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PUBLIC HEALTH ASSESSMENT

CITY DISPOSAL CORPORATION LANDFILL
(a/k/a CITY DISPOSAL SANITARY LANDFILL)
DUNN TOWNSHIP, DANE COUNTY, WISCONSIN


PREFACE: THE PURPOSE OF HEALTH ASSESSMENTS

The federal "Superfund" law requires the U. S. Agency for Toxic Substances and Disease Registry(ATSDR) to conduct a health assessment of all toxic waste sites that the U. S. EnvironmentalProtection Agency (EPA) proposes for inclusion on the list of the nation's most hazardous wastesites. This list formally is called the National Priorities List. The Wisconsin Division of Health(WDOH) works with ATSDR to prepare assessments. The purposes of health assessments are:

  1. To evaluate whether contaminants at the site pose a current or future threat to public health;

  2. To recommend any steps needed to protect the public from exposure to toxic substances, and

  3. To recommend long-term health studies, when appropriate.

For each assessment health professionals look at the types of contamination present, including eachchemical's toxicity; ability to move through soil, water or air; persistence in the environment; andability to accumulate in the food chain. They look at ways that people could be exposed tocontaminants such as eating, breathing, or touching the chemicals. Investigators check relevanthealth records when appropriate to see if there may be increases in health effects related to publicexposure to contaminants from the site. Finally, an assessment identifies the health hazards that asite may pose and recommends action to protect public health now and in the future.

A preliminary health assessment was done for this site in 1988. This public health assessmentmakes use of additional information since the time of the preliminary health assessment. Thisdocument was made available for public comment in August 1993. Public comments and WDOH's responses are listed in the last section of this assessment.


SUMMARY

The City Disposal Corporation Landfill, also known as the Dunn Landfill, operated from 1966 to1977. When the site was abandoned, it was capped with soil from the site and vegetated. The sitehad been used for the disposal of both municipal and industrial wastes. The site is located aboutone-half mile northeast of the Village of Oregon in Dane County, Wisconsin. The existing capallows rainwater to infiltrate the wastes and carry contaminants to the groundwater. Groundwater atthe site is contaminated with volatile organic compounds. Contaminated groundwater has migrateda short distance off-site. Private wells near the site have not been contaminated by the site. Thegroundwater pathway is the principal environmental pathway of concern. Contamination is notdischarging to surface water. Because the landfill is not generating very much methane gas, thelikelihood of significant contaminant releases to the air pathway is low. Although access is notsignificantly restricted, wastes are not exposed at the surface. Drums of investigative wastes storedon the top of the site may present a physical hazard, or an exposure risk if opened.

The potential for future exposure to contaminated groundwater poses a public health hazard. Futureexposures to contaminated groundwater are possible if contaminants move into private wells. Exposures to contaminants from groundwater could be from inhalation and dermal exposure duringshowering, and ingesting drinking water. Planned remedial activities are expected to adequatelyaddress these potential exposures. Exposures to contamination from this site are not known to haveoccurred. At present there appears to be no public health hazard associated with the site.

The WDOH, in cooperation with ATSDR's Health Activities Recommendation Panel, reviewed thedata and information used to prepare this health assessment. WDOH will conduct the following activities to respond to the recommendations of this assessment:

  1. Provide continuing public health education as new information related to public health issues becomes available;

  2. Review and comment on public health aspects of the remedial design for the site.

  3. Advise and consult with the Wisconsin Department of Natural Resources and the EPA onpublic health concerns that may arise as new information about the site becomes available.

BACKGROUND

Location of City Disposal Corporation Landfill site in Dane County, Wisconsin.

SITE DESCRIPTION/HISTORY

The City Disposal Landfill, covers 38 acres of a 58 acre landfill approximately one-half milenortheast of the Village of Oregon in Dane County, Wisconsin. This site is 400 feet west of abranch (man-made channel) of Badfish Creek. The site is surrounded by a rural residential andagricultural setting which is moderately populated. This unlined landfill was operated and filledwith municipal and industrial waste from 1966 through March of 1975. Industrial wastes includedsolvents, lubrication oil, and paint wastes. The site was divided into 12 cells of which 1, 2, 3, 4, 6,and 12 were used for waste disposal. Cells 1 and 12 were utilized from initial disposal until 1974. Cells 2, 3, 4, and 6 were filled or partially filled from 1974 until it was closed in 1977. Industrialwastes were disposed in cell 12 from 1966 through March of 1975 (1, pg. 9).

In the eastern part of the landfill, a portion of cell 12 was designated for the disposal of industrial waste. Cell 6, in the northwestern portion of the landfill, was also used for the disposal of industrial wastes. In cell 12 liquid industrial wastes were mixed with other solid wastes. Drums of liquid wastes were opened and drained into the cell. Refuse was then mixed with the liquid and compacted. It appears that drums were not disposed of with the wastes(1, pg.45). Specific wastes include: xylene, naphtha, cyclohexanone, tetrahydrofuran, and oil-water mixtures. These wastes were either contained in 55 gallon drums or dumped out of the drums and covered periodically. An estimated 2.7 million gallons of potentially toxic and hazardous waste were disposed from 1966 to 1975(5, pg 2). Industrial waste disposal was phased out in 1975. In 1977, the permit issued by the Town of Dunn expired and was not reissued. The site was operated by City Disposal Corporation and later by Acme Services, Inc.. After the site was closed, Acme and City Disposal Corp. were bought by Waste Management of Wisconsin, Inc. (WMWI) (1, pg. 9). The site is closed and capped. The second revision of the Remedial Investigation/ Feasibility Study Work Plan for this site was completed in April, 1988, with additions and revisions in August, 1988.

Site Location Map.

In May of 1981 Waste Management of Wisconsin, Inc. purchased approximately 38 acres ofproperty encompassing the filled area and an easement for access. In 1989 Waste Management ofNorth America purchased land to the north and south to eliminate potential access problems. Onetract of land adjacent to the southern portion of the fill area is not owned by Waste Management(1,pg.11). A preliminary health assessment was done for this site in 1988. No remedial activities havetaken place at the site. Waste Management of Wisconsin, Inc. has periodically repaired eroded areas(1, pg. 14).



