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PRELIMINARY PUBLIC HEALTH ASSESSMENT

WASTE MANAGEMENT OF WISCONSIN-BROOKFIELD
BROOKFIELD, WAUKESHA COUNTY, WISCONSIN


SUMMARY

The Waste Management-Brookfield Landfill was a former gravel pit used to dispose of municipal, commercial, andindustrial wastes. The landfill began accepting wastes in the l950's and closed in l980. The site was not licensed toaccept hazardous waste. However, the definitions of "Hazardous Waste" were not clearly identified until the passageof the Resource Conservation and Recovery Act (RCRA) late in the operation of the site.

Methane gas migration has been a problem at the site in the past. A gas extraction system was installed within thelandfill. Gas probes that measure total combustible gas have also been installed on site. Continuousmethane/combustible gas monitors were placed in two residential basements; relatively high levels of gas weremeasured in one residence in l985. Improvements on the gas extraction system were made following the detection ofmethane in the basements. The gas extraction system is monitored regularly and adjusted when needed. Theresidential monitors have not indicated a methane problem in basements since that time.

Groundwater beneath the site has been contaminated from the site. The landfill does not have a liner. WasteManagement has constructed a new clay cap that is well vegetated and maintained regularly.

The site poses an indeterminate public health hazard from inhalation exposure to contaminated indoor air migratinginto the basements of nearby residences. Samples of basement air have not been analyzed for contaminants ofpotential concern at the site. The site poses an indeterminate public health hazard from ingestion of contaminatedgroundwater in private wells near the site. Characterization of groundwater quality has not identified whethercontamination has migrated to private wells near the site. There is also an indeterminate public health hazard fromdermal exposure to contamination in the wetland south of the site. No samples for contaminants of concern have beentaken from surface water or sediments in this area that drained a portion of the site prior to installing the cap. The siteposes no apparent public health hazard from contact on-site soils and inhalation of ambient air at and near the site.

The Wisconsin Division of Health will provide continuing public health education as new information becomesavailable, review and comment on the remedial design, and provide site information to primary care physicians and public health professionals in the area.


BACKGROUND

Site Map

SITE DESCRIPTION AND HISTORY

The Waste Management-Brookfield Superfund Site (Brookfield Site) was originally an old gravel quarry cut out of theside of a south sloping hill. Waste disposal began in the 1950s and continued until 1980. In 1969 Waste Managementof Wisconsin, Inc. (WMWI) leased the site and continued operating it for disposal of municipal, commercial andindustrial wastes. In 1982 WMWI purchased the site.

The site is located in a residential area in the City of Brookfield, Wisconsin. Subdivisions are located to the north andwest of the site. There is a wetland between the site and a subdivision to the south of the site. Brookfield Road liesbetween the site and a subdivision to the east. There is a buffer (approximately 50 feet) between the fill area and theyards of the residences to the north of the WMWI property. Several gas probes and groundwater monitoring wellshave been installed in this buffer area, which is owned by Waste Management.

WMWI constructed a new clay cap on the landfill in 1988 to meet current regulatory standards. This cap has beenproperly graded and vegetated and does not show signs of erosion. Drainage ditches have also been installed to carryexcess runoff off site.

The geology consists of alternating layers of clay mixed with silt, sand and gravel sloping to the south. This glacialmaterial varies in thickness from about 140 feet at the base of the slope, to 290 feet at the top of the slope (northern-most portion of the site). A fractured dolomite bedrock lies beneath the glacial material. This bedrock slopes slightlytoward the east and is about 800 feet in thickness.(PELA, Pg.22)

Area Map

Groundwater is the primary source of drinking water in the area. The bedrock aquifer yields sufficient water to meet domestic, commercial and light industrial needs. Domestic water supply wells also draw water from the portion of the aquifer in the overlying glacial material. There are no confining layers separating the groundwater in the glacial material from the bedrock aquifer. Local mounding beneath the waste disposal area was noted in 1984. This mounding is caused by leakage from the landfill and may have diminished since 1988, when the new cap was placed on the site (PELA, 23).

