HomeMy WebLinkAboutCC2 December 3, 1991
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INFORMATION SUBMISSION FOR
MAJOR COMPREHENSIVE PLAN AMENDMENTS
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GENERAL INFORMATION
A. Sponsoring governmental unit: City of Andover
Name of local contact person: James Schrantz, City Admin.
Address: 1685 NW Crosstown Boulevard, Andover, MN 55304
Telephone: (612) 755-5100
Name of Preparer: David L. Carlberg, City Planner
Date of Preparation: November 19, 1991
B. Name of amendment: 1991 Andover Compo Plan Amendment
Description/Summary: The City of Andover is proposing to
add approximately 114 acres to its Urban Service Area on
a parcel known as the Waste Disposal Engineering, Inc.
Sanitary Landfill Site located within the City limits of
Andover (formerly Grow Township) in Anoka County,
Minnesota.
The Site has been listed as a "Superfund Site" under the
Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA) since September of 1983.
Operations at the site however did not cease until 1984.
Site operations were regulated by the Minnesota Pollution
Control Agency (MPCA) Solid Waste Disposal Permit SW-28.
Operations at the site included the landfilling of
general municipal and commercial waste and hazardous
waste disposal.
On August 30, 1991, the U.S. EPA issued an Administrative
Order "106 Order" to a selected group of potentially
responsible parties (PRP). The PRP's, were identified as
the SW-28 Group. For further background information
consult the Administrative Order 106 in Appendix A.
Subsequent to the "106 Order", the U.S. EPA notified the
PRP's that, at a minimum, a temporary sewer system and a
public owned treatment works access must be obtainable
from local control authorities. Hence, the City of
Andover is requesting that the MUSA be expanded at this
time to provide for remedial action on the WDE Site.
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Andover Compo Plan
Amendment
If the Metropolitan Council grants the MUSA expansion,
the PRP's will tap into the Crosstown sewer line on a
temporary basis. If the testing indicates that a
permanent connection is required, it will be proposed to
connect to the sanitary sewer line on Bunker Lake
Boulevard NW. For further information consult the letter
dated June 19, 1990 to Mayor James Elling from Alan W.
Van Norman, P.E. from Conestoga-Rovers and Associates
Limited in Appendix B. The letter indicates the sewer
line options and the total flow to be discharged. The
Response Action Final Design (Appendix C) indicates that
a total flow projection of 60-100 gallons per minute
(GPM) can be expected to be discharged from the site.
For additional information on the history and the
background of the site consult the Administrative Order
106 in Appendix A and the letter dated October 7, 1991
from Jon Christofferson, Conestoga-Rovers and Associates
to Ms. Van-Anh Thai Tang, Metropolitan Waste Control
Commission in Appendix D.
C. Please attach the following:
1. five copies of the proposed amendment
2. a city-wide map showing the location of the proposed
change.
3. the current plan map(s), indicating the area(s)
affected, if the amendment triggers a map change.
4. the proposed plan map(s), indicating the area(s)
affected, if the amendment triggers a map change.
D. What is the official local status of the proposed
amendment?
(Check one or more as appropriate.)
x
Acted upon by the Planning Commission (if applicable)
on November 26, 1991 (minutes enclosed)
x
Approved by governing body, contingent upon
Metropolitan Council review, on December 3, 1991.
Considered but not approved by governing body on
Other:
E.
Indicate what adjacent local governmental units affected
by the change have been sent copies of the plan amendment
and the date(s) copies were sent to them. Notification of
affected adjacent governmental units is required for major
plan amendments.
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City of Ramsey
City of Anoka
City of Coon Rapids
City of Ham Lake Oak Grove Township
The Comprehensive Plan Amendment will be forwarded to
these communities on or before December 10, 1991 .
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Andover Compo Plan
Amendment
Because of the comprehensive nature of most major plan amendments,
a summary checklist is attached to help ensure that the amendment
is complete for Council review and to determine whether the
proposed amendment is consistent with the metropolitan systems
plans or other chapters of the Metropolitan Development Guide.
Please indicate whether the amendment affects the following
factors. Where it does, the materials submitted must fully
address the issue(s).
II IMPACT ON REGIONAL SYSTEMS
A. Wastewater Treatment
1. Change in city's 2000/2010 flow projections.
No/Not Applicable.
Yes.
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x
The net change and calculations in the city's year
2000/2010 flow projections prior to the inclusion of
the WOE site are indicated in the Revised
Comprehensive Sewer Report of 7-1-91 (see Attachment
A) .
The WOE site is expected to pump additional discharges
between 60 and 100 gallons per minute into the MUSA
line. For the purpose of the expansion request, 100
GPM will be used. Consult the Response Action Final
Design, Section 6, Table 6.1, Appendix C and the
letter dated November 19, 1991 from John Davidson,
TKDA in Attachment B.
2. Community discharges to more than one metropolitan
interceptor.
x No/Not Applicable.
Yes.
At the present time the City only discharges to the
Coon Rapids Interceptor. However, a recent MUSA
amendment granted by Met Council on October 10, 1991
planned for a future connection to the CAB Interceptor
when it becomes available to the city.
B. Transportation
1. Relationship to Council policies regarding
metropolitan highways.
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x No/Not Applicable.
Yes.
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Andover Compo ,Plan
Amendment
2. Change in type and intensity of land uses at
interchanges and other locations within a quarter-
mile of the metropolitan highway system.
x No/Not Applicable.
Yes.
3. Impact on existing trip generation.
x No/Not Applicable.
Yes.
4. Capacity of road network to accommodate planned land
use(s).
x No/Not Applicable.
Yes.
5. Impact on transit and parking strategies.
x No/Not Applicable.
Yes.
6. Does the proposed amendment contain any changes to
the functional classification of roadways? (These
changes require Transportation Advisory Board (TAB)
review.)
x No/Not Applicable.
Yes.
C. Aviation
1. Impact on regional airspace.
x No/Not Applicable.
Yes.
2. Impact on airport search area.
x No/Not Applicable.
Yes.
3. Consistency with guidelines for land use compatability
with aircraft noise.
x No/Not Applicable.
Yes.
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4. Consistency with the long-term comprehensive plan for
an airport in the vicinity of the community or
proposed development.
x No/Not Applicable.
Yes.
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Andover Compo plan
Amendment
D. Recreation Open Space
1. Impact on existing or future federal, state or
regional recreational facilities.
x No/Not Applicable.
Yes.
III IMPACT ON METROPOLITAN DEVELOPMENT AND INVESTMENT FRAMEWORK
A. Land Use
1. Describe the following as appropriate:
a. Size of affected area in acres
114 acres
b. Existing land use(s)
c. Proposed land use(s)
Open Space (undeveloped)
Open Space
d. Number of residential dwelling units involved
N/A
e. proposed density N/A
f. Proposed square footage of commercial, industrial
or public buildings N/A
B. change in the city's population, household or employment
forecasts for 2000, or any additional local staging
contained in the original plan.
x No/Not Applicable.
Yes.
C. Change in the urban service area boundary of the
community.
No/Not Applicable.
x Yes.
See enclosed maps.
D. change in the timing and staging of development within the
urban services area.
x No/Not Applicable.
Yes.
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The WDE site area requested to be included in the Coon
Rapids Interceptor MUSA would add property to the urban
service area that to date was not considered to be
potential developable land due to the possible problems
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Andover Compo Plan
Amendment
related to the sanitary landfill site. It is also the
city's understanding that the inclusion of the site will
not affect or change the timing and staging of the city's
proposed Comprehensive plan that will be submitted to the
Metropolitan Council in the weeks to come. The City
understands that even at the time the site has been
capped and the remedial action performed, it will still be
considered an undevelopable parcel and must remain as open
space.
According to estimates done July 1, 1991 by the City's
consulting engineering firm, the Coon Rapids Interceptor
has sufficient capacity to serve the WOE Sanitary Landfill
property (see flow data in Attachment A and B).
IV IMPACT ON HOUSING
A. Impact on the supply and affordability of housing types
necessary to serve persons at different stages in the life
cycle.
x No/Not Applicable.
Yes.
B. Impact on the supply and affordability of housing types
necessary to serve persons at varying income levels.
x No/Not Applicable.
Yes.
C. Impact on the community's numerical objectives for low- and
moderate-income, modest-cost market rate, and middle- and
upper-income housing units.
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x No/Not Applicable.
Yes.
V. WATER RESOURCES
A. Does the plan amendment affect a Minnesota Department of
Natural Resources or U.S. Army Corps of Engineers protected
wetland? If yes, describe type of wetland affected and
show location on a map.
x
Yes.
No/Not Applicable
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The Response Action Final Design (Appendix C, Section 9,
Pages 75-77) and the Record of Decision (Appendix E, Page
30) indicate that two (2) U.S. Army Corps of Engineers
wetlands are affected. Consult Attachment J for maps of
wetland types and locations.
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Andover Compo Plan
Amendment
B. Will the wetland be protected?
Yes. Describe how.
No. Explain why not.
Since the proposed remedial action (See Appendix F) will
involve the construction of a cap in the flood plain of
Coon Creek and also the filling of wetlands, compliance
with the applicable permit requirements established by the
Army Corp of Engineers (COE), the U.S. Fish and Wildlife
Service and the U.S. EPAi including mitigation, is
appropriate. The City of Andover Ordinances (specifically
Ordinance No. 50, the Flood Plain Ordinance) shall also be
met as well as securing the proper permits from the Coon
Creek Watershed District (CCWD). Consult pages 30-31 and
33-34 of the Record of Decision in Appendix E and Section 9
of the Response Action Final Design in Appendix C.
x
C. Will the plan amendment result in runoff which affects the
quality of any surface water body? If yes, identify which
ones.
x Yes. How.
No.
The WDE Site is situated on the south side of Coon Creek,
which discharges into the Mississippi River eleven (11)
miles from the WDE Site. The quality of these surface
water bodies may be impacted, however a National Pollutant
Discharge Elimination Permit will be required if discharges
are to occur into Coon Creek.
D. Will the water body be protected?
x Yes. Describe how.
No. Explain why not.
A National Pollutant Discharge Elimination System (NPDES)
permit will be required if discharges occur into Coon Creek
from the Site.
The City recommends that the Minnesota Department of
Natural Resources, U.S. Army Corps of Engineers and the
Coon Creek Watershed District have the opportunity to
address this question to ensure the effects of the remedial
action be as minimal as possible on the quality of the
surface water and that the proper permits are secured.
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Andover Compo plan
Amendment
VI. IMPLEMENTATION PROGRAM
A. Change in zoning, subdivision, on-site sewer ordinances or
other official controls.
x No/Not Applicable.
Yes.
At this time, the City is aware that the forty acres south
of the site, which is not a part of this request,
(Northwest Quarter of the Northeast Quarter of Section 34,
Township 32, Range 24, Anoka County, Minnesota) will need
to be rezoned for commercial uses. However, the area
requested in this Comprehensive Plan Sewer Amendment will
remain as open space and will not be developed.
Section 8 of the Response Action Final Design (RAFD)
requests that the City implement "institutional controls"
with the intent of RAFD (See Appendix C, Section 8). The
City will execute the necessary institutional controls as
deemed necessary.
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Section 1.
Section 2.
Section 3.
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TABLE OF CONTENTS
ANDOVER COMPREHENSIVE PLAN AMENDMENT
General Information
(White Paper)
(Blue Paper)
Attachments
A. Revised Comprehensive Sewer Report
B. WDE Sanitary Sewer Flow Projections
C. On Site Septic Systems
D. Lot Availability Information
E. Sewer Staging plan
F. Existing Land Use Map
G. Proposed Land Use Map
H. Soil Suitability Map
I. City On-Site Septic System Maintenance
Information
J. Effected wetlands Maps
Appendices
(Goldenrod Paper)
A. Administrative Order 106
B. Letter to Jim Elling, June 19, 1990
C. Response Action Final Design
D. Letter to Van-Anh Thai Tang, MWCC
E. Record of Decision
F. Remedial Action Plan
G. Public Hearing Notification
H. Public Hearing Minutes
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INFORMATION SUBMISSION FOR
MAJOR COMPREHENSIVE PLAN AMENDMENTS
CHECKLIST FOR DETERMINING COMPLETENESS OF
MAJOR COMPREHENSIVE PLAN AMENDMENTS: SEWERS
A. Sewered Areas within the Metropolitan Urban Service Area
1. x Projected number of households and employees to be
served by metropolitan interceptor service area in 2000 and
2010.
Chart 1. Population
1980
9,387
Chart 2. Households
1970
888
Chart 3 . Employment
1970
240
*Metropolitan Council estimates.
1990
15,216
2000
22,900
2010
29,000
1980
2,469
1990
4,430
2000
6,800
2010
8,600
1980
310
1990
400*
2000
500*
2010
600*
Source: 1990 Census Data
Community Development Department, Anoka County
The household projections are based on Building Department
estimates for the number of new homes constructed each year
within the Metropolitan Urban Services Area. The building
Department estimates that 75 percent of the homes
constructed in Andover are being built in the Urban Service
Area. Over the past five years, an average 327 homes
were constructed each year, 245 within the Urban Service
Area. '
2. x Map showing interceptor service areas and staging (by 5
year periods) through 2010, including intercommunity
connections and proposed changes in government boundaries.
See Attachment E.
3.
x Projected flows in 2000 and 2010 for the total areas to
oe-served' and for each metropolitan interceptor service
area. (Indicate methodology and assumptions used in
calculating flows.)
See attachment A, Exhibit C, Revised Comprehensive Sewer
Report dated July 1, 1991 and Attachment B, letter from John
Davidson, P.E. of Toltz, King, Duval and Anderson for flows
related to the Waste Disposal Engineering (WOE) Site.
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Andover Compo plan Amendment
Checklist: Sewer
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SANITARY SEWER FLOWS - ANDOVER
(Millions of Gallons per Year)
Interceptor
Coon Rapids
1990
180
2000
Total
180
89
280
2010
196.5
133.5
330
191
CAB
Source:
(1) Metropolitan Waste Control Commission,
Wastewater Treatment and Handling
Implementation plan, March 19, 1991.
(2) Metropolitan Waste Control Commission, Anoka
Wastewater Treatment Plant Phase Out,
preliminary Design Report, July 1990.
4. x Existing and proposed land use by local service area as
proposed in current comprehensive plan (unless an amendment
is proposed) by the following categories: industrial
commercial, residential (by density), public open space, and
protected or conservation areas (wetlands, floodplains,
etc.) .
The most recent Comprehensive Land Use Map was completed in
1982 in the Andover Comprehensive Plan and Development
Framework. significant changes in the Urban Service Area,
Transportation and Housing elements of the Plan can be
noted. Attachment F is the existing land use map taken from
air photos and current housing subdivision plats, etc. The
existing as well as the proposed Land yse Maps are currently
being updated by the City as a part of the Comprehensive
Plan Update and are not available at this time. Attachment
F is the proposed Land Use Map from the 1982 Comprehensive
Plan and Development Framework.
5. x city objectives, policies and strategies for preventing
and reducing excessive infiltration and inflow (1/1) in
local sewer system. Summary of city policy requirements and
standards for minimizing 1/1 in new systems. Indication of
extent, source of significance of existing 1/1 problems and
determination of what can be cost-effectively removed. City
policy, program strategy, priorities, scheduling,
regulations and financing mechanisms for reducing and
preventing the problem.
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Andover Compo Plan Amendment
Checklist: Sewer
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The City of Andover has an active program to minimize I/I in
new systems and continued maintenance to the present system
as follows:
a. Full time observation of new systems during the
construction phase.
b. Air test method of testing between manholes at the 4 psi
in accordance with CEAM Standard utility Specifications.
C. Televising all new lines upon completion of backfill,
complete with videotape
d. Periodic visual inspections of manholes and leak
grouting where leaks are detected.
e. Solid manhole covers with concealed pick holes are
standard on all manholes.
f. Follow-up televising of deep trunk sewers (in water
Table) together with pressure grouting any leaks
detected.
B. Rural Service Area
1.
x
Map showing the following as applicable
c.N/A
Areas where allowable density exceeds 4 units per
40 acres; (Attachment C)
Areas generally unsuitable for conventional on-
site systems; (see Attachment H)
Location(s) of existing public and private
treatment systems.
a. x
b. x
2.
x
Description of on site sewage disposal system
management program/controls, covering the applicable
requirements in Table 1. (Where the local government's
rural service area density policy exceeds 4 per 40
acres, the local controls should include biennial
inspection and maintenance elements.)
See Attachment I.
3.
N/A
Description of conditions under which private,
community treatment systems (for example package
treatment plants, community drainfields) would be
allowed, including but not limited to, allowable land
uses, installation requirements and management
requirements, including local government
responsibilities.
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4. N/A Capacity of and existing flows to public and private
treatment systems.
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Andover Compo Plan Amendment
Checklist: Sewer
5.
N/A
For the expansion of existing and the development of
new municipal treatment systems, a description of the
following:
a. Projected number of households and employees
to be served in 2000 and 2010.
b. Map showing the service area and staging (by 5-
year periods) through 2010.
c. Existing and proposed land use by service area
as proposed in current comprehensive plan
(unless an amendment is proposed) by the
following categories: industrial commercial,
residential (by density), public open space,
and protected or conservation areas (wetlands,
floodplains, etc.).
d. Local objectives, policies and strategies for
preventing and reducing excessive infiltration
and inflow in local sewer system.
e. Proposed system timing and financing
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TOL TZ, KINO, DW ALL, ANDERSON
AND ASSOCIATES, INCORPORATED
ENOINEERS-ARCHlTEcrS-PLANNERS
SAINT PAUL, MINNESOTA
JUNE 4, 1991
REVISED JULY 1,1991
REVISIONS TO ANDOVER'S COMPREHENSIVE SANITARY SEWER PLAN
OF ANDOVER'S COMPREHENSIVE PLAN
ANDOVER, MINNESOTA
COMMISSION NO. 9140-001
I hereby certify that this report was prepared by me or under my direct supervision and that I am
a duly registered Professional Engineer under the 1aws of the State of Minnesota.
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9140-001
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TABLE OF CONTENTS
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1. Scope 3
2. Study Area 3
3. History 3
4. Procedure 4
5. Design Criteria 4
6, Conc1usions 4
7. Fe8.'libility 4
8. Cost Estimates S
9. Recommendations S
A.
B.
C.
D.
E.
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EXHIBITS
Study Area (Map attached)
Peaking Factor Curve
Design Summary
Service Area (Map auached)
Staging Plan (Map attached)
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9140-001
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REVISIONS TO THE COMPREHENSIVE PLAN FOR
TRUNK SANITARY SEWER IMPROVEMENTS
ANDOVER,MITNNESOTA
1.
Scope
The City Council of Andover has directed that the master pIan be updated to add area to
accommodate the projected residential development. The area is within future CAB
interceptor sewer boundaries. It i! the intent of the City of Andover to utilize the
maximum hydraulic capacity of the existing sewer system. A tenlporarv alternative to
extension of the north branch of the CAB interceptor across the Rum River in Anoka is
now included in this plan. That area will be served by a lift station and connected to the
Coon Rapids interceptor service area.
2. Study Area
The study area shown on the attached map (Exhibit A) was determined by using the soils
map from the Andover Comprehensive Plan, elevations from the U.S. Geological Survey
quadrangle maps and the Mark Hurd contour maps. The study area correlates closely
with the original SAC boundary for the Coon Rapids interceptor (plus the temporary
CAB service).
3. History
The 36-inch interceptor line located on Crooked Lake Boulevard at the Coon Rapids-
Andover boundary Wllll constructed in 1975 at a depth varying from 20 to 32 feet. The
36-inch interceptor was extended to Bunker Lake Boulevard. A 24-inch interceptor was
extended east and west of Crooked Lake Boulevard to provide service for the anticipated
growth in these areas.
The 24-inch interceptor line was extended to the north from BUDker Lake Boulevard to
service the Nonhwoods, Red Oaks Manor, and Smith's Green Areas. This 24" trunk
sewer was extended east along the north side of Coon Creek. in 1987.
An l8-inch interceptor line was extended to the east along Bunker Lake Boulevard to
provide service to the deve10ping areas. A contract was prepared and bids received in
1986 to extend this line further east to the Anoka County Highway Shop. The bid!
received were 30% over the engineer's estimate and were rejected. The city of Andover
elected to revise the comprehensive sewer plan and extend the intexceptor line along
Coon Creek at a much shallower depth than the proposed interceptor line along Bunker
Lake Boulevard.
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9140-001
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4.
Procedure
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The Mark Hurd contour maps were used to determine areas that are suitable for
deve10pment and areas that are not suitable for development because of surface water
problems. The SCS soils maps for Anoka County were also used to determine areas that
are not developable because of poor soils.
Those areas that are platted with large lots for septic tank systems (Rolling Oaks and
Evergreen Estates) were excluded from the proposed service area.
Bunker Lake Memorial Park and the areas shown on the map designated as agricultural
preserve were also deleted from the service area.
A portion of Watt's Garden Acres was also excluded from the service area because it is
more practical to divert the flow into the Coon Rapids system directly.
5. Design Criteria
The following design criteria were used for this report
Density - 2.1 units per developable acre.
Flow - 220 gallons per day per unit. This is based on 1990 flow record.'! of 181 x
106 annual gallons and 2247 connectlons.
Peaking Factor - See Exhibit "B"
6. Coltclusiol18
The existing sewer system can be extended to serve the temporary CAB service area
shown on Exhibit "D" by lift station and forcemain.
The capacity of the 24-inch RCP sewer located on Bunker Lake Boulevard from Round
Lake Boulevard to Crooked Lake' Boulevard can adequite1y accommodate this increase
in flow.
7. Fewbility
The proposed project is feasible.
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9140-001
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8.
Cost Estimates - Sanitary Sewer
Total Lots = 183
Sewer Area Charge
Sewer Connection Charge
Sewer Lateral Charge
Lift Station Charge
$4S61Lot
$24S/Lot
$2,76<J/Lot
S232ILot
Sanitary Sewer Estimated
Cost per Lot
$3,693/Lot
$4,300ILot
S3 500lLot
Estimated Watermain
Estimated Street and Restoration
Estimated Assessment per Lot
$1l,493/Lot
$2,103,219
Estimated Total Project Cost
9. Recommendations
A. The City modify its present policy that all sewers within the MUSA Boundary be
gravity flow systems (temporary).
B, A developer's agreement would require the deve10per to be responsible for
acquiring access to the present system by platting or permanent easement.
C. Work would proceed under Minnesota Statutes Chapter 429 for special
assessments.
D. A.lllaws, rules and regulations pertaining to wetland protection would be enforced.
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9140-001
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EXHIBIT B
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1.0
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0.5
1.0 2.0
ANNUAL AVERAGE DAILY FLOW (MGDl
3.0
FLOW V AAIATfON FACTORS
Flow Variation Factor
Average Flow (MGD)
4.0
3.9
3.8
3.7
3.6
3.5
3.4
3.3
3.2
3.1
3.0
2.9
2.8
2.7
2.6
25
0.00 to 0.1 1
0.12 to 0.18
0.19 to 0.23
0.24 to 0.29
0.30 to 0.39
0040 to 0.49
0.50 to 0.64
0.65 to 0.79
0.80 to 0.99
1.00 to 1.19
1.20 to 1.49
1.50 to 1.89
1.70 to 2.29
2.30 to 2.89
2.90 to 3.49 '
3.50 to 4.19
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EXHmIT C - DESIGN SUMMARY
COMPREHENSIVE SANITARY SEWER PLAN UPDATE
" ANDOVER,N.UNNESOTA
\~ COMMISSION NO. 8748
TABLE 1
FLOW IN 24.INCH TRUNK EAST OF CROOKED LAKE BOULEY ARD
Average Average
Cumu- Daily Daily Peak
la- Total Total Total Pipe
tive Flow Flow Peak Flow Capacity
AIea. Description Number Conn. Conn. MOD CPS Pactor CPS CFS
1 East Area City 513 513 .11 0.17 3.9 0.68
Limits
to 1
2 Hills of Bunker Lake 1-2 632 1145 .23 0.39 3.6 1.40 6.6
3 Northeast 2-3 1071 2216 .49 0.75 3.3 2.49 6.6
4 School, Winslow
Hills 3-4 935 3151 .69 1.07 3.1 3.32 6.6
S Santa's Tree Fann 4-S 417 3568 .78 1.21 3.0 3.64 6.6
6 Nightingale
Estates, etc. 5-6 594 4162 .92 1.42 3.0 4.25 6.6
7 Kensington Estates,
etc. 6-7 320 4482 .99 1.52 2.9 4.42 6.6
8 Red Oaks Manor 7-8 321 4803 1.06 1.64 2,9 4.74 6.6
9 Northwoods 8-9 236 5039 1.11 1.72 2.8 4.80 6.6
12.15 (Table 2) 943 5982 1.32 2.04 2.8 5.70 6.6
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Revised 64-91
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EXHIBIT C - DESIGN SUMMARY
COMPREHENSIVE SANITARY SEWER PLAN UPDATE
ANDOVER,MITNNESOTA
COMMISSION NO. 8748
TABLE 2
FLOW IN IS.INCH TRUNK ALONG BUNKER LAKE BOULEY ARD
EAST OF CROOKED LAKE BOULEVARD
Average Average
Cumu- Daily Daily Peak
1a- Total Total Total Pipe
rive Flow Flow Peak Flow Capacity
Area D .. Number Conn. Conn. MOD CFS Factor CFS CFS
escnot10n
12 Red Ow East End-12 227 227 .05 0.08 4.00 0.32 2.5
13 Watts Garden Acres 12.13 184 411 .09 0.14 3.9 0.55 2.5
14 Red Ow Manor 13-14 190 601 .13 0.20 3.8 0.78 3.6
15 Hidden Creek 14-9 342 943 .21 0.32 3.6 1.15 3.6
;'~)
Revised 6-4-91
6'd
-8-
'JOSS~ ~ '~'a'~'l 2S:60 ,6, 20 lnr
EXHIBIT C - DESIGN SUMMARY
COMPREHENSIVE SANITARY SEWER PLAN UPDATE
-j AND OVERt MrrNNESOTA
COMMISSION NO. 8748
'--./
TABLE 3
FLOW IN 24-INCH TRUNK WEST OF CROOKED LAKE BOULEVARD
AND TOTAL AT COON RAPIDS BORDER
Average Average
Cumu- Daily Daily Peak
la- Total Total Total Pipe
tlve Plow Flow Peak Flow Capacity
Area Descriotion Number Conn. Conn. MaD CFS Factor CFS CFS
lC Temporary CAB End to 1 183 183 .04 0.06 4.0 0.24 (Pumped)
1 NW Area End to 1 285 433 .10 0.15 4.0 0.60 2.9
2A Northglen 314 767 .17 0.26 3.9 1.01
2B Commercial 8S 8~2 .19 0.29 3.8 1.10
2C Chapman's 1-2 69 921 .20 0.31 3.8 1.18 4.6
3A Woodland Creek 233 1154 .25 0.39 3.7 1.44
3B Woodland Terrace 2-3 205 1359 .30 0.46 3.6 1.66 6.4
4A Meadow Creek
Baptist Church
& School 33 1391 .31 0.47 3.6 1.69
4B Crooked Lake
Elem. School 41 1432 .32 0.49 3.6 1.75
4C Meadow Creek
Addition 3-4 95 1527 .34 0.52 3.6 1.87 6.8
5 Crooked Lake
Boulevard 36" Trunk 125 1652 .36 0.56 3.6 2.02
Area East of
Crooked Lake
Boulevard 5982 7634
,- " Total City Flow
.J
(36" Tronk) 1.68 2.60 2.7 7.02 18.6
Revised 7-1-91
m'd -9- 'JOSS~ ~ '~'a'~'l 22:60 ,6, 20 lnr
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TKDA
TOLTZ. KING. DUVALL. ANDERsON
ANO A4S0C:IATES. INOO~PO~ATEO
ENGINEERS ARCHITECTS PLANNERS
November 20, 1991
Mr. James Schrantz
City Administrator
1685 Crosstown Boulevard NW
Andover, Minnesota 55304
Re: WDE Sanitary Landfill
Projected Flows
. Andover, Minnesota
Commission No. 9140-001
Dear Mr. Schrantz:
asoo AIoIeRICAN NAnONAlIlANK 8UII.OINC
$,OjHI' PAUI..IoI1NNE8OTA5S101.'103
..~......,
FAX St2ln:!_
In accordance with your request by telephone on November 19, 1991, we have reviewed the
effect ofWDE discharge of 100 gpm of wastewater into the Andover sewer system.