City Disposal Site Map. The Remedial Investigation and the Feasibility Study for the site have been completed by Waste Management's contractor. EPA's selected alternatives for the remedial action consists of three general activities. The first of these activities requires capping the site with an impermeable clay cap and an additional geomembrane over cells six and twelve. The purpose of this action is to prevent additional rain water from penetrating the cap and carrying contaminants from the wastes into the groundwater. The second activity will include the installation of gas extraction wells into the waste to manage landfill gas, and the installation of soil vapor extraction wells beneath the waste to remove VOC contamination. The gases removed in this way are then to be burned. The purpose of this action is to speed the overall cleanup of the site by removing contaminants from the wastes. The third activity consists of pumping and treating the groundwater from extraction wells near the site. This action will serve two purposes: 1) groundwater will be contained to prevent further contaminant migration, and 2) contaminants will be removed from the water and destroyed in a treatment process (2).



 

Groundwater flow from the City Disposal Site. Any planned remedial activity will not likelytake place for about eighteen months due to theextensive administrative requirements involvedwith the remedial design phase.

Groundwater flow in the area of the site flowscontrary to what surface topography wouldindicate. There is a groundwater dividethrough the center of the site passing fromnorth to south. Groundwater to the west of thedivide flows north, while to the east of thedivide the flow is to the northeast. BadfishCreek may influence local groundwater flow near the northeastern portion of the site. The combination of localgroundwater flow and influence from Badfish Creek has the effect of stalling northeasterly flow andforcing groundwater to the southeast near the creek (see figure 4).

The groundwater table at the site is relatively flat. For this reason groundwater flow is not verypronounced and is easily influenced by changes in hydrology. It is believed that during disposalactivities at the site, the addition of liquid wastes created a mounding effect near cell 12. Contaminated groundwater flowed radially from the disposal area until disposal ceased. Normalflow patterns resumed after disposal ceased. Residual contamination can still be detected inmonitoring wells just south of cell twelve as a result of the past mounding effect.

The landfill is located on the Milton Moraine. The moraine trends northwest throughout the area,and has an irregular hummocky topography with many kettles causing it to be poorly drained.

There is about 100 feet of relief near the site ranging from a ridge to the north of the site to the waterlevel of Badfish Creek. Surface water runoff at the site drains predominantly towards the northeastand east to Badfish Creek. This site is located in the Yahara River drainage basin. The YaharaRiver in turn flows into the Rock River several miles further downstream.

A soil survey was prepared as part of the remedial investigation to assess the composition, integrity,and thickness of the existing soil cover. The grade of the cover does not provide efficient drainage ofsurface water. Standing water has existed at several locations on site during field work(1, pg.39). Samples of the cap soils were a combination of clays, clayey and silty sand. The sandier soils werelocated primarily in the southeastern portion of the site(1, pg.42). There are locations where covermaterial is quite thin and even areas where waste has been exposed. The thickness of the cap rangesfrom six inches to approximately four feet with an average of 1.7 feet(1, pg.42).

Seepage Exiting ATSDR Website had been observed in the past on the southern slope at a number of locations. Seeps wereattributed to disturbances from cattle grazing on the slopes. Cattle were not allowed to access thelandfill area after September 1988. No leachate has been detected in leachate headwells since theywere installed in April of 1989. Leachate headwells were monitored twice weekly during theremedial investigation. The bottom of the wastes is five to twenty feet above the groundwatertable(1, pg.45).

SITE VISIT

The site visit was completed by Beth Fiore and Meg Ziarnik of WDOH on August 26, 1988. Alsoin attendance were staff from Wisconsin Department of Natural Resources (WDNR) and WMWI. Previously, WMWI had noted leachate, but none was noted that day. The time of the noted leachateis not documented. This could have been due to the drought conditions. Current activity at the siteis limited to the building of a decontamination area including the cement base and related grating. The cap is porous, of unknown depth, and appears incomplete in some areas. Three homes, one afarm and two strictly residential, border the road leading to the site. There is also a farm within viewfrom cell 12, approximately one-half mile away. Across that road there was a cable with a "NoTrespassing" sign. There was also a gate at the site entrance. The entire site is fenced primarilywith barbed wire and in some places posts with horizontal steel bars. These access restrictions werenot sufficient in the opinion of the site visitors. Cows are kept in a field across the road from the site. Off-site at Badfish Creek, there were clear signs that cows drink the creek water. The cows are keptoff the site by an electric fence in the area of cell 12. WDNR commented that the creek is used toaccess a hunting area upstream. Corn fields were adjacent to the site and residential gardens werelocated at two of the three homes near the site.

On that same day, WDOH staff met with local public officials to discuss concerns related to the site. The major concern appears to be the need for more private well testing to determine whetherresidents in the vicinity of the site are being exposed to contaminants. No health complaintsassociated with the site have been made to these officials(5, pg 3).

A second site visit was made by Chuck Warzecha of WDOH with the WDNR project manager onWednesday, April 8th, 1992. The location of the site with respect to private homes that had beensampled was identified. All of the wells adjacent to the perimeter of the site had been sampled inaddition to others. There is a gate across the access road to the site. The site is otherwise accessibleon foot. Badfish Creek and Grass Lake block access from the east other than the bridge on theaccess road. The rest of the site is surrounded by private property with no public access. There wereclear signs that people crossed the property on occasion. The cap of the landfill is covered with over100 drums of investigative wastes from the site. These wastes had been there at least through thispast winter and many have expanded under frost pressure. The cap of the site is heavily vegetated. The landfill cap is partially sloped, but there were areas where water would stand on the cap.

DEMOGRAPHICS, LAND USE, AND NATURAL RESOURCE USE

The nearest residence is approximately 800 feet from the site. There are three residences, includingone farm, at the road leading to the site. In all, there are four residences within 1500 feet of thewaste disposal boundary(1, pg 32). There are no future development plans for the site. Within ahalf-mile from the site are the village limits for the Village of Oregon.

Recent census data for the area of the site are presented by zip code. The site is included in the zipcode area for the Village of Oregon and near the zip code area for the Village of McFarland. Because of its location between the two population centers the figures for the two zip code areashave been averaged. The average population per household in this area is 2.85 people. The averagehousehold income is $39,124. Racial distribution is 98% White, 1.1% Black, .25% AmericanIndian, .35% Asian(3, pg 357).

The land surrounding the site is predominantly agricultural and rural residential. A small lake(Grass Lake) is less than a quarter of a mile northeast of the site. Badfish Creek runs from north tosouth along the eastern edge of the site between the site and Grass Lake. This creek consistsprimarily of treated effluent from Madison Metropolitan Sewerage District. The sewerage districtdischarges to the creek at a rate of 24 to 55 million gallons per day. There are residences and acattle farm to the east of the site within 1500 feet. Adjacent to the southwest are pasture lands andbeyond are residences approximately 1,000 feet away.

