groundwater.The proposed pumping locations and the rationale for selectingthese locations is presented in Section II (General ResponseActions and Technologies). The recovered groundwater would bedischarged on-site to Lagoons 3 and/or 4 or an alternate on-sitelocation which would be used as recharge basins. Concentrations ofVOCs in the groundwater would be reduced to satisfy the WPDESpermit requirements for groundwater recharge. Therefore, it wouldbe necessary to treat the groundwater by air stripping to achieveapproximately 99% VOC removals before on-site recharge.

43


On-site groundwater metals concentrations are below MCLsexcept for isolated exceedances measured at MW-4B, MW-lOA and MW-10B. These exceedances are not expected to be found in the pumpagedue to dilution, however, additional sampling during the designphase and the first two quarters after start-up will verify themetals concentrations in the pumping wells and determine the needfor any additional pretreatment of extracted groundwater.

Description

Groundwater would be pumped from recovery wells at the MelbyRoad area and at the southwest corner, as described in Alternative2 and shown in Figures 3 and 5. The groundwater recovered from thesouthwest corner and Melby Road area would be pumped to Lagoons 3and/or 4. An air stripping tower located at this area would reducethe levels of VOCs in the groundwater to the PALs or non-detectablelevels (using analytical methods specified by USEPA in consultationwith WDNR) prior to discharge to Lagoons 3 and/or 4.

Groundwater pumped from recovery wells at the Melby Road areaand the southwest corner could be discharged to existing Lagoons 3and 4, which were part or the original wastewater handling systemat the NPI site. These lagoons were used to recharge water allyear long; when the lagoons were covered with ice during thewinter, water was pumped into the lagoons under the ice layer. Thebottoms of Lagoons 3 and 4 consist of clean sand with no residualdeposits from previous use. These lagoons are located over 1,000feet upgradient of the Melby Road area and 2,000 feet sidegradientof the nearest on-site source areas. Any mounding of the watertable is not likely to extend far enough to affect contaminatedgroundwater at the NPI site. The piping layout for thisalternative is shown in Drawing No. 7.

The hydrogeologic conditions at Lagoons 3 and 4 are favorablefor groundwater recharge. Based on estimates of soil permeability

44


in the U.S. Geological Survey Report - Water Resources, Wisconsin,Chippewa River Basin, the soil permeabi1ity in the Eau Claireoutwash deposits ranges from 5 to 10 inches per hour. The rechargerate at 5 inches per hour could handle 8.5 million gallons per day(mgd) in the 3 acres of either Lagoon 3 or 4. The proposed capturewell system would produce approximately 0.58 mgd (400 gpm) ,allowing an order of magnitude safety margin for design purposes.The presence of the second lagoon would allow alternation ofrecharge areas if soil clogging occurred. The groundwater pumpedduring the July 1991 pumping test was clear with little evidence ofturbidity.

The water table at Lagoons 3 and 4 is located in the sandstonebedrock. Based on available logs, 20 to 40 feet of sand and gravelunderlies these lagoons. Infiltrating water would migrate downwardto the bedrock surface and then move along the northward slopingbedrock surface. The point at which this water would enter thesand and gravel aquifer would be about 100 feet north of Lagoon 4.The net changes in the water table due to artificial recharge atthe lagoons would be determined by water level measurements indowngradient monitoring wells MW-18 and MW-16A, B.

There would be no apparent impact on on-site groundwater flowpatterns or source areas. This conclusion is based on the distanceof Lagoons 3 and 4 from the source areas and the high permeabilityof the sand and gravel formation which would minimize water tablemounding and resulting changes in groundwater flow directions.

Groundwater and e f fluent d i scharge mon itor ing would beconducted as described in Alternatives 2 and 3 to determine whetherthe remedial action objectives are being met and to monitorcompliance with WPDES permit requirements.

45


Assessment

Overall Protection of Human Health and the Environment - Thisalternative would achieve the operable unit RAOs established inthis PFS. Pumping wells MW-14 and MW-15 would recover groundwateralong the width of the Melby Road area and prevent off-sitemigration of contaminated groundwater at this location. Similarly,pumping wells located at the southwest corner would recovergroundwater to prevent off-site migration of contaminatedgroundwater.

This alternative would reduce the extracted groundwater VOCconcentrations to the PALs or non-detectable levels (usinganalytical methods specified and approved by USEPA in consultationwith WDNR) by air stripping in conjunction with source control.The Draft FS Report will address source control and the remedialtimeframes predicted by groundwater modeling.


Compliance with ARARs - This alternative would comply withall ARARs. NPI would comply with WPDES permit requirements todischarge the recovered groundwater to on-site recharge basins(Lagoons 3 and/or 4) after on-site air stripping. NPI would complywith the WPDES permit requirement by air stripping to achieve thePALs in groundwater or to report VOC levels below the standarddetection limit of the analytical method specified and approved byUSEPA in consultation with WDNR. VOC emissions from an on-site airstripper would be minimal (less than 3.4 pounds per day) andemission controls are not necessary.

46


Lona-Term Effectiveness and Permanence - Periodic review ofdata generated from the groundwater monitoring well network wouldbe evaluated to determine the effectiveness of the monitoring wellnetwork and the groundwater recovery system. Changes to be madeensure the effectiveness of the remedy, if needed. The groundwatermonitoring program would reliably track the reduction of VOCconcentrations in on-site groundwater in relationship to achievingthe remedial goal.


If the data suggests that -the remedial action has beeneffective in reducing the concentration of a contaminant, but thata PAL does not appear to be achievable, an alternativeconcentration limit (ACL) may be issued. If the data gatheredshows that a remedial action has been ineffective or that furthercleanup is possible, additional remedial actions may be required.(WDNR letter to USEPA, March 7, 1991).

Short-Term Effectiveness - This alternative would beimplemented entirely on-site and would not pose health risks to thecommunity. Treatment by air stripping would effectively reduce VOClevels in the groundwater recovered on-site that is recharged togroundwater at Lagoons 3 and/or 4. VOC emissions from the airstripper would be minimal, would not require emission controls andwould not pose health risks to area residents.

On-site workers responsible for installing, operating andmaintaining the groundwater recovery, treatment and recharge systemcould be exposed to VOCs (i.e. - via inhalation) and any riskswould be controlled by the Health and Safety Plan. The approximateremedial timeframe required to reduce VOC levels in groundwater tothe PALs or to the lowest level technically and economically

47


feasible will be determined through modeling to be presented in theDraft FS Report.

Implementabilitv - Wells MW-14 and MW-15 at the Melby Roadarea are equipped with pumps to recover groundwater at thislocation. Extraction wells can be installed at the southwestcorner of the property with little difficulty.

An air stripping tower could be installed at the NPI site withlittle difficulty. It is expected that air stripping could reducethe concentration of VOCs in on-site groundwater to the remedialgoal or non-detectable levels (using analytical methods specifiedand approved by USEPA in consultation with WDNR) to comply with theWPDES permit requirements for groundwater recharge.

In the past, NPI's wastewater handling system recharged wateryear-round to Lagoons 3 and 4. Preliminary calculations indicatethat Lagoons 3 and 4 could recharge more than ten times the volumeof recharge proposed by this operable unit alternative. Based onpast experience and the favorable hydrogeologic conditions torecharge that exist at Lagoons 3 and 4, no technicalimplementability constraints are expected under this 400 gpmgroundwater recovery, treatment and recharge option.

Cost - The estimated capital cost of this alternative is$342,000. The estimated annual O&M cost of this alternative is$100,000. The present worth of the annual O&M cost ranges from$1,019,000 to $1,608,000 (based on 30 year timeframe and discountrates of 10% and 5%, respectively).


48


IV. COMPARATIVE ANALYSIS OF INTERIM ACTION ALTERMftTTVFfi

This section presents a comparison of the operable unitalternatives to remediate on-site groundwater that have beendeveloped and evaluated in this PFS. The comparative evaluationsare arranged according to the NCP criteria. Table 19 summarizesthe NCP evaluations of each alternative.

Overall Protection of Human Health and the Environment - Allremedies, except the No Action alternative, would achieve the RAOsestablished in this PFS. Treatment (either at the POTW or bycascade aeration or air stripping) would be provided byalternatives 2-5 to reduce VOC concentrations in the recoveredgroundwater. All alternatives will achieve the remedial goals foron-site groundwater over time.

Alternatives 2-5 would improve off-site groundwater quality bypreventing off-site contaminant migration in groundwater from theMelby Road area and the southwest corner of the NPI property.

Alternatives 3 and 4 would discharge treated groundwater tothe Chippewa River and Lake Hallie, respectively, and there wouldbe no significant change in surface water quality. Treatment bycascade aeration or air stripping, provided under eitheralternative 3 or 4 would be equally protective of human health andthe environment to the extent required by the regulations.

Under alternatives 3 and 4, VOC levels would be reducedinitially due to dilution of pumpage and subsequent on-sitetreatment (cascade aeration or air stripping) would further reduceVOC levels before the groundwater is discharged to the City stormsewer system or the dedicated pipeline. Therefore, VOC leaks fromthe storm sewer or pipeline, if any, are expected to be minor andshould not be a problem.

49


Compliance with ARARs - All alternatives developed in thisPFS, except the No Action alternative, would comply with allFederal and State ARARs. Groundwater recovered on-site at theMelby Road area and the southwest corner of the property would meetthe POTW's pretreatment standards and could be discharged directlyto on-site sanitary sewers under alternative 2.

The levels of VOCs in the recovered groundwater will besignificantly lower than the WDNR surface water criteria, asdiscussed in Section II. However, in accordance with WisconsinStatutes, Section 147.04 (2)(b) and Section 301(b)(2) of the CleanWater Act, the groundwater will be pumped and treated to reduce VOClevels. PFS alternatives 3 and 4 each provide two groundwatertreatment options to comply with the WPDES permit requirement totreat all discharges to surface water, even if untreated effluentwould not significantly impact receiving water quality. Based onthe VOC concentrations in groundwater recovered on-site, WDNRdetermined that a passive cascade aeration system would satisfy theWPDES permit best available treatment requirement, and alternatives3a and 4a include cascade aeration.

Alternatives 3b and 4b would treat groundwater recovered on-site by air stripping. Air stripping would achieve greater VOCremovals (determined by air stripper design) than cascade aeration,however the untreated groundwater concentrations are below theState water quality standards and there is no significantdifference in the technologies in terms of ARAR compliance. Airstripping to comply with the WPDES permit treatment requirementwould not achieve an increased environmental (water quality)benefit over cascade aeration.

VOC emissions from an on-site air stripper or cascade aerationsystem would be minimal (less than 3.4 pounds per day) and emissioncontrols would not be necessary to comply with WDNR air permitrequirements.

50


Alternative 5 would treat groundwater on-site by air strippingto achieve the PALs or non-detectable VOC levels to comply withWPDES general permit requirements for recharge through on-siterecharge basins (Lagoons 3 and/or 4).

Long-Term Effectiveness and Permanence - All operable unitalternatives, except No Action, would prevent off-site migration ofcontaminated groundwater from the Melby Road area and the southwestcorner of the NPI property and this would be verified by long-termgroundwater monitoring. Monitoring would also track the reductionsin VOC concentrations that result from on-site groundwater recoveryand treatment under alternatives 2-5. The performance of theselected action will be reviewed after 5 years of operation toevaluate the remedy's effectiveness in achieving the operable unitRAOs. If the data suggests that the remedial action has beeneffective in reducing the concentration of a contaminant, but thata PAL does not appear to be achievable, an alternativeconcentration limit (ACL) may be issued. If the data gatheredshows that a remedial action has been ineffective or that furthercleanup is possible, additional remedial actions may be required.(WDNR letter to USEPA, March 7, 1991).

Short-Term Effectiveness - Implementation of the alternativesdeveloped in this PFS will not pose any health hazards to thecommunity. Groundwater discharged to the sanitary sewer underalternative 2 would meet the POTW pretreatraent standards withouttreatment and should not interfere with POTW operations andeffectiveness. Groundwater discharges to on-site stormsewers/Chippewa River (alternatives 3a, 3b) and on-site rechargebasins (alternative 5) would comply with WPDES permit requirementsand would not significantly change surface water or groundwaterquality. In addition, alternatives 3a, 3b and 5 would beimplemented entirely on-site and disturbance of area residentswould be avoided.

51


Substantial off-site construction activity would be requiredto install a dedicated pipeline for direct groundwater dischargefrom the NPI site to Lake Hallie (alternative 4a, 4b) . Thisalternative would inconvenience area residents in a number of ways,including noise, dust, road closings and increased constructionequipment traffic. In addition, permission to install the pipelinethrough properties (and at the Lake Hallie shoreline) owned by theTown of Hallie, the City of Eau Claire and private citizens wouldbe required.

On-site workers responsible for installing, operating andmaintaining the groundwater recovery, treatment and monitoringsystems could be exposed to VOCs (i.e. - via inhalation) and anyrisks would be controlled by the- Health and Safety Plan. Theapproximate remedial timeframe required to achieve the PALs ingroundwater or the lowest level technically and economicallyfeasible will be determined through modeling that will be presentedin the Draft FS Report (when source control is addressed).

Implementabilitv - All alternatives presented in this PFS canbe implemented using labor and materials available from areacontractors. The City of Eau Claire has indicated that groundwaterdischarge to the City sanitary sewer/POTW (alternative 2) isunacceptable (see letter dated July 11, 1991 - Appendix C). Basedon this administrative issue, alternative 2 is not implementable.The City has also indicated, however, that it would allowrecoverable groundwater to be discharged to the city storm sewerduring a full-scale remedial action, as proposed by PFSalternatives 3a and 3b.

In an August 2, 1991 letter (see Appendix D), the City statesthat it "will allow the use of the City storm sewer system forconveyance of groundwater" recovered at the NPI site. This optioncan be readily implemented. The on-site infrastructure can becleared and rerouted as necessary, and the groundwater recovery

52


system can be designed to shut down during severe storm events toprevent sewer overload. This alternative's effectiveness inpreventing off-site contaminant migration would not be impacted byceasing groundwater recovery for several days several times peryear, as may be necessary to avoid storm sewer overload.

