Congressional District # 02
HAGEN FARMEPA ID# WID980610059
Last Updated: February, 2012
The Hagen Farm site is located at 2318 County Highway A in the town of Dunkirk, approximately one mile east of the city of Stoughton, Dane County, Wisconsin. The Hagen Farm property is about 28 acres in size. Within the property boundary is a waste disposal area of approximately 10 acres, underlain by contaminated groundwater. The site is bounded on the south by County Highway A and on the north by a gravel pit operation. The Yahara River is located about 1.5 miles to the west of the site and flows in a southerly direction. Regional groundwater generally flows toward the river in a southwesterly direction from the site.
The site was operated as a sand and gravel pit prior to the late 1950s. The gravel pit was then used for the disposal of waste materials from the late 1950s to the mid-1960s. Waste solvents and various organic materials, in addition to municipal wastes, were disposed of at the site including, acetone, butyl acetate, 1-2-dichloroethylene (DCE), tetrahydrofuran (THF), solid vinyl, sludge material containing methyl ethyl ketone, xylenes, and toluene. The site stopped accepting waste in 1966. Groundwater has been impacted by acetone, THF, vinyl chloride, xylene, DCE, and trichloroethylene (TCE).
Prior to disposal activities, the land comprising the waste disposal area was excavated for sand and gravel; thus, the natural habitat that existed at the site prior to these operations was destroyed. Land in the immediate vicinity of the site has been developed for agricultural, mining, and commercial uses. The unincorporated town of Dunkirk is primarily a farming community. Approximately 350 people reside within one mile of the site.
In 1983, the state of Wisconsin brought an enforcement action against Waste Management of Wisconsin, Inc. (WMWI) and Uniroyal Plastics, Inc., two potentially responsible parties (PRPs) at the site, for the abatement of a public nuisance. At the same time, residents near the site filed a civil action against WMWI and Uniroyal for potential health hazards and the devaluation of their properties. In 1986, the parties to the civil litigation reached a settlement that required in part, that WMWI purchase the Hagen property and adjacent properties. The state dismissed its enforcement action against the PRPs after the site was listed on the National Priorities List (NPL) in 1987.
The Hagen farm site is divided into two portions, termed "operable units," for ease of addressing potential environmental problems. The first, called the source control operable unit (SCOU), comprises the waste refuse and contaminated soils beneath the disposal area. The second, known as the groundwater control operable unit (GCOU), addresses the groundwater contamination plume beneath the site and downgradient of the property boundary.
Site ResponsibilityThis site is being addressed through potentially responsible party (PRP) actions, with federal and state oversight.
Threats and Contaminants
There were three waste disposal areas on the Hagen Farm site, with the largest occurring in one main area (Area A). Area A contained about 68,000 cubic yards of waste, including municipal refuse, paint sludges, grease, rubber, plastic sheeting, and several industrial chemicals. The contaminants of concern found in the waste and in groundwater in contact with the refuse were THF, benzene, ethylbenzene, toluene, xylenes, various semi-volatile organic chemicals, barium, lead, and mercury.
The contaminants of concern in the groundwater plume were volatile organic chemicals (VOCs). The most prevalent of these, THF, occurred in concentrations as high as 630,000 parts per billion (ppb). Though VOCs were not found in any private wells during the investigation, it was determined that contaminants in the waste and groundwater posed an unacceptable risk to human health. These exposures could occur primarily through direct contact, inhalation, and ingestion of the groundwater onsite and offsite. The highest concentrations of VOCs in groundwater were found near the former disposal areas. Soils and wastes on the property were also contaminated with VOCs. Ingestion and direct contact with contaminated soils and wastes also posed a potential health threat.
The PRPs signed an Administrative Order on Consent with the United States Environmental Protection Agency (EPA) in July 1987, whereby they agreed to conduct a Remedial Investigation and Feasibility study (RI/FS) at the site. An RI is an investigation into the nature and extent of contamination at the site and a FS is a study which evaluates cleanup alternatives for the site. The PRPs conducted the RI/FS between 1988 and 1992, and during which time EPA determined that the site cleanup would be best approached by dividing it into two operable units (OU). The first operable unit, called the source control operable unit (SCOU), comprises the waste refuse and contaminated soils beneath the disposal area. The second, known as the groundwater control operable unit (GCOU), addresses the groundwater contamination plume beneath the site and downgradient of the property boundary.
EPA signed a Record of Decision (ROD) in September 1990 to select the cleanup approach for the SCOU and EPA also signed a ROD that addressed the GCOU in September 1992. The ROD for the waste disposal area called for consolidating three waste disposal areas into Area A, capping the consolidated waste, and installing and operating an in-situ vapor extraction (ISVE) system. The ROD for the contaminated groundwater called for pumping and treating the groundwater.
A PRP, Waste Management of Wisconsin, Inc. (WMWI), conducted remedial design and remedial action (RD/RA) construction for the entire site under the enforcement authority of two unilateral administrative orders (UAOs). The UAO for the SCOU was issued in March 1991. The UAO for the GCOU was issued in November 1992.