As noted previously, the area proximate to the site is a sparsely populated agricultural andresidential area consisting of small farms. The primary crop in the area is corn which is raised forhuman consumption and livestock feed. Cattle are raised for beef or breeding, but not for milkingpurposes in the farm adjacent to the site. One of the farms about a half-mile up-gradient from thesite grows vegetables for selling at the Madison Farmers' Market.

Municipal wells for the Village of Oregon are not located within the area of potential impact fromthe site. The village has two water supply wells that are 953 and 394 feet deep respectively. Onlythe deeper of the two wells is routinely used while the other well is on standby. Both wells arescreened in the sandstone bedrock aquifer.(4, pg 138)

HEALTH OUTCOME DATA

"Health outcome data" is a phrase referring to records of death and disease. When there is evidencethat people near a site have been exposed to contaminants at levels that could lead to an increase inrates of death or disease, a review of health outcome data may be appropriate. A review also may beappropriate if there are reports of unusual clusters of disease near a site. As discussed in theexposure pathways section, there is no evidence of significant public exposure to chemicals from thelandfill, and WDOH is not aware of any reports of clusters of chronic disease near this site. Forthese reasons, no health outcome data are relevant to the evaluation of this site. Should information of human exposures be found, health outcome data may be reviewed.


COMMUNITY HEALTH CONCERNS

Historic community health concerns were identified through a review of the WDOH case file for thesite. Additional community health concerns were identified during two public meetings at the localtown hall. These meetings took place on May 26, 1992 and June 3, 1992(9). The following is asummary of community health concerns identified (similar concerns have been combined):

  1. Is it possible that passers by or area residents could experience health effects from air emissions from the site, now or during the construction phase?

  2. How will the water quality of Badfish Creek be affected by the discharge from thesite? Should residents be concerned?

  3. How will air emissions be monitored to assure that they are not harmful to thepublic?

  4. How will the increased truck traffic as a result of remediation affect the localresidents?

  5. Will private wells near the site be sampled in the interim period between now andbeginning the construction phase?

  6. What action can be taken if contaminants are found in the future in private wells?

  7. Could a survey be done via a questionnaire to determine if the site has been causinghealth problems?

These concerns are addressed in the Public Health Implications section.


ENVIRONMENTAL CONTAMINATION AND OTHER HAZARDS

The tables in this section list the contaminants of concern. We evaluate these contaminants in thesubsequent sections of the Public Health Assessment and determine whether exposure to them haspublic health significance. ATSDR selects and discusses these contaminants based upon the following factors:

  1. Concentrations of contaminants on and off the site.

  2. Field data quality, laboratory data quality, and sample design.

  3. Comparison of on-site and off-site concentrations with health assessment comparisonvalues for (1) noncarcinogenic endpoints and (2) carcinogenic endpoints.

  4. Community health concerns.

In the data tables that follow under the On-site Contamination subsection and the Off-siteContamination subsection, the listed contaminant does not mean that it will cause adverse healtheffects from exposures. Instead, the list indicates which contaminants will be evaluated further inthe Public Health Assessment. When selected as a contaminant of concern in one medium, that contaminant will be reported in all media.

ON-SITE CONTAMINATION

The majority of the contamination from this site is west of Badfish Creek on Waste Management'sproperty. "On-site" is considered to be Waste Management property.

Available information indicates that industrial wastes were disposed primarily in cells 6 and 12. The industrial wastes disposed on site consisted of solvents and heavy metals. Drums of liquidwastes were brought to the site and drained onto municipal wastes. The combination was thenmixed to reduce the amounts of free liquids and eventually covered with soils from the site. Electromagnetic investigations did not locate many metal objects in the fill area indicating thatwastes were not generally disposed of in the drums themselves. Outside of cells 6 and 12 wastesconsist primarily of municipal wastes(1, 45).

Soils

Soil borings through the waste disposal area found the waste thickness to be between 15 and 22 feetthroughout most of the site. The existing cover material consists of soils from the site. This cover isnot properly sloped to encourage rainwater to run off the site. There have also been reports ofwastes being exposed at the surface. These reports were likely related to the past cattle grazing thatoccurred on site. Cattle are no longer permitted on site. At the time of the most recent site visit(4/8/92) no evidence of exposed wastes were noted. The existing cap ranges in thickness from sixinches to four feet(1, pg 42).

Surficial soil samples were taken from the landfill surface during the remedial investigation. Somevolatile organic compounds (VOCs) were detected down slope from waste disposal and at isolatedlocations on the landfill surface. These organic compounds included acetone and methylenechloride, which are also common lab contaminants(1, pg.42). The waste thickness was determinedto range from 15 to 23 feet based on waste borings completed throughout the site.

Limited soil VOC contamination was noted in surface soils downgradient of cell 12. Thecontaminants were acetone and methylene chloride. The highest concentration of acetone in surfacesoils was 20,250 micrograms per kilogram (g/kg) from 0 - 1 foot in depth. Methylene chloridewas detected at 81.5 g/kg at its highest concentration. Both of these compounds are considered tobe common lab contaminants, however, they can also be related to site wastes. In each case thehighest concentrations are considerably below levels of potential health concern.

Air

Air monitoring at leachate wells in the site indicate that the landfill is not producing significantquantities of methane or other gases. Because of the age and porosity of the landfill media, it islikely that the site will no longer have the potential to produce significant quantities of landfill gases.

Groundwater

Volatile organic compounds and heavy metals have been detected in the groundwater beneath thesite above comparison values. Some of the contaminants have migrated from the landfill in highconcentrations. The areas of contamination are most pronounced beneath and to the north of cell 6as well as beneath and to the northeast of cell 12. Because of the competing groundwater flowbetween Badfish Creek and the site, much of the contamination from cell twelve has stalled in aslight depression northeast of the site. A portion of this contaminant plume has spread off-site to theeast beneath Badfish Creek. Because of the relatively flat groundwater table, contamination is notspreading very rapidly.

The highest concentration of groundwater contamination is beneath cells 6 and 12 as well as areasimmediately downgradient of those locations. A summary of groundwater contaminants detected inon-site groundwater is shown in Tables 1 and 2. Table 1 describes the contaminants from beneath cell 6 and Table 2 shows those from cell 12(1, Table 9).