Alternatives 4a and 4b, which provide direct discharge tosurface water via a dedicated pipeline which would be installednorth from the Melby Road area to Lake Hallie and would cross arailroad, a highway, private properties and several local roads.The pipeline would be routed through a residential area andinstallation activity could disrupt and otherwise inconvenienceneighborhood residents. A long lead time and considerable costsmay be required to obtain the necessary rights to properties ownedby the Town of Hallie and the City of Eau Claire, privateproperties (including the Lake shoreline) and easements.Opposition to alternatives 4a and 4b from local authorities andcommunity groups and difficulty coordinating with local, County andState agencies may occur.

The on-site groundwater recharge option (alternative 5) wouldutilize existing Lagoons 3 and/or 4, which have been used to handlewater at the NPI site in the past. Based on this past experienceand calculations that indicate Lagoons 3 and 4 could recharge morethan ten times the recharge (approximately 400 gpm) proposed bythis operable unit, and this option would be implementable at theNPI site.

Alternatives 3 and 4 would employ either cascade aeration orair stripping to satisfy the WPDES permit best available treatmentrequirement for groundwater discharges to surface water. Airstripping is more difficult to implement than cascade aerationbecause the air stripper requires considerably greater operatorattention and maintenance.

53


Alternative 3a (cascade/storm sewer) is readily implementableand can quickly and easily begin achieving the operable unit RAOs.

Cost - Tables 20 and 21 summarize the estimated costs thatwould be associated with each operable unit alternative presentedin this PFS. The estimated costs are presented in ranges, from thecost calculated using a 10% discount rate (pursuant to the NCP) tothe costs estimated using a 5% discount rate (pursuant to RI/FSguidance).

The No Action alternative is the least cost option, however,the remedial action objectives would not be achieved. Each of theremaining alternatives would achieve the RAOs with the samerelative effectiveness and within the framework of the ARARs.Groundwater recovery and sanitary sewer/POTW discharge (alternative2) would cost approximately $925,000 to $1,355,000, however, theCity of Eau Claire will not accept discharge of recoveredgroundwater from the NPI site. Groundwater recovery, cascadeaeration and storm sewer discharge (alternative 3a) would costapproximately $1,043,000 to $1,515,000. The companion alternative(3b) provides air stripping (instead of cascade aeration), wouldcost approximately $280,000 to $400,000 more, and would not achieveany additional water quality benefits. Therefore, selection ofalternative 3b over alternative 3a would not be cost-effective.

The alternatives that include a dedicated pipe to Lake Halliewith cascade aeration (alternative 4a) or air stripping(alternative 4b) have considerably higher estimated costs($1,653,000 to $2,343,000 and $1,841,000 to $2,608,000,respectively) than the storm sewer discharge alternatives (3a and3b) . The alternative 4 estimated costs do not include significantfees that would be required to obtain rights to easements andproperties along the dedicated pipeline path. Implementationproblems may be encountered during installation of the dedicatedpipe through residential areas and across a railroad, Highway 53

54

edor associates consulting engineers, p.c.

and local roads and administrative problems may be associated withobtaining the required access to Town, city and private properties.

Alternative 5, which provides groundwater recovery, airstripping and on-site recharge would cost approximately $1,361,000to $1,950,000.

Alternative 3a (cascade/storm sewer) is the cost-effective"alternative, is readily implementable and will achieve the operableunit RAOs.

55

>CDI—mGO


TABLE 1

SUMMARY OF VOC ANALYSES (UG/L)ON SITE MONITORING WELLS

WELL NUMBER

MW-1

MW-2BMW-3AMW-3BMW-3CMW-4A

MW-4B

MW-5A

MW-5B

MW-6

MW-7

MW-8

MW-9A

MW-9B

MW-10A

DATE

1/8810/881/881/881/881/881/8810/885/904/916/904/911/8810/885/904/911/8810/885/904J211/8810/885/904/911/8810/8810/885/9010/885/9010/885/9010/871/8810/884/91

TCE

--~———__———0.72.0 BJ0.8--1.01.0 BJ—«—0.6 BJ———0.6 BJ~——----—0.2 J————0.7 BJ

PCE

~————————0.2 J0.56.29.610.010—0.412.00.7„—0.1 J--—2.4„———0.14 J————0.1 J

1,1,1-TCA

1.33.4—0.4————0.2 J~2434.0300 D'400510 D460.0 DJ16.019.0410.034.014.024.019.012.0J1.11.3J0.65 J—55.056.07.54.03.9 J3.04.75.0

1,1 -DCA

——0.40.50.6———--79.0120 D210180 D220.0 DJ0.61.7150.08.0--1.50.9._--~——--—0.26„3.7 J3.05.26.0

1,1 -DCE

~————————0.2 J--3.15.65.03.0~0.65.00.50.31.20.80.3——----2.01.0~0.2 J————

1 ,2-DCE BENZENE

———————————4.08.36.03.0-,__10.00.3--____—._„--__„____._—___.

0.1 BJ

NOTES: MW - NPI monitoring wellJ - Estimated value (QA/QC criteria not within control limits)D - Indicates initial analysis exceeded the calibration range, was

diluted and reanalyzedB - Compound also detected in the blank


TABLE 1 (continued)


WELL NUMBER

MW-10B

MW-11A

MW-11B

MW-12A

MW-12B

MW-13A

MW-13B

MW-14MW-15MW-16A

MW-16B

MW-17B

MW-17C

MW-18MW-19

MW-20A

DATE

10/871/8810/884/911/8810/884/911/8810/884/911/8810/681/8810/881/8810/881/8810/8810/8810/881/8810/881/8810/881/8810/884/9110/884/9110/8810/884ai10/885/904/91

TCE

__—«--~0.871.0 BJ————0.1 8 J——0.50.75--0.44—--~~—~2.61.72.0 BJ----—4.34.0 BJ1.1—0.7 BJ

PCE

-»•

——~—0.430.5--——--——~~—~~1.94.0—0.25 J-_0.30 J

0.21 J0.2 J--—0.54 J0.25 J--1.50.50.7

1,1,1-TCA

^—

———29.0 D91. OD130 DJ—0.27 J0.4 J—0.44 J—0.22 J0.30.43 J~0.18J83.0130.018.08.12.10.770.5—0.8 J——--0.69 J—83.0 J33.042.0 BJ

1,1 -DCA

..———1.89.47.0--——————--—0.50.3881.075.00.62.10.30.38--—————0.21 J—32.05.010.0

1,1-DCE

„————0.50.4--————————__~~__0.2 J———~—._~--____—3.6 J2.02.0

1 ,2-DCE

———~——--——————0.7——~~3.7——~—0.80.570.4———1.21.01.50.20.2

BENZENE

__———————————————-,--——~—~—~—--————--——

NOTES: MW - NPI monitoring wellJ - Estimated value (QA/QC criteria not within control limits)D - Indicates initial analysis exceeded the calibration range, was

diluted and reanalyzedB - Compound also detected In blank


TABLE 1 (continued)


WELL NUMBER

MW-2QB

MW-21AMW-21BMW-22A

MW-22B

MW-24AMW-24BMW-25MW-34A

MW-34B

DATE

10/885/904/9110/8810/8810/885/9010/885/9010/8810/8810/886/904/916/904/91

TCE

1.1«2.0 BJ~—0.250.2 J0.620.5~—~493091.0

PCE

3.01.01.0 BJ————0.18 J0.1J—~—0.61.0o.u0.3

1,1,1-TCA

130.0J96.063.0 BJ——2.45.07.813.06.2——68.011.0

1,1-DCA

63.016.020.0———0.2 J0.430.6._——25.00.51.0

1.1 -DCE

4.6 J4.02.0———0.2 J0.510.60.57——~~~—

1 ,2-DCE

2.60.50.5———--——,.~——0.3~~

BENZENE

———————————--——~

NOTES: MW - NPI monitoring wellJ - Estimated value (QA/QC criteria not within control limits)D - Indicates Initial analysis exceeded the calibration range, was

diluted and reanalyzedB - Compound also detected in blank



TABLE 2

SUMMARY OF INORGANIC ANALYSES (UO/L) - APRIL 1991 SAMPLINO ON-SITE MONITORING WELLS

PARAMETER MW-4A MW-4B MW-5A MW-5B MW-6 MW-10A MW-10B

— 36.2 B 55.6 B 49.6 BALUMINUM 41.3BANTIMONY —ARSENIC —BARIUM 5.1 BBERYLLIUM —CADMIUM —CALCIUM 5110CHROMIUM —COBALT —COPPER 7.2 BIRON 40.7 BLEAD 2.2 BMAGNESIUM 918 BMANGANESE 6.3 BMERCURY —NICKEL —POTASSIUM 807 BSELENIUM 2.2 BSILVER —SODIUM 7870THALLIUM —VANADIUM —ZINC 250

48.6 B —

13.8 B 13.5 B 4.3 B 7.7 B 9.9 B 4.3 B

MW-11A MW-11B MW-14* MW-15*

48.6 B 32.4 B — —

6.0 B 7.7 B 82.5 B 78.4 B

—1430012.9

6.5 B22.5 B—4440 B41.0

2041320 B—

—21600—

——1.0 B628045.6

—2320 B4.1 B

—5330—

—2403.41900 B333

— .1840 B5.4

—10600—

_—2.5 B4310 B3.0 B

_686 B—

29.411000—

9.3 B42.2 B3.63640 B9.8 B

90.0950 B—

—10700—

— .59.4 B1.5 B4490 B3.0 B

9.4 B889 B—

—13700—

—27.6 B1.2 B3600 B4.6 B

—1150 B—

—10000—

——1.4 B3670 B3.3 B

—954 B—

8250

65.1

6450

60.0

10900 5100 4640 B 2530 B 25600 7510 —

10.9 B l l . O B 206 36.0 58.9 19.3 B 48.0

NOTES:MW - NPI monitoring wdl.B — Indicate! detected at leu than contract required detection

limit but greater than instrument dectkm limit.(—) - Indicatea compound not detected.(*) - MW-14 and MW-15 remits are from January 1988 lampling.

2.7 B

45.1



TABLE 2 (continued)

SUMMARY OF INORGANIC ANALYSES (UG/L)APRIL 1991 SAMPLING ON-SITE MONITORING WELLS

PARAMETER

ALUMINUMANTIMONYARSENICBARIUMBERYLLIUMCADMIUMCALCIUMCHROMIUMCOBALTCOPPERIRONLEADMAGNESIUMMANGANESEMERCURYNICKELPOTASSIUMSELENIUMSILVERSODIUMTHALLIUMVANADIUMZINC

NOTES:

MW-17B MW-17C MW-19 MW-23A MW-23B MW-34A MW-34B

— 52.1 B 32.4 B 70.8 B 36.8 B 54.6 B —

12.18 8.OB 11.6B 10.1 B 6.3 B 21.7B 6.3 B

10500 8440 9920 14000 10600 20900 9950— — — — 14.0 — —

6.5 B — — 6.5 B 6.5 B — —— 49.6 B 27.3 B 74.0 B — 26.0 B —1.7 B 2.3 B 1.2 B 1.3 B — 1.2 B —3320 B 2600 B 3280 B 5110 4020 B 7370 3990 B4.3 B 5.6 B 6.3 B 10.2 B 6. IB 20.2 2.6 B

— — — — — 18.3 B 16.4 B2070 B 1620 B 1770 B 1070 B 1470 B 1380 B 1 170 B

7540 3790 B 5720 8830 14300 13300 4340 B

10.7 B 45.8 30.7 20.5 73.6 50.3 55.2

MW - NPI monitoring well.B - In^imtTi dtfactffd at leu than contract required detection

limit but greater than instrument dection(— ) - Indicate* compound not detected.(*) - MW-14 and MW-15 remits are from January 1988 aunpling.


TABLE 3

CITY OF EAU CLAIR POTW INDUSTRIAL PRETREATMENT STANDARDS

Contaminant Limit fma/11

Cadmium 1.3Chromium 18.0Copper 16.0Nickel 17.0Zinc 4.7Mercury 2.0Lead 0.7Cyanide 2.0

mu1393


TABLE 4

SURFACE WATER QUALITY CRITERIA, DISCHARGE LIMITATIONS ANDMAXIMUM LEVELS MEASURED IN ON-SITE MONITORING WELLS

Chemical

TCE

PCE

1,1,1-TCA

a , i , -DCA1,1, -DCE

1,2-DCE

Wisconsin In-StreamSurface Hater Quality

Criteria (ug/L)

3601

491

33,0002

NC

481

15 ,0002

Limit on Dischargeto Chippewa River

(ug/L)

4,100,000

552,000

372,000,000

NA

541,000

169,000,000

Limit on Dischargeto Lake Ha Hie

(ug/L)

3,960

539

363,000

NA

528

16,500

Maximum On-siteConcentration,

April 1991 (ug/L)

30

10

460

220

3.0

3.0

Notes:

NC - There is no criteria for this compound

NA - Not applicable

1 - Criterion based on NR 105.09 human cancer values.

