PUBLIC HEALTH ASSESSMENT
KOHLER COMPANY LANDFILL
KOHLER, SHEBOYGAN COUNTY, WISCONSIN
Figure 1. General Site Map
Figure 2. Soil Testing Locations
Figure 3. Waste Sampling Locations
Figure 4. Monitoring Well Locations
Figure 5. Water Supply Wells Nearby
|Volatile Organic Compounds |
|Inorganic Chemicals |
RESPONSE TO COMMENTS ON PUBLIC COMMENT RELEASE
- Comments on adequacy of EPA's selection of a 2-foot clay (solid waste) cap rather than ahazardous waste cap with a synthetic liner to reduce leachate production: Several peoplesubmitted comments expressing concern that the EPA's selected remedy for source control wouldnot adequately control the discharge of leachate to river and that PCBs in leachate would seepinto the Sheboygan River. Other comments expressed concern that the assessment gave theinaccurate impression that PCBs are flowing with dissolved organic solvents from buried wastein the landfill to the river. Some comments noted that, because of a potential for PCBs andheavy metals in groundwater near the waste to flow to the river, there should be additional wellinstallation and on-going monitoring of groundwater and leachate for PCBs and metals.
Response: Because of the fish consumption advisory on year-round resident species of fish inthe river, concern about PCB contamination in the Sheboygan River is appropriate. PCBs werefound in landfill waste, in monitoring wells adjacent to landfill waste, in floodplain soils betweenthe landfill and the river, and in river sediments. Because there are significant levels of PCBsupstream of the landfill, the upstream sources may account for the PCBs in the floodplain andriver sediments by the landfill. While the remedial investigation did find several organic solventsflowing from landfill waste to the river, the investigation did not find PCBs flowing from landfillwastes to the river. Because of the river's diluting effect, organic solvent levels in the river arenot expected to affect human health. These points have been clarified in the health assessment. The EPA and the WDNR are the agencies that decide which specific remedial measures (sourcecontrol and groundwater remediation) are required for the site. The EPA solicited publiccomment on its proposed method for capping the landfill from 14 October 1991 to 6 January1992.
- Comments on the location of the river floodplain relative to the landfill site: A couple peoplenoted that, while the east half of the landfill is on an historical floodplain, the legal floodplain isat the edge of the waste-filled area.
Response: This information was clarified in the site description.
- Comment received 18 June 1993: Add to the summary that Kohler also manufactures smallengines. The foundry contributing waste sands, pollution control sludge, etc. is part of the smallengine manufacturing facility.
Response: The summary and site description were revised as recommended.
- Comment received 18 June 1993: Site operations have changed since the last site visit. Nolonger are larger pits used for slurried wastes. Slurried wastes are now deposited in shallowtrenches.
Response: The description of physical hazards was updated and the conclusion andrecommendation concerning the larger pits were deleted.
- Comment postmarked 25 June 1993: Disagree with statement that organizations do not appearto be concerned specifically with the Kohler Company Landfill site.
Response: The description of community health concerns was revised.
- Comment postmarked 30 June 1993: Concern with Hmong anglers being unaware of the fishconsumption advisory for the river.
Response: The Division of Health, in cooperation with several state and local organizations, hasundertaken a number of educational efforts aimed at informing Hmong anglers and their familiesabout the health hazards from eating Sheboygan River fish. These efforts are described in thePublic Health Assessment for the Sheboygan River and Harbor.
- Comment postmarked 2 July 1993: The EPA conducted a soil vapor survey in June 1990 (RIappendix S). These data should be included with information about environmentalcontamination.
Response: The description of on-site air contamination was revised to include these data.
- Comment postmarked 2 July 1993: Groundwater monitoring wells and two residential wellswere sampled after the RI was completed. These data should also be reported.
Response: The description of off-site groundwater contamination was updated to include these data.
- Comment postmarked 15 July 1993: It is inaccurate to say that groundwater contains PCBs. Filtered samples of groundwater do not contain PCBs, only unfiltered samples do.