Contaminants from cells 6 and 12 are of a different nature. It appears that a different combinationof wastes were disposed at each location. Both concentrations and parameters differ considerably. Contaminants of concern in groundwater based on exceedances of comparison values or the lack ofan applicable comparison value are listed in Table 3.

Table 1.

GROUNDWATER CONTAMINATION FROM CELL 6
Contaminant Range of Concentrations (g/L) Comparison Values (g/L)
Arsenic 12.0-63.0 3.0 RfD
Barium 670 700 RfD
Benzene 1.61 - 8.78 1.2 CREG
Cadmium 1.1 - 4.2 2.0 EMEG
1,1-Dichloroethane 174 - 496 None
1,2-Dichloroethane 2,610 0.38 CREG
1,1-Dichloroethylene 2.4 - 31.0 0.058 CREG
1,2-trans-Dichloroethylene 22.0 - 3,290 200 RfD
Iron 160 - 52,900 None
Manganese 61 - 3,700 1,000 RfD
Methylene chloride 16 - 1,130 4.7 CREG
Tetrachloroethylene 0.828 - 119.0 None
Tetrahydrofuran 12.3 - 1,800 None
Toluene 125 2,000 RfD
Trichlorethylene 1.10 - 120 None
Vinyl chloride 1.51 0.2 EMEG

Rfd - Reference dose. This concentration was calculated from a RfD which is an exposure dose below which no adverse health effects are expected. This value is lower for children than for adults and can be considered protective for both.

EMEG - Environmental Media Evaluation Guide. This concentration has been developed as a threshold level below which no adverse health effects are expected. This value is lower for children than for adults and can be considered protective for both.

CREG - Cancer Risk Evaluation Guide. Exposure to this level over a lifetime may increase a persons risk of developing cancer by a factor of 1 in 1,000,000.

g/L = microgram per liter


Table 2.

GROUNDWATER CONTAMINATION FROM CELL 12
Contaminant Range of Concentrations (g/L)

Comparison Values (g/L)
Arsenic 7.1 - 30.0 3.0 RfD
Barium 260 - 380 700 RfD
Benzene 1.59 - 7.61 1.2 CREG
Cadmium 1.1 - 3.2 2.0 EMEG
1,1-Dichloroethylene 1.6 0.058 CREG
1,2-trans-Dichloroethylene 21.5 - 1,400 200 RfD
Ethyl benzene 766 1,000 RfD
Fluoride 500 600 RfD
Iron 250 - 18,400 None
Manganese 29 - 2,180 1,000 RfD
Methylene chloride 192 - 767 4.7 CREG
Selenium 1.3 - 1.4 30 EMEG
Tetrachloroethylene 1.95 - 5.73 None
Tetrahydrofuran 18.5 - 160,000 None
Toluene 164 - 110,000 2,000 RfD
Trichlorethylene 1.37 - 367 None
Vinyl chloride 286 - 3,260 0.2 EMEG
Xylenes 572 - 3,290 20,000 RfD

Rfd - Reference dose. This concentration was calculated from a Rfd which is an exposure dose below which no adverse health effects are expected. This value is lower for children than for adults and can be considered protective for both.

EMEG - Environmental Media Evaluation Guide. This concentration has been developed as a threshold level below which no adverse health effects are expected. This value is lower for children than for adults and can be considered protective for both.

CREG - Cancer Risk Evaluation Guide. Exposure to this level over a lifetime may increase a persons risk of developing cancer by a factor of 1 in 1,000,000.


Table 3.

CONTAMINANTS OF CONCERN
VOCs Metals
Benzene Tetrachloroethylene Arsenic
1,1-Dichloroethane Tetrahydrofuran Cadmium
1,2-Dichloroethane Toluene Iron
1,1-Dichloroethylene Trichloroethylene Manganese
1,2-trans-Dichloroethylene Vinyl chloride  
Methylene chloride    

OFF-SITE CONTAMINATION

Areas east of Badfish Creek and off of Waste Management property are considered to be "off site".

Groundwater

Contaminated groundwater from the site has passed beneath Badfish Creek to the east from cell 12. Contaminants have been detected in a monitoring well on the private property adjacent to the east ofthe site. The private well on this property and others in the area to the east have not been impactedby the site. Contaminants detected in this off-site monitoring well are shown in Table 4. Thesecontaminants are similar in nature to those found in the well on the west side of the creek. No otherareas of off-site contamination are believed to exist.

Table 4.

Contaminants in Off-Site Monitoring Well
Chemical Concentration (µg/L) Comparison Value (µg/L)
Acetone
32.4
1,000 RfD
1,2-Dichloroethylene
51.6
200 RfD
Tetrahydrofuran
110
None
Toluene
1.79
2,000 RfD
Trichloroethylene
2.55
None

The potential exists for contaminants in the groundwater to migrate off-site to the north of cell 6 andto the northeast of cell 12. There are no residences in the immediate vicinity of these potential off-site migration routes. None of the sampling at these private wells have shown contamination fromthe site.

Private residential wells within approximately a half mile of the site have been sampled irregularlybeginning in 1983, through 1991. No site related contaminants have been detected in private wells. Lead was detected at 1900 g/L in a private well off-site. Because lead levels had not been elevatedin the past in this well, follow-up sampling was done. These sample results did not show elevatedlead levels. The lead detect of 1900 g/L is attributed to either sampling or laboratory error.

While the creek flows north to south, the groundwater flows north and northeast from the landfill. Madison Metropolitan Sewerage District discharges treated effluent into Badfish Creek. Treatedeffluent constitutes the majority of flow in the creek.

Surface water contamination attributable to the site has not been detected. The hydrology of thearea indicates limited potential for contaminant migration to surface waters. Groundwater from thesite is not discharging to surface water. Rain water runoff carrying contaminants from the site is nota likely outcome because of the lack of contaminants exposed to the surface and to permeability ofsite soils. Rain water is more likely to infiltrate site soils than runoff to local surface waters.

QUALITY ASSURANCE AND QUALITY CONTROL

The majority of the analytical data used to support this public health assessment were taken from theremedial investigation report completed for the site by Waste Management's contractor. All workwas completed with EPA oversight. Procedures used during all field activities were consistent withEPA guidelines and approved by both the US EPA and the Wisconsin Department of NaturalResources. Lab analytical procedures were completed following US EPA Contract Lab Programprotocols. All data associated with the remedial investigation have been appropriately reviewed andqualified prior to use(1, pg 34-36).

Data acquired from sampling activities prior to beginning the remedial investigation can be forgeneral screening purposes. The quality control documentation for these results is not as thorough. For this reason, redundant sample results from the remedial investigation have been used for allquantitative estimates in this public health assessment.