The RA construction activities were substantially completed by spring 1996. Waste consolidation and capping were completed in May 1992. The cap was designed to eliminate the threat of direct contact with the waste and to reduce the potential for additional contamination loading into the groundwater. The vapor extraction system was installed in January 1993 and is currently operating. The system was designed to treat contaminants in the waste disposal pit by drawing out volatile contaminants. Construction of the groundwater pump and treat system was completed in April 1996. The groundwater pump and treat system was designed to keep contaminated groundwater from impacting nearby residential groundwater drinking wells and to restore the groundwater aquifer to usable conditions. The vapor extraction system and groundwater pump and treat systems are expected to operate for approximately 10 years. A preliminary close out report for the site was completed on August 27, 1997.
Groundwater monitoring data from the last three years indicate that the contaminant plume has been significantly reduced. In August 2000, the PRP submitted a proposal to augment the pump and treat system with air sparging in order to accelerate the cleanup of the remaining groundwater contamination. In January 2001, the air sparge system, which pumps air into the groundwater, began operating. The air sparge system operated with the pump and treat system from January 2001 through August 2001. On August 23, 2001, U.S. EPA approved a temporary shutdown of the pump and treat system as a pilot test to evaluate the full scale effectiveness of the air sparge system. Temporary shutdown of the pump and treat system began on September 1, 2001.
In 2004, U.S. EPA performed a comprehensive review of the groundwater data under the pilot test and concluded that the air sparge system did not appear to be sufficient. Several of the VOC levels, particularly THF and vinyl chloride, did not appear to be declining. To address these concerns, the PRP installed four additional deeper air sparge wells and additional groundwater monitoring wells which began operating in April 2005. The U.S. EPA and WDNR are currently evaluating the rate of contaminant degradation in groundwater using the enhanced air sparge system in order to determine if the groundwater extraction system should be restarted. Monitoring of the groundwater will continue until the cleanup goals have been met. According to the latest monitoring data, there are still exceedances of THF and vinyl chloride, although these have primarily occurred in the source areas onsite and do not pose a health threat to nearby residents.
Two five-year review reports were completed for the site in 1996 and 2001. In general, the second report concluded that the remedy remains protective of human health and the environment, but recommended continued active remediation through the vapor extraction system, low-flow air sparging, groundwater extraction and treatment, or a combination of the two until it has been demonstrated to U.S. EPA that groundwater cleanup objectives have been achieved.
EPA issued a third five-year review report in September 2006. The comprehensive data review indicated that the enhanced air sparging system was effective; VOC concentrations in groundwater were generally showing a declining trend. The report concluded that the remedy was protective of human health and the environment in the short term, and that long term protectiveness was dependent on effective ICs at the site. The 11 residential wells closest to the site continue to be monitored on an annual basis. The sampling round conducted in August 2010 showed no site-related contamination in these wells.
On September 27, 2007, a consent decree (CD) was finalized between U.S. EPA and WMWI. The terms of the CD include the requirement that WMWI continue to perform studies and remedial response work at the site. An attached Scope of Work (SOW) for the RA Work Plan requires the continued implementation of the two RODs issued in September 1990 and September 1992, and the two ESDs issued in April 1991 and August 1996. In designing, implementing, and submitting deliverables for the ongoing RA work at the site, WMWI is required to adhere to the SOW, the RD/RA guidance and work plans, RODs, ESDs, all U.S. EPA-approved operation and maintenance (O&M) plans, all additional approved plans, and any additional guidance provided by U.S. EPA.
In July 2011, a fourth five-year review was released which included an analysis of groundwater contamination. Although the trends showed that the contamination levels decreased in some of the monitoring wells, the overall contamination levels in the groundwater have not declined significantly. Improvement of the groundwater remedy is currently being studied. Overall, the review found the remedy to be protective in the short term. The remedy will be protective in the long term once groundwater cleanup goals are achieved.
The Site is inspected by WMWI's O&M consultant on a monthly basis to conduct maintenance on the SCOU and GCOU treatment systems. As land development pressures in this area increase in the future, it will be increasingly necessary to reevaluate the need for off-property controls such as groundwater use restrictions.
In conjunction with the 2006 five-year review, an institutional control (IC) study and title commitment was performed by WMWI at the request of U.S. EPA. The study confirmed that deed restrictions had been placed on portions of all three property parcels owned by WMWI. The entire restricted contiguous area lies within the WMWI site property boundary. The restricted area is fenced and the restrictions run with the land. The restrictions prohibit any residential or commercial use of the property without the approval of EPA or WDNR. Restrictions also prohibit the use of groundwater or the installation of public wells in a known contaminated aquifer or within 1,200 feet of a landfill without the approval of WDNR. No new wells have been installed except for a replacement drinking water supply well on the downgradient commercial property. The aquifer for that well is not contaminated. The IC study information was recently reviewed by WMWI and was confirmed accurate as of 2010.
A site-wide ready for anticipated use (SWRAU) determination was made in September 2010 because the site cleanup met the following conditions: 1) All cleanup goals in the ROD, ESDs and other decision documents have been achieved for any media that may affect current or reasonable anticipated land uses so that there are no unacceptable risks; and, 2) All ICs or other controls required by the ROD or identified as part of the response action to help ensure long-term protectiveness have been put in place. To date, no property reuse is anticipated.
ContactsRemedial Project Manager, U.S. EPA
sheila sullivan (email@example.com)
Community Involvement Coordinator, U.S. EPA
AliasesNO NAME PROP AT 2318 COUNTY A.