2 - Criterion based on NR 105.08 human threshold values ;3(Q

mw!393

NATIONAL FRBSTO INDUSTRIES. INC.EAU CLAIRE, WISCONSIN

TABLE 5

SURFACE WATER CRITERIA AND DISCHARGE LIMITS FOR METALS ANDMAXIMUM LEVELS EXPBCTED IN GROUND WATER RECOVERED AT THE NPI STTB

PARAMETER Water OMlty Criteria (a|/QLtait w

to Lake Bailie 0«/l>Mo* Recent Mootoriag Well Rcauto (m/I)

MW-4A MW-4B MW-14 MW-15 MW-23A MW-23B MW-54A MW-34B

ALUMINUMBARIUMCALCIUMCHROMIUMCOPPERIRONLEADMAONESIUMMANGANESENICKELPOTASSIUMSELENIUMSODIUMZINC

NCNCNC

30.6 (1)5.99(1)1000(2)4.17(1)

NC100(2)

36.79(1)NC7.07NC

27.57(1)

NCNCNC

21,7164,265

711.9522,969NC

71.19526.193

NC5,033NC

19.629

NCNCNC

336.665.9

11.00045. §7NC

1.100404.7NC

77.77NC

303.27

41.3 B5.1 B5110

7.2 B40.7 B2.2 B91SB6.3 B

•07 B2.2 B7S70250

41.6 B13 IB1430012.96.5 B22.5 B

4440 B41.02041320 B

125065.1

S2.5 fi 71.4 B

2.7 B

4S.O 45.1

70 SB10.1 B14000—6.5 B74.0 B1.3 B511010.2 B—1070 B—SS3020.5

36.1 B6.3 B1060014.06.5 B——4020B6.1 B—1470 B—1430073.6

54.6 B21.7 B20900—_26.0 B1.2B737020.2U S B1310 B—1330050.3

_

6.3 B9950————3990 B2.6 B16.4 B1170 B3.SB4340 B55.2 1$

NOTES:

1 - WiacoMta NR 105 Ckrak Toikky Water OaaUy Criterioeu aMuawa rocctvtof i2- USEPAQMlky Criteria far Water. 1916.NC- NoUSEPAOTWiaMMfacbrafcloifciiyvalDcjpabUahtd.B- W&Mtebe&ul&&mv*namiJirt4eiectolia&totgn*utonto

ater aantecMU SO pf« uC»CO3

•neat detection limit.detected.

Dl*chufe ""<*•**«" have bccai Blatodi f backgrouad cooccotnlioM equal tern.

(fi

<O

I3


TABLE 6

WATER QUALITY STANDARDS FOR VOCsIN GROUNDWATER AT THE NPI SITE

Chemical

TCE

PCE

1,1,1-TCA

1,1, -DCA

1,1, -DCE

1,2-DCE (cis)

1,2-DCE (trans)

PreventiveAction Level

<ug/L)

0.18

0.10

40

85

0.024

10

20

EnforcementStandard(ug/105

1

200

850

7

100

100

MaximumContaminantLevel (ug/L)

5

5

200NA7

70

70

Notes:

NA ~ Not Applicable

nw1393


TABLE 7

ALTERNATIVE 2PUMP AND DISCHARGE TO SANITARY SEWERPRELIMINARY CAPITAL COST ESTIMATE

Item and Description Cost

1. Melby Road

a. Site Preparation $ 3,000b. 1,250 If 4" 0 PVC pipe @ $8/lf 10,000c. Electrical 15,000d. Instrumentation and Controls 5. OOPe. SUBTOTAL $33,000

2. Southwest Corner

a. Site Preparation $ 3,000b. Drill and Install 2 additional monitoring wells

§ $5,000 each 10,000c. 2 groundwater recovery wells @ $18,000 each 36,000d. 2 well pumps @ $2,500 each 5,000e. 750 If 4" 0 PVC pipe @ $8/lf 6,000f. Electrical 15,000g. Instrumentation and Controls 5.OOPh. SUBTOTAL S 80,000

3. SUBTOTAL $113, OOP

4. Contingency @ 20% 23,000

5. Engineering, Administration and legal @ 25% 28.000

6. TOTAL $164,000

NOTES;

If = linear feetPiping costs include trenching and installation

IM1393


TABLE 8

ALTERNATIVE 2PUMP AND DISCHARGE TO SANITARY SEWERPRELIMINARY ANNUAL OPERATING AND

MAINTENANCE COST ESTIMATE

CostItem and Description Year 1 Years 2-30

1. Maintenance (@ 10% of Capital Cost) $ 16,000 $ 16,000

2. Electrical Power (22.4 kWi$0.09/kW-hr) 18,000 18,000

3. Groundwater & Surface Water Monitoring

a. Sampling 29,000 9,000b. Analysis 35,000 8,000c. Data Review, Report Preparation 9.OOP 5.000

4. SUBTOTAL $107,000 $ 56f000

5. Administration (S 10%) 11,000 6,000

6. Contingency (@ 20%) 21.000 11.OOP

7. TOTAL $139,000 $ 73,000

Present worth for 30 years @ 10% discount rate

O&M Cost Year 1+ Present Worth of O&M Years 2-3P$139,PPP + $622,000$761,000


O&M Cost Year 1+ Present Worth of O&M Years 2-30$139,000 + $1,052,000$1,191,000

Note: Monitoring costs for year 1 include one round of sampling during remedialdesign phase.

0*1393


TABLE 9

ALTERNATIVE 3APUMP. CASCADE AERATION AND DISCHARGE TO STORM SEWER

PRELIMINARY CAPITAL COST ESTIMATE


1. Helby Roada. Site Preparation $ 3,000b. 1,700 If 4" 0 PVC pipe § $8/lf 14,000c. Passive Aerator 5,000d. Electrical 15,000e. Instrumentation and Controls 8.000f. SUBTOTAL $ 45,000

2. Southwest Corner

a. Site Preparation $ 3,000b. Drill and Install 2 additional monitoring wells

@ $5,000 each 10,000c. 2 groundwater recovery wells § $18,000 each 36,000d. 2 groundwater pumps @ $2,500 each 5,000e. 750 If 4" 0 PVC pipe 6 $8/lf 6,000f. Passive Aerator 5,000g. Electrical 15,000h. instrumentation and Controls 8.000i. SUBTOTAL $88,000

3. Storm Sewer Retrofit 15.000

4. SUBTOTAL $148,000

5. Contingency (@ 20%) 30,000

6. Engineering, Administration and Legal (@ 25%) 37.000

7. TOTAL $215,000

NOTES:

If - linear feetPiping costs include trenching and installation

mu1393


TABLE 10ALTERNATIVE 3A

PUMP. CASCADE AERATION AND DISCHARGE TO STORM SEWERPRELIMINARY ANNUAL OPERATING AND


CostItem and Description Year 1 YfrflT? ?-?0


2. Electrical Power (22.4 kW@$0.09/kW-hr) 18,000 18,000


a. Sampling 29,000 9,000b. Analysis 35,000 8,000c. Data Review, Report Preparation 9,000 5.OOP

4. SUBTOTAL $113,000 $ 62,000

5. Administration (@ 10%) 11,000 6,000

6. Contingency (3 20%) 23.000 12.000

7. TOTAL $147,000 $ 80,000


O&M Cost Year 1+ Present Worth of O&M Years 2-30$147,000 + $681,000$828,000



Note: Monitoring coats for year 1 include one round of sampling during remedialdesign phase

HM1393


TABLE 11ALTERNATIVE 3B

PUMP. AIR STRIPPING AND DISCHARGE TO STORM SEWERPRELIMINARY CAPITAL COST ESTIMATE


1.

2.

Helby Road

a. Site Preparationb. 4,500 If 4" 0 PVC pipe @ $8/lfc. Electricald. Instrumentation and Controlse. Pump Stationf . SUBTOTAL

Southwest Corner

a. Site Preparationb. Drill and Install 2 additional monitoring

@ $5,000 each

$ 3,00036,00015,0008,000

15 . 000$ 77,000

$ 3,000wells

10,000c. 2 groundwater recovery wells @ $18,000 each 36,000

3.

4.

5.

6.

7.

d. 2 well pumps £ $2,500 eache. 750 If 4" 0 PVC pipe @ $8/lff . Electricalg. Instrumentation and Controlh. SUBTOTAL

Air Stripping Tower (includes site preparationblower, instrumentation and controls)

SUBTOTAL

Contingency (@ 20%)

Engineering and Administration (@ 25%)

TOTAL

5,0006,00015,0008.000

$ 83,000

, piping.50.000

$210,000

42,000

53 . 000

$305,000

NOTES :



mu1393

TABLE 12

ALTERNATIVE 3B

PUMP- AIR STRIPPING AND DISCHARGE TOPRELIMINARY ANNUAL OPERATING

STORM SEWERAND

MAINTENANCE CQ_3T ESTIMATE

1.

2.

3.

4.

5.

6.

7.

Item and Description

Maintenance (@ 10% of Capital Cost)

Electrical Power (30 kW@$0. 09/kW-hr)

Groundwater & Surface Water Monitoring

a. Samplingb. Analysisc. Data Review, Report Preparation

SUBTOTAL

Administration (@ 10%)

Contingency (@ 20%)

TOTAL

costYear 1

$ 31,000

24,000

29,00035,0009,000

$128,000

13,000

26.000

$167,000

Years 2-30

$ 31,000

24,000

9,0008,0005,000

$ 77,000

8,000

15,000

$100,000


O&M Cost Year 1+ Present Worth of O&M Years 2-30$167,000 + $852,000$1,019,000


= O&M Cost Year 1+ Present Worth of O&M Years 2-30$167,000 + $1,441,000$1,608,000

Note: Monitoring costa for year 1 include one round of sampling during remedialdesign phase

mu1393



PUMP. CASCADE AERATION AND DIRECT DISCHARGE TO LAKE HALLIEPRELIMINARY CAPITAL COST ESTIMATE


1. Melby Road

a. Site Preparation $ 3,000b. 250 If 4" 9 PVC pipe @ $8/lf 2,000c. Electrical 15,000d. Instrumentation and Control 5.000e. SUBTOTAL $25,000

2. Southwest Corner

a. Site Preparation $ 3,000b. Drill & Install additional monitoring wells

@ $5,000 each 10,000c. 2 groundwater recovery wells @ $18,000 each 36,000d. 2 groundwater pumps @ $2,500 each 5,000e. 250 If 4" 0 PVC pipe @ $8/lf 2,000f. 5,000 If 6" 0 PVC pipe S $10/lf 50,000g. Electrical 15,000h. Instrumentation and Control 5.000i. SUBTOTAL $126,000

3. Piping Run from Melby Road to Lake Hallie

a. 5,500 If 6" 0 PVC pipe @ $10/lf $ 55,000b. Highway 53 Crossing

bored and jacked; 200 If e $250/lf 50,000c. Railroad Crossing

bored and jacked; 150 If @ $250/lf 38,000d. 6 road crossings; 75 If each @ $25/lf 12,000e. Pump Station 15,000f. Passive Aerator 5.000g. SUBTOTAL $175.000


RM1393

Table 13 Continued . . .

Item and Description cost

5. Contingency (@ 20%) $ 65,000

6. Engineering, Administration and Legal @ 25% 82.OOP

7. TOTAL • $473,000

NOTES:

If = linear feetPiping costs include trenching and installationCosts do not include purchase of property rights required toinstall off-site piping.

mu1393



PUMP. CASCADE AERATION AND DIRECT DISCHARGE TO LAKE HALLIEPRELIMINARY ANNUAL OPERATING AND


Cost

1.2.

3.

4.

5.

6.

7.


Maintenance (@ 10% of Capital Cost)

Electrical Power (26 kW@$0.09/kW-hr)



SUBTOTAL

Administration (3 10%)

Contingency (@ 20%)

TOTAL

Year 1

$ 47,000

21,000

29,00035,0009.000

$141,000

14,000

28.000

$183,000

Years 2-30

$ 47,000

21,000

9,0008,0005.000

$ 90,000

9,000

18.000

$117,000



Present worth for 30 years £ 5% discount rate



mu1393


TABLE 15ALTERNATIVE 4B

PUMP. AIR STRIPPING AND DIRECT DISCHARGE TO LAKE HALLTEPRELIMINARY CAPITAL COST ESTIMATE


1. Helby Road

a. Site Preparation $ 3,000b. 250 If 4" 0 PVC pipe @ $8/lf 2,000c. Electrical 15,000d. instrumentation and Control 5.000e. SUBTOTAL $ 25,000

2. Southwest Corner

a. site Preparation $ 3,000b. Drill & Install 2 additional monitoring wells

@ $5,000 each 10,000c. 2 groundwater recovery wells @ $18,000 each 36,000d. 2 groundwater pumps @ $2,500 each 5,000e. 250 If 4" 0 PVC pipe @ $8/lf 2,000f. 5,000 If 6" 0 PVC pipe S $10/lf 50,000g. Electrical 15,000h. Instrumentation and Control 5.000i. SUBTOTAL $126,000

3. Air Stripping Tower with Blower and Controls $50,000(includes site preparation, piping, blower

instrumentation and controls)

4. Piping Run from Melby Road to Lake Hallie

a. Pumping Station $ 15,000b. 5,500 Ib 6" 0 PVC pipe @ $10/lf 55,000c. Highway 53 Crossing

bored and jacked; 200 If 8 $250/lf 50,000d. Railroad Crossing

bored and jacked; 150 If @ $250/lf 38,000e. 6 road crossings; 75 If each @ $25/lf 12.OOPf. SUBTOTAL 5170.000


IW1393

Table 15 Continued . . .

Item and Description cost

6. Contingency @ 20% $ 74,000

7. Engineering, Administration and Legal @ 25% 93.000

8. TOTAL $538,000

NOTES:

If = linear feetPiping costs include trenching and installationCosts do not include purchase of property rights required toinstall off-site piping.

mw1393


TABLE 16

ALTERNATIVE 4BPUMP. AIR STRIPPING AND DIRECT DISCHARGE TO LAKE HALLIE

PRELIMINARY ANNUAL OPERATING ANDMAINTENANCE COST ESTIMATE

CostItem and Description Year 1 Years 2-30


2. Electrical Power (30 kW@$0.09/kW-hr) 24,000 24,000


a. Sampling 29,000 9,000b. Analysis 35,000 8,000c. Data Review, Report Preparation 9.000 5.000

4. SUBTOTAL $151,000 $100,000

5. Administration (@ 10%) 15,000 10,000

6. Contingency (@ 20%) 30,000 20.000

7. TOTAL $196,000 $130,000


O&M Cost Vear 1+ Present Worth of O&M Years 2-30$196,000 + $1,107,000$1,303,000



Note: Monitoring costs for year 1 include one round of sampling during remedialdesign phase

mu1393


TABLE 17ALTERNATIVE 5

PUMP. AIR STRIP AND ON-SITE RECHARGEPRELIMINARY CAPITAL COST ESTIMATE


1. Melby Road

a. Site Preparation $ 3,000b. 1,500 If 4" 0 PVC pipe S $8/lf 12,000c. Electrical 15,000d. Instrumentation and Control 5.000e. SUBTOTAL ' $35,000

2. Southwest Corner

a. Site Preparation $ 3,000b. 2 additional monitoring wells @ $5,000 each 10,000c. 2 groundwater recovery wells § $18,000 each 36,000d. 2 groundwater pumps @ $2,500 each 5,000e. 250 If 4" 0 PVC pipe @ $8/lf 2,000f. 4,000 If 6" 0 PVC pipe S $10/lf 40,000g. Electrical 15,000h. Instrumentation and Control 5.000i. SUBTOTAL $116,000

3. Air Stripping Tower with Blower and Controls 50,000(includes site preparation, piping, blower,

instrumentation and controls)

4. Excavation and Preparation of Lagoons 35.000


6. Contingency e 20% 47,000

7. Engineering and Administration @ 25% 59.OOP

8. TOTAL $342,000


mu1393


TABLE 18

ALTERNATIVE 5PUMP. AIR STRIP AND ON-SITE RECHARGEPRELIMINARY ANNUAL OPERATING AND


Cost

1.2.