PHYSICAL AND OTHER HAZARDS

There are large numbers of drums on site containing investigative wastes from the site. These drumsare easily accessible and could pose a physical hazard if tipped over. Because these drums havebeen on site through the winter they are not in good condition. Many that were filled to the top havebulging ends which could allow releases of potentially contaminated liquids or soils if moved.

Whenever municipal wastes are buried, methane can build up. If the soil covering the waste isporous, the gas is released on site. When a landfill cap is only slightly porous, however, methaneand other gases can migrate laterally through the soil. Given the geology of the area around the CityDisposal site, landfill gases potentially could migrate laterally through sand and gravel lenses in thesoil. The physical hazard that results is the accumulation of explosive gas in basements of homesnear the site. However, this site is producing relatively little methane and homes are not locatednear enough to the site to present a gas migration concern to those homes.

The increased truck traffic on the local roads during the construction of a cap could create a physicalhazard. This physical hazard has been a major concern of the local residents and should be considered strongly when selecting the remedy for the site.


PATHWAY ANALYSES

To determine whether nearby residents are exposed to contaminants migrating from the site,ATSDR evaluates the environment and human components that lead to human exposure. Thispathways analysis consists of five elements: A source of contamination, transport through anenvironmental medium, a point of exposure, a route of human exposure, and an exposed population.

ATSDR categorizes an exposure pathway as a completed or potential exposure pathway if theexposure pathway cannot be eliminated. Completed pathways have all five elements and indicatethat exposure to a contaminant has occurred in the past, is occurring, or will occur in the future. Potential pathways, however, have at least one of the five elements missing, but it could exist. Potential pathways indicate that exposure to a contaminant could have occurred in the past, could beoccurring now, or could occur in the future. An exposure pathway can be eliminated if at least oneof the five elements is missing and will never be present.

Groundwater flow beneath the site flows from cell 6 to the north and from cell 12 to the north east. There is a subtle groundwater divide passing from north to south through the center of the sitebetween the two contaminated cells. Contamination from cell 12 maybe additionally influenced byshallow recharge waters from Badfish Creek. The groundwater table at the site is relatively flatwhich indicates low flow speed. Combined with conflicting flow influences this has caused themajority of contamination to remain fairly near the site.

Groundwater flow in the area of the site flows contrary to what surface topography would indicate. There is a groundwater divide through the center of the site passing from north to south. Groundwater to the west of the divide flows north, while to the east of the divide the flow is to thenortheast. Badfish Creek may influence local groundwater flow near the northeastern portion of thesite. The combination of local groundwater flow and influence from Badfish Creek has the effect ofstalling northeasterly flow and forcing groundwater to the southeast near the creek (see figure 4). Contaminants have been detected on the east side of Badfish Creek consistent with this groundwaterflow pattern.

The groundwater table at the site is relatively flat. For this reason groundwater flow is not verypronounced and is easily influenced by changes in hydrology. It is believed that during disposalactivities at the site, the addition of liquid wastes created a mounding effect near cell 12. Contaminated groundwater flowed radially from the disposal area until disposal ceased. Normalflow patterns resumed after disposal ceased. Residual contamination can still be detected inmonitoring wells just south of cell twelve as a result of the past mounding effect.

Tetrahydrofuran (THF) is a volatile organic compound that readily releases to the air pathway. Thiscompound has been found consistently in the highest concentrations in the groundwater. THF isvery soluble in water. For this reason it is quite mobile in the groundwater. Because of its highsolubility THF is not expected to accumulate in the food chain. This compound is expected tobreakdown rapidly in the atmosphere. However, the THF contamination at this site is in thegroundwater and would not be expected to breakdown as readily(16,17,18).

COMPLETED EXPOSURE PATHWAYS

There are no completed exposure pathways at this site.

POTENTIAL EXPOSURE PATHWAYS

Groundwater Pathway

Groundwater contamination from various volatile organic compounds has been identified on site. The concentration, toxicity, and persistence of these compounds make this an environmentalpathway of concern. While private residential well testing off site does not show contamination, thepotential for exposure from this medium exists. The groundwater is contaminated and movement ofthe plume requires monitoring as private wells are proximate to the site. Current hydrogeologicconditions do not indicate that contamination is migrating towards private wells.

Contaminants have been detected on the east side of Badfish Creek consistent with this groundwaterflow pattern. Local wells have been monitored throughout the remedial investigation and have notshown site related contamination. One well showed a high level of lead in the water not related tothe site. Sampling of that well earlier had not detected high levels and confirmation sampling doneafterward again did not show high levels. This one high level lead detect is likely attributable toeither lab or sampling error.

Because not all site contaminants are migrating significantly from the site, not all contaminants areconsidered as contaminants of concern. Few compounds have migrated off-site, while others havethe potential to do so. In order to identify contaminants with the potential to migrate off-site,contaminants were selected based on their existence in monitoring wells significantly downgradientfrom the site. The highest concentrations from these wells have been selected as the future potentialexposure concentrations. These concentrations are very conservative because private wells are notnear wells with these concentrations. The contaminants that have been selected by this method arelisted in Table 5. Those that are not migrating from the site are listed in Table 6.

Table 5.

CONTAMINANTS OF CONCERN MIGRATING FROM THE SITE
VOCs Metals
1,2-trans-Dichloroethylene Arsenic
Methylene Chloride  
Tetrahydrofuran  
Toluene  
Trichloroethylene  
Vinyl Chloride  


Table 6.

CONTAMINANTS NOT MIGRATING FROM THE SITE
VOCs Metals
Benzene Cadmium
1,1-Dichloroethane Iron
1,2-Dichloroethane Manganese
1,1-Dichloroethylene  
Tetrachloroethylene  

Air

The air pathway is an unlikely exposure pathway at this site. The site is not producing significantquantities of methane. Air monitoring during sampling has not detected contaminants in ambient airaround the site. Residents live a sufficient distance from the site to ensure that even incidentalreleases would not create an off-site exposure concern.

The proposed remedial alternative is expected to provide additional protection for the air pathway. Any volatile contaminants removed from the site will be flared off if they are at levels above healthbased air standards(2). There is a potential for releases to the air pathway during cap construction ifwastes are disturbed. Truck traffic on site may also increase the dust in the amount of wind blowndust coming from bringing in cover material. This latter concern is more of a public nuisance than ahealth concern.