The revised Comprehensive Sanitary Sewer Plan dated July 1,1991, Table 3, Page 9, shows total
City flow as follows:
Average Daily Average Daily Total
Total Flow Total Flow Peak Peak Flow Pipe
MOD CFS Factor CFS Cqpacitv
Without
WOE Flow 1.68 2.60 2.7 7.02 18.6
The flows with WDE added are as follows:
Average Daily Average Daily Total
Total Flow Total Flow Peak Peak Flow Pipe
MOD CFS Factor CFS Cqpaci~
With
WOE Flow
1.82
Sincerely yours,
.
- ,
~~
JLD:j
rd
2.82
2.7
7.61
18.6
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AREAS WITHIN CURRENT ~USA BOUNDARY (2000)
January 31, 1991
~NAME OF ADDITION
Auditor's Sub No. 137
Auditor's Sub No. 82
Bent Creek Estates
Brandon's Lakeview Estates
Chapman's 1st Addition
Chapman's 2nd Addition
Chapman's 3rd Addition
Chapman's 4th Addition
Chapman's 5th Addition
Chapman's 6th Addition
Creekhaven
Creek ridge Estates
Creekside Estates
Cunningham Addition
Green Acres
Hartfiel's Estates
Hidden Creek 1st Addition
Hidden Creek 2nd Addition
Hidden Creek 3rd Addition
Hidden Creek East 1st Addition
Hidden Creek East 2nd Adition
Hidden Creek East 3rd Addition
Hills of Bunker Lake 1st Addition
Hills of Bunker Lake 2nd Addition
Hills of Bunker Lake 3rd Addition
Kadlec 2nd Addition
Kensington Estates 1st Addition
Kensington Estates 2nd Addition
Kensington Estates 3rd Addition
Kensington Estates 5th Addition
Kensington Estates 6th Addition
Kirby Estates
Lakeview Terrace Area
Meadowcreek Estates Area
Northglen & Northglen 3rd Addition,
Northglen 2nd Addition
Northglen 4th Addition
Northglen 5th Addition
Northwoods Addition & Plat 2
Oak Bluff 1st Addition
Oak Bluff 2nd Addition
Old Colony Estates 1st Addition
Quickstrom Addition
Red Oaks Manor 1st Addition
Red Oaks Manor 2nd Addition
Red Oaks Manor 3rd Addition
Red Oaks Manor 4th Addition
Red Oaks Manor 5th Addition
Red Oaks Manor 6th Addition
Rosella's Addition
, '\ Shady Knoll
,JShirley's Estates
- Smith's Green Acres
~
TOTAL
LOTS
50
91
8
4
10
10
10
10
15
11
26
61
6
9
83
58
46
62
63
47
46
21
149
64
79
19
76
32
39
43
6
6
98
92
113
113
36
36
108
25
74
55
33
23
16
25
119
50
29
25
20
6
15
BUILT
ON
46
87
4
4
10
10
10
10
14
10
15
61
5
9
81
27
46
62
53
39
25
o
119
26
45
16
36
17
27
19
o
6
95
90
113
109
36
36
105
24
46
34
33
23
16
25
119
50
24
24
20
6
12
VACANT
LOTS
4
4
4
o
o
o
o
o
1
1
11
o
1
o
2
31
o
o
10
8
21
21
30
38
34
3
40
15
12
24
6
o
3
2
o
4
o
o
3
1
28
21
o
o
o
o
o
o
5
1
o
o
3
MUSA Boundary
Page Two
TOTAL BUILT VACANT
NAME OF ADDITION LOTS ON LOTS
The Oaks 9 8 1
~ Wandersee Addition 5 3 2
o Weises Addition 5 4 1
Winslow Hills 80 34 46
Woodland Creek 1st Addition 87 14 73
Woodland Creek 2nd Addition 46 7 39
Woodland Terrace 1st Addition 76 70 6
Woodland Terrace 2nd Addition 10 7 3
Woodland Terrace 3rd Addition 7 7 0
Woodland Terrace 4th Addition Page 1 63 61 2
Woodland Terrace 4th Addition Page 2 24 20 4
Woodland Terrace 5th Addition 7 6 1
Woodridge Acres 17 17 0
Sub-Total 2807 2237 570
-
TOTAL BUILT VACANT
OTHERS LOTS ON LOTS
Section 27 32 29 3
Section 28 0 0 0
Section 29 41 36 5
Section 32 31 27 4
Section 33 60 52 8
TOTAL 164 144 20
APPROVED PRELIMINARY PLATS
TOTAL
LOTS
Hidden Creek East Phase IV
Hills of Bunker Lake Phase IV
Kensington Estates 4th Addition
Old Colony Estates Phase II
Woodland Creek Phase III
TOTAL
47
60
16
87
91
301
SKETCH PLANS
APPROX.
.-" Harstad Properties
,~Heil's First Addition
- Watt's Garden Replat
TOTAL
105
9
105
219
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CITY OF ANDOVER
COUNTY OF ANOKA
STATE OF MINNESOTA
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ORDINANCE NO. 37
AN ORDINANCE REGULATING THE INSTALLATION, CONSTRUCTION,
ALTERATION, EXTENSION, REPAIR AND MAINTENANCE OF INDIVIDUAL SEWAGE
DISPOSAL SYSTEMS: REQUIRING PERMITS FOR AND LICENSING OF PERSONS
ENGAGED IN THE CONSTRUCTION AND SERVICING THEREOF: PROVIDING FOR
THE INSPECTION OF SUCH SYSTEMS, AND THE ABATEMENT OF NUISANCES:
PROVIDING FOR THE INSPECTION OF PRIVATE WATER SYSTEMS, AND
PRESCRIBING PENALTIES FOR VIOLATIONS THEREOF: IN THE CITY OF
ANDOVER, COUNTY OF ANOKA, STATE OF MINNESOTA.
BE IT ORDAINED AND ENACTED BY THE COUNCIL OF THE CITY OF ANDOVER,
STATE OF MINNESOTA AS FOLLOWS:
SECTION 1. DEFINITIONS.
a. Septic Tank-Soil Absorption System. A Septic Tank-Soil
Absorption system is an on-site waste disposal system that
consists of a septic tank to hold sewage long enough to allow
digestion of the organic wastes, and a soil absorption field of
seepage trenches for disposal of the sewage affluent by
percolation through the soil.
b. Sewage. Any water-carried domestic waste, exclusive of
footing and roof drainage, of any residence, industry or
commercial establishment, whether treated or untreated, and
includes the liquid wastes produced by bathing, laundry and
culinary operations, and from toilets and floor drains. Raw
sewage which has not been subjected to any treatment process.
c. Permeable Soil. Any soil which has been found to be
suitable for use as a soil absorption field according to slope and
water table criteria as described in this Ordinance and has a
percolation rate between 1/2 and 60 minutes per inch.
d. Contamina~ion. The act of polluting or making impure,
used here to bacteriological or chemical impurities, including
nitrates.
e. Individual Sewage Disposal Systems. A sewage disposal
system other than a public or community system which receives
sewage from an individual establishment. Unless otherwise
indicated, the work "system" as it appears in this Ordinance means
"individual sewage disposal system".
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f. Building Sewer. The building sewer is that part f the
horizontal portion of the building drainage system extending from
the building drain to its connection with the septic tank and
carrying the sewage of but one building.
g. "Building drain" shall mean that part of the lowest
horizontal piping of a drainage system which receives the
discharge from soil waste, and other drainage pipes inside the
walls of the building and conveys it to the building sewer.
h. "Building Official" shall mean the Superintendent of
wastewater facilities in the City of Andover or his authorized
representative.
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i. "Person" shall mean any individual, firm, company,
association, society, corporation, or group.
j. "Shall" is mandatory; "May" is permissive.
k. "City" shall mean City of Andover.
SECTION 2. GENERAL PROVISIONS.
A. Construction Requirements.
All individual sewage disposal systems installed
subsequent to the adoption of this Ordinance and all
alterations, extensions and repairs to individual sewage
disposal systems irrespective of the dat of original
installation shall be regulated in accordance with all of the
requirements of this Ordinance. Where there is evidence of
septic tank effluent percolating from the ground,
contaminating ground water or surface water or causing odors
that are a nuisance, the system must be corrected and conform
to the standards within the requirements of Section 3 C (3.)
of this Ordinance.
B. General Requirements.
1. Location and installation of the individual sewage
disposal system and each part thereof shall be such that, with
reasonable maintenance, it will function in a sanitary manner
and will not create a nuisance nor endanger the safety of any
domestic water supply. In determining a suitable location for
the system, consideration shall be given to the size and shape
of the lot, slope of natural and finished grade, soil
permeability, depth of ground water, geology, proximity to
existing or future water supplies, accessibility for
maintenance and possible expansion of the systems.
2. No part of the system shall be located so that it is
nearer to any' water supply than outlined hereinafter, or so
that surface drainage from its location may reach any domestic
water supply or surface body of water.
3. Raw sewage, septic tank effluent, or seepage from a
soil absorption system shall not be discharged to the ground
surface, abandoned wells, or bodies of surface water, or into
any rock formation, the structure of which is not conducive to
purification of water by filtration, or into any well or other
excavation in the ground which does not comply with the
requirements of this Ordinance. This in accordance with a
process approved by the State Board of Health or the state
Pollution Control Agency.
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4. The lot size shall be sufficient to permit
installation of the individual sewage disposal system in
accordance with all the requirements pertaining thereto and
shall be in compliance with the City of Andover subdivision
and zoning Ordinances.
Page 2
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5. Installations of individual sewage disposal systems
shall not be made in low swampy areas, ares which may be
subject to flooding or areas where the permanent or seasonal
high-water table is closer than six and one-half (6-1/2') feet
to the ground surface or areas designated as flood plain or
wetlands. Areas that are wetland, low swamp or have wetlands
vegetation growing on it shall be considered unsuitable.
6. The system or systems shall be designated to receive
all sewage from the dwelling, building or other establishment
served, including laundry waste and basement floor drainage.
Footing or roof drainage shall not enter any part of the
system. Where the construction of additional bedrooms, the
installation of mechanical equipment, or other factors likely
to affect the operation of the system can be reasonably
anticipated, the installation of a system adequate for such
anticipated need shall be required.
7. The system shall consist of a building sewer, a
septic tank, and a soil absorption unit. The soil absorption
unit shall consist of a sub-surface disposal field. All
sewage shall be treated (digested) in the septic tank and the
septic tank drain field (soil absorption field) system shall
be considered the only acceptable system for installation
unless it can be demonstrated that this system is not feasible
on the particular lot in question and if it can be
demonstrated that the system being proposed as an alternate
will not create a pollution problem.
8. Soil absorption systems for the disposal of sewage
waste shall not be installed on land where the slope exceeds
twelve (12%) percent.
9. The city Council of the City of Andover hereby adopts
Minnesota "Individual Sewage Treatment Systems Standards,
Chapter 7080" and as amended. (37C, 11-06-90)
C. Sewer Construction.
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1. Any buried or concealed portion of the building
sewer, or building drain or branch thereof serving any
establishment shall be located in compliance with the State
Water Well Construction Code. The buried drain or branches
therof must be not less than fifty (50') feet from a private
well supply. If the building sewer is constructed of heavy
cast iron pipe with watertight joints and air tested or other
pressure pipe acceptable to the Department of Health, then the
distance may be reduced to twenty (20') feet. In any case
where the existing private well depth is less than fifty (50')
feet the above requirements shall become doubled. The air
test shall be made by attaching an air compressor or test
apparatus to a suitable opening and closing all other inlets
and outlets to the sewer and/or drain under test by means of
proper testing plugs. Air shall be forced into the system
until there is a uniform pressure of five (5# psi) pounds per
square inch in the section being tested. The system shall be
considered satisfactorily air tested if the pressure therein
remains constant for fifteen (15) minutes without the addition
of air. The Building Official or other qualified agent
designated by the City shall observe the test. The owner
page 3
shall be responsible for notifying the City and arranging the
test.
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2. The portions of any buried sewer more than fifty
(50') feet from a well or buried suction line shall be of
adequate size and construction of castiron, vitrified-clay,
cement-asbestos, concrete or other pipe material acceptable in
the Uniform Building Code. Clay pipe and clay pipe fittings
shall conform to A.S.T.M. specifications for standards
strength or extra strength clay pipe and clay pipe fittings.
No building drain or building sewer shall be less than four
(4") inches in diameter.
3. The space between the bell and spigot of vitrified-
clay pipe shall be packed with oakum, hemp or jute or
otherwise prepared so as to form a concentric opening uniform
in width around the pipe, which opening shall be filled with
Portland cement mortar or other acceptable sewer-joint
compound. poured joints are recommended. Where cement joints
are used they shall be carefully pointed on the outside and
left smooth on the inside by drawing through them a swab or
scraper. Construction of the line shall be such as to secure
water-tight and roof-tight joints, free of obstructions, and
shall provide a grade of not less than 1/8 inch per foot. The
ten (10') feet of sewer immediately preceding the septic tank
shall not slope more than 1/4 inch per foot. No building
sewer shall be laid parallel to and within three (3') feet of
any bearing wall, which might thereby be weakened. The depth
shall be sufficient to afford protection from frost. The
building sewer shall be laid in straight alignment insofar as
possible and changes in direction shall be made only with
properly curved pipe and fittings. Cleanouts will be required
at all 90 degree bends and for every seventy-five (75') feet
of service line from the house to the septic tank to the
distribution box. Cleanouts will not be required at 45 degree
bends or less. All 90 degree bends will be wide sweep ells.
D. Septic Tank.
1. the location of the ,septic tank shall be such as to
provide not less than the stated distances from the following:
a. Property lines, buried pipe
distributing water under pressure and
occupied buildings
10 feet
b. Any source of domestic water
supply or buried water suction line
c. Any other separate sewage
disposal system
50 feet
20 feet
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2. The liquid capacity of a septic tank serving a
dwelling shall be based on the total number of bedrooms or the
building size in square feet contemplated in the dwelling
served and shall conform to capacities given in Table 1 which
follows. The liquid capacity of a septic tank serving an
establishment other than a dwelling shall be sufficient to
provide a sewage detention period of not less than 24 hours in
the tank but in no instance shall it be less than 1200
gallons.
Page 4
TABLE 1
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Minimum Capacities for Septic Tanks
(provides for Use of Automatic Washers and other
Household Appliances)
Standard Single Family
Bedrooms
Minimum Tank
Capacity (Gallons)
2 or less............................. 750
3. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 1000
4. . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . .. 1250
5 & 6................................ 1500
7 & 8................................ 2000
3. The liquid depth of any septic tank or compartment
thereof shall be not less than thirty (30") inches. A liquid
depth greater than six and one-half (6-1/2') feet shall not be
considered in determining tank capacity.
4. No tank or compartment thereof shall have an inside
horizontal dimension less'than twenty-four (24") inches.
5. Inlet and outlet connections of the tank and of each
compartment thereof shall be submerged by means of vented tees
or baffled so as to obtain effective retention of scum and
sludge.
6. The space in the tank between the liquid surface and
the top of the inlet and outlet baffles or submerged pipes
shall be not less than twenty (20%) percent of the total
required liquid capacity, except that in horizontal
cylindrical tanks this space shall be not less than fifteen
(15%) percent of the total required liquid capacity.
7. The inlet baffle or submerged pipe shall extend at
least six (6") inches but not more than twenty (20%) percent
of the total liquid depth, to the nearest inch, below the
liquid surface and at least one inch above the crown of the
inlet sewer.
8. The outlet baffle or submerged pipe and the baffles
or submerged pipes between compartments shall extend below the
liquid surface a distance equal to forty (40%) percent, to the
nearest inch, of the liquid depth except that the penetration
of the indicated baffles or submerged pipes for horizontal
cylindrical tanks shall be thirty-five (35%) percent, to the
nearest inch, of the total liquid depth. They also shall
extend above the liquid surface to provide for scum storage as
required in Paragraph 5 above. In no case shall they extend
less than six (6") inches above the liquid surface.
9. There shall be at least one (1") inch between the
underside of the top of the tank and the highest point of the
inlet and outlet devices and partitions so as to provide the
required ventilation of the system through the main building
stack.
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10. The inlet invert shall be not less than three (3")
inches above the outlet invert.
page 5
11. Construction of the tank shall be such as to assure
its being watertight and to prevent the entrance of rainwater,
surface drainage, or ground water.
12. The tank shall be constructed of sound and durable
material not subject to excessive corrosion or decay. Metal
septic tanks shall comply with Commercial Standard 177.62 of
the U.S. Department of Commerce and have the capacity required
in Table 1.
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13. Adequate access to each compartment of the tank for
inspection and sludge removal shall be provided by a manhole
not less than twenty (20") inches or removable cover and by a
clean-cut pipe of not less than six (6") inch diameter
extending through the cover to a point above the tank not more
than six (6") inches below finished ground level. The point
at which the clean-out pipe passes through the cover shall be
so located that a downward projection of the pipe clears the
inlet and outlet device by not less than two (2") inches. The
top of the clean-out pipe shall be provided with a readily
removable water-tight cap and its location shall be marked by
a stake or other permanent means at the ground surface. The
inlet device shall be made accessible by either the removable
cover of the manhole or by the addition of properly placed
hand holes. All access covers, manhole covers, etc. shall be
so designated to prevent the access or entrance to the
facility by children.
E. Surface Disposal Field. (Soil Absorption Field)
1. Location of the disposal field shall be in an
unobstructed and preferably unshaded area, and the distances
given below shall be in minimum horizontal separations between
the disposal field and the following:
a. Any water supply well, or
buried water suction pipe
6 b. Streams or other bodies of water:
General Development lakes or streams
R~creational Development
Lakes or water
Natural Environmental lakes
or streams
Scenic River
Recreational River
c. Occupied buildings
d. Large trees (twelve [12"] or more
inches in diameter) (See
alternate in Section 2.e.6.d)
e. Property lines or buried pipe
distributing water under pressure
f. Other sewage disposal system
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50 feet
50 feet
75 feet
150 feet
100 feet
75 feet
20 feet
10 feet
10 feet
20 feet
2. When coarse soil formations are encountered, the
distances specified in Paragraph 1 above shall be increased
appropriately as determined by the City Zoning and Building
Page 6
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Coordinator or other qualified agent designated by the city.
Coarse textured soils with percolation rates faster than one-
half (1/2) minutes per inch shall be considered as unsuitable
because of the great hazard of contaminating the ground water
with nitrate.
3. A distribution box with removable cover and of
sufficient size to accommodate the necessary tile field
lateral lines shall be constructed at the head of each
disposal field.
a. Each tile field lateral line shall be connected
separately to the distribution box and shall not be
subdivided.
b. The inverts of all outlets shall be at the same
elevation and the inlet invert shall be at least one (1")
inch above the outlet inverts.
c. The outlet inverts shall be at least four (4")
inches above the distribution box floor for the purpose
of securing equal distribution of the septic tank
effluent to each tile lateral.
d. In the event that septic tank effluent is
delivered to the distribution box by pump or siphon, a
baffle wall shall be installed in the distribution box.
The baffle shall be secured to the bottom of the box and
shall extend vertically to a point at least level with
the crown of the inlet pipe. The plane surface of the
baffle shall be perpendicular to the inlet flow line.
e. where the slope of the ground surface does not
exceed six (6") inches in any direction within the area
utilized for the absorption field, the septic tank
effluent may be applied to the absorption field through a
system of inter-connected tiles lines and trenches and
distribution lines shall be constructed on a relatively
level grade, not to exceed six (6") inches difference in
elevation. If the slope of the ground surface exceeds
six (6%) percent in any direction within the area
utilize~ for the absorption field, serial distribution
may be used. The bottom of the trenches and distribution
lines shall be constructed on a relatively level grade.
The distribution tile system shall be arranged so that
each trench shall be filled with septic tank effluent
before effluent flows to succeeding trenches. The invert
of the overflow pipe in the first relief line shall be at
least four (4") inches lower than the invert of the
septic tank outlet.
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4. Minimum seepage area of the disposal field (soil
absorption field) (total flat area of trench bottom exclusive
of sidewall area) shall be determined by the following
percolation test procedure as applied to Table 2.
a. Numbers and location of test. Two (2) or more
percolation tests and two (2) soil borings to a depth of
at least twelve (12') feet will be required at the
location of the proposed sewage system. Percolation
tests shall be made during the months of April, Mayor
Page 7
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June or the seasonal high water table depth shall be
verified by a person competent in soil classification.
b. Type of test hole. A hole with horizontal
dimensions of four (4") to six (6") inches and vertical
sides shall be dug or bored to the depth of the proposed
absorption trench. The holes may be bored with an auger
of not less than four (4") inches in diameter.
c. preparation of test hole. The bottom and sides
of the hole shall be carefully scratched with a knife
blade or sharp pointed instrument to remove any smeared
soil surfaces and to provide a natural soil interface
into which water may percolate. All loose material shall
be removed from the hole and two (2") inches of course
sand or fine gravel shall be added to protect the bottom
from scouring.
d. Saturation and swelling of the soil. The hole
shall be carefully filled with clear water to a minimum
depth of twelve (12") inches over the gravel. Water
shall be kept in the hole for at least four (4) hours,
and preferably overnight, by refilling if necessary, or
by supplying a surplus reservoir of water, such as in an
automatic siphon. In sandy soils containing little or no
clay, the swelling procedure shall not be required and
the test may be made as described under Section 2e,4.e(3)
after the water from one (1) filling of the hole has
completely seeped away.
e. Percolation rate measurement. With the exception
of sandy soils, percolation rate measurements shall be
made on the day following the procedure described under
Item 4.d above and shall vary according to the following
conditions:
(1) If water remains in the test hole after the
overnight swelling period, the depth shall be
adjusted to approximately six (6") inches over the
gravel. From a fixed reference point the drop in
water level shall be measured at thirty (30) minute
intervals over a two (2) hour period. This drop
shall be used to calculate the percolation rate.
(2) If no water remains in the hole after the
overnight swelling period, clear water shall be added
to bring the depth of water in the hole to
approximately six (6") inches over the gravel. From
a fixed reference point the drop in water level shall
be measured at approximately thirty (30) minute
intervals for four (4) hours, refilling six (6")
inches over the gravel if necessary. The drop that
occurs during the final thirty (30) minute period
shall be used to calculate the percolation rate.
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(3) In sandy soils or other soils in which the
first six (6") inches of water seeps away in less
than thirty (30) minutes after the overnight swelling
period, the time interval between measurements shall
be taken as ten (10) minutes 'and the test shall be
run for one (1) hour. The drop that occurs during
Page 8
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the final ten (10) minutes shall be used to calculate
the percolation rate.
(4) Absorption Area Requirements for Private
Residences and Other Establishments (per bedroom
column provides for residential automatic sequence
washing machines). Percolation rates of one-half
(1/2) minute or less are considered undesirable and
must be approved by the city Council and state
pollution Control Agency before issuance of a permit
to construct.