3.

4.

5.

6.

7.


Maintenance (§ 10% of Capital Cost)

Electrical Power (26 kW@$0.09/kW-hr)



SUBTOTAL

Administrative (@ 10%)

Contingency (@ 20%)

TOTAL

Year 1

$ 34,000

21,000

29,00035,0009.000

$128,000

13,000

26.000

$167,000

Years 2-30

$ 34,000

21,000

9,0008,0005.000

$ 77,000

8,000

15.000

$100,000






mu1393


TABLE 19SUMMARY OF NCP EVALUATIONS

BCP CriterionAlternative- 1Ho Action

Alternative 2 :

Discharge to SanitaryS.W/TOIW

.'::-; " Alfcaxnaitiy* 3« .-'-:;• .V ;, -Cascade Aeration, Discharge to

: Storm Sewer*Pump. Air Stripping,"Diiaoharga to

Storm Sew«c» "

OvarallProtection ofHunan Health &tha Environment

Hill not preclude off-eitecontaminant nigration.

• Pumping will prevent off-sitecontaminant nigration from theMelby Road area and the southwestcorner of the property.

e Treatment at POTW will achieve theremedial goals for on-sitegroundwater.

Pumping will prevent off-sitecontaminant migration from tha MelbyRoad area and the touthMest cornerof the property.Cascade aeration will achieve theremedial goals for on-sitegroundwater.

e Pumping will prevent off-sitecontaminant Migration from theMelby Road area and the southwestcorner of tha property.

e Air atrlpping will achieve theremedial goal* for on-*itegroundwater.

Compliance WithARARs

Does not comply withFederal or State ARARs.

e Untreated groundwater recovered atthe Melby Road area and at theaouthwest corner meets POTW'*pretreatment standards.

e Complies with all Federal and StateARARs.

Cascade aeration would reducecontaminant levels in recoveredgroundwater.Will satisfy WPDES permitrequirement for treatment ofdischarges to surface water.Emission controls will not berequired for cascade system.Complies with all Federal and StateARARs.

e Air stripping would reducecontaminant levels in recoveredgroundwater.

e Will satisfy WFDES permitrequirement for treatment ofdischarges to surface water.

e Air stripper emission controlswill not be necessary to complywith WDHR air permit requirements.

e Complies with all Federal andState ARARs.

Long-TermEffectivenessand Permanence

Will not prevent off-sitecontaminant migration.Will not actively reatorethe on-site aquifer.

e Hill prevent off-site contaminantmigration,

e Performance review will beconducted after 5 years to evaluateeffectiveness in achieving RAOs.

e Long-term groundwater monitoringwill track reductions in on-sitecontaminant levels.

e Hill prevent' off-site contaminantmigration,

e Performance review will be conductedafter 5 years to evaluateeffectiveness in achieving RAOs.

• Long-term groundwater monitoringwill track reductions in on-sitecontaminant levels.

e Hill prevent off-site contaminantmigration,

e Performance review will beconducted after S year* toevaluate effectiveness inachieving RAOs.

e Long-term groundwater monitoringwill track reduction* in on-sitecontaminant levels.

Short-TermEffectiveness

e Implementation will notImpact the community.

e Hill not prevent off-sitecontaminant migration fromthe Melby Road area andsouthwest corner.

e Remedial timeframe*predicted by groundwatermodeling will be presentedin the Draft FS.

e Implementation will not impact thecommunity,

e Pumping will prevent off-aitecontaminant migration to improvegroundwater quality downgradient ofthe NFI *ite.

e POTW treatment will reducecontaminant concentration*.

e Groundwater recovered at Melby Roadarea and southwest corner would notimpact POTW operation,

e HASP will be followed to controlrisks posed to on-site worker*during implementation,

e Remedial timeframes predicted bygroundwater modeling will bepresented in the Draft FS.

a Implementation will not ijupact thecommunity,

e Pumping will prevent off-sitecontaminant migration to improvegroundwater quality downgradient ofthe HPI site.

a Cascade aeration will reduce VOCconcentration*.

e Treated groundwater discharge willnot degrade Chippawa River waterquality,

e HASP will be followed to controlrisks posed to on-site workersduring implementation.

e Remedial timafranas predicted bygroundwater Modeling will bepresented in the Draft FS.

e Implementation will not Impact thacommunity,

e Pumping will prevent off-sitecontaminant migration to improvegroundwater quality downgradientof the HPI site,

e Air stripping will reduce VOCconcentrations.

e Treated groundwater discharge willnot degrade Chippewa River waterquality,

e HASP will be followed to controlrisks posed to on-alte worker*during implementation,

e Remedial timeframes predicted bygroundwater modeling will bepresented in the Draft FS.

Continued. .

Table 19 Continued. . .

BCP CriterionAlternative 1

No Action

Alternative; 2Pimp, Discharge to Sanitary

Sewer/POIW

Alternative 3*Punp, Cascade Aeration, Discharge to

Storm Sewers

Alternative 3bPimp, Air Stripping, Discharge to

Stom Seweri

Imp1amantabi1ity • Readily Implamantabla. • Halls MH-14 and MH-15 at tha HelhyRoad araa ara equipped with pumpsand capture wells can be installedat the southwest corner with littledifficulty.

e City of Eau Claire will not acceptNPI groundwater discharge to theSanitary Sewer/POTH.

e Hot implamentable based onadministrative constraints.

* Walls W-14 and M4-1S at tha HelbyRoad area are equipped with pumpsend capture wells can be installed•t the southwest corner with littledifficulty.

e City of Eau Claire will acceptdischarge to NPI storm sewers.Storm sewer upgrade and/or dischargeshut-off device may be required.

e Cascade aeration system can bereadily constructed and will requireminimal maintenance.

a Hells MH-U and IW-15 at the MelbyRoad araa are equipped with pumpsand capture wells can be installedat the southwest corner withlittle difficulty.

• City of Eeu Claire will acceptdischarge to IPX stom sewers.Storm sewer upgrade and/ordischarge shut-off device may berequired.

e Air stripper can be Installed on-site by local contractors.

e Air stripper will require anoperator and frequent maintenance.

Cost

e Capital Cost

e AnnualOperating andMaintenanceCost

e Present Worth0 & H

e Total Cost

$164.000

$73.000

$761,000 to $1,191,000

$925.000 to $1,355,000

$215,000

$80.000

$828,000 to $1,300,000

$1,043,000 to $1,515,000

$305,000

$100,000

$1,019,000 to $1,608,000

$1,324,000 to $1,913,000

Continued. .


TABLE 19SUMMARY OF NCP EVALUATIONS

NCF Crit«rion

-. :; ::;' ' - Alternative *«C«c»da> Aeration, Direct Discharge to

: Surface Hater

*bPump, Air Strip, Direct Discharge to Surface

Hater

.Pump, Air Stripping, Oq-Site Recharge to

: Grouadwatec

Overall Protectionof Human Health &the Environment

e Pumping Mill prevent off-aite contaminantmigration fron the Melby Road area and thesouthwest corner of the property.

e Cascade aeration will achieve the remedialgoal* for on-aite groundwatar.

e Pumping will prevent off-site contaminantmigration from the Melby Road area and thesouthwest corner of the property.

e Air stripping will achieve the remedial goalafor on-site groundwater.

Pumping will prevent off-site contaminantmigration from the Helby Road ar«a and thesouthwest corner of the property.Air stripping will achieve the remedialgoals for on-site groundwater.

Compliance WithARARs

e Cascade aeration would reduce contaminantlevels in recovered groundwater.

e Hill satisfy HPDES permit requirement fortreatment of discharges to surface water.

e Emission controls will not be required forcascade system.

e Complies with all Federal and State ARARa.

e Air stripping would reduce contaminant levelsin recovered groundwater.

e Hill satisfy HPDES permit requirement fortreatment of discharges to surface water,

e Air stripper emission controls will not benecessary to comply with HDNR air permitrequirements.

e Complies with all Federal and State ARARs.

e Air stripping would reduce contaminantlevels in recovered groundwater to PALs ornon-detectable levels.

e Hill comply with HPDES permit requirementsfor on-site recharge to groundwater.

e Air stripper emission controls will not benecessary to comply with HDNR air permitrequirement*,

e Complies with all Federal and State ARARs.

Long-TermEffectivenessPermanence

ande Hill prevent off-aite contaminant migration,e Performance review will be conducted after 5years to evaluate effectiveness in achievingRAOa.

e Long-term groundwater monitoring will trackreductions in on-site contaminant level*.

e Hill prevent off-site contaminant migration,e Performance review will be conducted after Syears to evaluate effectiveness in achievingRAOs.

e Long-term groundwater monitoring will trackreductions in on-site contaminant levels.

e Hill prevent off-site contaminant migration.e Performance review will be conducted after Syears to evaluate effectiveness in achievingRAOS.

e Long-term groundwater monitoring will trackreductions in on-site contaminant levels.

Short-TerraEffec tivene aa

e Installation of the direct pipeline to LakeHallle will inconvenience area residents andexpose them to Increased noise and dust,

e Pumping will prevent off-site contaminantmigration to improve groundwater qualitydowngradlent of the HPI sit*,

e Cascade aeration will reduce VOCconcentrations.

e Treated groundwater discharge will not degradeLake Bailie water quality,

e HASP will be followed to control risks posed toon-site workers during implementation,

e Remedial timeframes predicted by groundwatarmodeling will be presented in the Draft FS.

e Installation of the direct pipeline to LakeHaliie will inconvenience area residents andexpose them to Increased noise and dust,

e Pumping will prevent off-site contaminantmigration to improve groundwater qualitydowngradiant of the HPI site.

e Air stripping will reduce VOC concentrations.e Treated groundwater diacharga will notdegrade Lake Bailie water quality,

e HASP will be followed to control risks posedto on-site workers during implementation,

e Remedial timeframe* predicted by groundwatermodeling will be presented in the Draft FS.

e Implementation will not impact thecommunity,

e Pumping will prevent off-site contaminantmigration to Improve groundwater qualitydowngradient of the HPI site,

e Air stripping is expected to reduce VOCconcentrations to the PALs or non-detectablelevels,

e Treated groundwater recharge will notdegrade groundwater quality of the on-siteaquifer,

e BASP will be followed to control risks posedto on-site workers during implementation,

e Remedial timeframes predicted by groundwatermodeling will be presented in the Draft FS.

Continued. . .

Table 19 Continued. . .

HCP Criterion

Alternative +»-Pump, Cascade Aeration, Direct Discharge bo

: Surface Heter

Altunativ* 4bPump, AiC Strip, Direct Discharge to

Hater

Alfcarnativ* 5Me Stripping. On-Stfc« Recharge

Groundwater

Implementability Hells MH-14 and Mrt-15 at the Melby Road areaare equipped with pumps and capture wells canbe installed at the southwest corner withlittle difficulty.Long lead tine required to purchase or obtainthe eights to install pipeline through nearlyone mile of publicly and privately ownedproperty.Cascade aeration system can be readilyconstructed and will require minimalmaintenance.Difficult to install pipeline over longdistance to surface water end ecross roadways,railroad end residential areas.Significant opposition expected.

e Halls MH-14 and MH-15 at the Melby Road areaare equipped with pumps and capture wells canbe installed at the southwest corner withlittle difficulty.

e Long lead time required to purchase or obtainthe rights to Install pipeline through nearlyone mile of publicly and privately ownedproperty.

e Air stripper can be installed en-site bylocsl contractors.

e Air stripper will require an operator andfrequent maintenance.

e Difficult to install pipeline over longdistance to surface water and acrossroadways, railroad and residential areas.

e Significant opposition expected.

e Hells MH-14 and I**-15 at the Melby Road areaare equipped with pumps and capture wellscan be installed at the southwest cornerwith little difficulty,

e Recovered groundwater (approximately 400gpm) can be recharged on-aite.

e Air stripper can be installed on-site bylocal contractors,

e Air stripper will require an operator andfrequent maintenance,

e Groundwater recharge during winter months ispossible baaed on past recharge experienceat the DPI site.