Response: The assessment was revised to say that unfiltered groundwater contains PCBs.
- Comment postmarked 15 July 1993: All data collected during the RI indicates that allgroundwater impacted by the site flows to the Sheboygan River. There is no evidence thatgroundwater flows beneath the Sheboygan River to nearby wells. "Worst case scenarios areintended to account for variables in exposure dose calculations. They are not intended to turn anunlikely route of migration into a possible route of migration."
Response: The pathways section was revised to reflect the strength of indications thatgroundwater under the landfill discharges to the river. The Division of Health continues torecommend on-going testing of monitoring wells across the river from the site because the levelof VOCs in groundwater under the landfill are so high and because the computer model used forthe RI may not reflect the complexity of groundwater flow through fractured bedrock.
- Comment postmarked 15 July 1993: The schedule for closing the landfill in 1995 istentative.
Response: The assessment was revised to note this information.
- Comment postmarked 15 July 1993: The discussion of aquifers underlying the site ismisleading. The description of the geologic strata should be clarified.
Response: The site description was revised as suggested.
- Comment postmarked 15 July 1993: The statement that the water table lies a few feet belowthe ground surface at the top of the site and slopes down to the river should be clarified.
Response: The site description was revised as suggested.
- Comment postmarked 15 July 1993: While the site is not fenced, it is posted and regularlypatrolled. The patrols have not noted unauthorized access to the site.
Response: This information was added to descriptions of site accessibility.
- Comment postmarked 15 July 1993: The description of the installation of monitoring wells is inaccurate with regard to their number, location, and depth.
Response: The description of on-site and off-site groundwater wells was revised and updated toclarify well locations.
- Comment postmarked 15 July 1993: The statement that VOC levels were detected in the air above the site during drilling operations is misleading. This could be misinterpreted to suggest that elevated VOCs were widespread. Air was monitored in a borehole or immediately adjacent to a recently collected sample.
Response: The description of on-site air contamination was clarified to reflect this information.
- Comment postmarked 15 July 1993: VOCs normally associated with gasoline were detectedin Monitoring Well 15 across the Sheboygan RIver from the site in 12/91 and 1/92. The uniquechemical signature of the compounds detected suggests that the chemicals are associated with the nearby highway rather than from the landfill.
Response: This possible source was added to the description of the results.
- Comment postmarked 15 July 1993: The residential well was resampled on 5/16/91 usingmuch lower detection limits and no VOCs were detected.
Response: The description of off-site groundwater contamination was revised to include thesedata.
- Comment postmarked 15 July 1993: The relevance of TRI information is not clear. Would itbe more appropriate to include other dischargers within the zip code?
Response: The Toxic Chemical Release Inventory is used to identify additional, nearby sourcesof site-related contamination. This information is intended to assist with the evaluation ofexposure to nearby populations. In this case the results of the TRI clarify the difficulty ofevaluating ambient air contamination associated with the landfill because the nearby factoryappears to be a significant source of VOCs to air. This explanation was added to the assessment.
- Comment marked 20 July 1993: Agree with recommendation that domestic well sitescontinue to be monitored.
Response: Nearby residential wells were tested at lower detection limits in 1992 and no VOCswere found. The Division of Health recommends on-going monitoring of wells across the riverfrom the site.
- Comment marked 20 July 1993: Agree that access to the landfill site should be restricted,presumably with a fence and signs.
- Comment marked 20 July 1993: Agree with recommendation that leachate and surface runoff continue to be monitored.
- Comment marked 20 July 1993: Support the idea that, with their permission, anglers who eatfish from the Sheboygan River should be monitored for long-term health effects.
- Comment marked 20 July 1993: Support idea that public health education efforts beundertaken by the State of Wisconsin to alert people to the connection between chronic healthproblems and environmental degradation, in general and with specific reference to the SheboyganRiver.
Response: With assistance from ATSDR, the Wisconsin Division of Health and WDNR areconducting (in 1994) an exposure investigation of Sheboygan River anglers and of familymembers in certain households. The results of this investigation will help to determine the needfor additional health studies.