On- and off-site groundwater monitoring has shown evidence of groundwater contamination at the site. Volatileorganic chemicals and lead have been detected in samples from residential wells north of the site. Lead andmethylene chloride were identified at concentrations that exceed the Wisconsin Groundwater Enforcement Standards. It is not clear whether lead and methylene chloride are actually in the groundwater or attributable to lab error or inhome plumbing. A public water supply system has been extended to all residences in the area of potential impactfrom the site. The public water supply wells are not located near the potential area of impact of the site. The closestmunicipal wells are located 1 and 1.5 miles away from the site.

The landfill produces methane, which was found to be migrating from the site in the mid 1980s. In response tomethane gas detections in the basements of nearby residences, WMWI monitored residential basements forcombustible gas. Two residential basements currently have continuous gas monitors and are checked on a regularbasis. A gas extraction system was installed within the landfill that draws gas to an on-site flare. In l985, one of thebasement gas monitors triggered the alarm on two occasions. Waste Management responded by increasing ventilationthrough the house and adjusting the gas extraction system to mitigate the migration of gas into the basement. Thesystem is monitored and adjusted regularly to prevent methane gas from migrating from the site. Improvements havebeen made in this system in order to maintain compliance with new state and federal air toxics regulations.

A Superfund Remedial Investigation has not yet been conducted at this site.

SITE VISIT

On November 21, l988, a representative from the Wisconsin Division of Health (WDOH) met with one representativefrom the Wisconsin Department of Natural Resources(WDNR) Southeast District, and two representatives from WasteManagement at the Waste Management Brookfield Site.

The entrance to the site is from Brookfield Road, which borders the east side of the site. A locked gate restrictedaccess from Brookfield Road; however, the gate only extended across the width of the drive leading into the site and itwould be easy to enter the site by walking around the fence.

The site was essentially unrestricted except for the gate at the entrance off Brookfield Road, a short length of cyclonefence that blocks off access from a cul-de-sac on the northeast side of the site, and several old wooden fences alongbackyards.

Upon entering the site, site visitors noted a small building with a flare on the top and a gaseous odor. The gasextraction system draws gas from within the landfill to the building and the flare. Gas probes, gas systemmaintenance manholes, and groundwater monitors were observed on the northern side of the site. The manholes werelocked with padlocks and many of the gas probes and monitoring wells were tilted as a result of soil slump.

The site slopes steeply to the south and had a thick cover of grass. Drainage ditches had been installed to carrysurface water run-off downhill, to the south and into the wetland to the south of the site. Several gullies wereobserved that had extended through the grass and flowed downhill, to the south. A service road that runs east-westthrough the site had been partially washed out, exposing a fabric layer and clay cap. A four-wheel drive vehicle hadbeen driving on the cap and had torn up much of the grass along the northern half of the site. These tracks were laterfound to be from the drill rig used to install the monitoring wells in that area. Deer tracks that had broken through thegrass cap were observed on-site.

The southern end of the site is bordered by a wetland. To the south of the wetland is a subdivision. Many pools ofstanding water were observed in ditches that ran along the road in front of houses to the south of the wetland.

Another site visit was made by Chuck Warzecha of the WDOH on June 15th of 1993. Chuck was accompanied byrepresentatives of both WDNR and WMWI. The site had similar access to that noted in the earlier visit. The cap wasin very good condition and nothing unusual or of concern was noted during the visit. The WMWI representativenoted that there has not been a problem with vandalism or trespassing on the property.

DEMOGRAPHICS, LAND USE, AND NATURAL RESOURCE USE

The Waste Management-Brookfield Landfill is surrounded by subdivisions. Many of the yards of these homes borderWaste Management property and are approximately 50 feet from the fill area. There is a nursing home and a schoolwithin 1/6 mile southeast of the site, along Brookfield road.

HEALTH OUTCOME DATA

A review of health outcome data is appropriate when there is evidence of people who have been exposed tocontaminants at levels which could lead to an increase in rates of death or illness. Such a review is also appropriatewhen community health concerns expressed can be related to exposures to contaminants at levels which could lead toan increase in rates of death or illness. "Health Outcome Data" refers to records of death and/or disease. A review ofhealth outcome data might also be appropriate if there are reports of unusual clusters or higher-than-expected levelsof specific diseases near a site. (?) Health outcome data related to this site is discussed in the Public Health Implications section.


