Congressional District # 01
FADROWSKI DRUM DISPOSALEPA ID# WID980901227
Last Updated: March, 2015
The Fadrowski Drum Disposal (FDD) Superfund site occupies about 20 acres of semi-rural land in the city of Franklin, Milwaukee County, Wisconsin. Edward J. Fadrowski owned the site between 1970 and 1982 and operated it as an unlicensed disposal site for demolition and construction debris. In 1981, the Wisconsin Department of Natural Resources (WDNR) disclosed that nonexempt waste was also disposed of at the site.
In December 1982, Menards, Inc. purchased the FDD site and two adjacent parcels and began constructing a Menards Home Improvement Center on the properties. In May 1983, excavators uncovered buried drums containing unknown liquids and sludges. WDNR sampled the drum contents and found them to be contaminated with high concentrations of lead and chromium. Trace levels of arsenic, the pesticide DDT, and petroleum-derived volatile organic compounds (VOCs) were also identified.
Site features include a pond located at the eastern edge of the site and about nine acres of wetlands bordering the pond to the west as well as a drum and debris disposal area.
The U.S. Environmental Protection Agency (EPA) placed the FDD site on the National Priorities List (NPL) on June 10, 1986.
Site ResponsibilityThe Fadrowski Drum Disposal site is being addressed by potentially responsible party (PRP) actions under federal and state oversight.
Threats and Contaminants
Sampling results from the Fadrowski Drum Disposal site showed that groundwater in one of the on-site monitoring wells contained low levels of mercury and benzene. Chromium, barium, and cyanide were also found in shallow groundwater at levels exceeding Wisconsin Preventive Action Limits. A surface water sample contained low levels of cyanide and VOCs and sediment samples contained polycyclic aromatic hydrocarbons (PAHs) and inorganic compounds. Subsurface soil samples from the site were contaminated with low levels of VOCs, especially toluene.
People could be exposed to these hazardous substances through drinking contaminated groundwater and surface water or by ingesting contaminated soil. Area residents could have been exposed to site contaminants by playing in the pond water. The contents of the buried drums could cause potential health effects if someone were to be exposed to them.
Note: there are several private wells located within 2,000 feet and several emergency backup municipal water supply wells for the cities of Franklin and Oak Creek located within three miles of the site; however, testing showed that drinking water quality in these wells had not been affected.
EPA and WDNR determined that a number of potentially responsible parties (PRPs) either generated or caused the release of the hazardous wastes that were disposed of at the FDD site. EPA then issued an Administrative Order on Consent (AOC) in May 1987 to these PRPs to undertake a remedial investigation and feasibility study (RI/FS) at the site.
The RI/FS was completed in May 1991 and EPA issued a record of decision (ROD) on June 10, 1991 that documented the selected cleanup action for the site based on the RI/FS results. The remedy included drum removal, excavation of contaminated soil, closure of the on-site pond, consolidation of waste, installation of a multilayered soil cover system over the consolidated wastes, and installation of groundwater monitoring wells, a leachate collection system, and a secure perimeter fence.
Menards, Inc., the current site owner, completed a remedial design (RD) for the selected cleanup actions. The RD was conducted under an enforcement agreement and was approved by EPA in March 1993. EPA then issued a unilateral administrative order (UAO) to the PRPs on April 21, 1993, directing them to implement the remedial actions (RA) specified in the ROD. The RA field activities were initiated in September 1993 and a major portion of the work was completed by September 1994. The work included: removial of 167 buried drums; excavation of about 100 cubic yards of contaminated soil; closure of the on-site 2.6 million-gallon pond; consolidation of over 18,000 cubic yards of waste; installation of a multilayered soil cover system over the consolidated wastes; and installation of groundwater monitoring wells, a leachate collection system, and a perimeter fence. Approximately nine acres of wetlands border the on-site pond on the west. In the past, runoff from the site flowed towards the wetlands; however, since the completion of the construction in September 1994, site runoff now flows into the drainage and leachate collection system.