TABLE 2
Required treatment area in square feet per bedroom (a), (b)
Percolation Per Gallon
Rate in Minutes of Waste
Per Inch Per Day Beds
1/2 or less ( e )
1/2 to 5 ( f) 0.83 125
6 to 15 1. 27 190
16 to 30 1. 67 250
31 to 45 2.00 300
46 to 60 ( g) 2.20 330
(a) Table is based on a sewage flow of 150
gallons per day per bedroom.
(b) In every case sufficient area shall be
provided for at least two (2) bedrooms in
residential units.
(c) When treatment system design is based on
gallons of waste per day the required treatment
area may be reduced for trenches only, by the
following percentages: Twenty (20%) percent for
twelve (12") inches of filter material below the
distribution pipe; thirty-four (34%) percent of
eighteen (18") inches; and forty (40%) percent
for twenty-four (24") inches.
(d) soil is unsuitable for standard system
if percolation rate is faster than 1/2 minute per
inch. alternate systems will be approved by the
Building Official.
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(e) Consider alternative sewage treatment
units for soils with this percolation rate range.
Alternate systems will be approved by the
Building Official.
(f) Soil is unsuitable for standard system
if percolation rate is slower than 60 minutes per
inch. Alternate systems will be approved by the
Building Official.
f. All tests shall be conducted by a registered
professional engineer. Two (2) copies of all tests shall
be submitted at the time of application for building
permit.
Page 9
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5. Additional criteria for judging soil suitability.
a. In areas of shallow ground water, the depth of
the water table shall be determined. No soil absorption
system shall be installed in an area where the water
table is at any time less than six and one-half (6-1/2')
feet below ground level or four (4') feet below the
bottom of the drain field trench. Soil absorption
systems installed in areas where impermeable layers are
found at depths of less than six and one-half (6-1/2')
feet shall be considered to be of special design.
b. Modification of the percolation test. when
knowledge of the characteristics and uniformity of the
soil is available through observation or experience, the
requirements for percolation tests may be changed at the
discretion of the Building Official.
6. Construction of disposal trenches.
a. All trenches in a disposal field shall be
constructed in accordance with the following standards:
1. Minimum number of lines per field............ 2
2. Maximum length of individual lines......... 100'
3. Minimum bottom width of trench.............. 18"
4. Minimum depth of cover of the tile lines.... 18"
5. preferred depth of cover of tile............ 24"
6. Maximum depth of cover of tile lines........ 36"
7. Maximum uniform grade of tile lines. 4" per 100'
8. preferred uniform grade of tile lines.......
. . . . . . . . . . . . . . . . . . . . . .. 2 to 4 inches per 100'
9. Size and spacing of trenches................
. .. . . . . . . .. . . . . . . . . . . . . . .. Conform to Table 3
10. Minimum filter material under tile........... 6"
11. Preferred depth of filter material
under tile.......................... 12 to 24"
12. Minimum filter material over tile............ 2"
TABLE 3
Width at Bottom
in Inches
Effective Absorption
Area in Square Feet
Per Lineal Foot
Minimum
Spacing of
Lines c to c
in Feet
18
24
30
36
1.5
2.0
2.5
3.0
6.0
6.5
7.0
7.5
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Absorption beds wider than five (5') feet shall be
provided with multiple distribution tile lines spaced not
more than five (5') feet nor less than eighteen (18")
inches on center, and not more than thirty (30") inches
from the side walls of the bed. Other construction
requirements (such as depth of filter material above and
below the tile lines, minimum and maximum depth of cover
of tile lines, etc.) shall conform to the requirements
for disposal trenches.
Page 10
b. Pipe used for the line between the septic tank
and the distribution box and tile laterals to the point
where the laterals
TRENCHES
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V Depth of filter material below distribution pipe (d) , inches
6 12 18 24
125 100 85 75
190 150 125 115
250 200 165 150
300 240 200 180
330 265 220 200
are separated by the maximum design separation
shall be of a material specified for use as building
sewers in the Minnesota Plumbing Code.
c. Perforated plastic pipe shall be laid with one
row of perforations on the bottom. Perforations shall be
at least 5/8" in diameter and spaced no farther than
thirty-six (36") inches apart.
d. Field tile used in the disposal field shall be
four (4") inch agricultural drain tile twelve (12")
inches in length and shall be laid with 1/4" open joints.
Alternate materials may be used if equivalent performance
is indicated.
1. All open joints shall be protected on top by
strips of asphalt-treated building paper at least ten
(10") inches long and three (3") to six (6") inches
wide or by other acceptable means.
2. All bends used in the disposal field shall
have tight joints at each end of the bend.
e. Filter material shall be crushed stone, gravel,
or similar insoluable, durable and acceptable material
having sufficient voids. This material may vary from 1/2
to 2-1/2 inches in size and shall be free of dust, sand,
or clay. The filter materials shall completely encase
the tile in accordance with Section 2.e.6.a In any case,
disposal trenches constructed within ten (10') feet of
large trees or dense shrubbery shall have at least twelve
(12") inches of filter materials beneath the tile.
f. The top of the filter material shall be covered
with untreated building paper or a two (2") inch layer of
hay or straw so as to prevent settling of backfill
material into the filter material.
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g. Where it is necessary to fill an area for
construction of tile laterals, the bottom of the tile
trenches shall extend not less than one (1') foot into
the original soil.
Page 11
h. The trench above the filter material shall be
overfilled with four (4") to six (6") inches of earth.
the backfill shall be handicapped.
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i. Before filter material is placed, all smeared or
compacted soil in the trench bottom shall be broken up
and removed by raking or other effective means to provide
natural soil conditions.
7. Maintenance.
a. Each property owner having an on-site sewage
disposal system shall on a bi-annual basis file a
maintenance report on that system with the City Clerk.
b. The city is divided into two (2) areas for the
purposes of biennial (bi-annual) reporting by property
owners. The areas west of CSAH No.9 shall report on odd
years and the area east of CSAH No.9 on even years.
(37A, 9-07-76)
c. Each property owner shall complete the
maintenance report of his on-site sewage disposal system
and submit the form by September 1st of that year. The
city requires that each property owner has his on-site
sewage disposal system pumped as often as required by
inspections, at stated in Section 2 Subsection 7 d.
Failure on the part of the property owner to have an on-
site sewage disposal system cleaned when said system is
found to require cleaning shall be caused for the City to
provide for the cleaning service and provide the property
owner with an advance notification of the date the system
will be cleaned. The cost of this service shall be
assessed to the property owner. (37B, 9-19-78)
d. The basis for determining if septic tank cleaning
is needed is the measurement of the depth of sludge and
scum in the septic tank. When, as a result of such
measurement, the top of the sludge layer in the tank or
any comp?rtment of the tank is found to be less than
twelve (12") inches below 'the bottom of the outlet baffle
or submerged pipe or if the bottom of the scum layer is
less than three (3") inches above the bottom of the
outlet baffle or submerged pipe, the owner or agent
shall arrange for the removal and sanitary disposal of
the contents of the tank.
e. Individual servicing of septic tanks and soil
absorption units shall require a permit from the City and
shall conform to the Minnesota Department of Health and
Minnesota pollution Control Agency specifications.
Disposal of sludge and scum removed from the system shall
be into a municipal sewer disposal system at a disposal
site approved by the Building Official.
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f. Owners of sanitary disposal systems shall be
required to cooperate with and assist the City in taking
water samples, as required, to test the adequacy of such
systems.
Page 12
8. Alternative Systems.
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a. Alternate methods of sewage disposal such as
holding tanks electric or gas incinerators, biological
and/or tertiary treatment plants or land disposal
systems, or other systems approved by the Building
Official wherever required or allowed in particular
circumstances, shall be subject to the standards,
criteria, rules and regulations of the Minnesota
Department of Health and Minnesota pollution Control
Agency.
SECTION 3. ADMINISTRATION.
A. Enforcing Officer.
The Building Official shall be responsible for the
adminstration of this ordinance. The Board of Appeals shall
hear and decide appeals and review any order, requirement,
decision or determination made by the Building Official
regarding the enforcement of this Ordinance. Such appeal may
be taken by a person aggrieved in conforming wit~ procedures
set forth in the City of Andover zoning Ordinance.
B. Issuance of Permits.
No building permit for any building requiring an on-site
disposal system shall be issued until the permit, as required
by this Ordinance has been issued.
C. Inspection.
1. The Building Official shall make such inspection or
inspections as are necessary to determine compliance with this
Ordinance. No part of a newly constructed system, or an
existing system which has been altered, extended or repaired
shall be covered until it has been inspected and approved by
the Building Official. It shall be the responsibility of the
applicant for the permit to give twenty-four (24) hours prior
written notice to the Building Official that the job will be
ready for in~pection or reinspection. It shall be the duty of
the owner or occupant of the property to give the Building
Official free access to the property at reasonable times for
the purpose of making such inspections.
o
2. If upon inspection the Building Official discovers
that any part of the system is not constructed or operating in
accordance with the minimum standards provided in this
Ordinance, he shall give the owner or applicant written
notification describing the defects. Such notice shall
prescribe a reasonable time within which such defect must be
corrected. If, after such written notice is given, and the
owner or applicant neglects or refuses to correct such defects
or fails to make the system conform to this ordinance within
the time specified in said notice, the City may then by any of
its duly appointed representatives, remove and repair the
defective system and charge the cost thereof to the owner or
applicant as the case may be, and the cost shall be assessed
against the property upon which the defective system is
located. No system shall be placed or replaced in service
until all defects have been corrected or eliminated, and a
Page 13
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reinspection has been made. The applicant shall pay an
additional fee for each reinspection that is necessary.
3. Any system which allows septic tank effluent to
percolate from the ground, contaminating ground or surface
waters, or causing noxious odors, or which because of its
operation or construction imperils the health, safety or
welfare of the public, is declared to be a nuisance. Upon
receipt of a petition setting forth facts that a system
constitutes a nuisance, the city Council shall hold a hearing
on the matter upon not less than five (5) days written notice
to the owner of the system or systems involved. If the
evidence at such hearing establishes that a nuisance does
exist, as determined by resolution of the City Council, the
City shall give written notice to the owner to abate such
nuisance within thirty (30) days. Upon the failure of such
owner to abate said nuisance within the prescribed time, the
cesspool, septic tank or private sewer system shall be
disconnected and the premises made sanitary under the
direction of the City Council.
4. In addition to the specifications herein provided,
the City may cause regular or periodic inspections of any or
all systems within the City to insure that all systems are in
proper operation and incompliance with this ordinance. It
shall be the duty of the owner or occupant of property to give
the inspector free access to the property at reasonable times
for the purpose of making such inspections. If the owner does
not give free access, the City may obtain a search warrant for
the purpose of determining health or safety violations on
private property.
D. Inspection and Testing of Water Systems.
1. The Building Official shall have the right to go upon
the private property for the purpose of inspecting and testing
wells, sources of water, outlets of water used for drinking
purposes, human consumption or domestic purposes with
reasonable and proper notification.
2. Any ~ater source producing water for such purposes
showing evidence of contaminating by organisms of the coliform
group, or containing nitrate nitrogen in concentrations
greater than ten parts per million, or containing foaming
agents in concentrations greater than 0.5 parts per million
may be declared unfit for human consumption, and thereafter no
person shall use or allow water to be used from such water
source for drinking purposes, human consumption or domestic
use.
o
The Building Official upon receipt of well testing
evidence showing contamination as outlined above shall
immediately contact the Minnesota Department of Health. The
Minnesota Department of Health has authority under State
Regulation 10812 as follows: "Any drinking water supply known
to be a positive or probable source of typhoid fever or other
disease, shall be condemned, either by the local board of
health or by the state Board of Health, and when so condemned
shall not be used again as a drinking water supply until
declared safe by the condemning party."
Page 14
SECTION 4. LICENSES.
o
A. Licensing.
1. No person, firm or corporation shall engage in the
business of altering, repairing, installing or constructing
within the City without first obtaining a license to carryon
such occupation from the City.
2. Applicant shall file with the City Clerk policies of
public liability and property damage insurance which shall
remain in force and effect during the entire term of said
license and which shall contain a provision that they shall
not be canceled without ten (10) days written notice to the
City. Public liability insurance shall not be less than one
hundred thousand ($100,000) dollars for injuries including
accidental death to anyone (1) person and subject to the same
limit for each person in an amount of not less than three
hundred thousand ($300,000) dollars on account to anyone (1)
accident, and property damage insurance in the amount of not
less than fifty thousand ($50,000) dollars for each accident
and not less than one hundred thousand ($100,000) dollars
aggregated. No work shall be done under license until said
insurance policies have been filed and approved by the City.
3. The applicant shall file with the City Clerk a surety
bond guaranteeing the conformance and compliance of work with
this Ordinance. Said bond shall be in the amount of two
thousand ($2,000) dollars. The City shall hold said bond for
one (1) year following the license period. Failure to comply
with provisions and requirements of this Ordinance shall
result in forfeiture of the bond.
4. Licenses shall be renewed annually. The annual
license fee shall be as set by City Council Resolution.
Applications for such license shall be made annually on a form
furnished by the City Clerk. Licenses shall be in effect from
January 1 to December 31 of that year. (37C, 11-06-90)
5. Application,for licenses sha~l be filed with the City
Clerk and sha~l be revi.wed and subject to the approval of the
City.
6. Any installation, construction, alteration or repair
of a sewage disposal system by a licensee in violation of any
provision of this Ordinance or refusal on the part of a
licensee to correct such defective work shall be cause for
revocation of or refusal to renew a license. Said license may
be revoked or its renewal refused, the licensee shall be given
a hearing by the City Council to show cause why such license
should not be revoked or refused. Notice of the time, place
and purpose of such hearing shall be in writing.
B. Permits.
~J
1. No person, firm or corporation shall clean, install,
alter, repair, or extend any individual sewage disposal system
in the City without first obtaining a permit therefor from the
Building Official for the specific installation, alteration,
repair, or extension.
Page 15
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2. Applications for permits shall be made in writing
upon printed forms furnished by the City Clerk and shall be
signed by the applicant. The application for permit, except
cleaning permits, shall be accompanied by a fee of twenty-five
($25) dollars. A $2.50 fee will be required for each cleaning
permit obtained from the City.
3. Each application for a permit, except for cleaning,
shall have thereon the correct legal description of the
property on which the proposed installation, alteration,
repair, or extension is to take place, and each application
for a permit shall be accompanied by a plot plan of the land
showing the location of any proposed or existing buildings
located on the property and complete plans of the proposed
system with substantiating data, soil borings, and percolation
rates, if necessary, attesting to the compliance with the
minimum standards of this Ordinance. A complete plan shall
include the location, size and design of all parts of the
system to be installed, altered, repaired, or extended. The
application shall also show the present or proposed location
of all nearby surface bodies of water, water supply facilities
and water supply piping, and the name of the person, firm or
corporation who is to install the system, and shall provide
such further information as may be required by the Building
Official. An application for cleaning a system shall only
contain the necessary information on the permit.
SECTION 5. PENALTIES AND VALIDITY.
A. Penalties.
1. Any person found to be violating any prov~s~on of
this ordinance shall be served by the Building Official with
written notice stating the nature of the violation and
providing a reasonable time limit for the satisfactory
correction thereof. The offender shall within the period of
time stated in such notice, permanently cease all violations.
2. Any person, firm, corporation or voluntary
association which violates any provision,of this Ordinance
shall be guilty of a misdemeanor, and upon conviction thereof
shall be punished as defined by State Law. (37C, 11-06-90
3. Any person violating any of the provisions of this
Ordinance shall become liable to the City for any expense,
loss or damage occasioned the City by reason of such
violation.
B. Validity.
1. All ordinances or parts of ordinances in conflict
with this ordinance are hereby repealed.
o
2. The invalidity of any section, clause, sentence or
provision of this ordinance shall not affect the validity of
any other part of this ordinance which can be given effect
without such invalid part or parts.
3. In the event any word, phrase, sentence, clause or
section is found to be in conflict with the provisions of this
Page 16
Ordinance, the most restrictive interpretation shall apply.
(37C, 11-06-90)
SECTION 6. ORDINANCE IN FORCE.
~)
This Ordinance to be in full force and effect from and after
its passage, approval and publication according to the law of the
State of Minnesota.
Adopted by the City Council of the City of Andover, this 3rd
day of August, 1976.
CITY OF ANDOVER
RICHARD J. SCHNEIDER
Mayor
ATTEST:
PATRICIA K. LINDQUIST
Clerk
37A, 9-07-76
378, 9-19-78
37C, 11-06-90
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page 17
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Section 1
Section 2
Section 3
Section 4
Section 5
Section 6
/' '\
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INDEX
ORDINANCE NO. 37
'SEPTIC SYSTEM ORDINANCE'
Defini tions
1
2
2
2
3
4
6
General provisions
A. Construction Requirements
B. General Requirements
C. Sewer Construction
D. Septic Tank
E. Surface Disposal Field
Administration
A. Enforcing Officer
B. Issuance of Permits
c. Inspection
D. Inspection & Testing of Water Systems
13
13
13
13
14
15
15
15
16
16
16
17
Licenses
A. Licensing
B. Permits
Penalties & Validity
A. Penalties
B. Validity
Ordinance in Force
Page 18
CITY of ANDOVER
,~ ,
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1685 CAOSSTOWN BOULEVARD N,W. . ANDOVER. MINNESOTA 55304 . (612) 755-5100
The City of Andover has a Private Septic System Ordinance.
Copies of this ordinance are available at City Hall. Failure of
individual systems results in problems not only for the
homeowners but also for the City Council.
Included in the Ordinance is a special section on the maintenance
of on-site sewage disposal systems. The purpose of this letter
is to inform you of the Private Septic System Ordinance and also
to give you suggestions on operation and maintenance of your
system.
SUMMARY OF MAINTENANCE PORTION OF ORDINANCE
a) The City shall mail, on or before March 1 of every other
year, to each owner having an on site sewage disposal system a
set of instructions and a form to be used in reporting on your
sewage disposal system. ~
b) The City will be divided into two areas for purposes of
biennial reporting by property owners. The area west of C.S.A.H.
No.9 (Round Lake Boulevard) shall report on odd years and the
area east of C.S.A.H. No 9 on even years.
c} Each property owner shall complete the maintenance report on
his on-site sewage disposal system and submit the form by
September 1st of that year. The City requires that each property
owner have his septic tank pumped as often as required by
inspection. The Building Official recommends every other year.
Failure on the part of the property owner to submit the forms
certifying that septic tank cleaning has been done shall be cause
for the City to have the septi~ tank cleaned. The City shall
contract for the cleaning service and provide the property owner
with an advance notification of the date the system will be
cleaned. The cost of this service shall be assessed to that
property.
d} A permit is requir~d for pump{ng septic tanks. The
application for this permit shall be made in writing on a form
provided by the City. A $2.50 fee is required for this permit.
e} A permit is required for installing, altering, repairing or ,
extending an on-site sewage disposal system. The application for
this permit shall be made in writing on a form provided by the
City. A $25.50 fee is required for this permit.
f} The contractor pumping the septic tank systems must be
licensed by the City. The contractor must conform to the
Minnesota Department of Health and Minnesota pollution Control
Agency regulations. Disposal of sludge and scum removed from the
systems shall be into a municipal sewer disposal system at a
disposal site approved by the City. -
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The City Council has provided this information to assist you and
if you have questions regarding this article, please contact the
City Building Official at 755-5100.
David Almgren
Building Official
Figure 18. Measuring sludge and scum in .
.eptlc tank.
..
OUTlET
)'
>.>
Bl.ACK COLOR
OtSTlNGUISHES SLt.JOGE
LAYER FROM LIQUID
..
,.....
"
1. The scum is measured with a pole that has a 4" x 4" piece of
plywood fastened to the bottom.
2. The pole is forced through the scum mat and then raised until
resistance from the bottom of the scum is felt. With the same
tool, measure the distance to ,the bottom of the outlet device.
If the layer and bo~tom of the outlet device ~re less than three
inches apart, your septic tank should be pumped. See Figure.
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CITY of ANDOVER
1685 CROSSTOWN BOULEVARD N,W, . ANDOVER. MINNESOTA 55304 . (612) 755-5100
ON-SITE SEWAGE DISPOSAL SYSTEM
MAINTENANCE REPORT
(Please complete in full and return)
1. Owner's Name (please print)
2. Address
3. Date
4. Date of Initial Installation (if known)
5. Date of last repair or reconstruction of system (if known)
6. Date of last septic tank pumping
7. Name of firm who pumped tank
Owner's Signature
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TABLE OF CONTENTS
SECTION
I. INTRODUCTION AND JURISDICTION
II. PARTIES BOUND
III. DEFINITIONS
IV. FINDINGS OF FACT
V. CONCLUSIONS OF LAW AND
DETERMINATIONS
VI. NOTICE TO THE STATE
VII. ORDER
VIII. NOTICE OF INTENT TO COMPLY
IX. WORK TO BE PERFORMED
X. QUALITY ASSURANCE
XI. FACILITY ACCESS, SAMPLING
DOCUMENT AVAILABILITY
XII. REPORTING REQUIREMENTS
XIII. REMEDIAL PROJECT MANAGER!
PROJECT COORDINATORS
XIV. RECORDS
xv. PENALTIES FOR NONCOMPLIANCE
XVI. OTHER CLAIMS
XVII. DELAY IN PERFORMANCE
XVIII. NOTICES
XIX.
CONSISTENCY WITH THE
NATIONAL CONTINGENCY PLAN
XX.
RESPONSE AUTHORITY
XXI.
ENFORCEMENT AND RESERVATIONS
PAGElS)
1-2
2-4
4-9
9-28
28-29
29-30
30
30-31
31-36
36
37-38
38-40
40-41
41-42
42-43
43
44
45
45-46
46
46-48
XXII. MODIFICATION AND MODIFICATIONS 48-50
TO WORK
XXIII. EFFEC'I'IVE DATES 50
XXIV. CERTIFICATION OF COMPLETION 50-51
OF REMEDIAL CONSTRUC'I'ION
XXV. ACCESS TO ADMINISTRATIVE RECORD 51-52
XXVI. OPPORTUNITY TO CONFER 52-53
',---)
UNITED ST~TES ENVIRONKENT~L PROTECTION ~GENCY
REGION V
IN THE MATTER OF:
Waste Disposal Engineering
Facility
Andover, Minnesota
RESPONDENTS:
(Attached as Appendix D)
--
~
)
)
)
)
)
)
)
)
)
)
)
PURSUANT TO SE
OF THE COMPREHE lVE
ENVIRONMENTAL RES
COMPENSATION, AND
LIABILITY ACT OF 1980,
as amended
(42 U.S.C. 99606(a)
U.S. EPA Docket No.
ADMINISTRATIVE ORDER FOR REMEDIAL DESIGN AND REMEDIAL ACTION
I.INTRODUCTION AND JURISDICTION
1. This Order is issued on this date to the Respondents listed
above by the United States Environmental Protection Agency ("U.S.
EPA") pursuant to the authority vested in the President of the
United States by section 106(a) of the Comprehensive Environmental
Response, Compensation and Liability Act of 1980 ("CERCLA"), 42
U.S.C. S9606(a), as amended. This authority was delegated to the
Administrator of the U.S. EPA by Executive Order No. 12580 on
January 23,1987,52 Federal Reqister 2926, (January 29,1987), and
was further delegated to the U.S. EPA Regional Administrators on
September 13, 1987 by EPA Delegation 14-14-B, and further delegated
to the Director of the Waste Management Division, Region V on
. '\
o
September 13, 1987 by Region V Delegation 14-14-B. By copy of this
Administrative Order, the State of Minnesota has been given notice
LIST OF APPENDICES
APPENDIX A
RECORD OF DECISION
APPENDIX B
REMEDIAL ACTION PLAN
APPENDIX C
RESPONSE ACTION FINAL DESIGN
APPENDIX D
LIST OF RESPONDENTS
APPENDIX E
SECTION 106 ADMINISTRATIVE RECORD INDEX
APPENDIX F
DEFINITION OF FACILITY
APPENDIX G
LIST OF POTENTIALLY RESPONSIBLE
PARTIES ISSUED A SPECIAL NOTICE LETTER
APPENDIX H
LIABILITY INFORMATION SUMMARIES
of the issuance of this Order as required by Section 106(a) of
(_) CERCLA, 42 U.S.C. Section 99606(a).
2. This Order directs Respondents to undertake remedial design
and remedial action activities for the WOE site located in Andover,
Minnesota, in response to an imminent and substantial endangerment
to public health or welfare arising from the release or threat of
a release of hazardous substances from the WOE site (the
"Facility", as specifically defined in section III, paragraph 7.F.
of this Order). This Order neither limits nor compromises the U.S.
EPA's ability to issue subsequent Orders, or take other actions, to
address any additional response action required at the WOE site.
The actions required by this Order are to implement response
actions, as defined under sections 101(25) and 104 of CERCLA, 42
U.S.C. 99601(25) and 99604, identified in EPA's Record of Decision
as defined in section III below, and the approved Response Action
Final Design (RAFO) Report as defined in section III below.
II.
PARTIES BOUND
J. This Order shall apply to and be binding upon each Respondent
identified in Appendix 0, their successors, and assigns.
Respondents are jointly and severally responsible for carrying out
all activities required by this Order.
Failure of one or more
Respondents to comply with all or any part of this Order shall not
in any way excuse or justify noncompliance by any other Respondent.
No change in the ownership, corporate status, or other control of
any Respondent shall alter any Respondent's responsibilities under
this Order.
"
'0
3
4. Respondents shall provide a copy of this Order to any
prospective owners or successors of the Facility, as Facility is
defined in paragraph 7. F. be 1 0.... , prior to the transfer of a
controlling interest in Respondent's assets, property rights, or
stock to the prospective owner or successor. Respondents shall
provide a copy of this Order to each contractor, sub-contractor,
laboratory, or consultant retained to perform any Work under this
Order, on the date such services are retained. Respondents shall
also ensure that a copy of this Order is provided to each person
....ho represents, in any capacity, any Respondent ....ith respect to the
Site or the Work and shall ensure that all contracts and
subcontracts entered into hereunder are conditioned upon
performance of the Work in conformity ....ith the terms of this Order.
