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MILWAUKEE COUNTY
FRANKLIN
Congressional District # 01
FADROWSKI DRUM DISPOSAL
EPA ID# WID980901227Last Updated: November, 2008
Site Description
The Fadrowski Drum Disposal site (FDDS) occupies approximately 20 acres of semirural land in the city of Franklin, Milwaukee County, Wisconsin. Between 1970 and 1982, FDDS was owned and operated by Edward J. Fadrowski as an unlicensed disposal site that accepted demolition and construction wastes. The Wisconsin Department of Natural Resources (WDNR) disclosed the disposal of nonexempt waste at the site in 1981. In December 1982, Menards, Inc. purchased the FDDS and two adjacent land parcels and began constructing the Menard's Home Improvement Center.
During excavation in May 1983, buried drums containing unknown liquids and sludges were uncovered. WDNR conducted sampling of 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.
The site was placed on the National Priorities List (NPL) on June 10, 1986. The United States Environmental Protection Agency (U.S. EPA) and WDNR believed that a number of potentially responsible parties (PRPs) either generated the hazardous wastes which were disposed of at the site, or caused the release of these substances at the site. The PRPs are those parties the U.S. EPA has determined may be legally responsible for the site's contamination. The remedial investigation and feasibility study (RI/FS) was completed in May 1991 by the PRP pursuant to a legal agreement [Administrative Order on Consent (AOC)] signed May 1987. The RI is a study that determines the nature and extent of contamination; the FS is a study that evaluates cleanup alternatives for the site.
Site Responsibility
This site is being addressed by Potentially Responsible Party actions under federal and state enforcement actions.Threats and Contaminants
The RI results confirmed that groundwater from one of the onsite monitoring wells contained low levels of mercury and benzene. Chromium, barium, and cyanide were found in shallow groundwater at levels exceeding Wisconsin Preventive Action Limits (PALs). A surface water sample from the onsite creek, flowing on the west side of the site, contained low levels of cyanide and VOCs. Sediment samples collected from the onsite creek and ditches contained polycyclic aromatic hydrocarbons (PAHs) and inorganic compounds. Subsurface soil samples from the site were contaminated with low levels of VOCs, especially toluene. There are several private wells located within 2,000 feet of the site and several emergency backup wells for the cities of Franklin and Oak Creek located within three miles of the site; however, testing showed that drinking water had not been affected by the site.
A risk assessment was performed to determine all possible exposures to the site contaminants. The assessment indicated that people may have been exposed to hazardous substances through drinking contaminated groundwater and surface water or by accidentally ingesting contaminated soil. Local residents in the area around the site, especially children, may be exposed to site contaminants by playing in the pond located at the eastern edge of the site. Buried drums onsite would pose a threat if the site is developed in the future. The RI indicated that some of the drums had ruptured, causing further contamination of the environment. Approximately nine acres of wetlands border the onsite 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 flows to an onsite drainage and leachate collection system.
Cleanup Progress
Based on the RI/FS, U.S. EPA issued a record of decision (ROD) on June 10, 1991, documenting the selected cleanup action for the site. Menards, a PRP for the site, completed a remedial design (RD) for the cleanup. The RD was conducted under an enforcement agreement and was approved by U.S. EPA in March 1993.
U.S. EPA 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. This included: the removal of 167 buried drums; the excavation of approximately 100 cubic yards of contaminated soils; the removal and closure of the onsite 2.6 million-gallon pond; the consolidation of over 18,000 cubic yards of waste; the installation of a multilayered soil cover system over the consolidated wastes; and the installation of groundwater monitoring wells, a leachate collection system, and a secure perimeter fence.
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 were conducted at the site by the PRPs.
The first five-year review for the site was completed by U.S. EPA in September 1998. The report concluded that although the remedy was protecting human health and the environment, groundwater monitoring needed to continue since groundwater cleanup goals had not been achieved.
A two-year statistical evaluation of contaminant levels in the groundwater, leachate, surface water, and sediment was completed in October 1999. The report evaluated the effectiveness of the remedy and the possibility of reduced monitoring. The report indicated that natural attenuation of site-related contaminants has been effective. Surface water and sediment in the onsite creek are no longer affected by site contaminants and no longer require regular sampling. The sampling frequency of groundwater and leachate was reduced to biannual monitoring.
A five-year statistical evaluation was completed by the PRPs in December 2002. The report indicated that the RA groundwater cleanup goals had been met for all contaminants, except fluoride, iron, and manganese. U.S. EPA and WDNR evaluated the groundwater data and determined that these exceedances were due to naturally elevated levels of these inorganics 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 selected as cleanup goals Wisconsin Alternate Concentration Limits (WACLs) instead of PALs for these inorganics.
In September 2003, U.S. EPA in cooperation with WDNR, conducted a second five-year review of the site to evaluate the effectiveness of the remedial action. The review confirmed that the cleanup was effective and that the site posed no risks to the community or environment. A final RA close out report was issued by U.S. EPA on August 8, 2003.
With the concurrence of WDNR, U.S. EPA deleted the FDDS from the NPL on September 6, 2005. A consent order was signed between Menards and the 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).
The third five-year review site inspection was conducted on May 23, 2008. The five-year review report, issued on 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. A site-wide ready for anticipated use (SWRAU) determination was also completed 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.
The fourth five year review will be completed in July 2013.
Property Reuse
In July 24, 2001, U.S. EPA relaxed the deed restrictions that were put into place as part of the remedy in order to encourage redevelopment. These areas had previously been considered buffer areas around the site; however, due to stable site conditions, the WDNR has since allowed limited commercial development in these areas. No reuse of the actual site property can occur due to the need to maintain the integrity of the landfill cap and containment system and the site monitoring wells.Contacts
Remedial Project Manager, U.S. EPAsheila sullivan (sullivan.sheila@epa.gov)
(312) 886-5251
Community Involvement Coordinator, U.S. EPA
patricia krause
(312) 886-9506
Aliases
FADROWSKI DRUM DSPLMENARD'S DRUM DSPL SITE