Since November 1995, the effectiveness of the remedy has been monitored through quarterly sampling of groundwater leachate, surface water, and sediment. By January 2003, a total of 16 quarterly groundwater surveys had been conducted at the site by the PRPs.
EPA completed the first five-year review (FYR) at the FDD site in September 1998. EPA concluded in the FYR report that the remedy was protective of human health and the environment, but the quarterly groundwater monitoring effort needed to continue since the groundwater cleanup goals had not yet been achieved.
In October 1999, the PRPs completed a two-year statistical evaluation of contaminant levels in the groundwater, leachate, surface water, and sediment and submitted a report of their findings. The report evaluated the effectiveness of the remedy and made a case for reduced frequency of monitoring. The report indicated that natural attenuation of site-related contaminants has been effective and that surface water and sediment in the on-site creek were no longer affected by site contaminants and should not require regular sampling. Upon review, EPA agreed to reduce the sampling frequency of groundwater and leachate to biannually from quarterly.
A statistical evaluation of five years of groundwater monitoring data was completed by the PRPs in December 2002 and a report was submitted that detailed the findings. The report stated that the RA groundwater cleanup goals had been met for all contaminants, except fluoride, iron, and manganese. EPA and WDNR evaluated the groundwater data in the report and determined that these exceedances were due to naturally elevated levels of these inorganic compounds in the region. Since the natural background levels of these constituents did not present health risks and could not be feasibly removed from the groundwater, the Agencies determined that Wisconsin Alternate Concentration Limits (WACLs), instead of Preventive Action Limits, would be the appropriate cleanup goals for these compounds.
EPA, in cooperation with WDNR, conducted a second FYR at the FDD site in September 2003 to evaluate the effectiveness of the RA. The review confirmed that the cleanup was effective and that the site posed no risks to the community or environment. EPA issued a final RA close out report on August 8, 2003.
With the concurrence of WDNR, EPA deleted the FDD site from the NPL on September 6, 2005. A consent order was signed between Menards, Inc. and WDNR in March 2005 to ensure the continued operation and maintenance of the site. The site groundwater continues to be monitored for parameters required under the 2005 consent order. None of the groundwater contaminants exceed drinking water maximum contaminant levels (MCLs) under the federal Safe Drinking Water Act.
EPA conducted the third FYR site inspection on May 23, 2008. The FYR report of July 30, 2008 found that the site-wide remedy is protective of human health and the environment in both the short and long term. The remedy is functioning as intended by the ROD and is expected to continue in this manner. EPA subsequently completed a site-wide ready for anticipated use (SWRAU) determination on February 22, 2008. This determination was made because the site met the following two criteria: 1) all cleanup goals in the ROD or other remedy decision documents have been achieved for any media that may affect current and reasonably anticipated future land uses, so that there are no unacceptable risks; and, 2) all institutional or other controls required in the ROD have been put in place and are effective.
EPA completed the fourth FYR of the FDD site on May 20, 2013. As with the previous FYR, the site remedy was determined to be protective of human health and the environment. Although ICs have been implemented in the form of deed restrictions, an updated Restrictive Covenant is being pursued to better assure that the remedy will continue to provide long-term protection and additional evaluation activities will occur to ensure that no other encumbrances will interfere with the ICs.
In July 24, 2001, EPA relaxed the deed restrictions that were put into place as part of the remedy in order to encourage site redevelopment. The areas that had previously been considered buffer areas around the site have, due to stable site conditions, allowed WDNR to permit limited commercial development in these areas. This portion of the site is well-positioned for commercial or recreational reuse. If Menards, Inc. decides to proceed with redevelopment of the site, EPA and WDNR will work with the interested parties to accommodate their goals while still ensuring the protectiveness of the remedy.
There is no planned reuse of the actual 11-acre capped landfill area. Integrity of the landfill cap, containment system and the site monitoring wells must be maintained into the future as long as waste remains in place.
ContactsRemedial Project Manager, U.S. EPA
sheila sullivan (firstname.lastname@example.org)
Community Involvement Coordinator, U.S. EPA
AliasesFADROWSKI DRUM DSPL
MENARD'S DRUM DSPL SITE