With regard to the activities undertaken pursuant to this Order,
each contractor and subcontractor shall be deemed to be directly
related by contract to each of the Respondents ....ithin the meaning
of Section 107(b)(3) of CERCLA, 42 a.s.c. Section 9607(b)(3).
Not....ithstanding the terms of any contract, Respondents are
responsible for compliance ....ith this Order and for ensuring that
all contractors, subcontractors and agents comply ....ith this Order,
and perform all Work in accordance ....ith this Order.
5. Within ten (10) days after the date of issuance of this Order,
each Respondent that owns real property ....hich comprises any part of
the Site shall record a copy or copies of this Order in the
appropriate governmental office where land ownership and transfer
records are filed or recorded in such manner so as to ensure that
4
<_) notice is provided to third parties of the issuance and terms of
this Order with respect to a~~ such parcels and properties. Within
t....enty (20) days after the effective date of this Order, said
Respondents shall provide notice of such recording and indexing to
U.S. EPA.
6. Not later than sixty (60) days prior to any transfer of any
property interest in any real property included within the site,
Respondents shall submit a true and correct copy of all transfer
document(s) to U.S. EPA, and shall identify the transferee by name,
principal business address and effective date of the transfer.
III.
DEFINITIONS
7. Unless otherwise expressly provided herein, terms used in this
Order which are defined in CERCLA or in regulations promulgated
under CERCLA shall have the meaning assigned to them in the statute
or its implementing regulations. Whenever terms listed below are
used in this Order or in the documents attached to this Order or
incorporated by reference into this Order, the following
definitions shall apply:
A. "Administrative Order" or "Order" shall mean this Order and'
all appendices and exhibits hereto.
B. "Architect" or "Engineer" shall mean the person, company or
"
\.J
companies retained by the Respondents to prepare the construction
plans and specifications and to implement the remedial action
required pursuant to this Order, the Record of Decision (ROD), the
Response Action Plan (RAP), and the approved Response Action Final
S
Design (RAFD) Report. The ROD, RAP, and RAFD Report are attached
to this Administrative Order as Appendices A, B, and C,
respectively, and incorporated herein. Each architect or engineer
shall be qualified to do those portions of the work for which it is
retained.
C. "CERCLA" shall mean the Comprehensive Environmental
Response, Compensation and Liability Act of 1980, 42 U.S.C. 9601 et
~., as amended by the Superfund Amendments and Reauthorization
Act of 1986, Pub. L. 99-499.
D. "Contractor" shall mean the company or companies retained
by the Respondent to undertake and complete the work required by
this Administrative Order. Each contractor and subcontractor shall
be qualified to do those portions of the work for which it is
retained.
E. "Day" shall mean a calendar day. In computing any period
of time under this Order, where the last day would fall on a
Saturday, Sunday or Federal holiday, the period shall run until the
end of the next working day.
F. "Facility" shall mean the "facility" as that term is
defined at Section 101(9) of CERCLA, 42 U.S.C. 59601(9) including,
but not limited to the site as defined below, where hazardous
substances have been deposited, stored, disposed of, or otherwise
placed, or otherwise came to be located.
G. "Hazardous substance" shall have the meaning provided in
Section 101(14) of CERCLA, 42 U.S.C. ~9601(14).
H. "MPCA" shall mean the Minnesota Pollution Control Agency.
/
6
,~-)
I.
"National contingency Plan" or "NCP" shall mean the
National contingency Plan promulgated pursuant to Section 105 of
CERCLA, 42 U.S.C. ~9605, codified at 40 CFR Part 300, inclUding any
amendments thereto.
J. "Paragraph" shall mean a portion of this Order identified
by an arabic numeral.
K. "Parties" shall mean the U.S. Environmental Protection
Agency and the Respondents.
L. "project Coordinator" or "PC" shall mean the person
designated by the Respondents to coordinate, monitor, and direct
the implementation of the remedial activities at the Facility.
M. "Response Action Final Design Report" or "RAFD Report"
shall mean the report dated June 6, 1988, prepared by the
Respondents under the 1984 Consent Order, as modified and approved
by U.S. EPA and MPCA, inCluding any supplements to the RAFD. The
RAFD Report and supplements to the RAFD is an enforceable part of
this Order and is attached hereto as Appendix C.
N. "Remedial Action Plan" or "RAP" shall mean the plan for
implementation of the Remedial Design and Remedial Action at the
Facility, and any subsequent amendments thereto.
The RAP is an
enforceable part of this Order and is attached hereto as Appendix
B.
o. "Record of Decision" or "ROD" shall mean the EPA Record
of Decision signed on Deceml:ler 1987, by the Regional Administrator,
U. S. EPA Region V attached hereto and incorporated herein as
,
Appendix A.
The Record of Decision is the decision document
'0
7
representing the selected remedial action for the Waste Disposal
Engineering Facility.
P. "Remedial Action" or "RAN shall mean those activities to
be undertaken by Respondents to implement the final plans and
specifications submitted by Respondents pursuant to the (Amended)
RD/RA Work Plan approved by U.S. EPA including any additional
activities required under of this Order.
Q. "Remedial Design" or "Ron shall mean those U.S. EPA
approved activities to plan the implementation of the Remedial
Action.
R. "Respondents" shall mean the parties who are named in
Appendix 0 to this Administrative Order.
S. "Response Costs" sh~ll mean all costs, including direct
costs, indirect costs, and accrued interest, incurred by the United
States to perform or support response actions at the Facility.
T. "Section" shall mean a portion of this Order identified
by a roman numeral and includes one or more paragraphs.
U. "Section 106 Administrative Record" shall mean the
Administrative Record which includes documents considered or relied
upon by U. S. EPA in preparation of this Order". The- Section" 106
,Administrative Record ~ndex is a listing,of ,all documents included
in the Section 106 Administrative Record, and is attached hereto as
Appendix E.
v. "Site" shall mean that property located within the city
limits of Andover, Anoka County, Minnesota that was operated as a
landfill for municipal, commercial and industrial waste from 1963
8
\~) through 1983 and known as the former Waste Disposal Engineering,
Inc. Sanitary Landfill. The site is located in Sections 27 and 34,
Township 32 North, Range 24 West, of Anoka County, and includes the
following described property, which is shown on the map attached as
Appendix F to this Order:
(1) the south half of the southeast quarter of Section 27,
Township 32, Range 24;
(2) all that part of the Northwest Quarter of the Southeast
Quarter lying southerly of the center line of Coon Creek
in Section 27, Township 32, Range 24;
(3) all that part of the Northeast quarter of the Southwest
quarter of Section 27, Township 32, Range 24, that is
described as following: Commencing at the Northeast
Corner of said Northeast quarter of the Southwest
quarter; thence West along the North line- thereof for
58.6 feet and to the center line of County State Highway
No. 18; thence South 32 degrees, 55 minutes West of for
550.17 f.eet along said center line; thence South 44
degrees , 11 minutes West for 342.85 feet along said
center line ; thence South-- '45' degrees', 26 minutes East
for 872 feet and to the Southeast corner of said
Northeast quarter of the Southwest quarter; thence North
along the East line of said Northeast quarter of the
Southwest quarter and to point of commencement;
- ,
.;.{: (4) the Northeast quarter of the Northeast quarter of Section
34, Township 32, Range 24;
'0
9
(5) the north 200 feet of the Northwest Quarter of the
Northeast quarter of section 34, Township 32, Range 24;
(6) the east 200 feet of the Southeast Quarter of the
Southwest Quarter of section 27, Township 32, Range 24;
and
\ (7) the west 200 feet of the Northeast Quarter of the
Southeast quarter of section 27, Township 32, Range
24.
w. "State" shall mean the State of Minnesota.
X. "United states" shall mean the united States of America.
Y. "U.S. EPA" or "the Agency" shall mean the united States
Environmental Protection Agency.
Z. "Work" shall mean all activities Respondents are required
to perform pursuant to this Order, appendices hereto, and all
approved plans and schedules pursuant thereto, including but not
limited to, the Remedial Design, Remedial Action, operation and
Maintenance, and any activities required to be undertaken pursuant
to the order, ROD, and RAP.
IV.
FINDINGS OF FACT
Based on information contained in the Administrative Record in
this matter (an index of which is attached as Appendix E) U.S. EPA
hereby finds:
8. The Facility is located within the city of Andover
(formerly Grow Township), Anoka county, Minnesota (see Attachments
land 2 of the ROD), approximately 15 miles north of the City of
10
.~)
Minneapolis. It is situated south at Coon Creek, west of Hanson
Boulevard, East of Crosstown Boulevard.
9. The WOE Site consists of a total of approximately 114
acres.
The area of actual disposal in the landfill covers
approximately 73 acres.
The WOE site is located in a rural
surrounding on the edge of suburban development consisting of small
farms and some residential development.
10. Prior to MPCA permitting as a solid waste disposal system
in 1971, the WOE Site ....as operated as a solid waste dump ("dwnp")
for at least nine years by previous owners of the property. The
dump ....as established in about 1963 by Leonard E. Johnson and ....as
licensed in the later years of the Johnson operation, by Grow
Township.
11. The dump ....as purchased by Waste Disposal Engineering,
Incorporated ("WOE, Inc.") in 1968.
A permit to operate as a
sanitary landfill ....as granted by the Grow Township Board effective
mid-year, 1968.
12. In 1970 WOE, Inc. submitted a permit application to the
MPCA to operate a solid waste disposal system.
A proposal to
. ,
dispose of hazardous substances in a specially constructed trench
at the landfill (generally referred to herein as "WOE Pit") was'
included in the permit application. On March 30, 1971, the KPCA
issued permit SW 28 to WOE, Inc. to operate the WOE site as a solid
....aste disposal system including construction and operation of the
WOE Pit. Approval for the solid waste disposal system was also
"-
'~i given by Anoka County and the Metropolitan Council.
11
13. Construction of the WOE Pit began in 1971 and 'Was
completed in 1972. The MPCA approved the design of the WOE pit.
The WOE pit 'Was to include an 18 inch layer of clay overlain with
a six inch thick bituminous liner follo'Wed by six inches of crushed
limestone. Oepth to ground water beneath the WOE pit 'Was to be at
least ten feet.
Materials to be disposed of in the WOE Pit
included solvents, oils, paint sludges, caustics, and acids. A
permanent record of the disposal activities at the WOE Pit 'Was to
be kept at the WOE Site by WOE, Inc. and the information reported
monthly to the MPCA. It is believed that the WOE Pit 'Was operated
from November, 1972 to January, 1974. WDE, Inc. did not follow the
plans approved by the MPCA for WOE Pit disposal operations. A
truck loaded with barrels broke through the asphalt liner in
November, 1972 and repairs were not completed until July, 1973.
Indiscriminate barrel disposal, spillage of barrel contents, and
water collecting in the WOE Pit were also problems noted in an MPCA
inspection report in 1972.
14. The MPCA ordered the WOE Pit closed effective February 1,
1974 due to changes in regulations and because the MPCA determined
that a high potential 'for ground'~ater pollution existed at the ~-oE
site. That determination was based on the following facts: WOE,
Inc. submitted inadequate hazardous waste disposal reports; WOE,
Inc. did not submit required monitoring results; and previous MPCA
investigations indicated cracks in the asphalt liner from heavy
vehicles. Although the WOE pit ceased operation, the
continued operation.
landfill
,
12
.' ')
'-../
15. Approximately 6,600 containers (ranging from 1 gallon
pails to 55 gallon drums) holding a ~ide variety of ~astes (acids,
caustics, ~aste paints, spent solvents, plating sludges, cyanides)
have been disposed in the WOE pit. An undetermined quantity of
hazardous ~aste, much of it as bulk loads, ~as disposed throughout
the landfill.
Based on interviews and government files,
approximately 3.2 million gallons of hazardous waste have been
disposed before, during, and after operation of ~he WDE pit at the
WDE site. using these estimates, only 10 percent of the hazardous
waste expected to be at the site would have been disposed in the
WDE pit.
16. The WDE site gre.... from three acres in 1964, to 41 acres
in 1970, to its present day permitted size of 114 acres. The area
of actual disposal in the landfill covers 73 acres (see Attachment
3 of the ROD). The maximum thickness of waste is 40 feet. The
landfill contains nearly 2.5 million cubic yards of waste. Much of
the landfill is covered by lime sludge obtained from the
Minneapolis Drinkin~ Water Treatment Plant. The sludge thickness
ranges from three to six feet (average of four feet).
. '\
\ '
',,..../
17. The WOE site ceased operations. in. February, 1984 and has
remained abandoned and inactive. The property'of the site has gone
through tax forfeiture so that it is currently property of the
state of Minnesota ....ith administration by Anoka County. WDE, Inc.
failed to respond adequately to MPCA requests to address final
sanitary landfill closure.
18. The Minnesota Department of Health in January, 1983
13
issued a drinking water well advisory in portions of the City of
Andover due, in part, to hazardous substances disposal at the WDE
site.
19. Pursuant to Section 105 of CERCLA, the WDE Facility was
placed on the National Priorities List of hazardous waste sites by
publication in the Federal Register on September 8, 1983, 48 Fed.
Reg. 40658-40682 (1983).
20. In March, 1984 the MPCA and U.S. EPA entered into a
Consent Order with 9 companies. Three more companies joined the
group and executed the Consent Order in April, 1984. The twelve
companies (known as the "Respondents" in the Consent Order) are
Economics Laboratory, Inc., Ford Motor Company, Honeywell, Midland
Cooperatives, Inc., Mineo Products, Onan Corporation, Sperry
Corporation (Unisys), Thermo King Corporation, Warden Oil, Control
Data Corporation" Cornelius Company, and FMC Corporation. In May
1987, the MPCA and U.s. EPA were notified by letter that three
additional companies (Minnesota Mining and Manufacturing Company,
Cargill Inc. and Union Brass and Metal Manufacturing Company) had
.
voluntarily joined these- companies as respondents to the Consent
Order.
21. The Respondents to the 1984 Consent Order, commonly
referred to as the SW-28 Group, agreed to accomplish the following
tasks:
A. Design, initiate and complete the landfill and pit
Remedial Investigation/Feasibility Study (RI/FS);
B. Establish a trust fund to pay for the RI/FS work;
{~ )
14
C.
Establish a $1 million trust fund in the event the
Respondents do not implement the remedial actions
as selected by the MPCA and U.S. EPA;
D. Design the selected response action: for the WOE
site designated in the U.S. EPA Record of Decision;
and
E. Enter into good faith negotiations leading to an
agreement to address remedial and removal actions
at the WDE Site.
22. The SW-28 Group completed a Remedial Investigation ("RI")
Report on December 18, 1986.
23. The RI data indicates the following:
A. The surficial deposits, or Upper Sand Unit, are fine to
medium sand, have relatively high permeabilities, and are 40 to 73
feet thick in the landfill.
B. There is a thin, gray silt till unit (0 to 15 feet thick)
within the Upper Sand unit. The unit is present in most deeper
borings at the siie at depths between 30 to 40 feet. It lacks
continuity and it is not relied upon as an effective confining
unit.
C. Below the Upper Sand unit is a red-brown clay/silt till
unit. The unit is relatively dense, has low permeabilities (10-sto
10-~entimeters per second (em/see)), and serves as an aquitard for
the Lower Sand unit underlying the till unit. The till thickness
ranges from 10 to 40 feet thick, becoming progressively thinner
" '\
...... j from north to south across the site. The surface of the till unit
15
is highest immediately below the WDE Pit area of the landfill, and \
slopes downward concentrically from the peak (see Attachment 4 of
the ROD). The steepest slope is to the northwest and west.
D. Underlying the red-brown till is the Lower Sand Unit. It
becomes finer and more silty with depth. The thickness of this
unit is on the order of 80 feet thick.
E. Groundwater in the Upper Sand unit or the Upper Sand
Aquifer is under water table conditions (unconfined). Ground water
flow in the Upper Sand at the site is pronounced to the north
across the site and discharging into Coon Creek (see Attachment 5
of the ROD). Ground water flow rates in the Upper Sand Aquifer are
on the order of 25 to 30 feet per year.
F. Groundwater in the ~wer Sand unit or the ~wer Sand
Aquifer is under confined conditions and in the vicinity of Coon
Creek, artesian conditions exist (Le., monitoring well 260).
Regional ground water flow in the Lower Sand Aquifer is to the
southwest, ultimately discharging into the Mississippi River,
approximately 4 mi~es downgradient of the WDE Site. At the WDE
site, Lower Sand Aquifer flow is apparently towards the west-
northwest due in part to the readings from one particular
monitoring location. Absent this one well, ground water flow
patterns would be entirely consistent with the regional patterns.
G. The Lower Sand Aquifer is used extensively for domestic
water supply, particularly southwest (and downgradient) of the
site. The Upper Sand aquifer is used by some residents having sand
points, particularly north of Coon creek.
16
~,)
H.
curren~ly, there is a downward component of groundwater
flow within the Upper Sand Aquifer at the WOE Site, except as one
approaches Coon Creek where the gradient switches to produce an
upward flow.
I. The vertical gradient of groundwater across the red-brown
till unit is upward from the Lower Sand Aquifer to the Upper Sand
Aquifer under the limits of refuse disposal and in the area between
the refuse and Coon Creek. The vertical gradient of groundwater
across the red-brown till unit between the Lower Sand and Upper
Sand aquifers is downward immediately south of the limits of refuse
disposal. The gradient is consistently downward at monitoring well
nest 1 and is variable (downwards and upwards) at monitoring well
nest 23 (see Attachment 6 and 7 of the ROD).
J. The lateral ground water gradient in the Upper Sand
aquifer is approximately 0.005. with a hydraulic conductivity of
1.6 x 10-6cm/sec to 1 x 10-3cm/sec-and an assumed porosity of 30
per cent, the average vertical ground water velocity downward
across the red-browp till is approximately 0.4 to 2.0 feet/year.
K. Ground water contamination exists within the Upper Sand
aquifer beneath and downgradient of the landfill and ultimately
enters Coon Creek. The degradation is most severe in the upper
portion of the Upper Sand aquifer. A total of 39 VOCs have been
reported to be present in groundwater. An additional 14 semi-
volatile organic compounds and 32 metals were also reported.
contaminants include typical landfill type contaminants (reduced
"\ pH, chlorides, and high Chemical Oxygen Demand (COD)] and a wide
',./
17
variety of organic constituents, including aromatic and halogenated
volatiles, and low levels of metals (see Attachments 8 to 12 of the
ROD). The highest concentrations of some of the volatile organics
found to be released in ground....ater include methylene chloride
(230,000 ppb), dichloroethylene (62,000 ppb), trichloreothane
(36,OOO ppb), tetrahydrofuran (2300 ppb), methyl ethyl ketone
(280,000 ppb), benzene(750 ppb), and xylenes (56,000 ppb).
L. The areal distribution of contaminants show the most
severe contamination at and downgradient of the WDE Pit (wells W6,
W8, W11, and W22A). High concentrations or "hot spots" were
detected at other scattered locations (i.e., W28A, and W31A) within
the landfill, reflecting the scattered pattern of disposal
practices throughout the history of the landfill operations.
currently the WOE Pit area shows the most serious ground water
degradation and is the dominant source of contaminants, notably
volatile organics, entering Coon Creek. contamination in the Upper
Sand is most severe near the water table and decreases with depth,
producing a stratified plume (see Attachment 13 of the ROD). There
is some localized contamination present north of Coon Creek but
this appears to be due to underflow and reversal back to Coon Creek
because of Coon Creek's stratigraphy. None of the private wells
north of Coon Creek show contamination.
M. contaminants in the Upper Sand Aquifer are well above the
legally enforceable Maximum Contaminant Levels (MCLs) established
under the Safe Drinking Water Act. Vinyl chloride, reported at
10,000 ppb, is 5000 times its regulatory maximum of 2 ppb. 1,1,1
18
. "-
',_) trichloroethane reported at 36,000 ppb is in excess of 180 times
its MCL of 200 ppb. Trichloroethylene reported at 4,000 ppb is 800
ti~es its MCL of 5 ppb.
N. Of the organic compounds released to groundwater, 11 are
known or probable human carcinogens and 4 are possible human
carcinogens. Maximum concentrations of benzene, a known human
carcinogen, have been reported up to 750 ppb, corresponding to a
lifetime excess cancer risk of 7.5 x 10-4 through ingestion of
onsite ground water in the Upper Sand Aquifer. Values of vinyl
chloride, also a known human carcinogen have been reported up to a
maximum concentration of 10,000 ppb. This corresponds to a lifetime
excess cancer risk of 6 out of 10 via ingestion of onsite
groundwater within the Upper Sand Aquifer. Methylene chloride,
another probable human carcinogen, is reported with maximum
concentrations of up to 230,000 ppb. This corresponds to an excess
lifetime cancer risk of 4.6 x 10-2 through ingestion of onsite
groundwater within the Upper Sand Aquifer.
O. Of the organic compounds detected in groundwater, 31 are
also either acutely or chronically toxic via ingestion.
Groundwater in the Upper Sand Aquifer exceeds many of the drinking
water health advisories compiled by U.S.EPA, Office of Drinking
Water. While not legally enforceable, health advisory levels are
set to be protective of sensitive populations and give general
indications of drinking water quality. Cis, dichloroethylene is
reported with concentrations up to 62,000 ppb which is 15.5 times
.', the acute drinking water health advisory for a 10 kilogram child
'"j
19
and 900 times the life time chronic advisory for a 70 kilogram
adult. Methylene chloride at 230,000 ppb is 23 times the one day
acute drinking water advisory and 1500 times the lifetime chronic
drinking water advisory for a 70 kilogram adult.
P. Coon Creek is the primary receptor of Site - contaminated
ground water in the Upper Sand Aquifer. Coon Creek discharges into
the Mississippi River 11 river miles downstream from the Site. The
discharge into the Mississippi River is approximately 3 miles
upstream of the intake for the St. Paul water supply and 7 miles
upstream of the intake for the Minneapol is water supply. No
contaminants, particularly volatile organics, are detectable
upstream of the WOE site in Coon Creek. Trace levels of some
volatile organics are detectable along most of Coon Creek bordering
the north side of the WOE Site. At the point the contaminant plume
from the site enters the creek, the levels of a variety of volatile
organics, particularly chlorinated volatiles, are present, and
persist several miles downstream of the Site. Non-halogenated
volatiles are observed in high concentrations in ground water near
the Creek and are thought to dissipate quickly upon entering the
Creek. However, these compounds do persist when ice cover
conditions exist. The levels of volatiles in Coon Creek where the
site plume enters the Creek are in the range of 1 to 30 ug/1 for
several different halogenated volatiles. A tota~ ot 12 VOCs are
consistently reported to be present in surface water samples taken
from Coon Creek. All of these compounds were also reported to be
in groundwater. Of the organic compounds detected in surface
;,--)
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20
water, three (3) are probable carcinogens. Some compounds in Coon
Creek are above Water Quality criteria established under the Clean
Water Act for consumption of water and fish. Methylene chloride is
reported to be as high as 5.8 ppb, which yields an excess lifetime
cancer risk level of 3 x 10-5.Cis, dichloroethylene is reported to
be as high as 25 ppb, yielding an excess lifetime cancer risk of
7.6 x 10-40ased on consumption of groundwater and a risk of 1.4 x
10-~ased on consumption of fish.
Q. The Lower Sand aquifer has not shown any levels of
contamination to date. However, the long-term integrity of the
Lower Sand aquifer cannot be completely guaranteed. The gradient
across the till is downward immediately south of the landfill and,
if ground water conditions were to shift in the future, the
downward gradient may expand northward under the landfill. Also,
heavier-than-water, non-aqueous phase liquids (NAPL) may migrate
along the surface of the till southward (down the slope of the till
surface) to the zone of downward gradients and, in the long-term,
potentially impact . ground water quality. Thirdly, most of the
residential wells southwest (and downgradient, in terms of the
regional flow, within the Lower Sand of the WOE Site) are installed
in the Lower Sand and may be impacted if contamination were to
reach the Lower Sand aquifer. The presence of such a large number
of wells southwest of the site has the potential to aggravate the
downward gradient condition along the southern portion of the site.
R. The WDE site has 11 gas probes, located primarily along
the western and southern sides of the landfill to monitor areas of
Ii
21
current residential development (see Attachment 5 ot the ROD).
Coon Creek (along the north and northeast sides ot the Landtill)
apparently provides a hydraulic barrier to gas migration.
Evergreen trees immediately along the west side of the landfill are
showing signs of stress. Combustible gas measurements show the
highest levels (15 to 30 percent by volume) in gas probe nest 6,
Iii th 5 and 8 percent levels also reported in probes 1 and 4
respectively. Volatile organic analyses in these probes also
indicate the presence of a variety of compounds, principally
halogenated compounds. As with combustible gas described above,
probes GP-1, GP-4, and GP-6 show the highest concentrations. Those
probes along the south do not currently indicate migration. The
fact that oft-site gas migration is limited at this time may be due
to the current relatively high water table conditions and the high
porosity and permeability of the surficial deposits in the area.
lfuile there are no MCL equivalent standards for air releases,
levels of individual contaminants (1,1,2,2-tetrachloroethene, 1,3-
dichloropropene) exceed established industrial standards, Threshold
Limit Values (TLVs), tor on-site workers in GP-4 and GP-6,
immediately adjacent to the landtill. In addition, the levels ot
some contaminants (methylene chloride, benzene, trichloroethene)
exceed the potency factors for carcinogens identified in the Public
f1ealth Risk Evaluation Data Base. Because the landfill is
relatively young, methane and other gases will continue to be
generated and pose a long term threat. Gas generation typically
peaks 10-20 years after cessation of disposal activities.