COMMUNITY HEALTH CONCERNS

The Division of Health in Wisconsin is not aware of any health complaints associated with this site. However, therehas been minimal contact with citizens in the community. As part of the Superfund process in Wisconsin, interviewswill be conducted with local citizens and officials. WDOH participates in these interviews with the EPA and WDNR as they develop their community relations plan.


ENVIRONMENTAL CONTAMINATION AND OTHER HAZARDS

This section describes contamination and other hazards associated with the Brookfield Superfund site. Contaminantsof concern are selected for further analysis in following sections. Areas considered to be "on-site" are those areas onWaste Management Property. All other areas are considered to be "off-site". Environmental sample results aresummarized in this section as they apply to both on-site and off-site contamination. Detailed accounts of each sampleand results from analysis can be found in the WDNR files for the site.

The tables in this section list the contaminants of concern. We evaluate these contaminants in the subsequent sectionsof the Public Health Assessment and determine whether exposure to them has public health significance. ATSDRselects 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 comparison values 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-site Contamination subsection,the listed contaminant does not mean that it will cause adverse health effects from exposures. Instead, the listindicates which contaminants will be evaluated further in the Public Health Assessment. When selected as acontaminant of concern in one medium, that contaminant will be reported in all media.

A comparison value is a contaminant concentration level below which human exposure is likely to be without harmfulhealth effects. Comparison values are derived from toxicity data and exposure dose assumptions for specific media(e.g. soils, drinking water, etc.). These values are referred to when possible to help select potential contaminants ofconcern from the results of samples taken from the site.

ON-SITE CONTAMINATION

This site is an unlined landfill. As a result, leachate from the landfill has migrated into the groundwater beneath thesite. An engineered cap was placed over the site in 1988 to prevent rainwater from infiltrating the landfill and causingadditional leachate migration to the groundwater. The breakdown of organic wastes in the site is producing methanegas. This gas has migrated from the landfill in the past.

Groundwater
Groundwater contamination has been detected in groundwater beneath the site. VOCs were detected in the analysis of on-site groundwater directly beneath the site. These VOCs are likely to be indicative of the organic contamination leaching into the groundwater. The following is a summary of the VOCs detected and the maximum levels from a 1986 sampling event:

A complete characterization of groundwater quality on-site has not been completed. Monitoring wells have beensampled regularly and analyzed for indicator parameters, though analysis for contaminants of concern has been limited.

Table 1.

CONTAMINANTS IN ON-SITE GROUNDWATER (CH2M Hill) Concentrations in g/L

Volatile Organic Compound Concentration Comparison Value Source
Benzene 57 1 CREG
Chloroethane 13 NONE  
1,1-Dichloroethane 110 NONE  
1,1-Dichloroethene 85 0.06 CREG
1,2-Dichloroethane 29 0.4 CREG
trans-1,2-Dichloroethene 1500 200 RMEG
1,2-Dichloropropane 11 700 EMEG
Ethylbenzene 1200 1000 RMEG
Tetrachloroethene 52 0.7 CREG
1,1,1-Trichloroethane 5 200 LTHA
Trichloroethene 340 3 CREG
Vinyl chloride 180 0.2 EMEG
Xylenes (total) 6000 20,000 RMEG

g/L = microgram per liter
CREG = Cancer Risk Evaluation Guide for 1x10-6 excess cancer risk
EMEG = ATSDR's Environmental Media Evaluation Guide
LTHA = EPA's Drinking Water Lifetime Health Advisory
RMEG = Reference Dose Media Evaluation Guide, calculated from EPA's reference dose

Air

Ambient air has not been tested at the site. In December of 1990 and January of 1991 test burns of flared emissions were conducted (Mostardi-Platt Assoc.). The results of those tests measured destruction efficiencies for benzene, vinyl chloride, and methane to be as follows:

Benzene 91.2%
Methane 100%
Vinyl chloride 97.2%

Because the site was capped and the gas extraction system has been installed, gas migration to the air on-site has been limited to the emissions from the flare. These emissions meet current Federal and State air toxics standards. Methane levels and gas pressure are currently being monitored by on-site gas probes installed on the northern side of the site.