Surface Water

Badfish Creek has shown contamination in the past, but the origin of the contamination is not relatedto site contaminants. Groundwater contaminants are not discharging to the surface waters of eitherBadfish Creek or Grass Lake. There is no pathway for contaminants to migrate to surface water.

The proposed remedial alternative requires a discharge of treated groundwater from the site. It islikely that Badfish Creek would be the discharge point. The State of Wisconsin requires that alldischarges to surface waters meet surface water quality discharge criteria. The standards fordischarge are based on protection of public health and of sensitive aquatic life. These standardstypically are far more stringent than human health based standards and are protective of publichealth. The discharge from this site must meet these discharge standards.

Soils

There is limited potential for persons to come in contact with contaminated soils or wastes from thesite while walking on-site. Access is not restricted for persons entering the site on foot. It is believedthat all wastes previously exposed at the surface by cattle walking on the cap are now sufficientlycovered. The site is well vegetated and any potential exposures would be minimal.

Soil sampling has shown limited contamination of surface soils. These levels of contamination arebelow levels which would present a concern for an area regularly used by the public.

The selected remedy for the site includes the addition of a thick clay cap which will further reduce the potential for exposure.


PUBLIC HEALTH IMPLICATIONS

TOXICOLOGICAL EVALUATION

The following section consists of summaries of the toxicological implications for each contaminantof concern for completed or potential exposure pathways.

Arsenic

Arsenic has been detected at six locations near the site. Concentrations range from 7.1 g/l to 63.0g/l. Arsenic was not consistently detected at each location. Significant migration from the site is alow potential and there have not been any exposures up to this point in time.

The future potential exposure level of arsenic in a drinking water supply is 8.2 g/l.

The US EPA has classified arsenic as a Class "A" human carcinogen(15). Studies have indicatedthat ingestion of arsenic increases the risk of developing skin cancer. Darkening of the skin anddevelopment of small "warts" can be an indication of long term arsenic exposure. Arsenic is alsosuspected of increasing the risk of cancer of internal organs, such as the liver, kidneys, andbladder(11, 50).

1,2-trans-Dichloroethylene

This compound has been detected at nine locations across the site. Groundwater concentrationsrange from 21.5 g/L to 3,290 g/L. The highest readings are from the north edge of cell six andjust northeast of cell twelve.

EPA has developed an oral RfD of 0.02 milligrams per kilogram per day (mg/kg/day) for 1,2-trans-dichloroethylene(10). This level of exposure may be associated with some blood disorders inhumans, as it has been shown to do so in laboratory animals.

Methylene Chloride

Methylene chloride has been detected at ten different locations at the site. The compound has notbeen consistently detected at any of those locations. This compound is a common lab contaminantthat may periodically show up erroneously in sample results. The detected levels in groundwaterrange from 16 g/L to 1,130 g/L.

Ingestion of methylene chloride, also known as dichloromethane, has been shown to cause increasesin the incidence of liver and mammary cancers in laboratory animals. The US EPA classifies thiscompound as a potential human carcinogen(15). There have been no studies conclusively showingthat methylene chloride causes cancer in humans. Non-cancer health effects are not expected fromexposure to methylene chloride at concentrations from the City Disposal site(12).

Tetrahydrofuran (THF)

This compound has been consistently detected in the plume both on and off of the site. Very littletoxicological data is available for THF. Short term exposures to the highest levels of THF on-sitethrough inhalation could irritate the eyes, nose, throat and lungs. Long term exposures may effectliver or kidney function. THF has not been tested for its ability to cause cancer(16,17,18).

Toluene

Toluene has been detected at seven locations throughout the site. All but one of these locations arenear cell twelve. Groundwater concentrations range from 96.2 g/L to 110,000 g/L, with thehighest concentrations again being near cell twelve.

Long term exposures to concentrations in drinking water at this site may cause damage to thenervous system and to the kidneys(13).

Trichloroethylene

Trichloroethylene has been detected across most of the site. Levels detected in groundwater rangefrom 1.1 g/L to 367 g/L. This compound has been detected in the off site monitoring well east of Badfish Creek at a level of 2.55 g/L.

There is very little data available for human exposure to trichloroethylene. In the past EPA hadconsidered trichloroethylene to be a probable human carcinogen. That designation has since beenwithdrawn and is under review. Some animal studies have linked trichloroethylene to causeleukemia, cancer of the kidney, and liver tumors. The reader should be aware that the potentialexists for exposure to this compound to be linked with an increased cancer risk. Inhalation andingestion exposures may have an additive effect. Concentrations at this site, when compared to theformer slope factor present no apparent increased cancer risk

No non-cancer health effects are expected from exposure to trichloroethylene at this site.

Vinyl Chloride

Vinyl Chloride has been detected primarily near cell 12 at the site. Groundwater concentrationsrange from 1.51 g/L to 3,260 g/L.

There is little information about the human health effects of exposure to vinyl chloride resultingfrom oral ingestion. Laboratory animal studies of exposure to vinyl chloride describe adverse effectsto the liver. Cancer studies of laboratory animals describe increases in liver cancers. Vinyl chlorideis classified by the U.S. EPA as a known human carcinogen(15). Long term exposure to thecontaminated drinking water from the site could result in an increased risk of developing cancer.

Non cancer health effects would also be possible. Liver damage, nerve damage and decreasedimmune reactions are possible non cancer health effects that could be related to such exposures.

HEALTH OUTCOME DATA EVALUATION

Based on existing data from the remedial investigation and current research on diseases caused bycontaminants which were found at the site, the levels of exposure to contaminants are too low toinitiate any studies of death and illness. In fact no exposures to contaminants from the site have beendocumented. In the event additional data becomes available which shows local residents exposed tocontaminants from the site, such a study may be desirable.


COMMUNITY HEALTH CONCERNS EVALUATION

There have been community health concerns raised through the course of the history of site activities. The following summaries address those concerns.

  1. Is it possible that passers by or area residents could experience health effects from air emissions from the site, now or during the construction phase?
  2. The primary contaminants of concern at this site are volatile compounds, which means thatthey evaporate into the air easily. However, exposure to contaminants in the air by personsoff-site are extremely unlikely. Measurements of contaminant concentrations in the air on-site have not indicated that a problem exists. The proposed remedy for cleaning up the siteincludes capping the site and installing a vapor extraction system. This remedy will further reduce the likelihood of exposure.