.,:_)
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22
S. The wetlands north of the site are listed in the National
Wetland Inventory as a Type 2 wetland (Class Palustrine, emergent,
subj ect to intermittent flooding, drained). The U. S. Fish and
Wildlife service has identified the presence of sedges, reed canary
grass, cattails, and willows.
T. Wetlands between the limit of refuse disposal and Coon
Creek, particularly in the area of monitoring well nests 2 and 13,
have been impacted by seeps and shallow leachate of the site.
Migrating waterfowl may utilize these wetlands.
U. Land resources in the area are used for agricul ture,
residential, and light industrial purposes. Some land is
undeveloped (See Attachment 14 of the ROD). Historically, the area
surrounding the WDE site was comprised of small farms and small
residential developments. Currently, more extensive residential
development has been or is planned to be constructed around the
site.
V. Potentially impacted water resources consist of the
groundwater in the ,Upper and Lower Sand Aquifers and surface waters
in Coon Creek and the Mississippi River. The Upper Sand is used as
a source of potable water in the immediate area. Irrigation and
livestock watering are other uses of the ground and surface waters.
W. The WOE site has a variety of exposure pathways, for the
release of hazardous substances. The existing pathways include
ingestion/dermal exposure from contamination of Coon Creek by Upper
Sand ground water, and direct contact threat to people on site
exposed to wastes and leachate. There is also the risk of physical
23
injury due to the existing hazards at the Site (Le., exposed
cables, rusty drUl:1s, etc.). Other potential pathways include
drinking water contaminated from leakage into the Lower Sand (L e. ,
NAPL) or migration beneath and north of Coon Creek within the Upper
Sand. Controls are necessary to protect public health, welfare, or
the environment from the threatened and continuing releases of
hazardous substances. The releases are described as follows:
1. Heavily-contaminated ground water within the Upper
Sand Aquifer, particularly from the WDE Pit, is
currently discharging into Coon Creek resulting in
low but persistent levels of various chlorinated
volatile organics in Coon Creek.
2. Leachate seeps are sporadically active near the
base of the north face of the landfill along Coon
Creek. When the leachate seeps are active, they
pose a direct contact risk to people and wildlife
on the WDE site. The leachate seeps ultimately
drain into Coon Creek via inter flow or overland
flow.
3. Potentially hazardous wastes and other landfill
wastes, are gradually being exposed as the
existing, unprotected lime sludge cap erodes. The
lime sludge alone does not support any vegetative
cover and is subject to wind erosion under dry
conditions and runoff erosion during periods of
even moderate rainfall. Extensive and deep (up to
24
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10 feet deep) gullies have developed particularly
in the northwest quarter of the landfill. As the
lime sludge cap erodes, the potential for direct
contact exposure to waste increases over time.
4.
The highest
levels of Upper Sand Aquifer
groundwater contamination are at and downgradient
of the WOE pit and in isolated/random locations in
the landfill (so called "hot spots"). While the
ground water contamination being discharged to Coon
Creek is largely limited to the immediate vicinity
of the Site, there is also some evidence of one
small pocket of contamination in the vicinity of
well nest 21, raising concerns regarding the
adequacy of Coon Creek as a complete hydraulic
barrier.
There are also long-tere concerns
regarding NAPL migration in the Upper Sand Aquifer,
and contamination entering the Lower Sand aquifer
due ,to NAPL migration or dissolved contaminants
migrating downward south of the site_ To date, no
contamination has been detected in private wells.
5. Gases, both methane gas from the landfill and
individual volatile organics from wastes, are being
released from the site in quantities that exceed
Threshold Limit Values.
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24. A Feasibility Study (FS) Report prepared by some of the
25
SW28 Group was approved with modifications on August 10, 1987. The
FS examined various remedial alternatives regarding the release and
threatened release of contaminants from the WOE site. The FS
Report included a proposed remedial action at the Facility.
25. Pursuant to section 117 of CERCLA, 42 U.S.C. section
9617, notice of the completion of the RIjFS and the proposed
remedial action was published in a major local newspaper of general
circulation. The notice announced the opportunity for public
comments on the RI/FS and proposed remedial action to be submitted
in writing to U.s. EPA by September 29, 1987, or orally at a public
meeting which was held in the City of Andover, Minnesota, on
september 14, 1987. U.S. EPA has kept a transcript of the public
meeting and has made this transcript available to the public as
part of the administrative record located at both the U.S. EPA,
Region V, 230 South Dearborn Street, Chicago, Illinois and the MPCA
offices located at 520 Lafayette Road, st. Paul, Minnesota.
26. certain persons have provided comments on U.s. EPA IS
proposed remedial action, and to such commentors u.s EPA provided
a summary of responses, all of which have been included in the
administrative record referred to above;
27. Considering the proposed remedial action and the public
comments received, u.s. EPA reached a decision on a final remedial
action, which is embodied in a document called a Record of Decision'
(UROD") (attached hereto as Appendix A and incorporated by
reference) signed by the Regional Administrator on December 31,
1987 I to which the MPCA has given its concurrence. The ROD
26
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includes a discussion of U.S. EPA I S rationale for the adopted
remedial action and for any significant changes from the proposed
remedial action contained in the FSi
28. Pursuant to Section 117(b) of CERCLA, 42 U.S.C. Section
6917(b), U.S. EPA provided public notice of adoption of the final
remedial action embodied in the ROD, including notice of the ROD's
availability to the public for review in the same locations as the
administrative record referred to above. The notice was published
in a major local newspaper of general circulation, and the notice
included an explanation of any significant changes and the reasons
for such changes from the proposed remedial action contained in the
FS:
29. On June 6, 1988, in accordance with the 1984 Consent
Order, the 5W28 Group submitted a Response Action Final Design
(RAFD) Report to U.S. EPA and MPCA for approval. The RAFD Report
is a conceptual design of the remedial action embodied in the ROD
and included additional field studies. The approved RAFD Report
concludes that the gray silt till unit is continuous below the WOE
Pit and the lime sludge barrier layer of the cap described in the
ROD will be replaced with clay. U.S. EPA approved the RAFD Report,
with conditions, on December 16, 1988. U.S. EPA and MPCA granted
final approval of the RAFD report on May 19, 1989. Appendix C to
this Order is the RAFO Report.
30. Appendix B to this Administrative Order is a Remedial
Action Plan ("RAP") for implementing the final remedial action
" embodied in the ROD and the approved RAFD Report. U.S. EPA has
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27
determined that the RAP is consistent with the ROD and the approved
RAFO Report.
31. In accordance with section 121(f) (1) (F) of CERCLA, 42
U.S.C. section 9621(f) (1) (1'), U.S. EPA notified the State of
Minnesota on July 12, 1989, that U.S. EPA intends to commence
negotiations with PRPs regarding the scope of the remedial design
and remedial action for the Facility, and U.S. EPA has provided the
State with an opportunity to participate in such negotiations and
be a party to any settlement;
32. By letter dated July 12, 1989, U.S. EPA pursuant to
Section 122 of CERCLA, 42 U.S.C. Section ~9622, notified certain
parties listed in Appendix G, that the U.S. EPA determined them to
be potentially responsible parties (IPRPs") regarding
implementation of remedial action at the WOE site. At that time,
U.S. EPA notified PRPs of the beginning of the 120 day negotiating
moratorium required by Section 122(e) (2) (A) of CERCLA, 42
U.S.C.~9622(e) (2) (A).
33. U.S. EPA has complied with the moratorium required by
Section 122(e) of CERCLA, 42 U.S.C. S9622(e), prohibiting U.S. EPA
from commencing action under Section l04(a) or taking actions under
Section 106 for 120 days after PRP receipt of the July 12, 1989,
U.S. EPA notification.
34. Pursuant to Section 122(j) of CERCLA, 42 U.S.C. Section
9622(j), on July 12, 1989, U.S. EPA notified the Federal Natural
Resource Trustee of negotiations with PRPs on the subject of
addressing the release or threatened release of hazardous
32
,~ a plan for satisfaction of permitting requirements; (4) a quality
assurance project plan; (5) a groundwater monitoring plan; and (6)
an operations and maintenance plan. The RD/RA Work Plan and other
documents submitted shall demonstrate that the Respondents can
properly conduct the actions required by this Order. The RD/RA
Work Plan shall also include a schedule for implementation of the
RD/RA Work Plan tasks and submittal of RD/RA reports. The RD/RA
Work Plan shall require the Respondents to perform and complete
remedial design and construction within the schedule shown in the
RAP, and shall attain and maintain all requirements including
design criteria and performance goals identified in the ROD, the
approved RAFD Report and the RAP.
51. The RD/RA Work Plan and other required documents and
reports (hereinafter referred to as "documents") shall be subject
to review, modification and approval by U.s. EPA in consultation
with the MPCA.
<J
52. If the RD/RA Work Plan or other document is acceptable,
approval shall be gFanted, in writing, and the RD/RA Work Plan or
other document shall become an integral and enforceable element of
this Order. In the event of any disapproval, u.s. EPA shall
specify, in writing, the reasons for disapproval.
53. Within thirty (30) calendar days of receipt of any U.S.
EPA letter stating disapproval, the Respondents shall submit an
amended document, including the word processing diskettes in
appropriate format as determined by the U.s. EPA RPM, to U.s. EPA
which incorporates all U. S. EPA requested changes and
33
modifications, and those changes and modifications only. The U.S.
EPA shall review the a:lended document and shall either notify
Respondents, in writing, of approval, disapproval or modification
of the document or any part thereof, or shall modify the document
itself.
Failure to incorporate all changes and modifications
requested by U.S. EPA, or to submit unso1icit~d~han~_~s_ and
modifications, shall be deemed noncompliance with the terms of this
Order.
54. If U.S. EPA modifies any docu:lent, that document is
considered approved by U.S. EPA, Respondents shall implement the
Work required by the approved or amended document within the
schedule specified in the document or this Administrative Order.
55. Respondents shall proceed to implement the work detailed
in the approved (amended) RD/RA Work Plan within five (5) calendar
days of receipt of written approval by U.S. EPA. Unless otherwise
directed by U.S. EPA and as mandated by Section 122(e) (6) of
CERCLA, the Respondents shall not commence remedial action until
they receive written approval of the RO/RA Work Plan by U.S. EPA.
The fully approved or modified RO/RA Work Plan and all documents
generated under its direction shall be deemed incorporated into and
made an enforceable part of this Administrative Order. Respondents
shall conduct and complete the tasks outlined in the RD/RA Work
Plan in accordance with the National Contingency Plan,
U.S. EPA guidance including, but not limited to, Superfund Remedial
Design and Remedial Action Guidance, and the requirements of this
Administrative Order, including the specifications and schedules
40
,~~
all appropriate action to protect human health, welfare or the
environment, or to prevent, abate, or minimize an actual or
threatened release of hazardous substances at or from the WOE site.
XIII.
REMEDIAL PROJECT MANAGER/PROJECT COORDINATORS
69. U.S. EPA will designate a Remedial Project Manager
("RPM") and/or an On Scene Coordinator ("OSC") for the Facility,
and the U.S. EPA may designate other representatives, including
U.s. EPA and MPCA employees, and federal and state contractors and
consultants, to observe and monitor the progress of any activity
undertaken pursuant to this Administrative Order.
The RPM/OSC
shall have all of the authority lawfully vested in an RPM by the
National contingency Plan, 40 C.F.R. Part 300 as amended, including
the authority to halt, conduct or direct any Work required by this
Administrative Order or to direct any other response action
undertaken by U.S. EPA or the Respondents at the Facility.
Respondents shall also designate a Project Coordinator who shall
have primary responsibility for implementation of the Work at the
Facility.
70. To the maximum extent possible, except as specifically
provided in the Administrative Order, communications between
Respondents and U.S. EPA concerning the terms and conditions of
this Order, implementation of the Work under this Administrative
Order, and 'all documents, reports, approvals, and all other
correspondence concerning the activities relevant to this Order,
.' I shall be directed through the Project Coordinator and the RPM/OSC.
"-/
41
71. Within seven (7) calendar days after the effective date
of this Administrative Order, Respondents shall notify U.S. EPA and
MPCA, in writing, of the name, address and telephone number of the
designated PRP Project Coordinator. Fred Bartman is the U.S. EPA
RPM for this Administrative Order. His telephone number and
address are presented in section XVIII.
72. The U.S. EPA and the Respondents shall each have the right
to change their respective designated RPM/OSC or Project
Coordinator. Respondents shall notify U. S. EPA, as early as
possible before such a change but in no event shall Respondents
give notice to U.S. EPA less than 24 hours before such a change.
Notification may initially be verbal, but shall promptly be reduced
to writing.
XIV.
RECORDS
73. During the pendency of this Administrative Order and for
a period of ten (10) years after its termination, Respondents shall
make available to' U. S. EPA and shall retain, all records and
documents in their possession, custody, or control which relate to
the performance of this Administrative Order, including, but not
limited to, documents reflecting the results of any sampling,
tests, or other data or information generated or acquired'by any of
them, or on their behalf with respect to the Facility. At the
conclusion of the ten (10) year period of document retention,
Respondents shall provide written notice to the U.S. EPA, RPM, U.S.
EPA Office of Regional Counsel, and the MPCA at least ninety (90)
~)
42
calendar days prior to the destruction of any such documents, and
upon request of U.S. EPA, the Respondents shall relinquish custody
of the documents to U.S. EPA.
74. Respondents may assert business confidentiality claims
covering part or all of the information provided in connection with
this Administrative Order in accordance with Section 104(e) (7) of
CERCLA, 42 U.S.C. S9604(e) (7), and pursuant to 40 CFR S2.203(b).
7S. Information determined to be confidential by U.S. EPA
will be afforded the protection specified in 40 CFR Part 2, Subpart
B. If no such claim accompanies the information when it is
submitted to the U.S. EPA, the public may be given access to such
information without further notice to Respondents.
76. Information acquired or generated by Respondents in
performance of the Work that is subject to the provisions of
Section 104(e) (7) (F) of CERCLA, 42 U.S.C. 99604(e) (7) (F), shall not
be claimed as confidential by Respondents.
xv.
. PENALTIES FOR NONCOMPLIANCE
77. Respondents are advised, pursuant to Section 106(b) of
CERCLA, 42 U.S.C. S9606(b), that willful violation of, or failure
or refusal to comply with this order, or any portion thereof, may
subject the Respondents to a civil penalty of not more than $25,000
for each day in which such violation occurs or such failure to
comply continues.
Failure to comply with this Administrative
Order, or any portion thereof, without sufficient cause may also
'....J subject Respondents to liability for punitive damages in an amount
43
equal to three times the amount of any costs incurred by the
Hazardous Substance Superfund as a result of Respondents' failure
to take proper action, pursuant to section 107(c) (3) of CERCLA, 42
U.S.C. 59607 (c) (3).
XVI.
OTHER CLAIMS
78. The United States, by issuance of this Order or by the
RPM/OSC I S exercise of his/her legal. authorities pursuant to the
NCP, assumes no liability for any injuries or damages to persons or
property resulting from acts or omissions by Respondents or the
United States, their directors, officers, employees, agents,
representatives, successors, assigns, contractors, or consultants
in carrying out any action or activity pursuant to this Order.
79. U.S. EPA is not to be construed a party to, and does not
assume any liability for, any contract entered into by Respondents
in carrying out the activities pursuant to this Administrative
-Order. The proper completion of the Work under this Administrative
.....
Order'~s solely the. responsibility of the Respondents. This Order
does not constitute any decision on preauthorization of funds under
CERCLA.
XVII .
DELAY IN PERFORMANCE
80. Any delay in performance of this Order that, in u.S.
EPA's judgement, is not properly justified by Respondents under the
terms of this section shall be considered a violation of this
Order. Any delay in performance of this Order shall not affect
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44
Respondent I s obligations to fully perform all obligations under the
terms and conditions of this Order.
81. Respondents shall notify U.S. EPA of any delay or
anticipated delay in perfor1lling any requirement of this Order. Such
notification shall be made by telephone to U.S. EPA's RPM or
Alternate RPM within forty-eight (48) hours after Respondents first
knew or should have known that a delay may occur. Respondents shall
adopt all reasonable measures to avoid or minimize such a delay.
within five (5) business after notifying U.S. EPA by telephone,
Respondents shall provide written notification fully describing the
nature of the delay, any justification for the delay, any reason
why the Respondents should not be held strictly accountable for
failing to comply with any relevant requirements of the Order, the
measures planned and taken to minimize the delay and a schedule for
implementing the measures that will be taken to mitigate the effect
of the delay. Increased costs, access problems or expenses
associated with implementation of the activities called for in this
Order is not a justification for any delay in perfor1llance.
XVIII.
NOTICES
82. Whenever, under the ter1lls of this Administrative Order,
notice is required to be given, or a report or other document is
required to be forwarded by one party to another, such
correspondence shall be directed to the following individuals at
the addresses specified below:
'\
'-)
45
As to the United states or U.S. EPA:
A. stuart Hersh
Assistant Regional
Counsel
Attn: Waste Disposal Engineering
(5CS-TUB-3 )
U.s. Environmental Protection
Agency
230 South Dearborn Street
Chicago, Illinois 60604
B. Fred Bartman
Remedial Project Manager
Waste Disposal Engineering
Facility
Remedial and Enforcement
Response Branch 5HS-11
U.s. Environmental Protection
Agency
230 South Dearborn Street
chicago, Illinois 60604
XIX.
As
to the
state of
Minnesota:
Minnesota Pollution
Control Agency
Attn: Waste Disposal
Engineering
site Project
Leader
520 Lafayette Road
St. Paul, MN 55155
Minnesota Pollution
Control Agency
Attn: Supervisor
Site Response Section
520 Lafayette Road
st. Paul, MN 55155
CONSISTENCY WITH
NATIONAL CONTINGENCY PLAN
83. The U. S.. EPA has determined that the Work, if properly
. -
performed as set forth in Section V hereof, is consistent with the
, .
provisions of the National Contingency Plan pursuant to 42 U.S.C.
~9605.
xx.
RESPONSE AUTHORITY
84. Nothing in this Administrative Order shall be deemed to
limit the response authority of the United States under 42 U.S.C.
~9604.
46
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XXI.
ENFORCEMENT AND RESERVATIONS
8S. U.S" EPA reserves the right to bring an action against
Respondents under section 107 of CERCLA, 42 U.S.C. S 9607, for
recovery of any response costs incurred by the united States
related to the WDE Facility. This reservation shall include but
not be limited to past costs, direct costs, indirect costs, the
costs of oversight, and the costs of compiling the cost
documentation to support oversight cost demands, as well as accrued
interest as provided in section 107(a) of CERCLA.
86. Notwithstanding any other provision of this Order, at any
time during the response action, u.s. EPA may perform its oW'n
studies, complete the response action (or any portion of the
response action) as provided in CERCLA and the NCP, and seek
reimbursement from Respondents for its costs, or seek any other
appropriate relief.
87. Neither the RAP nor the RD/RA Work Plan constitute a
warranty or repres~ntation of any kind by the United States that
the RAP or RD/RA Work Plan will achieve the performance objectives
set forth in the ROD, the approved RAFD Report and this Order.
u.s. EPA reserves all rights and defenses that it may have pursuant
to any available legal authority. In addition, nothing in this
Order shall preclude u.s. EPA from taking any additional
enforcement actions, including additional activities under this
Order, modification of this Order, or issuance of additional
\ Orders, and/or additional remedial or removal actions as u.s. EPA
'--..)
47
may deem necessary, or from requiring Respondent(s) in the future
to perform additional activities pursuant to CERCLA, 42 U.S.C. ;
9606(a) , or any other applicable law.
88. Notwithstanding any provision of this order, the United
States hereby retains all of its information gathering, inspection
and enforcement authorities and rights under CERCLA, RCRA and any
other applicable statutes or regulations.
89. Nothing herein is intended to release, discharge, or in
any way affect any claims, causes of action or demands in law or
equity which U.S. EPA may have against any person, firm,
partnership or corporation for any liability it may have arising
out of, or relating in any way to, the generation, storage,
treatment, handling, transportation, or disposal of any hazardous
substance, hazardous wastes, contaminants, or pollutants at, to, or
from the WDE site. U.S. EPA expressly reserves all rights, claims,
demands, and causes of action it has against any and all persons
and entities.
90. Nothing herein shall be construed to release the
Respondents from any liability for failure of the Respondents to
perform the work required hereunder in accordance with this Order
and/or approved Work Plans. In addition, nothing in this Order
shall be construed to prevent U. S. EPA from seeking legal or
equitable relief to enforce the terms of this Order, or from taking
the legal or equitable action it deems appropriate and necessary.
This Order and the successful completion of the Work required
hereunder do not represent satisfaction, waiver, release, or
48
.~) covenant not to sue, of any claim of the United States against the
Respondents relating to the WOE site (including claims to require
Respondents to undertake further response actions and claims to
seek reimbursement of responses costs pursuant to section 107 of
CERCLA) .
91. If a court of appropriate jurisdiction issues an order
that invalidates any provision of this Order or finds that a
Respondent has sufficient cause not to comply with one or more
provisions of this order, the Respondent shall remain bound to
comply with all provisions of this Order not invalidated by the
-
court's order.
------
XXII.
MODIFICATION AND MODIFICATIONS TO WORK
92. Except as provided for herein, there shall be no
modification of this Administrative Order without written approval
of U.S. EPA.
93. U.S. EPA may determine that modifications to the Work
identified in this Order and attachments to this Order, may be
necessary to achieve the response objectives in the ROD and
pursuant thereto in the approved RAFD Report, the RAP, or this
Order. If U.S. EPA determines that modifications to the Work are
necessary, U.S. EPA may require Respondents to submit a work plan
for additional response activities.
u. s. EPA may also require
.')
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Respondents to modify any plan, design, or other deliverable
required by this Order, including any approved modifications to
this Order.
49
94. Not later than thirty (30) days after receiving U.S.
EPA's notice that additional response activities are required
pursuant to this Section, Respondents shall submit a Supplemental
Work Plan for the response activities to U.S. EPA for review and
approval. The review and approval process shall be identical to
the process set forth herein at Section VIII.
9S. Upon approval by U.S. EPA, the (Amended) Supplemental
Work Plan shall be implemented by Respondents according to the
standards, specifications, and schedules therein. Respondents
shall notify U.S. EPA of their unequivocal intent to perform such
additional activities within seven (7) calendar days after receipt
of U.S. EPA's request for additional response activities. If a
conference is requested by one or more Respondents pursuant to
section XXVI, this Order shall be effective on the fourteenth (14)
calendar day following the day of the conference, unless such
effective date is modified by the U.S. EPA Region V, Waste
Management Division Director. No extensions to the above time
frames shall be granted without sufficient cause. All extensions
must be requested, in writing, and shall not be deemed accepted
unless approved, in writing, by U.S. EPA.
XXIII.
EFFECTIVE DATES
96. This Administrative Order shall be effective twenty-one
days (21) calendar days following service of the Order as provided
herein. If a conference is requested by one or more Respondents
pursuant to Section XXVI, this Order shall be effective on the
so
~) fourteenth (14) calendar day of the conference, unless such
effective date is modified by U.S. EPA, Region V, Waste Management
Division Director. No extensions to the above time frames shall be
granted without sufficient cause. All extensions must be requested
in writing, and shall not deemed accepted unless approved, in
writing by U.S. EPA.
XXIV.
CERTIFICATION OF COMPLETION OF REMEDIAL CONSTRUCTION
97. When the Respondents determine that they have completed
the construction activities of the Work, they shall submit to U.S.
EPA and MPCA a Notification of Completion of construction. Upon
receipt of such Notification, U.S. EPA shall schedule final
inspections and close out activities as described in the June 1986
U. S. EPA Superfund Remedial Design and Remedial Action (RD/RA)
Guidance.
Such activities shall include, at a minimum, the
fol.lowing:
A) "Prefinal Construction conference" by U.S. EPA and the
Respondents:
B) "Prefinal Inspection" by U.S. EPA:
C) Preparation of a "PrefinaL Inspection Report" by the
Respondents:
D) "Final Inspection" by U.S. EPA and the Respondents.
98. The final remedial construction report shall summarize
the Work performed and any modification to the RO/RA Work Plan.
The
summary shall
include or reference any supporting
'\
,....J
documentation.
Sl
99. Upon receipt of the final remedial construction report,
U. S. EPA shall review the accompanying report and any other
supporting documentation and conduct any appropriate site
inspection.
U.S. EPA, in consultation with MPCA shall issue a
certification of Completion of Remedial Construction upon its
determination that the Respondents have satisfactorily completed
the construction activities required by this Order.
Following
certification, Respondents shall continue to perform all work
required by this Order, including but not limited to:
A. Operation and Maintenance of the Remedial Action pursuant
to the approved RD/RA Work Plan.
B. Monitoring and reporting pursuant to the RD/RA Work Plan
and this Order.
C. Any additional Work requested by U.S. EPA pursuant to
this Order.
D. Retention of documents pursuant to this Order.
xxv.
ACCESS TO ADMINISTRATIVE RECORD
.
100. The Section 106 Administrative Record supporting the
above Findings of Fact, Conclusions of Law and Determinations is
available for review on weekdays between the hours 8:00 a.m. and
S:oo p.m., at the United States Environmental Protection Agency,
Region V, 230 South Dearborn street, Chicago, Illinois 60604.
Please contact Mr. Fred Bartman, Remedial Project Manager, at (312)
353-6083, for review of the Administrative Record.
/
.~
~J
S2
XXVI.
OPPORTUNITY TO CONfER
101. within seven (7) calendar days after receipt of this
Administrative Order, Respondents may request a conference with
U.S. EPA to discuss this Administrative order. If Respondents
desire such a conference, please contact Mr. stuart Hersh,
Assistant Regional Counsel, (312) 886-6235.