Sampling information is not available for surface soils prior to the installation of the cap. The cap was constructedfrom clean fill material and would not be expected to contain contamination. Surface water sampling has not beendone at the site.

OFF-SITE CONTAMINATION

Nine basements to the north and east of the site are monitored monthly between October and April for methane andpercent combustible gas. Two residences have continuous gas monitors with audio alarms in their basements. One ofthe continuous monitors sounded in December of l985; residents alerted a representative from Waste Management. The Waste Management representative came to the house, opened windows, and turned on a window fan to eliminatethe gas problem. The gas extraction system was then adjusted to prevent further infiltration of landfill gas into thebasement. Gas monitoring in the basements subsequent to this incident indicates that methane gas is not present atexplosive concentrations. An analysis of air in the basement to identify volatile organic constituents and associatedconcentrations in landfill gas has not been performed.

Residential wells have been monitored for lead, arsenic and organic chemicals. There is a history of bacteriologicalcontamination in private wells in this area. Residential wells to the north that border Waste Management are routinelymonitored for indicator parameters (e.g., Ph, total organic carbon, hardness). Arsenic and lead were detected in one ofthe quarterly analyses, though the data quality is suspect and the levels are not quantifiable. Two VOCs were alsodetected in private wells near the site. Those compounds were: methylene chloride and trichloroflouromethane. Because of a lack of quality control during the sampling, concentrations of these compounds are not quantifiable. There has been very limited sampling of contaminants of concern in private wells near the site. There is no groundwater monitoring information of private wells located to the south of the site.

QUALITY ASSURANCE AND QUALITY CONTROL

Very limited sampling has taken place at the site for potential contaminants of concern. Quality control information isnot available for the sampling that had taken place.

TOXIC CHEMICAL RELEASE INVENTORY

The 1988, 1989 and 1990 Toxic Chemical Release Inventory (TRI) was searched for chemical releases near the site. No releases related to or potentially impacting the site were noted.

PHYSICAL AND OTHER HAZARDS

A potential physical hazard exists from methane gas migration. The migration could potentially cause gas to collectand build up in basements to levels that could pose an explosion hazard. Methane had been detected at 5% in abasement. This hazard has been reduced and possibly eliminated with the addition of the gas extraction system.


PATHWAYS ANALYSES

COMPLETED EXPOSURE PATHWAYS

There are no known completed exposure pathways at this site.

POTENTIAL EXPOSURE PATHWAYS

There is a potential for inhalation exposure to VOCs in the basements of nearby residences. This potential wouldhave been greater prior to the installation of the gas extraction system. However, this pathway has not beeninvestigating.

There is also a potential for ingestion of contaminated drinking water from residential wells near the site. Thisexposure pathway has not been investigated.

Air
Large quantities of gas are generated from the waste in this landfill. This gas is currently being extracted and flared on-site. Gas monitoring at on-site gas probes and in residential basements has indicated that landfill gas has migrated off-site in the past. Engineering improvements on the gas extraction system have been made to control the migration of gases. At the present time, gas monitoring does not indicate that high levels of landfill gas are migrating off-site. On-site gas monitoring wells are tested twice a month for pressure, percent combustibles and percent oxygen. Nine residences to the north and east of the site are monitored monthly from October to April for combustible gas. If mechanical failure occurs that results in a loss of the gas extraction system for more than one day, gas monitoring is done on a daily basis until the system is again in operation.

The gas extraction system is powered by electricity and does not have a back-up power source such as a battery-started generator. If the electricity went out for more than 24 hours, Waste Management would bring in a generator tocontinue operating the system and the Wisconsin Department of Natural Resources would be notified. It is difficult topredict how far landfill gas might migrate within 24 hours without the gas extraction system in operation. The twocontinuous gas monitors located in residential basements are also electrically powered and do not have batterybackups. If electricity were to go out and methane migrated into basements while the gas extraction system was out,residents would not be alerted if concentrations of methane rose to levels that might pose an explosion hazard.