  3. How will the water quality of Badfish Creek be affected by the discharge from the site remediation, should residents be concerned?
  4. Discharges from the site should not cause any problems for area residents. The discharge of treated groundwater from the site must meet state surface water discharge standards. These standards are set to be protective of both public health and the environment.

  5. How will air emissions be monitored to assure that they are not harmful to the public?
  6. All air emissions must meet state and federal ambient air standards. Air sampling must beset up to measure compliance with these standards. The proposed remedy is expected toinclude flaring off all gases generated by the site and cleanup activities. This burning ofcontaminants at the site should ensure that harmful levels of contaminants are not released from the site.

  7. How will the increased truck traffic affect the local residents?
  8. The increased truck traffic will be very noticeable based on the projections included in thefeasibility study. Efforts are being discussed to ensure that this increased traffic is plannedto avoid risks of accidents. Persons walking or driving in the area during times of heavy truck traffic may be at increased risk traffic related accidents.

  9. Will private wells near the site be sampled in the interim period between now and beginning the construction phase?
  10. Residential wells will be sampled during the design phase.

  11. What action can be taken if contaminants are found in the future in private wells?
  12. If contaminants are detected in private drinking water wells above levels that present healthconcerns, alternative drinking water supplies will be provided. If any levels ofcontaminants are detected, sampling will be done at those wells much more frequently.

  13. Could a survey be done via a questionnaire to determine if the site has been causing health problems?
  14. At this time such a study would not likely provide useable information. Because we do nothave known exposures there is no health related conditions to expect to find. Many otherfactors related to both domestic and worker exposures could not be ruled out as a source of health problems.


CONCLUSIONS

The potential for future exposure to contaminated groundwater poses a public health hazard if thesite were not cleaned up as planned. Future exposures to contaminated groundwater are possible ifcontaminants move into private wells. Exposures to contaminants from groundwater could be frominhalation and dermal exposure during showering, and ingesting drinking water. Exposure to thesecontaminants could produce adverse health effects. Planned remedial activities are expected toadequately address these potential exposures. The groundwater pathway appears to be the onlylikely pathway for exposure to contaminants at the site.

Contaminants have migrated from the site in the direction of private wells although no public orprivate drinking water supply wells have yet been impacted by the site. Exposures to contaminationfrom this site are not known to have occurred. At present there appears to be no public healthhazard associated with the site. Monitoring of residential wells at risk of contamination had beensuspended until the beginning of the construction phase. However, private well sampling will bedone during the design phase under an administrative order.

Wastes are not exposed at the surface and the site is not discharging leachate to surface soils orsurface water. For this reason no adverse health effects would be expected as a result of exposure tocontaminated soils on-site.

The proposed plan for the clean up of the site is expected to be protective of public health at the siteand remove the potential future exposure to contaminated groundwater. The selected remedy willnecessarily create additional truck and heavy machinery traffic. This additional traffic couldincrease general traffic accident risks and possibly cause dust problems at and near the site. Accessto the site is not sufficiently restricted to prevent potential for trespassers to come in contact withcontaminants in the drums or be otherwise injured by the drums themselves.


RECOMMENDATIONS

Based on the conclusions developed in this report the Wisconsin Division of Health and ATSDR makes the following recommendations:

  1. Increased vehicle traffic resulting from the construction of the new cap should be coordinatedaround local use times and any other local concerns that could minimize traffic risks. Measuresshould be taken to reduce the amount of truck traffic on the local roads where possible, while not significantly reducing the protectiveness of the remedial action.

  2. Access to the site should be sufficiently restricted during and after completion of the site activities to prevent exposure to contaminants at the site.

  3. Dust control measures should be used during construction to minimize dust from both vehicle traffic and wind blown contaminants from exposed wastes.

  4. Contaminated groundwater must be effectively prevented from reaching private wells as described in the EPA's recommended remedial alternative for cleaning up the groundwater. Failure to do so may result in adverse health effects for local residents.

  5. The drums of investigative wastes on the cap should be better secured in order to minimize the physical hazards that they pose.

NEED FOR FOLLOW-UP HEALTH ACTIVITIES

The ATSDR Health Activities Recommendation Panel and the WDOH evaluated the data on thissite to determine what needs exist for additional research and/or local education about health relatedconcerns. Such activities could include further studies on cases of disease in the vicinity of the siteor providing residents with additional information about the health effects of exposures to specifictoxic chemicals coming from the site. There are no indications that people have been exposed tochemicals from the site. Both the community and local health professionals need to be providedwith continuing information pertaining to public health issues related to the site. If additionalinformation shows that there has been public exposure to toxic substances, the WDOH and ATSDR will reconsider the need for more action.


PUBLIC HEALTH ACTIONS

The WDOH, in cooperation with ATSDR, will conduct the following activities to respond to the recommendations of this assessment:

  1. Provide continuing public health education as new information related to public health issues becomes available;

  2. Review and comment on public health aspects of the remedial design for the site. Specifically review plans to address the following:

    1. Safely coordination of increased vehicle traffic during construction of the cap;

    2. Implementation of dust control measures during cap construction;

    3. Proper restriction of access to the site where appropriate;

    4. Development of a plan to monitor the effectiveness of groundwater cleanup methods;

    5. Secure the drums remaining on-site;

    6. Development of contingency for providing alternative water supplies if contaminants are found to exceed health based groundwater standards in private wells.

  3. Advise and consult with the Wisconsin Department of Natural Resources and the EPA onpublic health concerns that may arise as new information about the site becomes available.

PREPARERS OF THE REPORT

Chuck J. Warzecha
Hydrogeologist
Section of Environmental Epidemiology and Prevention
Bureau of Public Health
Division of Health
Wisconsin Department of Health & Social Services

ATSDR Senior Regional Representative

Louise Fabinski
Regional Services
Region V
Office of the Assistant Administrator

ATSDR Technical Project Officer

William Greim
State Programs Section
Division of Health Assessment and Consultation


CERTIFICATION

This City Disposal Corporation Landfill Public Health Assessment was prepared by the WisconsinDepartment of Health and Social Services under a cooperative agreement with the Agency for ToxicSubstances and Disease Registry (ATSDR). It is in accordance with approved methodology and procedures existing at the time the public health assessment was begun.

William Greim, M.S., M.P.H.
Technical Project Officer
Remedial Programs Branch
Division of Health Assessment and Consultation (DHAC)
ATSDR


The Division of Health Assessment and Consultation, ATSDR, has reviewed this public health assessment, and concurs with its findings.