102. Any such conference shall be held within seven (7)
calendar days from the date of request or such other time approved
by U.S. EPA. At any conference held pursuant to Respondents I
request, Respondents may appear in person and/or by an attorney or
other representative.
103. Any comments which Respondents may have regarding this
Administrative Order, the correctness of any factual determinations
upon which the Order is based, the appropriateness of any action
which Respondents are ordered to undertake, or any other relevant
and material issue must be reduced to writing and submitted to U. s.
EPA within seven (7) calendar days following the conference or if
no conference is held, within seven (7) calendar days following the
service of this order. Any such writing should be directed to
stuart Hersh, at the address cited above.
104. You are hereby placed on notice that U.S. EPA will take
any action which may be necessary in the opinion of U.S EPA for the
protection of public health and welfare and the environment; and
Respondents may be liable under section 107 (a) of CERCLA, 42 U.S. C.
;9607(a), for the costs of those Government actions.
IT IS SO ORDERED:
S3
BY: 1tl{F #'~ (CR./..:)
David A. Ulln "7
Director
Waste Management Division
U.S. EPA, Region V
~UG ~ 3 1!391
Effective Date:
/
..---j -
ConsulUng Engineers
CONESTOGA-ROVERS & ASSOCIATES LIMITED
651 Colby Drive,
Waterloo. Ontario, Canada N2V 1 C2
(519) 884-0510
eRA
'\
'..J
June 19, 1990
Reference No. 1472-90
The Honourable James E. Elling
Mayor of Andover
1685 Crosstown Boulevard NW
Andover, Minnesota
55303
Dear Mayor Elling:
Re: Sanitary Sewer Discharge
Remedial Action
WDE Sanitary Landfill
Andover, Minnesota
On behalf of the SW28 Group for the WDE Sanitary Landfill (SW-28 Group),
Conestoga-Rovers & Associates (CRA) is requesting sewer availability and
connection approval. The WOE Site is located south of Coon Creek between
Hanson Boulevard and Cross Town Boulevard. In 1983 the Site was designated a
federal. Superfund Site by the United States Environmental Protection Agency
(USEP A). Assuming successful negotiation of a Consent Decree to construct the
remedy, it is anticipated that a temporary connection on CrossTown Boulev<lrd will
be required to permit testing and interim operation during construction. If testing
indicates that a permament connection is required, it will be proposed to connect to
the sanitary sewer on Bunker Lake Boulevard.
The proposed remedy for the Site includes a groundwater extraction and treahr.ent
system. Groundwater must be pumped for up to 180 days to pennit detailed analysis
of the water quality over time for detailed lIeatment design calculations. Durin;
this period of pumping it is proposed that the discharge be directed to the sanitary
sewer. MPCA has also requested that efforts be made to maintain pumping while
treatment facility is constructed. This would require discharge to the sanitary sewer
for a longer period of time. /
/
If the extracted water can be practically treated to a sufficiently high standard of
quality to permit-freated water di~charge to Coon Creek, pem1anent use of the
sanitary sewer may not be required. However, as treatability has not been
determL."1ed, it would be appropriate to consider this request to be for perm:ment
access to the sanitary sewer. .
~~
CONESTOGA.ROVERS & ASSOCIATES LIMITED
Consulting Engineers
\
,-.J
June 19, 1990
Reference No. 1472-30
'- 2-
The Response Action Final Design report indicated that a total flow of 60 to
100 gallons per minute was expected. The final flow rate must be determined after
the installation and testing of the extraction wells. Consequently, at this point, it
would be prudent to consider the higher estimate of 100 gallons per minute as the
requested flow rate but it should be acknowledged that this is not a final
determination of flow.
We understand that the City of Andover will be presenting this request to
Metropolitan Council and Metropolitan Waste Control Commission. If appropriate,
we are available for any support that may be required such as visual aids,
calculations or attendance at meetings.
We appreciate the City's attention to this matter and look forward to further
discussion at our next meeting. In the mean time, if you should have any
questions, please do not hesitate to contact Jon Christofferson at our St. Paul office at
(612) 639-0913.
Yours truly,
CONESTOGA-ROVERS & ASSOCIATES
a ~ /( OV#\.ClM..
Alan W. Van Norman, P. Eng.
AVN/jdh
Encl.
,
.. )
c.c.: Margaret Coughlin - Dickinson, Wright
William Kepple - Dorsey & Whitney
Shell Bleiweiss - McDermott.....Will & Emery
Thaddeus Lightfoot - Weil, Gotshal & Manges
Maclay Hyd~ - Gray, Plant, Mooty, Mooty & Bennett
Dan McDonald - Unisys'Corporation
Richard Marchek - U nisys Corporatio-n
Norwood Nelson - Onan Corporation
William Seeley - Bastlund, Sols tad & Hutchinson, Ltd.
Tom Dailey, c/o Dick Nowlin - Doherty, Rumble & Butler
Karen Hansen - Popham, Haik
Jon Christofferson - CRA
~
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NOTE
Due to the size and the limited number of copies of the Response
Action Final Design document, the document will not be included in
the report. However, a copy will be available for review in the
Planning Department at the Andover City Hall.
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CONESTOGA.ROVERS & ASSOCIATES LIMITED
651 Colby Drive
WaterlOO. Ontario. Canada N2V 1C2
(519) 884-0510
Consulting Engineers
October 7, 1991
Reference No. 1472-90
Ms. Van-Anh Thai Tang
ME1ROPOLITAN WASTE CONTROL COMMISSION
Mears Park Center
230 East Fifth Street
St.Paul,Milxnesota 55101
Dear Ms. Thai Tang:
RE: WDE Sanitary Landfill
Access to Sanitary Sewer
We wish to thank the Metropolitan Council and the MWCC staff members present for
our meeting of September 30,1991. The meeting went a long way towards clarification
of the issues invo[ved in the Comprehensive Plan Amendment to the City of Andover's
Municipal Urban Service Area (MUSA). This letter provides the additional information
requested at the meeting such that your commission and the Metro Council can provide
a letter stating your posItion on this matter.
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Background / Overview
The Waste Disposal Engineering Inc. (WOE) Sanitary Landfill (Site) is located within
the city limits of Andover (formerly Grow Township) in Anoka County, Minnesota.
The Site location is presented on Figure 1.1. A Site plan is presented on Figure 1.2-
Operations at the Site were permitted to include land filling of general municipal and
commercial waste and hazardous waste disposal within a separately constructed area.
Site operations were regulated by Minnesota Pollution Control Agency CtvfPCA) Solid
Waste Disposal Permit'SW-28. Operations at the Site ceased in 1984.
The Site was listed asa "Superfund Site" under the Comprehensive Environmental
Response, Compensation and Liability Act (CERCLA) in September 1983. In March
1984, a group of potentially responsible parties (PRP) identified as the SW-28 Group
signed a Consent Order Wlth United States Environmental Protection Agency (U.s.
EP A) and :MPCA. A Remedial Investigation/Feasibility Study (RIfFS) has been
completed under the Consent Order.
On December 31, 1987 U.S. EP A and :MFCA published a Record of Decision (ROD) for
the Site. The ROD was received by the SW-28 Group on January 22,1988. The Consent
Order required that the SW28 Group prepare a Response Action Final Design (RAFO).
U.S. EP A and MPCA approval of the RAFD was the final task defined in the Consent
Order. The RAFO was submitted June 1988 and has since been approved. This
concluded the responsibilities of the SW-28 Group under the Consent Order.
On August 30, 1991, the U.S. EP A issued an Administrative "106 Order" to a selected
group of PRPs. This group is our current client for the Site. Subsequent to the "106
Order", our client has been notified by U.S. EP A that we must demonstrate that, at a
minimum, temporary sewer system and public owned treatment works (POTW) access
will be obtainable from local control authorities. This demonstration must be provided
CONESTOGA.ROVERS & ASSOCIATES LIMITED
Consulting Engineers
o
Reference No. 1472-90
Page 2
within our Remedial Design/Remedial Action (RD/RA) Work Plan which is required
by the 106 Order to be submitted on October II, 1991. Representatives of the City of
Andover were present at our September 30 meeting to state their support of the
necessary MUSA Comprehensive Plan Amendment.
Quantity and Quality of Water to be Discharged
Concept
The WDE Site remedy includes a groundwater pump and treat component.
Groundwater will be captured in eight or more groundwater extraction wells installed
between the area of waste disposal and Coon Creek as illustrated on the enclosed
figure. It is expected that extracted groundwater will be treated and discharged to
Coon Creek. Both the mechanical and treatment designs require that the extraction
wells be test pumped to determine equilibrium flow rates and raw water quality.
During testing, groundwater cannot oe discharged to the creek. Consequently, access
to the sanitary sewer is requested in accordance with conditions outlined in the balance
of this letter.
PumTJin~ Test
Test pwnping will be conducted in two separate phases. In Phase I, each well will be
tested individually for up to 48 hours. After the extraction well is installed and
developed, e~ch well will be test~d for one-half increments at approxi~ately.l /3,2/3
and 3/3's of Its expected productlOn rate. One-half hour recovery penods will be
included between each increase in pumping. This test will permit evaluation of
individual well yield and selection of pumping rate that can be maintained for 48 hours.
An aquifer test at the selected pumping rate Wlll then be p'erformed. for up to 48 hours.
Shorter test periods may be considered if hydraulic equilibrium is demonstrated. At
the end of t.ne test, water quality samples will be collected to assess water quality from
the extraction well..
Water quality expected during each Phase I pumping test can be estimated by
reviewing water quality data for monitoring wells Wlthin the expected zone of capture
for each extraction welL Expected water quality is presented as Table 1. Metals are not
expected to be present at high concentrations in any of the extraction well tests.
Comments on organic chemical concentrations in each extraction well follow:
EWl - gxpected flow rate 8 to 10 gpm.
Planned. location is on edge of flow passing beneath landfill, as a result, water
will contain relatively low concentrations of organic chemicals.
EW2 - ~ected. flow rate 8 to 10 gpm.
.~ Low concentrations of organic chemicals expected.
EW3 - Previously tested
CONESTOGA.ROVERS & ASSOCIATES LIMITED
Consulting Engineers
\
'--)
Reference No. 1472-90
Page 3
EW4 - Expected flow rate 8 to 10 gpm.
High concentrations of organic chemicals expected.
- Measured concentrations not expected to be as high as predicted concentrations
due to integrating effect of pumping flow groundwater.
Expected rate 8 to 10 gpm.
Expect low concentrations of organic chemicals, probably higher than predicted
value but below MWCC guidelines.
Expected pumping rate 8 to 10 gpm.
High concentrations of organic Chemicals predicted.
Measured results not expected to be as high as predicted due to integrating
effect of pumping on groundwater.
Expected flow rate 8 to 10 gpm.
Relatively low concentrations of organic chemicals predicted, expect to be
below MWCC guidelines.
EW8 - Expected flow rate 8 to 10 grm.
No organic chemicals predicted.
- Expect low concentratlOns after pumping.
EW6-
EW5-
EW7-
EW9 - Expected flow rate 0 to 5 gpm.
High concentrations of organic chemicals predicted.
- This well will not be discharged directly to the sanitary sewer.
Phase II
Phase II test pumping will consist of combined fumping of all extraction wells at their
res:eective design flow rates. TIlls pumping wi! occur for an extended period of time
while treatability studies are conducted on the combined extraction weIlflow. U.S.
EP A has ordered that the pumping be maintained continuously while the treatment
process is designed and constructed. As a result, under this strategy, pumping will be
required for 180 to 360 days.
. -
:~
Discharge water quality for Phase II testing will be predicted from the results of Phase I
testing. It is expected that Phase II water qualitY. will meet MWCC discharge criteria as
most of the volume of groundwater pumped WIll be from extraction wells with
relatively low concentrations of organic chemicals.
A monitoring program acceptable to MWCC will be implemented during the design
and construction period when water will be discharged to the sanit~ sewer. Monthly
monitoring of the discharge to the sanitary sewer for VOC and BNA 15 proposed
initially.
. "-
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.~~
CONESTOGA.ROVERS & ASSOCIATES LIMITED
Consulting Engineers
Reference No. 1472-90
Page 4
We trust this letter provides the information you require to resfond favorably to the
request for temporary discharge to the sanitary sewer. We wil need your response no
later than Octooer 10 for it to be submitted with our report on October 11, 1991. Should
you have any questions, please do not hesitate to contact Margaret Coughlin at
telephone number (313) 223-3738 or me at telephone number (612) 639-0913.
Sincerely,
CONESTOGA-ROVERS AND ASSOCIATES
'5i~L,~~
C~ l~.' Christofferson
~
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cc: Richard Thompson; Metro Council
Leo Hermes; MWCC
Mayor Ken OrtIel; City of Andover
James Schantz; City at Andover
Colleen Hermann; Anoka County
Margaret Coughlin; Dickenson, Wright
Alan Van Norman; CRA
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RECORD Ot DECISfON
REMEDI~L ALTERNATIVE SELECTION
Site: Waste Disposal Engineering, Andover, Minnesota
Doc~ents Reviewed
.
The following documents, which describe' the physical characteristics of the
Waste Disposal Engineering Site and which analyze the cost-effectiveness of
various r'e'!!edial altematives, have been r"ev;ewed by the United States En-
vi romental Protection Agency.(U.S. EPA) and. fonn the basis for this ~ecord
of Decision (ROD):
MOdified Appendix B, Remedial Investigation, Conestoga - Rove~ &
Associates Limited (CRA), January 30, 1986.
OA/OC Data Assessment, CRA, tebruary 1, 1986.
OA/OC Data Assessment, Volume 11 Appendices, CRA, tebl"'.l4ry 1, 1986.
Addendun to Modified Appendix B, CRA, February 28, 1986.
Remedial Investigation, CRA, March 31, 1986.
Supplementary Monitoring Report, CRA, Jul)' 25, 1986.
Pit Investigation, Sl.JlIIIary Reporf, CRA, August 7, 1986.
Suppl ementa.l Remed 111 Investigat ion Report, CRA, September 22, 1986.
Alternatives Report, CRA, April 18, 1986.
Deta.l1ed Anal)'sis Report, CRA, October 9, 1986.
Detailed Anal)'sis Report Appendices, CRA, October 9, 1986.
Response of SW28 Group to U.S. EPA Letter Dated May 28, 1987, CRA,
July 9, 1987. .
Public cOtl'lllents received during the 21-day conment period, and the
Responsiveness Sl.JlIIIar)'.
S~ary of Remedial Alternatives Selection.
I have al so considered other docUllents which are included in the attached
index to the administrative record.
(
~-
Desc riotion of Remedy
The selected renedial altemative for the Wast! Disposal Engineering Site is
to cover the landfill with a vented cap, to contain contaminated ground water
discharges from the landfill through downgradientground water extraction
wells, to contain an area within th.e landfill which.J"Iceived hazardous waste
(hereinafter referred to as the -Pit-) with a slurry wall and extraction
well system, to avoid usage of conti!llinated groundwater and reversal of the
upward gradient between the lower and uppel"'S sand aquifel"'S through institutional
controls to lim~t wells on and near the site. to fill-in and replace a wetland
aru affected by the site, to treat and dispose of extracted ground water,
which is expected to be accomplished by cal"tlon adsorption and discharge to
Coon Creelt, and to monitor the site. The selected altematlve includes the
following major ccmponents.
Lime sludge cap meeting Resour-:e Conservation and Recovery Act (~Ci\A)
technical perfonnance standards.
Ground water extraction wells in the-upper sand aquifer between
Coon Creek and the landfill.
Cl ay sl urry wall around the Pit with pumping inside the wall.
Institutional controls to prohibit uopel"'S sand aquifer wells at the
site and just north of Coon Creelt and to prohibit lower sand aquifer
well s near the 1 andfill.
Cal"tlon adsorption trutment of extracted ground water (ai r stripping
or a comoination is possible based on design.
Discharge of treate~ extracted ground water to Coon Creek.
Monitoring, including geophysical WOM: around the site to locate
heavier-than-water non-aqueous. phase liquid monitoring, to assure
the effectiveness of th. remedy.
Consistent with the Comprehensive' Environmental Response, Compensation and
Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and National Oil and Hazardous Substances
Pollution Contingency Plan P<<:P), 40 C.F.R Part 300, I have detennined that,
at the Waste Dispoul Engineering Site,. the seleete<1 T"tllledial altemative
is cost-effective, provides adequate protection of public health, wel fan!,
and the envi ronment, .and utl1 izes treatment to the maximun extent practicable.
The action will requi re operation and maintenance activities to ensure continued
efhctiveness of the remedial altemative as ~11 as to ensure that the perfor-
mance Objectives meet appl icable State and Federal surfaee and groundwater
c rit eri a .
/ )
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I have determined that the action being ta~en is consistent with Sec~ion
121 of SA~A. The State of Minnesota has been consulted and is expec~ed ~o
concul' with the selected r-emedy.
In accordance with Section 121 (cl of SA~A. the I"e'nedial action at the
Waste Oisposal Engineel'ing Site shal' be I'eviewed no less often than evel'y five
yeal'S after' initiation of suCh r"e'lledial action to assu~ that human health
and the envi rorrnent al'! being protected by the r-emedial action being
impl emented.
~;f~. av'1'rUf~
.i:v--L Valdas V. Ada:n~us if
U Regional Administl'atol'
I ').. - 3 1- 8' 9-
Date
Attachments: (1) Su::maI'Y of ~emedial Altemative Selection
f (2) Responsiveness S~aI'Y
(3) ....OE Administl'ative Record Index
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Sit;! SUlTTTlary of Renedial Altemative Selection
Waste Disposal Engineering Site
Andover, Minnesota
1. Site Location and Description:
The WOE Site is located within the City of Andover (fonnerly Grow
Township), Anoka County, Minnesota (see Attachments I, Z), approx-
imately 15 miles north of the City of Minneapolis. It is situated on
the south side of Coon Creek, which discharges into the Mississippi
River 11 river miles downstream froom the Site. The discharge into the
Mississippi River is approximately 3 miles up.stream of the intake for
the St. Paul water supply and 7 miles upstream of the intake for the
Minneapol is water supply. .
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The WOE Site is situated within the Anoka Sand Plain. The topography
is gently roll ing to flat, with shallow water tabl es (1 ess than 20
feet) and numerous wetlands. The area surrounding the WOE Landfill
historically was COTlprised of small farms and small r-esidential de-
velopments. Ilm1ediately south of the Site are- a series of scrapyards.
During the past year, more extensive residential development has been
or will be constructed and planned for around the Site. The Site is
bounded on the north by Coon Creek, with flows in a west-northwesterl y
direction at this location. To the west, the Site is bounded by Anoka
County Road 18 (Crosstown Boulevard), (ann land, and a residential
development (Red Oaks Manor). The southem boundary of the Site
consists of'woodlandS and coomercial developments (mostly scrapyards)
along Anoka County Road 16 (Bunker Lake Boulevard). Hanson Boulevard
borders the eastem edge of the WOE Site. Along the eastern edge of
the Site are two overlapping easl!'l1ents, United Power Association (45
feet wide) and Northern States Power COTlpany (ISO feet wide).
The original dl.lllp was established in 1963 by a Mr. Leonard Johnson.
Disposal of waste.s was by burial or.buming in pits or trenches. WOE
purchased the facility in 1968 and. was licensed by Grow Township to
operate as a sanitary landfill. In 1970, WOE submitted a sol idwaste
permit appl ication to the MPCA,including a proposal to build a
sp~ially constNCted pit fot" disposal of hazardous waste. The permit
(SW-ZS) was issued on March 3D, 1971 to operate th~ WOE Site as a
sanitary landfill. The Site operating pennit was revoked by the
MPCA in FebnJary, 1984.
The hazardous waste pit received hazardous wastes from /tlvl!'l1ber, 1972
to January, 1974. The base of the pit was spec.ified to be an IS-inch
layer of clay overlain by a six-inch bituminous layer and six inches
of crushed 1 imestone. Approximately 6,600 containers (ranging froom 1
gallon pails to 55 gallon drums) holding a wide variety of wastes
(acids, caustics, waste .paints, spent solvents, plating sludges,
cyanides) are thought to have been disposed in the pit. An unde-
termined quantity of hazardous waste, much of it as bun loads, was
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disposed throughout the landfill. Based on interviews and government
files. approximately 3.2 million gallons of hazardous waste are thought
to have been disposed at the WOE Site. Using these estimates. only 10
pen:ent of the waste expected to be at the Site would have been
disposed in the pit.
The area of actual refuse disposal in the landfill covers an area of 73
acres (see AttacMlent 3). The maxim\Sll thicKness of waste is 40 feet.
The landfill contains nearly 2.5 million cubic yards of waste. Much of
the landfill is covered by lime sludge obtained from the Minneapolis
DrinKing Water Treatment Plant. The 1 ime sl udge consists of very fine
particles of lime that yields I clay-liKe substance. The sludge
thidness ranges from three to six feet (average of four feet).
Additional lime sludge is stockpiled on ten acres immediately southeast
of the area of I"'l!fuse di sposal.
The WOE facility ceased operations in February. 1984 and has ~ained
abandoned and inactive. The property of the Site has gone through tax
forfeiture so that it is currently property of the State of Minnesota
with administration by Anoka County.
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II. Site History:
Prior' to development of the WOE Site in the early 1960's. land use con-
sisted of cropland and pasture1and. and open deciduous woodland with
scattered wetland pockets. The area consisted of a glacial outwash
plain characterized by low relief, poor extemal drainage. and fine,
sandy soil. Also located at the Site wel"'l! two related drainage
channels. One of these channels was eventually buried'by the landfill
whll e the othe r was abandoned when Coon C reel: was st ra ig htened. In
addition, by 1964, three field ditches had been constructed on the
northeast portion of the pl"'l!sent landfill. These ditches. which are
partially burfed, drafn to the north and enpty into Coon Creek.
As indicated earlier, the landfill (d\Sllp) was established fn the early
1960' s by Leo'nard E. Johnson. By 1964, the dll1lp covel"'l!d only three
acres. In 1970, the land fi 11 had expanded to cove r 41 acres, and by
1982 to its present-day s.ize of 114 acres. The d\Sllp was pun:hased by
WOE in 1968. In 1971, construction of the WOE Pit began. The Pit was
completed in 1972 and was operated until Janua~, 1974. The landfill
operated until 1984.
III. Results of the Remedial Investigation:
A. Investigations
Investigations at the Waste Disposal Engineering (WOE) Site
included the following:
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1. Review and evaluation of historical disposal practices and
other ~cor-ds ~lating to tne Site.
2. Extensive aQuifer sarnpl ing and water level measurements to
determine ground water Quality, flow di~ctions. etc.
3. Soil sampling in the northeast portion of the Site to define
soil contamination in the a~ of historic drainage ditches.
4. Coon C~ek sampl ing to define the Site's impacts on the cree~.
S. Soil borings to d~fine the geology at the Site.
6. Lime sludge testing to define whether or not it could be
conside~d as a conponent of the landfill cap.
7. Landfill gas meaSUr?llents to define gas level s within the
landi 11 .
B. _Geology
The WOE Site is situated within the Ano~a Sand Plain. The surficial
deposits were glacial meltwate.. deposits (forming outwash plains
associated lo/ith Grantsbu~ Sublobe later reworKed by tl'le Mississippi
River). These deposits are fine to medium sand. have ~latively hign
permeabilities. and are 40 to 73 feet thick at the landfill. The
outwash plain is relatively flat, and laCKS good drainage. Nume~us
small laltes 'and wetlandS ~flect high lo/ater table conditio"s. ~any
streams in the area. including Coon Creek. have been channelized to
lower inverts and improve drainage. Several drainage ditcnes were
p~sent in the Northeast quarter of the Site prior to the landfill in;.
The~ is a thin. gray silt till unit (0 to 15 feet thiclt) within the
Upper Sand Unit. This silt till is present in most deeper borings at
tl'le Site at depths around 30 to 40 feet. foiOwever. its continuity is
uncertain. because its presence is not indicated in sone drilling logs,
and it is not ne1ied upon as an effective confining unit.
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aelow the Upper Sand is a red-bro-" clay-silt till It is a
relatively dense till. has low permeabilities C10-~ to 10-6 centimete~
per second (cm/sec)], and serves as an aquitard for the underlying
lo~r sand. The till thickness ranges from 10 to 40 feet thick and
bec~ing progressively thinner from north to south across the Site.
The surface of the till unit is highest-immediately below the Pit area
of the landfill, and slopes dOlo'l'llo/ard concentrically from the peak (see
Attachment 4). The steepest slope is to the, northlo/est and west.
Underlying the red-bro-" till is the LOWl!r Sand. This outwash wllS
deposited by the Superior advance and retreat and consists of rela-
tively coarse sand and gravel. It becones finer and more silty with
depth. The thickness of this unit is on the order of 80 feet thick.
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C. Ground WatH
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The Upper Sand aquifer is under water table conditions (unconfined).
Ground water flow in the lIppeI' Sand at the Site is pronounced t~ tt'le
north discharging into Coon Creel: (see Attac~ent 5). Coon C~el:
serves as the regional discharge for the Upper Sand aquifer. At the
Site, the water table contours parallel Coon Creel:. Ground water
elevations are generally in the range of 867 feet near the Creel: to 38~
feet south of the landf111. Ground water flow rates in the Upper Sand
are on the order of 25 to 30 feet per year.
ne Lower Sand aquifer is under confined conditions and is artesian
under the WOE Site. In fact. in the vicinity of Coon Creek. flowing
artesian conditions exist (i .e.. monitoring well 2611). Ground .ater
flow in the Lower Sand aquifer in the region is to the southwest.
ultimately discharging into the Mississippi River, approximately 4
mi,les do"'"'gradient of the WOE Site. At the WOE Site, ground .ater f10..
aopears to be more towards the west'-northwest because of the rUdin;s
fro'll one particular monitoring well. Without this one well. gr~und
water flow patterns would be enti rely consistent with the regional
pattern. Piezometric levels in the Lower Sand aquifer are general1y in
the rarfge of 876 to 878 feet at the Site.