Cost

e Capital Cost

e Annual Operatingand MaintenanceCost

e Present Worth• 0 & M

e Total Cost

$473,000

$117,000

$1.180,000 to $1.870,000

$1.653,000 to $2.343,000

$538,000

$130,000

$1.303,000 to $2,070,000

$1.841,000 to $2,608,000

$342,000

$100,000

$1,019,000 to $1.606.000

$1,361,000 to $1,950,000

Notes:• "prevent off-site contaminant migration" implies contaminant levels that exceed HCLs or EScs.• All costs are estimated and those costs presented as ranges reflects costs calculated using 10%discount rate to costs calculated using 5% discount rate.MW1393

NATIONAL PRESTO INDUSTRIES, INCEAU CLAIRE, WISCONSIN

TABLE 20

SUMMARY OF REMEDIAL ALTERNATIVE COST ESTIMATESPRESENT WORTH BASED ON 10% DISCOUNT RATE

Alternative

1. No Action2. Pump, Discharge to

Sanitary Sewer

3a. Pump, CascadeAeration Dischargeto Storm Sewer

3b. Pump, Air StripDischarge to StormSewer

4a. Pump, CascadeAeration, DirectDischarge to LakeHallie

4b. Pump, Air Strip,Direct Dischargeto Lake Hallie

5. Pump, Air Strip,On-Site Recharge

CapitalCost <$>

—__

164,000

215,000

305,000

473,000

538,000

342,000

AnnualOfiM(U <$)

___

73,000

80,000

100,000

117,000

130,000

100,000

O&M PresentWorth (S)

_- .—

761,000

828,000

1,019,000

1,180,000

1,303,000

lf 019 ,000

TotalCost {$}

___

925,000

1,043,000

1,324,000

1,653,000

1,841,000

1,361,000

NOTES:

1. Annual O&M Cost for Years 2-30.

mu1393

NATIONAL PRESTO INDUSTRIES, INCEAU CLAIRE, WISCONSIN

TABLE 21

SUMMARY OF REMEDIAL ALTERNATIVE COST ESTIMATESfPRESENT WORTH BASED ON 5% DISCOUNT RATE)

Alternative

1. No Action2. Pump, Discharge to

Sanitary Sewer3a. Pump, Cascade

Aeration Dischargeto Storm Sewer

3b. Pump, Air StripDischarge to StormSewer

4a. Pump, CascadeAer at ion , D ir ectDischarge to LakeHallie

4b. Pump, Air Strip,Direct Dischargeto Lake Hallie

5. Pump, Air Strip,On-Site Recharge

CapitalCoat (S)

——

164,000

215,000

305,000

473,000

538,000

342,000

AnnualOfiMu> {$)

34,000

73,000

80,000

100,000

117,000

130,000

100,000

O&H Pre**ntWorth (S)

550,000

1,191,000

1,300,000

1,608,000

1,870,000

2,070,000

1,608,000

TotalCost (S)

550,000

1,355,000

1,515,000

1,913,000

2,343,000

2,608,000

1,950,000

NOTES:

1. Annual O&M Cost for Years 2-30.

mu1393

FIGURES

eder associates consulting engineers, p.c.FIGURE 1


Location MapScale 1" = 2,000'

Source: East Eau Claire 7.5min. topographicquadrangle - 1972

conGUftlnQFIGURE 2

SK407-4L

Appnat. GroundvotirBain Boundary

BURIED VALLEY MAPNATIONAL PRESTO INDUSTRIES, INC.

EAU OAJRE, MSCONSIN

Ma/by Rood

•der associates consulting engineers, p.c.FIGURE 3

US49713A

Fane* Lfne

Monltorwjg Well Location

Capture Well Location

TCA/Sot Vapor fsoconcmtratianContour - lOOppb

Grotftdwater Flow Direction

MELBY ROAD SITECAPTTTRE WF.T.T.S

NATIONAL PRESTO INDUSTRIESEAU CLAIRE, WSCXINStN

•der assocfotM consulting angkiMrv, p.c.FIGURE 4

Fane* Utie

Uanttorha Well Location

Capture Wtf Location

Vapor /soconctntrationContour - lOOppb

Groundwattf Ftow D&vction

Groundwotar Strtomffo* Une

AOUFFK PARAUFJEFfS:

T - 60.000gpd/ft(K -

I - .0014

70'I

MELBY ROAD SITECAPTURE ZONE

(AFTER ONENATIONAL PRESTO INDUSTRIES

EAU CLAIRE. WISCONSIN

eder associates consulting engineers, p.c.FIGURE 5

MW-2QA.B(

O

MS49713B

LEGENDZ?,V/? Monitoring We/I (WW Prefix)

/VP/ Monitoring Woil (MW Prefix)

Production Well (W Prefix)

USEPA Monitoring Well (RW Prefix)

TCE Concentration (Average) fa Monitoring Well Circled

Capture Well - Capture Zone Indicated by Line

Groundwater Flow Direction

Water-Table Contour

SOUTHWEST CORNER CAPTURE WELLSNATIONAL PRESTO INDUSTRIES, INC.

EAU CLAJRE. WISCONSIN

0I

700'

eder (associates consulting engineers, p.cFIGURE 6

21'~0

.•• jv ••• »*.-'* ,v -•*.r • - - • ' .v - • * * • - • • ' .v '•" *"•.'•'y' "i-V .".".".•" "i/.' , . * ** - - . • _ . . , . • " *1, ,' , . . ' . '" *ljr

PLAN

1 — 1

E

3

3 .V.V.Y.Y. Compact*-:::::::::::;::: fill::.

-M —————— * —————

-K

?tf

•*

—— X——

M

——— M— ———— **—

.1

-M ——— XJ

-t< ———— —— Vi- — - ———— M —————— ~*-p-1

SK497I3A

SECTION A-A PASSIVE AERATION STRUCTUREPHASED FEASIBILITY STUDY

NATIONAL PRESTO INDUSTRIES, INC.EAU CLAIRE. WSCONS1N

APPFNDIX A

APPENDIX A

NR 106.06 WISCONSIN ADMINISTRATIVE CODE FORMULASTO CALCULATE SURFACE WATER DISCHARGE LIMITATIONS

54-4NRIM

WISCONSIN ADMINISTRATIVE CODE

4. The acute toxicity criteria must be met within 10% of the distancefrom the edge of the outfall structure to the edge of a mixing zone whichmay be determined in accordance with s. NR 102.05 (3).

5. The acute toxicity criteria shall be met within a distance of 50 timesthe discharge length scale in any direction. The discharge length scale isdefined as the square root of the cross-sectional area of any dischargeoutlet. If a multiport diffuser is used, this requirement must be met foreach port using the appropriate discharge length scale for that port.

6. The acute toxicity criteria shall be met within a distance of 5 timesthe local water depth in any horizontal direction from any discharge out-let. The local water depth is defined as the natural water depth (existingprior to the installation of the discharge outlet) prevailing under the mix-ing zone design conditions for the site.

(d) Whenever the representative background concentrations for atoxic or organoleptic substance in the receiving water, as determined bya. NR 106.06 (3) (e), are greater than the limitation based on acute toxic-ity as determined in this subsection, the effluent limitation for thatwastewater shall equal the representative background concentration ofthat substance. In the event the discharger's relative contribution to themass of the toxic or organoleptic substance in the receiving water is negli-gible in the best professional judgment of the department, the depart-ment shall establish an alternate effluent limitation for the discharger. Inmaking this judgment, consideration shall be given to the type of sub-stance being limited, the uses potentially affected and other relevant fac-tors. The alternate effluent limitation shall represent, in the judgment ofthe department, application of the best demonstrated treatment tech-nology reasonably achievable for that substance.

(3) LtyiTATIONS BASED ON CHRONIC TOXICITY OR LONG-TERM I HP ACTS.(a) Water quality criteria. The department shall calculate water qualitybased effluent limitations to ensure that the chronic toxicity criteria(CTC), the wild and domestic animal criteria (WDAC), the taste andodor criteria (TOC). the human threshold criteria (HTC), and humancancer criteria (HCC) appropriate for the receiving water as specified inchs. NR 102 to 105 will be met after dilution with an appropriate allow-able quantity of receiving water Sow as specified in this subsection, subs.(4) to (8) and s. NR 106.11. The available dilution shall be determinedaccording to par. (c) unless the conditions specified in s. NR 102.05 (3)require less dilution be allowed.

(b) Calculation of limits. Water quality based effluent limitations tomeet the requirements of this subsection shall be calculated using theprocedure specified in subd. 1. or 2 except as provided in par. (e) 3. to 6,Chemical specific water quality based effluent limitations may be ex-pressed as a maximum concentration limitation (in units of mg/L orequivalent units), as a maximum load limitation (in units of kg/day orequivalent units), or both.

1. For discharges of toxic or organoleptic substances to Dewing receiv-ing waters, the water quality baaed effluent limitation for a substanceshall be calculated using the following conservation of mass equationwhenever the background concentration is less than the water qualitycriterion:Rccuter. Pefanury. 1989, No. 398

DEPARTMENT OF NATURAL RESOURCES 54-6NRIM

Limitation = (WQCMQs*<l-f)Qe) -Qe

Where:

Limitation Water quality baaed eBueat limitation (in uniU ol mm per unit ol vol-ume).

WQC = The water quality criterion concentration (in units ol mass per unit vol-uroei as specified in sub. 11) and par. (a).

4, = Receiving water design flow (in unto of volume per unit time) as speci-kd in par. Ic),

Qt - EBuent Bow (in units ol volume per uait tint) u ipecifed in par. (d).

( - Fraction ol the eBuent low that it withdraw* Iron tht receiving water,and

C, * Background concentration ol the substance (in unit* ol mass per unitvolume) as speciied in par. (et.

Note In applying this equation, all units lor the low and concentration parameters reapec-lively, shall bt continent.

2. For discharges of toxic or organoleptic substances to receiving wa-ters which do not exhibit a unidirectional Bow at the point of discharge,such as lakes or impoundments, the department may calculate, in theabsence of specific data, water quality based effluent limitations usingthe following equation whenever the background concentration is lessthan the water quality criterion:

Limitation - 11 (WQC) - IOC,

Where:

Limitation •» Water quality based eBuent limitation (in units ol m*M per unit ol vol-ume}

WQC - The water quality criterion concentration (in units ol mass per unit vol-ume) asspecifted in sub. (1) and par. (a).

C, =• Background concentration ol th* aubataace (in units of mass per unitvolume) as speciied in par. (e).

On a case-by-case basis other dilutional factors may be used, but in nocase may the dilution allowed exceed an area greater than the area wheredischarge induced mixing occurs. The discharge is also subject to the con-ditions specified in s. NR 102.05 (3). The discharger may be required todetermine the size of the mixing zone using acceptable models or dyestudies.

3. The limitation calculated in subd. 1. or 2. may be converted to amaximum load limitation by multiplying the calculated concentrationlimitation by the rate of effluent flow as determined in par. (d) and appro-priate conversion factors.

(c) Receiving water design flow (Q.). The value of Q, to be used in calcu-lating the effluent limitation for discharges to flowing waters shall be de-termined as follows:

1. The department shall make reasonable efforts to determine the areaof the zone of passage and the dilution characteristics. discharges.

2. The department may require that the discharger provide informa-tion on the discharge mixing and dilution characteristics of discharges.

Register. February, 198». No. 196

54-6NK IN

WISCONSIN ADMINISTRATIVE CODE

3. The discharger shall be allowed to demonstrate, through appropri-ate and reasonable methods that an adequate zone of free passage existsin the cross-section of the receiving water or that dilution is accom-plished rapidly such that the extent of the mixing zone is minimized. Incomplex situations, the department may require that the demonstrationunder this subdivision include water quality modeling or field dispersionstudies.

4. Following the determinations under subds. 1. to 3., the value of Q, ofthe receiving water for calculating effluent limitations based upon thechronic toxicity criteria specified in s. NR 105.06 shall be determined ona case-by-case basis. In no case may Q^ exceed the larger of the averageminimum 7-day flow which occurs once in 10 years (7-day Q10) or, if suffi-cient information is available to calculate a biologically based receivingwater design flow, the How which prevents an excursion from the crite-rion using a duration of 4 days and a frequency of less than once every 3years (4-day, 3-year biological flow).

5. If the requirements of subds. 2. and 3. are not satisfied, the depart-ment shall notify the permittee and identify the deficiencies and allowadditional time, if necessary, to complete the demonstration. If the dem-onstration cannot be completed satisfactorily, the value of Q. of the re-ceiving water for calculating effluent limitations based upon the chronictoxicity criteria specified in s. NR 105.06 shall equal % of the 7-day Q10 or% of the 4-day, 3 year biological flow.

6. Q, may be reduced from those values calculated in subds. 3. to 5.where natural receiving water flow is significantly altered by flowregulation.

7. Q. shall equal 85% of the average minimum 7-day flow which occursonce in 2 years (7-day Qz) of the receiving water for calculating effluentlimitations based upon the wild and domestic animal criteria specified inch. NR 105. Whenever a discharger determines, through techniques ac-ceptable to the department, the average minimum 30-day flow which oc-curs once in 5 years (30-day Qj), this value shall be used as Q,.

8. Except as provided in subd. 9., the value of Q. shall equal the meanannual flow of the receiving water for calculating effluent limitationsbased upon the human cancer criteria or the human threshold criteriaspecified in ch. NR 105 or the taste and odor criteria as specified in ch.NR102.

9. Q. may be reduced from those values calculated in subd. 8. wheneverthe department determines such discharges may directly affect publicdrinking water supplies.

(d) Effluent flova (Q.). 1. For dischargers subject to ch. NR 210 andwhich discharge for 24 hours per day on a year-round basis, Q, shall equalthe average day design flow rate unless it is demonstrated to the depart-ment that such a design flow rate is not representative of projected flowsat the facility.

2. For all other dischargers not subject to ch. NR 210, Q« shall equalthe average annual flow rate.

3. For seasonal discharges, discharges proportional to stream flow, orother unusual discharge situation*, Q, shall be determined on a case bycase basis.RcfttUr. February. 1989. No. 398

1

DEPARTMENT OF NATURAL RESOURCES 54-7N R I M

(e) Background concentration* of toxicant or organoleptic tubttancet (Ct).The representative background concentration of a toxic or organoleptksubstance shall be used in deriving chemical specific water quality basedeffluent limitations. Except as provided elsewhere in this paragraph, therepresentative background concentration shall equal the geometric meanof the acceptable available data for a substance. Background concentra-tions may not be measured at a location within the direct influence of apoint source discharge.

1. The department shall determine representative background concen-trations of toxic substances on a case-by-case bans unifl available dataon the receiving water or similar waterbodua in the state and best profes-sional judgment.

2. The department may utilize representative seasonal concentrationsand may consider other information on background concentrations sub-mitted to the department.

3. Whenever the representative background concentration for a toxicor organoleptic substance in the receiving water is determined to begreater than any applicable water quality standard or criterion for thatsubstance and the source of at least 90% of the wastewater is fromgroundwater or a public drinking water supply, the effluent limitation forthat substance without dilution shall be equal to the lowest applicablewater quality standard or criterion except as provided by subd. 4. Facili-ties subject to ch. NR 210 and which discharge to the same surface waterfrom which the water supply is withdrawn shall be subject to subd. 5.