The general direction of soil gas migration appears to be towards the north and east. Methane concentrations in soilare monitored on the northern end of the site and in several residential basements located to the immediate north andeast of the site. In l985, 5% concentration of combustible gasses was found in the southwest corner of one of thebasements. The gas extraction system was then modified to eliminate further gas migration into this basement.

Gas monitoring to date has been used to identify concentrations of methane that may pose an explosion threat. Inhalation of VOCs in the basements of nearby homes may also be a exposure pathway. However, An analysis of airin the basement to identify volatile organic constituents and associated concentrations in landfill gas has not beenperformed.

Groundwater
On-site groundwater monitoring has shown evidence of groundwater contamination at this site. Sand/gravel layers may provide a conduit for gas or groundwater migration while the clay/silt layers are less permeable and will tend to block migration. The private wells north of the site draw water from the dolomite aquifer. In l987, a municipal water main was installed in the subdivisions to the north of the site. All residents north of the site are believed to be using the municipal water supply. However, it is possible that some residents to the north of the site continue to use water from private wells. Residents are required to be connected to the municipal system by the end of the 1998. Closing and grouting private wells is not mandatory and private wells may be used for outside watering purposes even after the ten-year deadline. Groundwater flow is believed to be primarily to the southeast. Some residents to the south of the site may also be using private wells.

Exposure to groundwater may occur through ingestion of drinking water, and through dermal contact and inhalationvia showers and cooking. Characterization of groundwater quality has not been done to determine if contaminants aremigrating from the site to possible points of exposure. There has not been enough sampling of private wells near thesite to determine if any have been impacted from the site.

Surface Water
The site slopes steeply to the south and a wetland is located to the immediate south of the site. Drainage ditches have been installed that route excess surface water runoff to the wetland to the south of the site. Standing water is present in the wetland and in front of homes located south of the wetland. It is possible that surface water runoff prior to capping of the landfill has resulted in surface water contamination to the south of the site. This surface water has not been sampled for potential contaminants of concern.

Dermal exposure to or ingestion of potentially contaminated surface water in the wetland or in ditches are potentialexposure pathways. Contaminated sediments and soils may be a concern since the wetland is not restricted and it ispossible that children or pets that enter the wetland area. This potential pathway may no longer exist since the addition of the clay cap on the site in 1988.


PUBLIC HEALTH IMPLICATIONS

TOXICOLOGICAL EVALUATION

There are no known completed exposure pathways at this site.

Landfill gas that may migrate into residential basements or that is dispersed in the ambient air is a public healthconcern. There is a potential for exposure to volatile organic chemicals via inhalation. Individual volatile organiccontaminants in the landfill gas from the Waste Management-Brookfield Site have not yet been specifically monitoredfor, however, gas generated from landfills commonly contains volatile organic chemicals which are of concern tohuman health. A potential also exists for high levels of combustible gas to migrate and be confined in residentialbasements, creating an explosion hazard.

Exposure to contaminated groundwater is also of concern at this site if persons were to drink it. There has not beenenough sampling of private wells near the site to determine if any have been impacted from the site.

HEALTH OUTCOME DATA EVALUATION

No data are available that indicate health effects would be expected for people living near the site. The review ofhealth outcome data will be considered when remedial investigation data become available and indicate that anexposure may have occurred, or be occurring.


COMMUNITY HEALTH CONCERNS EVALUATION

The Division of Health in Wisconsin is not aware of any health complaints associated with this site. However, therehas been minimal contact with citizens in the community. As part of the Superfund process in Wisconsin, interviewswill be conducted with local citizens and officials. The Wisconsin Division of Health participates in these interviewswith the EPA and Wisconsin Department of Natural Resources as they develop their community relations plan.

All community health concerns will be addressed as they arise and presented in the full public health assessment for the site.


CONCLUSIONS

The site is a closed landfill with a history of gas migration problems. Groundwater contamination has been identifiedbeneath the site. A cap and an active gas extraction system were constructed on the site in 1988 in response to theseproblems. The Superfund remedial investigation process has not yet begun at the site. There is very limited samplingdata available for the site.