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The Lower Sand aquifer is used extensively for domestic water su:ply,
particularly southwest'(and do",",gradient) of the Site. The Upper Sand
aquifer is used by some residents having sand points. particul arly
north of Coon Creel:. One issue of primary concem has been t!'le
relative vertical piezometric gradients within the Upper Sand a:;uifer
and between the Upper Sand aquifer and Lower Sand aquifer across the
red-brown till confining unit. This is particularly critical since the
gradients and flow directions are roughly opposite between the Upper
Sand aquifer and Lower Sand aquifer.
In general, there is a downward component of flow within the Upper
Sand at the WOE Site. except as one approaches Coon Creek where the
gradient switches to produce an upward flow.
The vertle:al gradient across the red-brown till unit between the Lower
Sand and Upper Sand aquifers is upward under the limits of refuse di s-
posal and the area between the refuse and Coon Creek. The vertical
gradient across the red-brown till unit bet~en the Lower Sand and
Upper Sand aquifers is downward irmlediately south of the limits of
refuse- disposal. The gradient is e:onsistently downward at monitnring
well nest 1 and is variable (downwards and upwards) at monitoring well
nest 23 (see Attachment 6).
The lateral ground water gradient in the Upper Sand aquifer is approx-
imately 0.005. With a hydraulic e:onductivity of 1.6 x 10-3 en/see: and
an ass\Illed porosity of 0.3. the average 1 ateral g round water movement
in the Upper Sand is approximately 27 feet per year. The vertical
ground water gradient across the red-brown tnl at well nest 1 is 0.038
using a hydraulic conductivity range of 2 x 10:.6 en/sec to 1 x 10-3
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cm/sec and an assumed porosity of 0.3, the average vertical ground
water velocity downward across the r-ed-brown till is approximately 0.01
to 2.0 feet/year. This is 1.5 to 7.4 percent of the lateral flo_rates.
Ther-efore, ground water flow in the Upper Sand aQuifer is primarily
lateral towards Coon Creeic, but there is a do...nward component across
the red-brown till south of the limits of refuse disposal (see
Attachment 7).
O. Extent and Magnitude of ContatTlination
Ground water contlrllinatian exists within the Upper Sand aQuifer
beneath and downgradient of the landfill and ultimately enters Coon
Cr-eeic. The degradation is most severe in the upper portion of the
Upper Sand aquifer. Contaminants include typical landfill type con-
taninants (reduced plol. ChlorideS, and COO) and a wide variety of
organic constituents, including aromatic and halogenated volatiles,
and low levels of metals (see Attacnments 8 to 12l. Some of the
volatile organics found in highest concentrations include methylene
chloride, dichloroethyl ene, trichloroethane, tetrahydrofuran, methyl
ethyl ketone, benzene, and xylenes.
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The ar-eal distribution of contaminants show the most sever-e contamina-
tion at and downgradient of the pit' (wells WS, W8, W11, and W22Al.
High concentrations or .hot spots. wer-e detected at other scatter-ed
locations (i .e., W28A, and W31A) within the landfill, r-eflecting the
scattered pattem of d;s~osal practices throughout the history of the
landfill operations. At this point in time, the Pit area shows the
most serious ground water degradation and is the dominant source of
contilminants, notably volatile organics, entering Coon Creeic. Conta-
mination in the Upper Sand is most severe near the water table and
decreases with depth, produc:1ng a stratified plume (see Attachment 13).
Coon Creeic is the primary receptor of contlrllinated ground water in
the Upper Sand aquifer leaving the WOE Site. No contaminants,
partic:ularly volltile organics. are detectable upstrelrll of the WOE
Site. Very 10_ llvels of sane volatile organic:s are detectable along
most of Coon Cree~ along the-north side of the WOE Site until the
contlrllinant pl~e from the Pit enters the Creek. At that point, the
1enls of a variety of volatile organics. particularly chlorinat~
volatiles. are present, and persist several lIiles do,," stream of the
Site. Non-halogenated volatiles are observtd in high concentrations in
ground waUl' nul' the Creek and ar-e,thought to volatilize quickly upon
entering the Creek. However. the non-halogenated volatiles dO persist
when ice cover c:onditions exist. The levels of volatiles in Coon Creek
where the Pit pl Ullt enters the Creek are in the range of 1 to 30 ug/l
for several different halogenated volatiles. There is some
cont511ination present in one monitoring well nest ilTl!lediately north of
Coon Creek; but this appears to be due to some localized underflow and
reversal back to Coon Creek bec:ause of some fine-grained lenses under
Coon Creek. None of the private wells further north of the c:reek shOw
any cont511ination.
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The Lower Sand aquifer has not shown any indications of contamination
to date. A numaer of factors are responSible for the lack of impact.
including the presence of 10 to 40 feet of a dense till confining the
aquifer, an upward gradient across the till unit, and a pronounced flow
in the Upper Sand aqui fer northwards towar-::ls Coon Creek. However, the
long-term integrity of the Lower Sand aQuifer cannot be completely
guaranteed. The gradient across the till is downward irm1ediately south
of the landfill and, if ground water conditions were to shift in the
future, the downward gradient may expand northward under the landfill.
.0.1 so, heavier-than-water, non-aqueous phase 1 iquids (NAPL) may migrate
along the surface of the till southward (down the slope of the till
surface) to the zone of dO-'1ward gradients and, in the long-term,
potentially impact ground water Quality. Thirdly, most. of the
residential wells southwest (and dO-'1gradient, in terms of the regional
flow, in the Lower Sand) of the WOE Site are conpleted in the Lower
San<1 and may be impacted if serious contamination were to reach the
Lower Sand aQui fer. The presence of such a 1 ar-;e ntJlllber. of wells
sout/'lwest of the Site does have the potential to aggravate the downwar-::l
gradient condition southwest of the Site.
Eo Landfi 11 Gas
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The WOE Site has 11 gas probes, located primarily along the westem
and southem sides of the landfill (see Attachment 51. Probes were
installed at these locations because Coon Creel: (along the north and
northeast sides of the Landfill) provides a hydraul ic barrier to gas
migration artd because the closest residential develo~ents are in these
directions. Also, sone ever-;reen trees irrrnediately along the west side
of the landfill are showing signs of stress. Combustible gas
measurements show the highest levels 05 to 30 percent) in gas probe.
nest 6, with a few pereent levels in probes 1 and 4. volatile or-;anics
analyses also indicate the presence of a variety of organics,
principally halogenated or-;anics, in the gas probes. As with
combustible gas, probes liP-I, GP4, and GP..o show the highest
concentrations and the hrgest variety of volatile or-;anics (see
Attachment 16). These gas probes are irm1ediately adjacent to the
1 and fill and represent the worst case (Attac~ent 16). Probes further
fran the landfill (GP-2, GP-g, GP-I0 show much lower vapor gas
concentrations and fewer cCJllpounds) and those along th~ south are
completely clean. The fact that gas migration seems to be very limited
beyond the landfill is due to the relatively high water table -
conditions and the high porosity and permeability of the surficial
deposits in the area. SCJlle of the levels of individual contaminants
(l,I,Z,Z-tetrachloroethane, 1,3-dichloropropene) do exceed Threshold
Limit Values in GP-4 and GP-6 irm1ediately adjac:tnt to the-landfill. In
addition, the levels of some cont~inants (methylene chloride, benzene,
trichloroethene) exceed the potency factors for cueinogens identified
in the Public Health Ris~ Evaluation Data Base. With the fact that
methane and specific volatile gases are being generated and that the
landfill is a relatively young facility (most waste disposed in the
last 10 yeaM), concerns do renain regarding long-term migration of
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F. Wet 1 and s
The wetlands north of the site ar-e listed in the National Wetland
Inventory as a Type Z wetland (Class Palustrine, emer-gent,
subject to intennittent flooding, drained). The U.S. Fish and
Wildl ife Service has identified the presence of sedges, r-eed
canary grass, cattails, and willows.
IV. Potential Recectors and Pathways:
A. Potent ial Recectors
Land r!sources in the area ar-e used for agricultur-e. r-es-idential,
and light industrial purposes. Some land is undeveloped. No
unique agricultural land or wildlife habitat exist around the Site.
(See Attacnment 1~).
Potentially impac.ted water r-esources consist of the groundwater in
the Upper and Lower Sand aqui fers and surface waters in Coon Creek
and tne Mississippi River. Although used as a source of potable
water in the ar-ea, including just north of the Site, th~ Upper Sand
aquifer is less significant as a potable water source than the
Lower Sand aquifer. Mississippi River irrigation and livestock
watering are other possible uses of the ground and surface waters.
Coon Cr-eek and the MissisSippi River al"'!' important to wildlife in
the area and contain fish and other aquatic organisms. _
Wetlands between the limit of r-efuse disposal and Coon Cr-eek,
particularly in the ar-ea of monitoring Wl!11 nests 2 and 13, have
been impacted by seeps and shallow leachate of the Site. Migrating
waterfowl may utilize these wetlands.
8. Releases
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The WOE Site has a variety of exposul"'!' pathways, existing or
potential, for the release of hazardous substances. The-
existing pathways include ingestion/dennal exposul"'!' f~ con-
ta'llination of Coon C~elt by Upper Sand ground wAter, and d1 ~ct
contact for people on site with exposed ~astes and leachate,
The~is also the rislt of physical injury due to th.. existing
hazards at the Site (i.e., exposed cables, rusty drums, etc.).
Potent i a 1 pathways incl ude contaminated d ri nlting water (rom
contaninated ground water (ran leakage into the Lower Sand
(i.e., NAPL) or migration beneath Coon C~elt within the Upper
Sand. Control S are necessary to protect public hulth,
welfare, or the environment fr"Oll the continuing r-eleases of
hazardous substances. The releases al"'l! described as follows:
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1. Heavily-contaminated ground water within the Upper Sand aquifer,
par-ticularly from the Pit, is currently discharging into Coon
Creel: resulting in low but persistent levels of various
chlorinated volatile organics.
2. Leachate seeps are sporadically active near the base of the no~h
face of the landfill near Coon Cree~. When the leachate seeps are
active, they do pose a di rect contact riSk to people and wild1 ife
on WOE Site. The leachate seeps ultimately drain into Coon Cree~
via interflow or overland now.
3. Landfill wastes, and potentially hazardous wastes, ar-e gradually
being exposed as the existing, unprotected lime sludge cap erodes.
The lime sludge alone does not support any vegetative cover and,
because of the very fine-grain size, is subject to wind erosion
under dry conditions and rtJnoff erosion during periqds of even
moderate rainfall. Extensive and deep (up to 10 feet deep)
gull ies have developed particul ately in the no~hwest qua~er of
the landfill. As the lime sludge cap erodes, the potential for
direct contact exposure to wastes increases over time. Althougn
the-potential for di rect contact is low, ther-e is SO'Tle undefined
chance for acute exposures.
4. Ground water contamination in the Upper Sand aquifar grea~ly ex-
ceeds U.S. EFA Maximum Contaminant Levels esta~lished under ~he
Safe Drinking Water Act and Water Ouality Criteria es~a~lished
under t~e Clean Water Act and Minnesota Recommended A110waole
Limits (RAL's). The highest levels of contamination are at and
downgradient of the Pit and in isolated/randO'Tl locations in the
landfill (so called .hot spots.). Although the ground water
contamination is largely limited to the site, being discharged to
Coon Creek, there is one small pocket of contamination exceecing
RALls and nearing Water Ouality Cr.iteria, but exceeding only
methyline chloride, in the vicinity of well nest 21, raising
concerns ~ard1ng the adequacy of Coon Creek IS a cO'llplete
hydraulic barrier. There at"e" al so long-term concerns regarding
NAPL mig ration in the Upper Sand, and contamination entering the
Lower Sand aquifer due to NAPL migration or dissolved contaminants
migrating downward south of the Site. To dite. no contamination
has betn detected in private wells.
5. Gas. both methane" gas from the landfill and individual volatile
organics from wastes. is being released from the Site and
to the west. Gas migration does appear to be limited due to
these high porosity and permeability of the surficial soils.
C. Exposure Pathways
The WOE FS defi ned th f rteen exposu re routes f /"OllI whi ch response
objectives were derived (See Attact'rnent 15). The routes are as
follows:
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1. Inhalation of Oust and/o~ Volatilized Ch~icals (dust includ!S
contamInants aosoroed to oust partIcles). Three g~oups of
people a~ expected to be affected by such a release: on-site
investigators/workers, trespassers, and nearby dO\ofl\olind
residents. The response objective is to control the potential
dust and/or volatilized chemical emissions.
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2. Inhalation of Chemicals as a Resu4t of Incomoatible Waste
Reactions. Potential incompatible waste reactions range from
m1nor reactions that may increase or decrease the rate of
chemical releases from the site to major reactions that release
large volumes of volatilized chemicals. The large 'iollJ1\e
rel ease from an undisturbed landfill has a low probabil ity due
to the slow rate of release of individual containers, the
sortlent properties of the solid waste, the buffering affect of
surrounding soils, and the cool temperatures and anaeroeic
conditions in the 1 andfill. No major release has been
recol"ded. The response objective is to reduce the p~oeabi 1 ity
of incompatible waste reactions and to control the effects of
"reactions that may oc~ur.
3. Inhalation of Lime Sludae iracked Off-Site b Local ~esidentS
As ocal residents use tne site fo~ recreational acti'iites and
as most of the sit~ is covered by lime sludge, lime sludge is
expect~d to be tracked off-site and inhaled as dust. The
response objective is to remove the opportunity for contact
with the lime sludge.
4. Inhalation of Soil Gas Contaminated b the Pit and Landfill.
Land 1 gas 1S generated !'t every sanltary and 1 ':i1 tne
anaerobic decomposition of solid waste. This gas can be
pushed out into surrounding soil s. The gas. can a1 so car~y
volatilized organic compounds from industrial wastes. Gas
was present in the soil, although no volatile organic
compounds were above detection limits in the nbient air. The
response object1v~ is to control sol1 gas migration.
5. In estion o'f Lime Slud e.;oraclced Off-Site b Local Residents.
As oca reSldents use the S1U. or' recreationa activ1t1es and
as the site is covered with 11me sludge, I1me sludge is
expected to be ingested. The response objective is to renO'ie
the opportunity for' contact with the lillll sludge.
S. Ingestion of Lime 51 udge On-Site. On-site invest ig ato rsl
workers and trespassers are expected to be exposed. The
response objeetive is to prtvent the opportunity for' contact
with the lim~ sludge.
7. . In esHen of Uo er Sand AQuifer Water Contaminated b the Pit.
he ground \oIater conti!!l1natlon rom the pit arta appears to oe
confined to the Upper Sand aquifer and to"discharge into Coon
Creek. As the till layer mounds under the Pit, !(APL could
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migrate off-site in vi~ually any dir"l!ction because it loIill
tend to follolol the slope of the till layer rather than the
ground loIa:er (10101. The r"l!sponse objectives ar"l! to control
futur"l! exposure to Upper Sand aquifer ground water both
fran ar"l!as that may become contaminated and from aroea5 .heroe
pumping may affect contaminant dis:ributions, and to eliminate,
or minimize, future conu,"inant r"l!leases to Coon Croeek and
subsequently the Mississippi River.
8.
Incestion of Uooer Sand lIcuihr ....ater Contaminated b the
Landfi . The ground loIater contaminatlon frO'll tne ancflll
also appears to be confined to tne Upper Sand aquifer and to
discharge into Coon Croeek. As :he till layer mounds under tne
landfill. NAPL could migrate off-site in virtually any
. di rection. Although specific contamination souro:es may tle less
significant than the Pit, the area impac:ed, and therefore tne
total release, may ultimately be substantial. .No receptors
exist between th~ landfill and creek at this time. The
res~onse orJjectives aroe to control futuroe exposure and minimize
future roeleases to the Upper Sand aquifer, and to el imina:e or
minimize futuroe cont~inant releases to Coon Creek and
subsequently the Mississippi River.
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9. !noestion of Lo~r Sand Acuifer ....ater Contaminated b a ~elease
rom "ne upper Sana ..cu1ter. "Itnougn tne Lo~r Sana aqulter
does not snolol any lmpact from the site at this time, it is an
important drink ing water souro:e that must be protected. The
possibilities for future I:ontaminatien are primarily if
contaminated groundlolater flews through the till layer because
the existing upgradient is reversed, or heavier than loIater non-
aqeous phase liquidS (NAPL) accumulate on the till surface and
r"l!ach sufficient depth to push through the till against the
uogradient. The response Objective 15 to protect the LOloler
Sand aquifer- by controll ing vertiCil gradients and the- impact
of NAPL accumulation.
10. Ingestion of Water and Fish from Coon Croeek. Low level
contanination from the site has been foun~ in th~ creek. The
response objective is to eliminate or minimize contaninlnt
loadings to Coon Croeek.
11. Ingestion of (loosed ....aste/Leachate. Trespassers and on-site
investigators/workers could be affected by such an exposure.
The response objectives is to prevent' exposure- to loIaste/1eachates.
12. Oermal Contact with Coon Cl"!ek. Although the creek is not an
attractive water sport stl"!.n, children may phy in the cl"!ek.
The response objective is to eliminate or minimize contaminant
loadings to Coon Creek.
13. Dermal contact with (xoosed Waste and/or Leachate. Trespassers
and on-site investigatorsllolerkers could be affected by such an
r "-
'. )
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(
11
exposu~. ihe ~sponse objective is to prevent di ~ct contact
to ex~osed waste/leachate.
V. Altematives Evaluation:
4.
5.
6.
, 7.
8.
9.
A. Resoonse Objectives
The ~sponse objectives are listed froan the "Exposure Pathways"
discussion, above (see IV.C.), as follows:
1. Control potential dust and/or volatilized chemical emis-
sions.
2. Control contact with lime sludge.
3. Control contact with exposed waste/leachate.
Minimize contaminant. releases to the Upper Sand aquifer.
Eliminate or minimia conta'!!inant releases to Coon C~!I:.
Reduce the probability of incompatible waste reactions.
Control the effects of possible reactions that may occur.
Control futu~ exposu~ to the contaminated Upper Sand
aqui fer.
Protect the Lo~r Sand aquifer by controlling the vel"tical
gradient and the impact of heavier-than-water non-aque<Jus
phase liquid (NAPL) accumulation.
10. Control soil gas migration.
B. Altemat;ve.s Screened
Th~ Feasibility Study analyzed 1'~1de variety and large number of
altematives to deal ~ith th~ various. releases... identified.
previously. The- alt.mativ.s Ire:
1. No Action
2. Capping
a. Normal Portland Concrete Pavl!11ent
b. Asphaltic Concrete Pavenent
c. In-situ Soil Ac1mixtures
d. Sprayed-on Covers
e. Low Permeabil ity Soil Cover Meeting ,",PCA Solid Waste
Rules
f. Low Permeability Soil Cover Exceeding MPCA Solid Waste
Rules
. ,
/'
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12
g.
h.
i .
Low Fermeability Soil Cover to RCRA Ferformance Standan:1s
Synthetic Me-:1~ ranes to RCRA Performance Standards
Co:nposite Constroct ion to RCRA Performance Standards
3. Ground Water Cut-Off Wall
a. Sl urry Wall
b. Sheet Piles
c. Injected Sc~ens
d. Grout Curtain
4. Ground Water Fumping
a. ir-eatment Options
b. Di sposal Options
5. Leachate Collection Drain
6. Site Grading
7. Waste Removal (Excavation)
8. Deep Well Injection
9. Inciner-ation
10. Landspr-eading/Biotr-eatment
11. TemlXl rary Warehousing
12. Off-Site Hazardous Waste Landfill .
13. On-Site Hazardous Waste Landfjl1
14. Landfill Closu~
I. Rodent Cont rol
b. Maintenance
c. Final Cover/Vegetation
d.. Gas.
e. Drainage
All of the alternatives were sc~ened in the Alternatives Report (dated
April 18, 1986), with SO'lle alternatives being- eliminated fl"Olll further
consideration. The remaining alternatives, which a~ discussed below
under wAlternatives Conside~d. (SH VII.,B., below), we/"!! mo/"!! fully
eval uated in a Detailed Analysis Report (dated Oetober 9, 1986).
C. Alternatives Conside~d
. "'
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1. No Action - This alternative discusses actual and potential
1mpacts caused by cont4mination from the Waste Disposal
(
13
Engineering (WOE) Site if no cleanup actions are taken.
used as a baseline against which other altematiYes an!
and includes site monitoring. The altemative includes
tenn monitoring and covers the following:
It is
com pa n!d
long-
a. Conta'Tlinant monitoring in the- Upper Sand aquifer
through wells along the landfill perimeter, primarily
downgradient of the wastes, and within the landfill to
act as an earl ier waming of ~leases of contaminants
(includes residential wells).
b. Cont~inant monitoring in Coon Creek.
I
,
c. Monitoring through wells of the Lower Sand aquifer to
assure contamination is not occurring and to monitor
gradient between the Upper and Lower Sand aquifer.
. d. NAPL mon i to ri ng wells wi th sumps to co 11 ect NAPL.
Wells are proposed forknOloln a~u of higher level
contamination. In additiort, a geophysical
investigation .is proposed to locate low a/"!as around
the' landfill whe~ additional monitoring.can be. placed.
e. Monitoring of gas migrating beyond the landfill.
f. Background wells in the Upper and Lo~r Sand aquifer<s,
and in Coon Cl"'t!ek to define ambient conditions in al"'t!as
not contaminated by the landfill.
2. Caooing _ This al temative involves pl acing a low penneaoi 1 ity
cover over the a~a of concem. ne cover would be vented to avoid
gas build-up. The cap would eliminate the oppo~unity for din!ct
contact with the waste, stabilize the waste pile, discourage
rodents and other vemin, control 040rs and vapors, control surface
Nn-off, contl"Ol dust, p/'Ollote vapors, transpiration, and control
the percolation of water.fnto and. th",ugh. the .waste (infiltration).
The mo~ water going through the. waste, the mo~ leachate
(contaninated'l fquid) pl"Oduce<t.. Thert were fin capping
altematives conside~d:
. ,- - .'.
a. Low Pe rmeabi1ity Cover Exceeding Minnesota Poll ut i on Cant rol
Agency (MPCA) Standards. ThiS' calt consists of grass
vegetated cover, over 6 inches (-) of topsoil. over 6- of
sand latera] drainage (hydraulfc. conductivity (K) a",und 1 X
10.3 cent ;mete rs per second (eml s) J, over 24- of compacted
clay (K less. than or equal to 2 X 10-6 em/s).
b. Low Permeabil ity Cover Meeting Resource Conservation and
Recovery Act (ReRA) Performance Standards. This cap consists
of grass vegetated cover. over 6- of topsoil, over 30. of clean
fill. over geotextile filter fabric, over 12. of sand lateral
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,
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14
drainage (K greater than or equal to 1 X 10-3 ClI/S~, over 24"
of compacted clay (K less than or equal to 1 X 10- Ollis).
c.
Synthetic Liner Meeting RCRA Performance Standards. Cap
consists of grass vegetated cover, over 6" of topsoil, over
12" of clean fill, over geotextile filter fabric, over 6" of
sand lateral drainage (K g~ater than or equal to 1 X 10-3
cm/s), over high density polyethylene synthetic liner, on 6"
of sand cushion.
d.
Composite System Meeting RCRA Performance Standards. This cao
consists of grass vegetated cover, over 6" of topsoil, over 24"
of clean fill, over geotextile fabric, over 12" of sand lateral
drainage (I:: greater than or equal to 1 X 10-3 enl s), over high
density polyethylene synthetic liner, over 6" of sand cushien.
over 24" of compacted clay (K less than or equal to 1 X 10-7
cml s) .
e.
Lime Sludge Meeting RCRA Technical Performance Standards. This
-cap consists of grass vegetated cover, over 6" of topsoil, over
30" of clean fill, over geotextile filter fabric, over 12" sand
lateral drainage. (I:: greater than or equal to 1 X 10-3 Ollis)
over 36" of 1 ime sl udge (I< less than 2 X 10-6 enl s).
3. Groundwater Cut-off ....all with Cae. This altemative involves a cae
(see lten 2., aoove) and a low permeability perimeter barrier "nlen
would be keyed into the red/bro-'1 silt till (the till layer oe:..een
the Upper and Lower Sand aquifers). The perimeter barrier wall
would consist of a soil.bentonite slurry wall which will contain
cont.!'Tlinants within the wall. To insu~ an inward gradient across
the wall the groundwater level within the wall would be kept lower
than outside the wall. If a leaK.occurs the inward gradient will
cause water to flow into the walled a~a the~by avoiding
diseha~es outside the wall. Two methods of maintaining the
inward gradient are:
a-. Groundwater Extraction Well s. The water level within
the wall is lowered by I PLlllp-out well.
b. Groundwater Collection Drain. The water level within
the wall is lowered using perforated pipe connected to
a sump. The water in the sump would then be pumped-
out.
4. Groundwater Interce tion and Extraction. This altemative
,nvo ves a cap see 'tern 2., above an interception and r"!"lloval
of contaminated groundwater fl"C)(ll the Upper Sand aquifer through
creation of a hydraulic barrier.
a. Groundwater Pumping With Cap. This involves wells to
intercept and extract cont.!'Tlinated groundwater fron the
Upper Sand aquifer do~gradient of the waste site.
15
r
b. Gl'Oundwater Collection Drain. This involves perforated
pipe to intercept the flow of groundwater downgradient
of the waste site. The pipe leads to a sump. The
sump is pumped-out to extract the water.