Robert C. Williams, P.E., DEE
Director, DHAC, ATSDR


REFERENCES

  1. "Draft Remedial Investigation Report for the City Disposal Corporation Landfill", P.E. LaMoreaux & Associates, Tuscaloosa, AL, September 11, 1991. 3 Volumes.

  2. "Final Feasibility Study for the City Disposal Corporation Landfill", P.E. LaMoreaux & Associates, Tuscaloosa, AL, March 24, 1992. 2 Volumes.

  3. "Sourcebook of Zip Code Demographics". CACI Marketing Systems, Arlington, VA. 1990 Census Edition, Volume One. 1989.

  4. Syftestad, Eric P.. "Public Water Supply Data Book, 1985". State of WisconsinDepartment of Natural Resources, Division of Environmental Standards, Public WaterSupply Section.

  5. Fiore, Beth. "Preliminary Health Assessment for the City Disposal Site", WisconsinDivision of Health. November 8th, 1988.

  6. Department of Natural Resources Groundwater Quality Standards. Chapter NR 140Wisconsin Administrative Code. February 1992.

  7. Comparison Tables for Selecting Contaminants of Concern. Director, Division of Health Assessment and Consultation, ATSDR. April 6, 1992.

  8. Toxicological Profile for Vinyl Chloride {Draft}. U.S. Department of Health and Human Services, Public Health Services, Agency for Toxic Substances and Disease Registry. February 18, 1992.

  9. Warzecha, Chuck. Memo to File, Dunn Town Meeting on City Disposal Superfund Site. May 27, 1992.

  10. Toxicological Profile for cis 1,2 Dichloroethylene, trans 1,2 Dichloroethylene, and 1,2Dichloroethylene {Draft}. U.S. Department of Health and Human Services, Public HealthServices, Agency for Toxic Substances and Disease Registry. December 1990.

  11. Toxicological Profile for Arsenic {Draft}. U.S. Department of Health and HumanServices, Public Health Services, Agency for Toxic Substances and Disease Registry. February 18, 1992.

  12. Toxicological Profile for Methylene Chloride {Draft}. U.S. Department of Health andHuman Services, Public Health Services, Agency for Toxic Substances and DiseaseRegistry. February 18, 1992.

  13. Toxicological Profile for Toluene {Draft}. U.S. Department of Health and HumanServices, Public Health Services, Agency for Toxic Substances and Disease Registry. December 1989.

  14. Toxicological Profile for Trichloroethylene {Draft}. U.S. Department of Health andHuman Services, Public Health Services, Agency for Toxic Substances and DiseaseRegistry. February 18, 1992.

  15. Integrated Risk Information System (IRIS). 1991.

  16. Groundwater Advisories Supporting Documentation. Wisconsin Division of Health.September, 1989.

  17. Hazardous Substances Data Bank (HSDB). National Library of Medicine. Updated May7th, 1991.

  18. Hurst, Pei-Fung. US EPA, Chemical Mixtures Branch. Letter to Jae Lee, US EPA RegionV. Provisional Rfd for Tetrahydrofuran (THF). June 22, 1990.

RESPONSE TO PUBLIC COMMENTS

{Responses to comments follow in bold type.}

1. Tables 1 & 2 use three different evaluation criteria (RfD, CREG, & EMEG) as reference forcomparison of the various contaminant concentrations.

a) Is my interpretation of the information correct, thinking that the comparison values usingCREG for a reference are potentially more harmful than those contaminants EMEG values?

The cancer risk evaluation guide (CREG) is used for comparison when cancer is the primaryhealth effect related the chemical exposure. The environmental media evaluation guide(EMEG) is used when the primary health effect related to the chemical exposure issomething other than cancer. The level of exposure that could cause an increased cancerrisk is generally much lower than the level of exposure that could cause other health effects.

b) Are the EMEG values potentially more harmful than the RfD?

No. Each of these comparison value sources are related to similar risk levels for noncarcinogenic chemical exposures. When an EMEG is not available the RfD may be used.

c) I believe there is a typo on the unit of measure for both tables. Are the range of concentrationand comparison values both in micrograms per liter? (one uses a lower case "l" & the other uses an upper case "L")

Yes. Both represent micrograms per liter. The inconsistency has been changed in thetables.

d) Please explain how, if at all, these different criteria compare.

See the responses to comments 1.a. and 1.b..

2. #5 of the recommendations on page 27 and #2 F of the public health action on page 28 implythat the state will perform testing of the private wells at risk of contamination on a regular basis. Please identify which wells are to be tested, and provide the schedule for sampling.

The recommendations are that the responsible party perform the monitoring of the privatewells. The workplan for the remedial design does not identify the specific wells or themonitoring frequency. The EPA project manager for the site will make thosedeterminations.

Background /3

The sentence that starts with "Hazardous waste disposal was..", should read "Industrial waste disposal was..". Technically, during the time this facility operated, there was no list of defined hazardous waste.

The change as been made in the text.

Background /4

The last sentence on this page should be reworded to state: 1) The installation of gas extraction wells into the waste for the management of the landfill gas, if present in sufficient quantity and 2) The installation of soil vapor extraction wells beneath the waste for the purpose of removing potential VOC contaminants from the underlying soils.

This information has been added.

Background /5

Residential well sampling is required by the Unilateral Administrative Order and will be conducted during the design phase. The most recent sampling was June 1993.

This information has been noted and the appropriate changes have been made.

Site Visit /6

The sentence that starts, "The cap is porous..., should end with...and is complete in most areas. This conveys a more accurate picture of the situation.

This information is noted, however, observations from the site visit cannot be changed.

On-Site Contamination /10

Request that the term hazardous wastes (2nd paragraph, 2nd sentence) be replaced bythe term industrial waste, for the reason previously stated.

The text has been changed.

Pathway Analyses /17

Third paragraph, third sentence; substitute "maybe" for "is" after Cell 12. Thirdparagraph, tenth sentence; insert "maybe" after Badfish Creek.

The text has been changed in the third sentence. There is no tenth sentence in thisparagraph.

Community Health Concerns /25

Residential well sampling will be performed during the design phase.

This information has been noted and the appropriate changes have been made to the text.

Conclusions /26

Second paragraph, fifth sentence; residential sampling will be conducted during thedesign phase.

This information has been noted and the appropriate changes have been made to the text.

Recommendations /27

Item 5 should be deleted as residential well sampling will be done in the design phase.

This information has been noted and the appropriate changes have been made to the text.

Public Health Actions /28

Item F should be deleted, residential well sampling will occur.

This has been changed.


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