The site poses an indeterminate public health hazard from inhalation exposure to contaminated indoor air migratinginto the basements of nearby residences. Samples of basement air have not been analyzed for contaminants ofpotential concern at the site. The site poses an indeterminate public health hazard from ingestion of contaminatedgroundwater in private wells near the site. Characterization of groundwater quality has not identified whethercontamination has migrated to private wells near the site. There is also an indeterminate public health hazard fromdermal exposure to contamination in the wetland south of the site. No samples for contaminants of concern have beentaken from surface water or sediments in this area that drained a portion of the site prior to installing the cap. The siteposes no apparent public health hazard from contact on-site soils and inhalation of ambient air at and near the site.


RECOMMENDATIONS

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

  1. Restrict unauthorized access to the site.

  2. Fully characterize groundwater quality both on-site and off-site.

  3. Identify private wells in the potential area of groundwater quality impact from the site and sample those wells.

  4. Evaluate the potential for contaminants to have migrated to the wetland south of the site and sample if the potential is indicated.

  5. Provide backup (battery-powered or generator) for continuous gas monitors and alarms in the event of electrical failure.

  6. Develop a standard procedure for actions to be taken if the electricity goes out and the gas extraction system stops operating.

  7. WDOH should conduct interviews with local citizens and officials to determine what if there are community health concerns.

NEED FOR FOLLOW-UP HEALTH ACTIVITIES

The Division of Health and the ATSDR Health Activities Recommendation Panel reviewed the data on this site todetermine the need for more action on health-related concerns. Such action could include conducting more studies oncases of disease in the area or providing information about exposure to toxic chemicals.

Community education about this site is needed as part of ongoing efforts at Wisconsin's Superfund sites. If theremedial investigation of this site shows that exposure to toxic substances is more widespread than previous samplingfound, the Wisconsin Division of Health and ATSDR will reconsider the need for other activities.


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.

  3. Provide site information and offer health information to primary care physicians and public health professionals in the geographic region of the site.

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

  5. If future WDOH evaluations indicate that additional completed exposure pathways exist or that the community has expressed specific health concerns, then WDOH will consider reviewing health outcome data bases.

PREPARERS OF REPORT

Chuck J. Warzecha
Hydrogeologist
Section of Chronic Disease & Health Assessment
Bureau of Public Health
Division of Health
Wisconsin Department of Health & Social Services

ATSDR Regional Representatives

Louise Fabinski and Manna Edwards
Regional Services
Region V
Office of the Assistant Administrator

ATSDR Technical Project Officer

William Greim
State Programs Section
Remedial Programs Branch
Division of Health Assessment and Consultation


CERTIFICATION

This Waste Management of Wisconsin Public Health Assessment was prepared by the Wisconsin Department ofHealth and Social Services under a cooperative agreement with the Agency for Toxic Substances 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
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

CH2M Hill, Ecology & Environment. "Inspection Report for Waste Management of Wisconsin, Inc., Brookfield, WI." March 7, 1986.

P.E.L.A.. "Brookfield Sanitary Landfill, In-field Conditions Report." Prepared for Waste Management of Wisconsin, Inc.. July 5, 1984.

Mostardi-Platt Associates, Inc. "A Gaseous Study." Performed for Waste Management of Wisconsin, Inc. Brookfield facility Landfill Gass System. January through February 1991.

Leedom, J.B., Waste Management of Wisconsin, Inc.. Memo to Gretchen Wheat, Wisconsin Department of Natural Resources. "First Quarter 1993 Gas Management System Report." April14, 1993.

USEPA. "HRS Scoring Package for Waste Management of Wisconsin, Inc. Brookfields Landfill Site. August 1990.

Young, Mary, Wisconsin Division of Health. Memo to Waste Management of Wisconsin, Inc. Brookfield File. "Site Visit." October 8, 1991.

Warzecha, Chuck, Wisconsin Division of Health. Memo to Waste Management of Wisconsin, Inc. Brookfield File. "Site Visit." June 15, 1993.


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