4. The department may establish limitations greater than the applica-ble water quality standard or criterion for the substance as required bysubd. 3. in a range up to, but not greater than, the representative back-ground concentration of the substance in the receiving water. The limita-tion shall only be increased above the standard or criterion if it is demon-strated to the department that the concentration of the substance in thegroundwater or public drinking water supply at the point of intake ex-ceeds the applicable standard or criterion for that substance and thatreasonable, practical or otherwise required methods are implemented tominimize the addition of the toxic or organoleptic substance to thewastewater. This subdivision shall not apply where groundwater is with-drawn from a location because of noncompliance with the standards con-tained in ch. NR 140.

5. Whenever the representative background concentration for a toxicor organoleptic substance in the receiving water is determined to begreater than any applicable water quality standard or criteria for thatsubstance and the source of more than 10% of the wastewater for anydischarger is from the same receiving water, the effluent limitation forthat substance shall equal the representative background toxicant con-centration of that substance in the receiving water as determined by thedepartment. In the event the discharger's relative contribution to themass of the toxic or organoleptk substance in the receiving water is negli-gible in the best professional judgment of the department, the depart-ment shall establish an alternate effluent limitation for the discharger. Inmaking this judgment, consideration shall be given to the type of sub-stanceDeing limited, the uses potentially affected and other relevant fac-tors. The alternate effluent limitation shall represent in the judgment ofthe department, application of the best demonstrated treatment tech-nology reasonably achievable and shall not exceed the effluent limitation

r. Pcbnury; 1989. No. 398

APPENDIX B

APPENDIX B

SAMPLE WPDES GENERAL PERMIT

Part I, page 1 of 12WPDES Permit No. WI-0046566-2

GENERAL PERMIT TO DISCHARGE UNDERWISCONSIN POLLUTANT DISCHARGE ELIMINATION SYSTEM

In compliance with the provisions of Chapter 147, Wisconsin Statutes, anyfacility located in the State of Wisconsin discharging

CONTAMINATED OR UNCONTAMIMATED GROPNDffATER

meeting the applicability criteria listed in Part I of this General permit, ispermitted to discharge these wastewaters directly to

surface waters of the state and/or indirectly to state groundwaters

in accordance with the effluent limitations, monitoring requirements and otherconditions set forth in this permit.

This permit shall become effective on the date of signature.

This permit to discharge shall expire at midnight September 30, 1995

State of Wisconsin Department of Natural ResourcesFor the Secretary

Mary JBureauDivisi

ky, Director,tewatwr Man^gedent

r Environmentar"Quality

\o

Dated FEB 8 - • 1991

Remedial Action General Permit WPDES Permit No. WI-0046566-2

Table of Contents

Part I,Section Page

A Applicability Criteria 2

B Special Conditions (for all discharges) 4

C Effluent Limitations For Discharges To SurfaceWaters From Remediation of Groundwater Contaminatedby Petroleum Products 6

D Effluent Limitations For Discharges To SurfaceWaters From Remediation of Groundwater Contaminatedby Volatile Organic Compounds 8

E Limitations For Discharges To Groundwaters ViaInfiltration From Groundwater Remedial Actions 10

F Reporting Requirements 12

Part II

General conditions (for all WPDES Permittees)

Part I, Page 2 of 12WPDES Permit No. WI-0046566-2

A. APPLICABILITY CRITERIA

1. Eligible Facilities

This permit is only applicable to uncontaminated or treated contaminatedgroundwater discharges to surface waters or to groundwaters where theDepartment determines that the discharge will not have significant impactson receiving waters.

2. Pollutants Regulated bv this Permit

This permit is designed to regulate the impacts on surface waters from thedischarge of groundwater contaminated by petroleum products and volatileorganic compounds. The permit can also be used to regulate pollutantslisted in NR 140 for wastewater discharges to groundwaters via infiltration.

3. Pollutants Not Properly Regulated bv this Permit

The permit does not adequately protect surface water quality when wastewaterdischarges from groundwater clean-up remediations require limits forpriority pollutant pesticides, toxic metals, phenols or. cyanide. Thispermit is not applicable to discharges requiring limits for these compounds.A separate WPDES permit shall be drafted- on a case-by-case basis for adischarge requiring limits for pollutants of this nature. Except forpolynuclear aromatic hydrocarbons from petroleum product releases, aseparate permit shall also be drafted for a discharge requiring limits forpriority pollutant GC/MS acids or base neutral compounds. Polynucleararomatic hydrocarbons are limited in the permit since they may be found ingroundwater contaminated by petroleum products.

4. Bioaccumulating Toxic Substances

This permit does not authorize the discharge of any of the following 21 bio-accumulating toxic substances. This permit is noj: applicable to dischargescontaining these compounds; such a discharge must be regulated by anindividually drafted permit.

5.

Acroleinalpha-BHCbcta-BHCgamma-BHC (Lindane)tcch.-BHCChlordane3,3'-Dichiorobenzidinc

Cover Letter

DieldrinEndosulfanEndrinFluorantheneHeptachlor4,4'-DDTHcxachlorobenzene

MercuryPCBPentachlorobenzene1,2,4,5-Tetrachlorobenzene23,7,8-Tetrachlorodibe nzo- p-dioxbToxaphcnc2,4,6-Trichlorophenol

This permit is only valid if accompanied by a letter from the Departmentstating that pollutants present in the discharge have been evaluated forcompliance with the applicable surface water or groundwater qualitystandards, and that the general permit limits are sufficiently restrictiveto protect surface and groundwater quality. The cover letter will specify


A. APPLICABILITY CRITERIA (Cont.)

which parameters must be monitored to document compliance with water qualityor treatment technology based standards. Monitoring may be required forparameters not listed in the effluent limit table so that pollutant removalin the treatment system may be evaluated.

6. Outstanding Resource Waters

This permit does not authorize discharges to outstanding resource waters asdefined in Ch. NR 207 and NR 102.10. This permit does not authorizedischarges that would lower the water quality of downstream outstandingresource waters. An individually drafted WPDES permit is required toprotect outstanding resource waters from the effects of any discharge.

7. Waters Classified as a Public Water Supply

This permit does not authorize direct discharges to waters classified as apublic water supply in Ch. NR 103 and NR 104. An individually drafted WPDESsite specific permit is required to protect public water supplies from theeffects of a remediation discharge.

8. Exceptional Resource Waters

This permit may authorize discharges that lower the water quality ofexceptional resource waters as defined in NR 102.11 when the discharge meetsthe requirements of Ch. NR 207, such as preventing or correcting an existinggroundwater contamination situation or a public health problem.

6. More Than One Permit (GP) Can Apply

A WPDES Permit shall be obtained for all wasteuater discharges from afacility that are conveyed through storm sewers, ditches or direct pipes tosurface waters or groundwaters of the state. Facilities dischargingwastewater meeting all the applicability criteria of this permit shallcomply with the effluent limitations, monitoring requirements, and otherconditions of this permit. Chapter 147, Wis. Stats, requires that if awastewater discharge to the environment does jiot meet all of theapplicability criteria of this permit, that discharge must be authorizedunder another WPDES permit. That other permit may be a different generalWPDES permit, or it may be a WPDES Permit specifically drafted for thedischarges from the facility. A facility may discharge wastewater incompliance with one general WPDES permit and discharge other wastewaters incompliance with a different general permit (e.g. the Remedial Action GP forone discharge, and the Non-contact Cooling Water GP for another discharge).The appropriate general WPDES permit is determined by the applicability ofthe permit to the wastewater being discharged. In no way shall thiscondition be used to avoid more stringent requirements.


B. SPECIAL CONDITIONS

1. Surface Water and Groundwater Standards

This permit does not authorize discharges of pollutants in quantities whichwould be harmful to human, animal, plant or aquatic life. No discharge isallowed that would violate surface water quality standards (Ch. NR 102, NR105, NR 106, and NR 207 Wis. Adm. Code) or groundwater quality standards(Ch. NR 140, Wis. Adm. Code).

2. Treatment of Contaminated Groundwater

Any discharge of contaminated groundwater, including pump tests, shall betreated for pollutant removal prior to discharge. The level of treatmentshall be adequate to assure compliance with water quality standards or shallbe equivalent to Best Available Treatment Economically Achievable, whicheveris more restrictive. The treatment unit shall be adequately sized,designed, and operated to remove contaminants identified through samplingand characterization of the discharge. .—

'-———:——" /~o\- K3. Submittal of the Treatment System Design for Approval

Section 144.04, Wisconsin Statutes requires review and approval ofconstruction plans and specifications for wastewater treatment systems.When treatment units for contaminated groundwater are package unitspurchased from a supplier, a minimum plan submittal would be a diagram, asummary of the design, and the sizing calculations for the units.

4. Inspection. Maintenance. and Documentation

Separated contaminants, and solids if present, shall be removed on aperiodic basis to maintain the treatment capacity and efficiency of thesystem. The water discharge side of the treatment unit shall be maintainedclean and there shall be no contaminant sheen or scum on the equipment. Allremoved substances shall be disposed of in accordance with General Condition#18 in Part II of this permit. Documentation of contaminant disposal shallinclude: the amount removed, date of removal, hauling firm, and ultimatefate of the separated material. These records shall be maintained on sice.

5. Floating Solids and Foam

There shall be no direct discharge to surface waters of floating solids orvisible foam in other than trace amounts.

6. Devaterine

Discharges from pumping uncontaminated groundwater to lower the water tableor dewater excavations shall contain Total Suspended Solids (TSS) at 40 mg/Lor less, and Oil/Grease at 10 mg/1 or less on a daily maximum basis. Totaldaily flow, TSS and oil/grease shall be monitored at a frequency specifiedin the cover letter accompanying this permit.


B. SPECIAL CONDITIONS (Cont.)

7. Chlorine for Bacterial Control

Chlorine may be used to control the growth of micro-organisms in thetreatment system. The preferred chlorination system would be to clean andchlorinate the treatment unit when it is out of service, and then capturethe cleaning wastewater for acceptable offsite disposal, such as a sanitarysewer. Alternatively, the cleaning wastewater may be treated for removal ofsuspended solids and other pollutants, and then discharged under thispermit. However, the discharge of chlorinated water to surface waters underthis permit shall not contain detectable amounts of Total Residual Chlorineusing Standard Methods #408B, D or E (DPD titration or colorimetric) or byusing an ion specific electrode approved in Ch. NR 219. Monitoring oftribalomethanes or other chlorinated hydrocarbons may be required for adischarge of chlorinated water. Other biocides may not be discharged underthis permit.

8. pH Limit and Monitoring For Surface Water Discharges

The pH of all surface water discharges authorized by this permit shall bemaintained within the range of 6.0 to 9.0 standard units. A grab sampleshall be analyzed whenever treatment unit cleaning solutions are discharged.

9. Dike or Berm Leakage

Where treatment or disposal ponds are contained by dikes or berms, no aboveground leakage is allowed on the outer surface of such dikes or berms.

10. Other Permits For Work Near Surface Waters

Any work performed below, or within 500 feet of the ordinary high water markof navigable waters, in wetland areas, or within areas subject to localfloodplain and shoreland regulations, must conform to all such county orlocal ordinances. Also, all applicable state permits and/or contractsrequired by Chapters 30, 31, and 87, Stats, (or Wisconsin AdministrativeCode adopted under these laws), and federal permits must be obtained asnecessary for wetland, shoreland or floodplain work of this nature.

11. Other Permits For Air Emissions

The emission of Volatile Organic Contaminants from air stripping ofcontaminated groundwater shall be either exempted from, or in compliancewith a DNR air emission permit. Current regulations call for a permit foremissions of more than 300 pounds of benzene per year. Other air emissionsfrom treatment of contaminated groundwater shall be evaluated on a case-by-case basis regarding the need for an air emission permit.


C. EFFLUENT LIMITATIONS FOR DISCHARGES TO SURFACE WATERS FROM REMEDIATION OFGROUNDWATER CONTAMINATED BY PETROLEUM PRODUCTS

During the period beginning on the date of signature and lasting until September30, 1995, the permittee is authorized to discharge groundwater that has beentreated for removal of petroleum products to surface waters of the state.Surface waters includes ditches, storm sewers and pipes that convey wastewater tocreeks, streams, rivers and lakes in Wisconsin.

1. Where to Sample. Samples representative of the discharge shall be collectedafter treatment and prior to discharge to the environment. When treatmentefficiency reporting is required, the influent sample shall be collectedbefore the wastewater passes through the treatment unit.

2. Regular Wastewater Testing. The cover letter accompanying this permit shallspecify which parameters shall be monitored to assure compliance with waterquality or treatment technology based standards.

3. Surface water effluent limits are specified below for discharges ofgroundwater that have been treated for removal of petroleum products.

Parameter•"•"' n_/ <cO ^

Flow \ C?Total BETXBenzene, (c) S

Polynuclear AromaticHydrocarbons, (d)

Oil/Grease, (e)Total Suspended Solids, (f)

Effluent Limit

750 ug/L, Daily Maximum50 ug/L, Monthly Avg.

0.1 ug/L, Monthly Avg.10 mg/L, Daily Maximum40 mg/L, Daily Maximum

Sample Type

Total DailyGrabGrab

GrabGrabGrab

SampleFrequency

DailySee (a) belowSee (a) below

See (a) belowSee (a) belowSee (a) below

Teat Method—— ^— —

See (b) belowSee (b) below

See (b) belowSee (b) belowSee (b) below

a. Sample Frequency. The discharge shall be sampled weekly during the firstfour weeks of discharge, and then sampled every two weeks. After three months, theDepartment may, by letter, authorize a monthly sampling frequency. Reduced samplingwill only be allowed if the pollutant levels in the discharge are always well belowpermit limits, and there is little chance that influent pollutants may break throughthe treatment unit and violate permit limits. After reviewing a year of sampledata, the Department may reduce the sampling frequency to quarterly.

b. Test Methods. The following test methods shall be used unless specifiedotherwise by a letter from the Department. EPA methods 602, 624, or 1624 shall beused for determination of benzene, ethyl benzene, toluene and total xylenesincluding ortho-, meta-, and para-xylene. EPA method 610 HPLC shall be used for thedetermination of polynuclear aromatic hydrocarbons. EPA method 413.1 (StandardMethods 503A) shall be used for determination of oil and grease when required. EPAMethod 160.2 (Standard Methods 209C) shall be used for determination of totalsuspended solids when required.

c. Benzene . Compliance with the benzene effluent limit will require effectivewastewater treatment consisting of free product separation followed by removal of


C. EFFLUENT LIMITS FOR PETROLEUM PRODUCT REMEDIATIONS (Cont.)

the benzene dissolved in the wastewater. Some pollutant removal will be required inall cases, even when the untreated wastewater could meet the limits listed above.The 50 ug/L benzene limit will assure compliance with Wisconsin Water QualityStandards in almost all cases. A more restrictive water quality based benzene limitwould be included in a permit specifically drafted for a direct discharge to waters,such as the Great Lakes or Lake Winnebago, that are classified as public drinkingwater sources.

d. Polvnuclear Aromatic Hydrocarbons. Groundwater remediation of "heavier"products such as heating fuel, diesel fuel, jet fuel, and other similar substancesmay contain polynuclear aromatic hydrocarbons. Detection of any combination of thefollowing polynuclear aromatic hydrocarbons shall be less than 0.1 ug/L:benzo(a)pyrene, benzo(a)anthracene, benzo(b)fluoranthene, benzo(k)fluoranthene,benzo(g,h,i)perylene, chrysene, dibenzo(a,h)anthracene, indeno(1,2,3 -cd)pyrene,phenanthrene, and pyrene. A more restrictive site specific permit shall be draftedfor a direct discharge of polynuclear aromatic hydrocarbons to waters, such as theGreat Lakes or Lake Winnebago, that are classified as public drinking water sources.

e. Oil and Grease. Monitoring will not be required if the petroleum product issolely gasoline. For "heavier" products such as heating fuel, diesel fuel, jetfuel, and other similar substances, monitoring is important to assure that freeproduct separation followed by VOC removal is effectively treating the wastewater.

f. Total Suspended Solids. Monitoring for TSS shall be required at sites wheregroundwater is pumped from open pits or trenches. Discharges from wells will notrequire monitoring for TSS.

g. Grab Sample. A grab sample means a single sample taken at one moment of timeor a combination of several smaller samples of equal volume taken in less than a twominute period.

h. Daily Maximum Effluent Limitation. A daily maximum effluent limit is to becompared with the result of each analysis performed during that day. Compliance isachieved when each analysis result is less than the maximum daily effluentlimitation.


D. EFFLUENT LIMITATIONS FOR DISCHARGES TO SURFACE WATERS FROM REMEDIATION OFGROUNDWATER CONTAMINATED BY VOLATILE ORGANIC COMPOUNDS

During the period beginning on the date of signature and lasting until September30, 1995, the permittee is authorized to discharge groundwater that has beentreated for removal of volatile organic compounds to surface waters of the state.Surface waters includes ditches, storm sewers and pipes that convey wastewater tocreeks, streams, rivers and lakes in Wisconsin.

1.

2.

3.

Where to Sample. Samples representative of the discharge shall becollected after treatment and prior to discharge to the environment. Whentreatment efficiency reporting is required, the influent sample shall becollected before the wastewater passes through the treatment unit.

Regular Wastewater Testing. The cover letter accompanying this permitshall specify which parameters shall be monitored to assure compliance withwater quality or treatment technology based standards.

Surface water effluent limits are specified below for discharges ofgroundwater that have been treated for removal of volatile organiccompounds. These limits are not restrictive enough to protect the qualityof waters classified as a public drinking water source. A discharge mustbe covered by a site specific WPDES permit when the following limits arenot sufficiently restrictive to meet state water quality criteria.

ParameterFc C

Effluent Limit

FlowTotal Suspended Solids, (e)Acrylonitrile

BromofonnCarbon TetrachlorideChloroformDichlorobromomethane

1,2-Dichloroethane1,1-DichlorocthylcncMethyl BromideMethyl Chloride

L, lA2,-TetrachlorocthancTctrachlorocthylcnel,L2,-Trichloroethane

. TrichlorocthylcneVinyl Chloride

40 mg/L, Daily MaximumSee (c) below

120 ug/L, Monthly Avg.150 ug/L, Monthly Avg.120 ug/L, Monthly Avg.120 ug/L, Monthly Avg.

180 ug/L, Monthly Avg.50 ug/L, Monthly Avg.


50 ug/L, Monthly Avg.50 ug/L, Monthly Avg.SO ug/L, Monthly Avg.


(ySample Type

Total DailyGrab

GrabGrabGrabGrab

GrabGrabGrabGrab

GrabGrabGrabGrabGrab

Frequency

DailySee (a) below

See (a) belowSee (a) belowSee (a) belowSee (a) below

Sec (a) belowSee (a) belowSee (a) belowSee (a) below

See (a) belowSee (a) belowSee (a) belowSee (a) belowSee (a) below

Test Method

See (b) below

See (b) belowSee (b) belowSee (b) belowSee (b) below

See (b) belowSee (b) belowSee (b) belowSee (b) below

See (b) belowSee (b) belowSee (b) belowSee (b) belowSee (b) below

a. Sample Frequency. The discharge shall be sampled weekly during the firstfour weeks of discharge, and then sampled every 'two weeks. After three months, theDepartment may, by letter, authorize a monthly sampling frequency. Reduced samplingwill only be allowed if the pollutant levels in the discharge are always well below


D. EFFLUENT LIMITS FOR VOLATILE ORGANIC COMPOUND REMEDIATIONS (Cont.)

permit limits, and there is little chance that influent pollutants may break throughthe treatment unit and violate permit limits. After reviewing a year of sampledata, the Department may reduce the sampling frequency to quarterly.

b. Test Methods. The following test methods shall be used unless specifiedotherwise by a letter from the Department. EPA methods 601 or 624 shall be used fordetermination of volatile organic compounds. EPA Method 160.2 (Standard Methods209C) shall be used for determination of total suspended solids when required.

c. Acrvlonitrile. Discharges containing detectable quantities of Acrylonitrileshall not be regulated by this permit, but by a separate WPDES permit specificallydrafted for the discharge. This permit does not regulate acrylonitrile because ofthe very low water quality criteria, problems in treating the compound and thedifficulties of obtaining adequate analysis detection limits.

d. Treatment of Volatile Organic Compounds. This permit requires effectivetreatment, such as air stripping or activated carbon adsorption, for dischargescontaining volatile organic chemicals. Some pollutant removal will be required inall cases, even when the untreated wastewater could meet the limits listed above.This requirement for wastewater treatment will assure compliance with WisconsinWater Quality Standards in almost all cases. When more restrictive water qualitybased effluent limits are needed, such as for direct discharges to very low flowcold water fisheries, outstanding resource waters, or to waters that are classifiedas public drinking water sources, a site specific WPDES permit shall be individuallydrafted to regulate the discharge.

e. Total Suspended Solids. Monitoring for TSS shall be required at sites wheregroundwater is pumped from open pits or trenches. Discharges from wells will notrequire monitoring for TSS.

f. Grab Sample. A grab sample means a single sample taken at one moment of timeor a combination of several smaller samples of equal volume taken in less than a twominute period.

g. Monthly Average Effluent Limitation. A monthly average effluent limit is tobe compared with the result of the average of all the analyses performed during the.month. Compliance is achieved when the average analysis result is not greater thanthe monthly average effluent limitation.


E. LIMITATIONS FOR DISCHARGES TO GROUNDWATERS VIA INFILTRATION FROM GROUNDWATERREMEDIAL ACTIONS

During the period beginning on the date of signature and lasting until September30, 1995, the permittee is authorized to discharge vastewaters that have beentreated for pollutant removal to groundwaters of the state. A discharge togroundwaters in Wisconsin includes wastewater infiltration from irrigation, drainfields, ditches, and ponds that may impact water beneath the ground surface.

1. Treatment of Wastewater Pollutants For Discharges to Seepage. Uastewatertreatment will be required to minimize the level of substances in thegroundwater and to prevent exceedance of the groundwater preventive actionlimits (PAL) contained in Chapter NR 140, Wisconsin Administrative code, tothe extent that it is technically and economically feasible.

2. Where to Sample. Compliance with the NR 140 groundwater quality standardsshall be demonstrated either by sampling water from groundwater monitoringwells or by sampling wastewater treatment effluent before discharge. Whentreatment efficiency reporting is required, the influent sample shall becollected before the wastewater passes through the treatment unit.

3. Cover Letter. Limits and monitoring requirements necessary to assurecompliance with Ch. NR 140 groundwater quality standards will be specifiedby letter on a case by case basis.

4. Preventive Action Limits for Petroleum Product Reroediations. The followingare the Ch. NR 140 FAL's for petroleum products:

Benzene - 0.067 ug/L Toluene - 68.6 ug/LEthylbenzene - 272 ug/L Xylene - 124 ug/LEDB - 0.001 ug/L

5. Preventive Action Limits for Volatile Organic Compound Remediations. Thefollowing are the PAL's for volatile organic compounds listed in NR 140:

1.1-Dichloroethane - 85 ug/L1.2-Dichloroethane - 0.05 ug/L Tetrachloroethylene - 0.1 ug/L

1.1-Dichloroethylene - 0.024 ug/L 1,1,1,-Trichloroethane - 40 ug/L1.2-Dichloroethylene (cis) - 10 ug/L 1,1,2,-Trichloroethane - 0.06 ug/L1,2-Dichloroethylene (trans) - 20 ug/L Trichloroethylene - 0.18 ug/L

Methylene Chloride - 15 ug/L Vinyl Chloride - 0.0015 ug/L

6. Enforcement Standards. The enforcement standards for the compounds listedabove are 10 times the preventive action limit, except for the followingcompounds that are listed with their enforcement standard: Benzene- 5 ug/L.1,2-Dichloroethane - 5 ug/L, 1,1-Dichloroethylene - 7 ug/L,Trichloroethylene - 5 ug/L, and Vinyl Chloride - 0.2 ug/L.


E. LIMITS FOR REMEDIAL ACTION DISCHARGES TO SEEPAGE (Cont.)

7. §ample Frequency. The discharge shall be sampled weekly during the firstfour weeks of discharge, and then sampled every two weeks. After threemonths, the Department may, by letter, authorize a monthly samplingfrequency. Reduced sampling will only be allowed if the pollutant levelsin the discharge are always well below permit limits, and there is littlechance that influent pollutants may break through the treatment unit andviolate permit limits. After reviewing a year of sample data, theDepartment may reduce the sampling frequency to quarterly.

8. Test Methods. The following test methods shall be used unless specifiedotherwise by a letter from the Department. EPA methods 602, 624, or 1624shall be used for determination of benzene, ethylbenzene, toluene and totalxylenes including ortho-, meta-, and para-xylene. EPA methods 601 or 624shall be used for determination of volatile organic compounds.

9. %gport;j.ng J esulj:s. Compliance with the groundwater standards may bedemonstrated by reporting an analytical result less than the PAL or byreporting a result less than the level of detection using the recommendedanalytical test methods specified above.

10. Flow. Total daily discharge volume records shall be retained forinspection for 3 years and shall be submitted with other monitoring reportsas required. The required flow measurement method shall be specified inthe cover letter accompanying this permit.


F. REPORTING REQUIREMENTS

1. Monitoring results shall be submitted to the Department by letter on amonthly basis, or during the month following analysis for less frequentmonitoring requirements.

2. Records shall be maintained of total daily discharge volumes. Such recordsshall be retained for inspection by this Department or shall be submittedwith other monitoring reports if required.

3. Reports required by this permit shall be signed:

(a) for a corporation by a principal executive officer of at least thelevel of Vice President or his/her duly authorized representativehaving overall responsibility for the operation of the facility forwhich this permit is issued,

(b) for a partnership by a general partner, and

(c) for a sole proprietorship by the proprietor.

4. Discharge monitoring reports, and any other special reporting requiredby Fart I or Part II (the general conditions) of this permit, shall besubmitted to the address of the DNR district office printed on thedischarge monitoring report, or to:

Wisconsin Department of Natural ResourcesWPDES Permit SectionP.O. Box 7921Madison, Wisconsin 53707

PART IIGENERAL CONDITIONS

1. Duty toThe permittee shall comply with all conditions of the permit. Any permitnoncompliance is a violation of the permit and is grounds for enforcementaction, denial of coverage under the general permit, or denial of a permitre issuance application.

2. Permit actionsAs provided in s. 147.03, Stats., after notice and opportunity for a hearingthe permit may be modified or revoked- and reissued for cause. If thepermittee files a request for an individual permit or a notification ofplanned changes or anticipated noncompliance, this action by itself does notrelieve the permittee of any permit condition.

3. Property rightsThe permit does not convey any property rights of any sort, or any exclusiveprivilege. The permit does not authorize any injury or damage to privateproperty or any invasion of personal rights, or any infringement of federal,state or local laws or regulations.

4. Inspection and entryThe permittee shall allow an authorized representative of the Department, uponthe presentation of credentials, to:

a. Enter upon the permittee7 s premises where a regulated facility oractivity is located or conducted, or where records are required underthe conditions of the permit;

b. Have access to and copy, at reasonable times, any records that arerequired under the conditions of the permit;

c. Inspect at reasonable times any facilities, equipment (includingmonitoring and control equipment), practices or operations regulatedor required under the permit; and

d. Sample or monitor at reasonable times, for the purposes of assuringpermit compliance, any substances or parameters at any location.

5. Recording of resultsFor each effluent measurement or sample taken, the permittee shall record thefollowing information.

a. The date, exact place, method and time of sampling or measurements;b. The individual who performed the sampling or measurements;c. The date the analysis was performed;d. The individual who performed the analysis;e. The analytical techniques or methods used; andf. The results of the analysis.

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6. Records retentionThe permittee shall retain records of all monitoring information, includingall calibration and maintenance records and all original strip chartrecordings for continuous monitoring instrumentation, copies of all reportsrequired by the permit, and records of all data used to complete theapplication for the permit for a period of at least 3 years from the date ofthe sample, measurement, report or application. The Department may requestthat this period be extended by issuing a public notice to modify the permitto extend this period.

7. Signatory requirementAll applications, reports or information submitted to the Department shall besigned for a corporation by a responsible corporate officer including apresident, secretary, treasurer, vice president or manager; and for amunicipality by a ranking elected official; or other person authorized by oneof the above and who has responsibility for the overall operation of thefacility or activity regulated by the permit. The representative shallcertify that the information was gathered and prepared under his or hersupervision and based on inquiry of the people directly under his or hersupervision that, to the best of his .or her knowledge, the information istrue, accurate and complete.

8. Compliance schedulesReports of compliance or noncompliance with interim and final requirementscontained in any compliance schedule of the permit shall be submitted inwriting within 14 days after the schedule date, except that progress reportsshall be submitted in writing on or before each schedule date for each report.Any report of noncompliance shall include the cause of noncompliance, adescription of remedial actions taken and an estimate of the effect of thenoncompliance on the permittee's ability to meet the remaining schedule dates.

9. • TransfersA permit is not transferable to any person except after notice to theDepartment. In the event of a transfer of control of a permitted facility,the prospective owner or operator shall notify the Department WPDES permitsection in writing. The Department may require the prospective owner to filea new permit application and obtain an individual permit to reflect therequirements of ch. 147, Stats.

10. Proper operation and maintenanceThe permittee shall at all times properly operate and maintain all facilitiesand systems of treatment and control which are installed or used by thepermittee to achieve compliance with the conditions of the permit. Thewastewater treatment facility shall be under the direct supervision of a statecertified operator as required in s. NR 108.06(2). Proper operation andmaintenance includes effective performance, adequate funding, adequateoperator staffing and training as required in ch. NR 114 and adequatelaboratory and process controls, including appropriate quality assuranceprocedures. This provision requires the operation of back-up or auxiliaryfacilities or similar systems only when necessary to achieve compliance withthe conditions of the permit.

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11. Duty Co mitigateThe permittee shall take all reasonable steps to minimize or prevent anyadverse Impact on the waters of the state resulting from noncompliance wichthe permit.

12. Duty to provide informationThe permittee shall furnish the Department, within a reasonable time, anyinformation which the Department may request to determine whether cause existsfor modifying, revoking or reissuing the permit or to determine compliancewith the permit. The permittee shall also furnish the Department, uponrequest, copies of records required to be kept by the permittee.

13. Sampling proceduresSamples and measurements taken for the purpose of monitoring shall berepresentative of the volume and nature of the monitored discharge and shallbe taken at points specified in the permit using sample types specified in thepermit and the following procedures:

a. For effluent flow measurement and sample collection - ch. NR 218.b. For groundwater sample collection.and analysis - ch. NR 214.

14. Test proceduresMonitoring shall be conducted according to test procedures listed in ch.NR 219, or any other test procedures specified in the permit.

15. Additional monitorineIf a permittee monitors any pollutant more frequently than required by thepermit, using test procedures specified in ch. NR 219, the results of thatmonitoring shall be recorded and reported in accordance with this chapter.Results of this additional monitoring shall be included in the calculation andreporting of the data submitted in the DMR.

16. Monitoring reportsThe monitoring results shall be reported at the intervals specified in thepermit. Monitoring results shall be summarized on forms designated by theDepartment.

Note: The forms used for monitoring reports are DMR Forms 3200-28 and3200-40.

17. Noncompliance notification

a. The permittee shall report the following types of noncompliance by atelephone call to the Department's district office within 24 hoursafter becoming aware of the noncompliance.

(1) Any noncompliance which may endanger health or the environment.(2) Any violation of an effluent limitation resulting from anunanticipated bypass.(3) Any violation of an effluent limitation resulting from an upset.(4) Any violation of a maximum daily discharge limitation for thosepollutants specifically designated in the permit to be reportedwithin 24 hours.

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b. A written report describing the noncompliance reported in condition17, part a. shall be submitted to the Department's district officewithin 5 days after the permittee becoming aware of thenoncompliance. The Department may waive the written report on acase-by-case basis based on the oral report received within 24 hours.The written report shall contain a description of the noncomplianceand its cause; the period of noncompliance, including exact daces andtimes; the steps taken or planned to reduce, eliminate and preventreoccurrence of the noncompliance; and if the noncompliance has notbeen corrected, the length of time it is expected to continue.

c. Reports of all noncompliance not required to be reported undercondition 8 or condition 17, parts a. and b. shall be submitted withthe monitoring reports required under condition 16.. The reportsshall contain all the information listed in condition 17, part b.

18. Removed substancesSolids, sludges, filter backwash or other pollutants removed from or resultingfrom treatment or control of wastewaters or intake waters shall be stored anddisposed of in a manner to prevent any pollutant from the materials fromentering the waters of the state. Land disposal of treatment plant solids andsludges shall be at a site or operation licensed by the Department under ch.NR 180 or 181, or in accordance with ch. NR 214.

19. Solll reportingThe permittee shall notify the Department in accordance with ch. NR 158, inthe event that a spill or accidental release of any material or substanceresults in the discharge of pollutants to the waters of the state at a rate orconcentration greater than the effluent limitations established in the permit,or the spill or accidental release of the material is unregulated in thepermit, unless the spill or release of pollutants has been reported to theDepartment under condition 17.

20. Planned changesIn accordance with ss. 147.02(4)(b) and 147.14(1), Stats., the permittee shallreport to the Department any facility expansion, production increase orprocess modifications which will result in new, different or increaseddischarges of pollutants. The report shall either be a new permit applicationor, if the new discharge will not violate the effluent limitations of thepermit, a written notice of the new, different or increased discharge. Thenotice shall contain a description of the new activities, an estimate of thenew, different or increased discharge of pollutants and a description of theeffect of the new or increased discharge on existing waste treatmentfacilities. Following receipt of this report, the Department may issue anindividual permit to specify and limit any pollutants not previously regulatedin the general permit.

Note: The notification should be directed to the Industrial WastewaterSection.

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21. Increased discharge of toxic pollutants

a. 'Routine or frequent increase'. The permittee shall notify theDepartment in writing as soon as it knows or has reason to believethat any activity has occurred or will occur which would result, on aroutine or frequent basis, in the discharge of any toxic pollutantwhich is not limited in the permit, if that discharge exceeds thehighest of the following levels.

(1) One hundred micrograms per liter (100 ug/1);

(2) Two hundred micrograms per liter (200 ug/1) for acrolein andacrylonitrile; five hundred micrograms per liter (500 ug/1) for2,4-dinitrophenol and for 2-methyl-4,6-dinitrophenol; and onemilligram per liter (1 mg/1) for antimony;

(3) Five times the maximum concentration value reported for thatpollutant in the permit application; or

(4) A notification level greater than the level in sections (1), (2),or (3) above, which the Department has included as a specialcondition of the permit.

b. 'Nonroutine or infrequent increase'. The permittee shall notify theDepartment in writing as soon as it knows or has reason to believethat any activity has occurred or will occur which would result, on anonroutine or infrequent basis, in any discharge of a toxic pollutantwhich is not limited in the permit, if that discharge will exceed thehighest of the following levels.

(1) Five hundred micrograms per liter (500 ug/1);

(2) One milligram per liter (1 mg/1) for antimony;

(3) Ten times the maximum concentration value reported for thatpollutant in the permit application; or

(4) A notification level greater than the level in sections (1), (2),or (3), above which the Department has included as a specialcondition to the permit.

22. Duty to halt or reduce activityUpon failure or impairment of treatment facility operation, the permitteeshall, to the extent necessary to maintain compliance with its permit, curtailproduction or wastewater discharges or both until the treatment facilityoperations are restored or an alternative method of treatment is provided.

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23. BypassThe permittee may bypass waste treatment facilities if this is necessary forthe essential maintenance of the facilities and if the bypass does not exceedpermit effluent limitations. The permittee may also bypass if the bypass isdue to runoff in excess of the 10 year, 24 hour rainfall event and the bypassis designated as a specific discharge point in the WPDES permit. All otherbypasses of waste treatment facilities, including diversion of wastewater fromland disposal systems to surface waters, are prohibited unless the followingconditions are met:

a. The bypass is necessary to prevent loss of life, personal injury orsevere property damage;

b. There are no feasible alternatives to the bypass, such as the use ofauxiliary treatment facilities, retention of untreated wastes ormaintenance during normal periods of equipment downtime; and

c. The permittee submitted written notice 10 days before the date of thebypass and the Department' s district office wastewater supervisor hadapproved the bypass in writing prior to its occurrence; or

d. In the event of an unanticipated bypass, the permittee notified theDepartment verbally within 24 hours and in writing within 5 days ofeach unanticipated bypass.

24. The department shall withdraw a point source from coverage by a generalpermit and issue an individual permit upon written request of the discharger.

25. The department may require any point source covered by a general permitto apply for and obtain an individual permit if:

a. The point source is a significant contributor of pollution or if thepoint source is more appropriately regulated by an individual permit.Any person may submit a written request that the department takeaction under this section;

b. The point source is not in compliance with the terms and conditionsof the general permit;

c. A change occurs in the availability of demonstrated technology orpractices for the control or abatement of pollutants from the pointsource or class of discharger;

d. Effluent limitations or standards are promulgated for a point sourceor class of point sources covered by the general permit and aredifferent than the conditions contained in the general permit;

e. A water quality management plan containing requirements applicable tothe point source is approved.

v:\perm\ww9gcond.beb

APPENDIX C

APPENDIX C

JULY 11, 1991 LETTER FROM CITY OF EAU CLAIRE

TO EDER ASSOCIATES

tmcnt of Public Works

(715) 839-4934

City of Eau Claire203 S. FARWELL STREET - P.O. BOX. 5148, EAU CLAIRE, WISCONSIN 54702-5148

July 11, 1991

Leonard EderEder Associates480 Forest AvenueLocust Valley, New York

Dear Mr. Eder:

11560

In your July 8, 1991, letter to me, you indicated that youplan to discharge ground water from National Presto Industriesintercepter wells into Eau Claire's storm sewers after the systemis in full operation.

As I indicated to you previously, the city needs to know theflow rate, the point of discharge, and how the system will bedesigned to shut down during rainstorms before we approve the useof our storm sewers for this project. He have problems with stormsewers in this area, and the storm sewers may need to be upgradedto accept this plan.

If you intend to pursue using Eau Claire's storm sewers, sendyour request and additional information to:

William BittnerDirector of Public WorksCity Hall203 S. Farwell StreetEau Claire, WI 54703

Discharge of the full scale pumping operation into sanitarysewers is not acceptable to the City.

Please let me know if I can be of any assistance. The citywould like to help you make this go as smoothly as possible. Myphone number is 715 839-5045.

Sam Spanel, P.E.Utilities Administrator

cc: William BittnerBrian AmundsenRichard NaumanMike GiffordJim Boettcher

RECEIVEDAT EA

JUL 171991

Fii-t

OTHER

APPENDIX D

APPENDIX D

AUGUST 2, 1991 LETTER FROM CITY OF EAU CLAIRETO EDER ASSOCIATES

RCV BY'EDES ASSOCIATES J fl- 2-91 i UBCPK JCITY OF EAU CLAIRE •* 51flfl713848;« 2

of Public Works(71 fi) 839-4004

City of Eau Claire209 a. PARWCLL STREET • P.O. BOX 9146, EAU CLAIRE. WISCONSIN 34702-0140

August 2, 1991

Mr. Leonard Bder, P.H.Hder Associates480 Forest AvenueLocust Vallay, Ntw York 11560

Re: Groundwetcr Interceptor Well Discharge,National Presto Industries

Dtar Mr. Edit;

Tills is in response to your letter of July 26, 1991. The City of Bau Claire will allowthe use of the dry storm sewer system for conveyance of groundwater interceptedfrom the National Presto Industries site.

As discussed, the City will require the installation of a system, acceptable to the dry,which discontinues pumping when the capacity of the storm sewer is taxed.

We look forward to working with you on your effort* to implement the remedialaction.

Sincerely)

WUliam L BittnerDirector of Public Works

WLBigy

APPENDIX E

APPENDIX E

ESTIMATE OF CASCADE AERATION SYSTEM

VOC REMOVAL EFFICIENCY

The removal efficiency of a cascade aerator was estimated bydrawing a comparison between a cascade aerator and a surfaceaerator, recognizing that the most significant difference betweenthe two is the form of power used to mix the air and water. In thecascade aerator, mixing is created by gravity rather than bymechanical agitation, as is the case with the surface aerator.However, by analogy with the surface aerator the VOC removal ratefor the cascade is related to the amount of mixing and agitation.Therefore, once the power generated by the cascading water iscalculated, the VOC removal rate due to mixing can be calculated byusing a common correlation between surface aerator horsepower andVOC removal.

The energy for mixing can be calculated based on the dynamichead of the falling water:

= &xSGxH3960

Where: WHP - water horsepowerQ = flow rate (gpm)SG = specific gravity of water (1)H = dynamic head (ft)

Once the horsepower of the falling water is known, thefollowing correlation for a surface aerator can be used todetermine the VOC removal efficiency for the cascade:

, Ci 1 Du,Mr x a xHP = 8.34 x MOD x -=±-1 \ x **cCe 0.56 x 3 x 24

Where: MGD = flow rate in millions of gallons perday

Ci = influent concentrationCe = effluent concentration

D0sat = dissolved oxygen saturation level atoperating temperature in milligramsper liter

o = relative rate of oxygen transfer ascompared to clean water (l forgroundwater)

9 = temperature correction constant.(1.024)

By using this approach, it is estimated that for a flow rateof 500 gpm a nine foot high cascade would have a removal efficiencyof 50% with an air temperature of 20°C. During the winter monthswhen the average temperature in Eau Claire is -10°C, the removalefficiency would drop to 44%.

PHASED FEASIBILITY STUDYNATIONAL PRESTO INDUSTRIES, INC.

EAU CLAIRE, WISCONSIN

eder associates consulting engineers, p.c.NEW YORK MICHIGAN WISCONSIN GEORGIA

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eder associates consulting engineers, p.cNEW YORK MICHIGAN WISCONSIN GEORGIA

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