5. Excavation of the Pit. This alte_mative involves removal of about
5500 cu01C yards of materi al, incl uding dru1TT1led wastes and
contaminated soil. Removal is expected to occur at least to the
asphalt lining of the Pit. Oisposal is expected via one or a
combination of the following:
a. On-site RCRA facility. This would involve redisposal of
wastes consistent with RCRA at the site.
b. Off-site RC~A facility. This would involve trans-
portation and disposal of wastes at an existing.
compliant facility away from the site.
c. Incineration of wastes in a rotary kiln incinerator opera-
ted at the site. Li~uid wastes from ~uenching and scru~~ing
would be collected and disposed at a RCRA facility or
treated and dischar:;ed. Residual materials remaining after
incineration would be disposed at a RC~A compliant facility
or de1isted and buried on-site.
S. Excavatfon and Disoosal and Gl'Oundwater Pumpin of the Pit Ar-ea.
ThIS a tematlve IS a comOlnatlon of itl!TlS 4.a. and 5, aoove.
7. Treatment of Extracted Gl'Oundwater.
a. Ai r Stripping. By exposing contll'llinated water to the ai r
volatile compounds are I"e'lloved from the water. This
a1temative is often used for low level volatile compound
contamination or to reduce or el iminate some contaminants
prior to treatment with other pl'Ocesses such as activated
cart/on.. As cont~in~ts are dischar-ged into the atmo-
sphere, activated cart/on treatment is often re~ui red of
the contaminated ai I' before it is dischar-ged into the
atmosphe re.
b. Carton Adso",tion. Cont~inated water is exposed to the
activated cart/on. The carton relIoves contaninants and must
be replaced periodically.
c. A combination of a) and b), above. These technologies can
be used together to reduce ai I' poll ution caused by ai I'
st~ipping via activated carton, to increase the life of the
activated carton by air stripping, or to increase contani-
nant removal efficiencies.
'-
8. 01soosa1 of Extracted Gl'Oundwater..
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16
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j
a. Coon Cr-eel:. This involves dir-ect discharge to Coon
Cr-eel: .
b. Publicly Owned Sewage Treatment Worl:s. This involves
discharge to a neartly sanitary sewer, which would
discharge to the sewage treatment plant.
c. Infiltration. This involves discharge into an in
filtration pond, which allows tr-eated water to r-eenter
the Upper Sand aquihr.
d. Irrigation/Evapotranspiration. This involves land
application of the discharge.
D. Aoclicable, or Relevant and.Aeoroe,.;a:e
Altematives Z, 3 and 4 involve capping th~ Site. Resource Conser.
vation and Recovery Act (RCRA) r-equi rements for closur-e of a RC~A
landfill is an ARAA for capping the Site.
..
Altematives 3 and 4 involv~ groundwater extraction and discha!je.
If discharge is to Coon Cr-eel: (altemative a.a.) or land application
(altemative a.d.), National Pollutant Discharge Elimination System
(NPDES) permit r-eQui rements ar-e an ARAR. If discharge is to the
sanitary sewer (altemative a.b.) an agr-eement with the Metropolitan
Waste Control COll1llission (MWCC) in accordance with its pr-etrutment
progran under the Clean Water Act is an ARAR.
Altematives Z, 3 and 4 must attain Army Corps of Engineer 404 permit
reQuirements for construction of the c.ap in the floodplain. Filling of
wetlands in the flOOdplain must also meet these neQuirements.
Altematives 1, Z, 5 and 6 would allow continued discharge of
contaminated water to Coon Cneek where Water QJality Criteria and
drinking water standards (for the Mississippi River) would apply.
Altematives 2 through 8, 'ItOuld involve air emissions either through
excavation or- tltrougn ground water'extracttonand' treatll'lent which must
be considered under the- Clun Air Act and State requirements.
~ ~.:
E.. Reduction of Toxicity, MObility, or Volume
Altemative 1 does not reduce toxicity, mObility, or vollJlle.
Altemative 2 will reduce the IlIClbility of contaminants in the waste and
the vol UTle of contaninants entering the groundwater by restricting
infiltration through the waste. Because the vol\llle and mobility of
contaninants is r-educ~, the toxicity of the ccntaninated groundwater
is reduced.
"--
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o
17
1'.
Altemative 3 has the advantages of a1temative 2 plus it further
reduces the mobil ity, toxicity and volume of contaninated groundwater
and NAPL discharges off-site by containing th~ ..ithin the barrier. ,l.
concem 15 that if not extensively monitored, NAPL discharges may pool
along the barrier ..all and that the ..eight of the NAPL will cause it to
penetrate and contaminate the Lo..er Sand aquifer. Consequently, tne
barrier is considered more desirabl! 10" a smalle,. area which can be
more easily monitored (i.e., the Pit).
Altemative 4 has the advantages of altemathe 2, plus it furtner
reduces the mobility, toxiCity, and voll.lTle of contaninated ground..ater
by creating a hydraulic barrie" to contain such contamination on-site,
as ..e" as reduce it through ground..at!/' extraction. This a1temative
does not contain NAPL discharges.
(
Altemative 5, by exposing deteriorating drums of incompatible ..astes,
hu a potential for causing a significant increase in the toxicity,
mobility, and volume of contaminant discharges to the ai,. and
grounddter during the excavation and handling of wastes. The long-
terTTl reduction of toxicity. mobility and volume of contaminants from
the material excavated would be significant, after tl'le riSKS of
excavation are. experienced. This would not affect contamination of the
ground..ater from the rest of the landfil1.
Altemative.6 has the benefits of altematives 4 and 5 for the
cont5'l1inated. ground..ater around the Pit area.
F. Short-terTTl Effectiveness
Altemative 1 would not be effective in addressing contamination
from the site. It would monitor conditions at the site.
~'- .'--~-
Altemative 2 would cause short-tem impacts due to constnJction of the
cap. These would include noise from heavy equipment, dust, and
1 nc reased chances fo" di rect contlct with wutes by const nJct i on
pel'Sonnel. If the lime sludge is not used, exposure of wastes, and
~oval and disposal of the Time sludge would cause additional ris~s.
The chances fo,. contact with wastes, contaminated gas releases, and
infiltration through the wastes would be reduced by the cap.
Alternative 3 would pose risks associated with altlmative 2 plus risks
tQ. worlcel'S phc.i n9 th~ blrri e,. ,wa 11. G roundwate I' contam inat ion and
NAPl discharges within the barrier would be contained. RAPl 1 evel s fal"
the Pit barrier alternative would be. reduced, IS needed, within the
barrilr by extraction wells.
Alt.ernative 4 would pOst risks associated with alternative 2 plus SQr.le
minimal sho'rt-tenn risk during constnJction to workers. Groundwater
contamination would be contained and reduced through groundwaU,.
extraction. NAPl would not be contained. .
(.
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18
A1temative 5 would pose significant short-term risk due to the
excavation and handling of incompatible wastes. Work-t"S, local
populations, the air, groundwater and surface water could be impacted
by short-tenn di scharges.
Altemative 5 has short-tenn impacts of altematives 4 and 5 except
that to the extent the souro:es of NAPL a~ removed without incident,
the~ would no longer be souro:es of NAPL from the Pit.
G. Long-tenn Effectiveness and Pennanence
Altemative 1 would not be effective in add~ssing contamination from
the site. Continuous professional management would be ~qui ~d to
assu~ that ~sponses could be initiated based on the monitoring. The
detennination and timeliness of ~qui~d actions would also be of
concem. The rel iabil ity of this altemative alone is suspect due to
the compl exity of the management ~qui ~d.
Altemative 2 would ~qui ~ long-term ca~ of the cap. The
chances for contact with the wastes, contaminated gas ~leases,
and infiltration through'the wastes would be ~duced. The lime
sludge cap has greater long-tenn risks due to uncertainties in
the use of lime sludge. Its advantages a~ it is al~ady
on-site, and if not used, would be a significant disposal
proolem as ,it would need to be removed.
Altemative 3 would ~qui ~ care and monitoring of the barrier
wall. Groundwater cont~ination and NAPL within the barrier wall
would be contained. For the landfill, where NAPL could accumulate
undetected against the barrier wall due to the lenth of such a wall,
the~ would be additional concem due to the potential that such an
event could cause contl'llination in the' Lower Sand aquifer over the
long term. NAPL accumulation is expected to be detected by moni-
toring wells and controlled by punping out those wells within
the smaller Pit b'arrier, if necessary. Any breach in the wall
could be discovered by the increased punping rates necessary to
maintain an inward gradient KroSS the wall. Replacement would be
expensive. -' . .
Altemative 4 wouldrequi r"! minimal additional construction.
Groundwlter interception and extraction is cOl'!'lllonly used.
reliable, and replacing wells is ~latively inexpensive.
Long-term operation and maintenance is ~qui red. Groundwater
contamination is contained and reduced. NAPl is not contained.
'\
j
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Altemative 5 would requir"! long-term care of any excavate<!
contaminated materials remaining on-site. If disposed off-site, riSkS
due to transportation, accidents, and redisposal would oecur. If
contained on-site, some leakage of the containment facility and
sp~ading of cont.rnination is possible, although less than from the
existing Pit. Long-term care would be, ~qui ~d of an on-site facility.
19
--
Long-tem NAPL discharge from excavated materials would not be
ex pec ted.
Altemative 6 is a combination of altematives 4 and 5 for the Pit and
would have tne same impacts.
H. Imple~entablllty
Altemative 1 is easily implemented, but less reliable than
other altematives.
Altemative 2 is cOlTl'llon and easily constr"\Jcted. Caps utili-
zing 1 iners would be mOn! difficult due to the need to reduce
slopes sucn that the liner would not tear.
Alternatives 3 and 4 would be re~uired to meet Natlonal Pollutant
Oi scha rge El imination System (NPOES) pennit re~ui /"E!'1Ients for di scnarges
to Coon Creel:, or an agreement with the publicly owned sewage treatment
wor\.:s for discharge to the sanitary sewer. Altemative 3 could be more
difficult to construct such that ade~uate containment is achieved.
Alternative 4 is cOlTl'llon and easily constr"\Jcted. Capture zones can be
measured to assure ade~uate coverage. NAPL would not be addressed.
Alternative 5 would be difficult due to the need to excavate the
...astes, and, in the case of incineration, site an incinerator.
Also, some wastes may be prohibited from being landfilled.
Alternative 6 would be the same as 4a and 5 except NAPL would
be addressed if not caused during excavation.
Alternative 8a would be n!l1able and would n!Qui n! the e~uival ent of an
N?OES permit. Impl ementabil ity is expected to be easy, ho~ver tni s
cannot be assured until the pennit conditions In! I:nown during design.
Altemative 8b would be reliable and would re~uire compliance with the
pretn!atment n!quirenents of the POTW. Implementability is technically
easy, however problems with ",ceptance by the?aTW due to the dilute
nature of the waste stream and depletion of the area's 9"'wth' capacity
allocation at the ?aTW, are-conce.ms.
Altemative 8e would be easllyimplernented, outside problems with land
a~uisition, but causes c.oncem due to the addition of water to anan!a
of the Upper Sand aquifer, just south of the Site-, whent a downgradient
exists between the Upper and Lo.er Sand aquifers. This would also
increase eoncems about creation of I downgradient under the landfill
itself.
Altemative 8d would' n!~uin! the equivalent of an NPOES ~mit, but is
not considered ntliable for the cold climate at the Site.
"-
t. Cost
-
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20
1. Altemative 1 has a capital cost for monitoring of S70,000 plus a pr-esent
wor-tn IrW) or operations and maintenance (0 & "1) of S647,529 for a total ?\oI of
$717,529.
2. Altemative 2 costs are as follows:
Type of Cap
Capital Cost
of Cao
a. Cao meeting $ 4,697,280
MPCA Standar-js
b. Cap Exceeding 9.101,736
,",PCA St and a r-j s
c. Soi 1 RCRA Cap 12,709,760
d. Synthetic Liner 12,552,220
RCi\A Cap
( e. CO'l'Ip:lsite RCRA 19,119,365
, Cap
f. Lime - sl udge 8,196,500
RCRA Cap
PI.' of 0 & M
of C ao
235,673
235,573
235,573
820,107
235,673
235,673
Total PW Total PW
of cao includlna
monl:0,.,na
(altemat lVe ~)
4,932,953
5,650,482
9.337,409
10,054,938
12,945,433
13,562,962
13,472,327
14,189,856
19,355,038
20,072.567
8,432,173
9,149,702
(The Pit was also consider-ed alone. HOllever, since the
Pit was found to have several feet of clay capping
alneady, no additional cap was needed. Had the clay not
been thene, a less permeable cap might have been needed for
the asphalt-lined Pit to Keep water from acc~ulating in the
Pit. )
3. Estimated costs for altemative 3 a~ IS follows:
a. For the Landfill (must also add altemativecap c:ost):
Type of Syst!'ll
Caoital Cost
of System
PW of 0 & M
of System
Tota 1 P'tl
of System
1) G roundwate r Cut-
off \oIall with
collection drain
, '\
'J i1) G roundwate r Cut-
off Wall with
S 5,238,996
4,770,976
123,753
5,362,749
123,753
4,894,729'.
r. 21
'- extraction ~ell
b. For the Pit:
i ) wall ~ith d ra in 389,536 86,308 475,844
ii) Wall ~ith ~ell 302,723 86,308 389,031
4. Estimate costs for al-;emative 4 are as follows:
a. For the Landfill (must al so add cap cost):
1) Ground\Olater Pumping
\OI;th Extraction \OIell 812,000 41,478 853,478
ii) Leachate collection .1,452,500 41,478 1,493.978
b. For the Pit:
1) Well 127.120 90.498 217,618
( i1) Drain 201.495 51,375 252,871
,
5. Estimated costs for altemative 5 are as follo~ :
a. Excavation and Off-
site Landfill
1) Emell e. Alabama 2,810,851 37,708 2,~48,559
ii) Chicago. Illinois 1.963,851 37.708 2,001,559
b. Excavation and Qn- 645.051 37,708 682,759
site Landfill
-
c. Excavation and Qn- 6,275,851 37.708 6.313.559
site Incineration
., -".
6. Estimated costs for altematlve 6 a~ as. follows:
a. Excavation and Off-site
Disposal ~ith GroundW'ater
Punping
1) Emelle. Alabama 2,935.171 41.478 2.976,649
ii) Chic~go. Illinois 2,088,171 41,478 2.129,649
b. Excavation and Qn- 744.171 41.478 785,649
site Disposal with
, , Groundllater Pumping
22
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7. Estimate c:osts for altel'1'1ative 7 (ground water t~atment) are as follow;:
a. For the Landfill
i) Cartlon Adsorpt ion
ii) Air Stripping
91,000
91,000
84,000
470,138
355,295
263,953
561,138
446,295
347,953
.) Ground water pumping
u) Ground water punping
within c:ut-off wall
b. For the Pit
i) Carton Adsorption
.) Ground water pumping
U) Ground water p\1'llping
within c:ut-off wall
91.000
162,319
253,319
91,000
44,670
135,670
i i) Ai r Stripping
84,000
44,306
128,306
8. Altel'1'1ative 8 (ground water disposal) estimated c:osts are as follows:
a. For the Landfill
I'
i ) Coon C ~el: 28,700 381,789 410,~89
ii) Sewage Treatment
Plant 413,280 488,125 901,405
i i i) Infiltration
Pond 256.500 245,099 501.599
i v) Irrigation 322,000 324.285 646,285
b. For the Pit
i) Coon Creek 28,000 362,936 390,936
i1) Sewage Treatment
Plant 371,28Q.. ".; . .265,160.. 636,440
111) Infiltration
Pond 97,500 245,099 342,599 -
iv) I rrigltion 189,000 324,285 -.. 513,712
J. Community Ac:c:eptance
'~.J
The community hiS been involved in the planning p~ess as
described later in Section XI. Information in the RI assisted in
the lifting of a ~ll advisory by the Minnesota Department of
Health. Initially remoVll of the Pit was c:onsidered desirable.
However, IS discovered during the RI/FS investigation of the site,
there are hazards involved in excavation and the benefits are not as
great IS originally thought, considering industrial wlStes have
(
23
been disposed throughout the landfill, not just in the Pit.
Pr-esent1y, ther-e is concern that sewer capacity, and therefor-e
growth, is adversely affecUd if extracted ground waul' is
di schar-;ed to the sanitary sewer. The time1 iness of the process
has also been questioned.
K. State Acceotance
The ~PCA has approved the Detailed Analysis Report, as modified under
the Consent Qroder. That report, as modified, includes the selec~ed
alternatives described herein as its recocmtended alternative.
L. Overall Orotect ion of Human Heal th and the Envi ronme"t
1. Abilitv to Meet the Response Objectives Listed in V.A..
Aoove:"
/"
a. No Action (alternative 1). This alternative provides, through
monnor1ng. information on which the need for r-esponse could
be made, although the long-term management requi r-ed to
determine when and what M!sponse is called for, and tne
timeliness of such response are concerns. It does not provide
protection of any receptor or potential receptor of contami-
nated M!1 eases.
'.
"
This alternative does not meet any of the lisUd response
Objectives.
b. Capp;ng only (alternative 2). A cap would meet Objectives I,
2, and 3 oy covering the landfill. Objective 10 would be
aChieved by vents in the cap. Objective 7 would be met
sOllewhat by th~ bulk and weight of the cap. Over the long-term
a cap wol,lld r-educe cont~i!'lant ~1eases to the Upper Sand
aquifer (partially addl"'!ssing objKtive .) by redu:.ing
infiltrltion through Jhe landfill. Reduce<! contaninant
~leases to the Upper Sand aquifer would l"'edu:.e Coon Cr-eek
l"'eleases (partially muting objKtin 5).' Objectives 6, 8 and
9 are not ,met, by thisaltemative.
Capping altematives vary mainly in the ~unt of infiltration
they allow into the landfill.
c. Groundwate...Cut-Off Wall with Ca and Groundwater Extraction
e a temat1ve a. h15 a ttmatlve wau conSlSt 0 a cap,
a-cray cut-off wall around the enti~ waste area which would be
keyed into the till layer, and a ground water extraction we"
to maintain an inward gradient within the cut-off wall such
that in the event of leakage through the will water would flow
into, not out of, the walled a~l. This alternative would meet
all of the Objectives of capping (see item b.t above). In
addition, Objective 4 would be met to a gr"!ater degree. A
major known source area which contributes to the primary
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contaminant plume in tne Upper Sand aquifer would be contained.
Objective 5 would be met as tne source of contamanents to Coon
Creel: tnrougn tne groundwater would be el iminated tnrougrl
contairrnent. For the Pit, a small area, tne NAPL would not be
allowed to accumulate significantly due to tne monitoring/pump-
out wells (objective g is met for the Pit area only). For the
landfill, due to tne lar13er area encircled by tne wall, it is
pOSSible that NAPL could accumulate along tne wall without
detection, increasing the probability of contamination of the
Lower Sand aquifer (objective g is not met). NAPL would not be
allowed to migrate along tne till away fl"Olll the walled area
which n!duces the chances of exposure to the NAPL (Objective
8). Objective 6 is not met by this altemative, nor is the
maintenance of an upward vertical gradient.
d.
G~undwater Cut-off lIall, with Cao and _G~undwater Co"e~tio" Or!;.,
(altematlve 30). TnlS lS Slml1ar to ltefll c., aoove.
e. G~undwater Pumoing with Cae (altemative 4a). This is similar to
itell c., aoove, except tnat objectives 8 and 9 are not met because
NAPL would not be contained.
f. Leachate Collection Drain with Cao (alternative 4b). Tnis is
Slml1ar to lam e., aoove.
g. Excavat'ion and Off-site Disoosal of tne Pit (altemative- Sb).
Excavation of tne Pit poses trle greater risk. of significant shOrt-
terTII r-eleases associated with objectives 1, Z, 3, 6, and 7 due to
excavation activities and handling of wastes while exposing them to
the ai r. This altemative meets Objectives 4, 5 and tne NAOL
portion of Objective 9. Objective 8 Is met to the extent trlat NA?L
discnarges are eliminated. Objectives 1, 2, 3, 6 and 7 would be
met in the long-terTII dter th~ short-term risk.s ar-e endur-ed.
h. Excavation and On-site DisQosal of the Pit (altemative Sa). This
1$ S1mlllr to ltem g.. aoove. except over th~ long-terTII ther-e is a
continuing potentia' for remaining wastes to leak.. which would mean
objectives 4 and 5 would be llIet to. I lesser degree..
i. Excavation and On-site Incineration >(altemltiv~ 5c) .>> This is
Slmllar to ltem g.. aoove.
VI.
Selecting the Recommended Alternative
The Detailed Analysis Report. prepar-ed by potentially r-esponsible
parties in accordance with a Consent Order issued by U.S. EPA and
MPeA. recOlTlTlended implementation of the following altemative r-esponse
action which. in concert. are expected to t"!liably and cost-effectively
protect public health. ~1fat"! and the envi ronment by physically
isolating the buried waste to eliminate direct contact exposures and
minimize liquid migration; to capture, remove, and treat all
25
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contaminated ground .ater currently leaving the WOE Site and eliminate
releases of hazardous substances to receptors; to prevent t~e migration
of NAPL from the Pit ar'U; and to monitor and control gas migration
from the Site. The selected remedy consists of:
A. Extensive monitoring progralll to monitor for gas. dissolved
conta'llinants. and NAPL at the perime!!!' of the IIOE facility.
B. Installation of a soil cap. incorporating the existing lime
sl udge at the IIOE Site as the low penneabil ity 1 ayer. which w11 1
meet RCRA Perfonnance Standards.
C. Installation of a ground water extraction system along the northem
boundary of the facility to intercept conta'llinated ground water leaving
the WOE Sit! and currently entering Coon Creek.
O. Treatment of contaminated ground .ater using air stripping
and/or activated caroon (posSibly with pretreatlTlent for other
contaminants). Treated water will be discharged to Coon CreeK.
E. Institutional controls to: 1) avoid wells near and under the Site
in the Upper Sand aquifer, and; 2) as a precautionary measure to be
considered to 1 imit additional wens in the Lower Sand aquifer near the
Site to help assure continued maintenance of the upward vertical
gradient b~tween the Upper and' Lowe,.. Sand aquifers.-
ihe Detailed Analysis Report .as approved with modifications by the
MPCA and U.S. EPA. The most significant modification was to add
another component to the set of response action altematives
necommended in the OAR. The additional response action involves the
installation of a slurry wall around the Pit (keyed into the l"!d-bro\Oll'\
s i1 t t i 11) and a sepa rate g round water PUTIp-out and NAPL cont 1'01 system
exclusively for the Pit. In addition. the cap is upgraded tP be mol"!
in confonnance with RCRA tKhnical guidance standards. Thirdly, a
geophysical survey will be conducted to better design the NAPL
monitoring networlt. Fourthly. the. overall gas and ground water
monitoring networlt is upgrad.!o to cover the perimeter of the WOE Site.
Finally, a wetland between the WOE facility and Coon Creek will be
filled because it does recein periodic leachate discharges and will be
replaced with a. newly constructed wetland.
. ~ ., .
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The recOlllllended altematives. in concert. deal with the
WOE Si te IS a whole because of the' si Zit' of the fa nn," fac11 ity
(up to 40 feet of wutes over 73 acres). the disperse nature of
concentrated sources of hazardous waste (known and unknown -hot
spots-). and the deteriorating condition of the present site
cover. Much attention was focused upon excavatingt~ Pit
because it.s location is well defined and it is clearly having
a significant current impact on ground water and Coon Creelt.
However, the Pit represents 10~ of the hazardous wastes
disposed at the Landfill so excavation of the M!TIaining wastes
from the Pit would not malte a significant difference in the
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long-tem when looicing at the site as a whole. The
concentration of wastes in the Pit, including acids, caustics,
cyanides. fl!mmables, and solvents, does pose a severe safety
risk to workers and the surrounding residential arus due to
n!actions of incompatibles. A test excavation of the Pit
conducted in June, 1985, indicated that many of the wastes are
in deteriorated containers 01" have al ready been released fran
ruptur-ed containers. Many of the reactives an! in plastic
containers and ar"! extrenely difficult to locate by detecting
equipment or excavation equipment. Even if wastes wer"!
excavated successfully from the Pit, sOlIe wastes will be
extremely difficult, if not impossible, to dispose in the near
futur-e and this situation is aggravated even more by the
implementation of RCRA ~endments, including the 'land ban,"
wnich prohibits land-filling certain types of wastes. The
costs for excavation of the. Pit and disposal are estimated to
range from S 0.7 to 6.3 million dollars, depending upon the
disposal method (on-site land disposal, off-site land disposal,
incinerators). Since landfilling the excavated wastes (on-site
or off-site) may not be implementable due to land ban
considerations, the S6.3 million for on-site incineration is
probably the mo~ r"!al istic cost estimate for disposing the
excavated wastes. Also, off-site land disposal is the least
preferr-ed option for deal ing with these wastes per Section 121
of CERCLA.. Even with the excavation of the Pit, response
actions for the entire WOe: Site (adequate cap, ground water
extraction and treatment system, gas monitoring, ground water
monitoring. NAPl monitoring) a~ necessary, in laroge part due
to the disperse and unknown pattem of past wast! disposal.
Containment of Pit wastes. in combination with the other
response actions. will accOllplish the same overall Objectives
as excavation of the Pit. Excavation'of the pit would only
eliminate the need for a slurry wall about the Pit. Because of
the obvious safety concems. disposal difficulties with
excavated wastes, high cost (S6.3million), and remaining need
for other response actions, the effectiveness of excavation is
minimal. However, sCXll~ control of the release fran the Pit
would be effective in reducing the existing impact on Coon
C reelt and mi t igate any NAPL ~l eases' that may, occur. . A. sl u rry
wall around the Pit, with its o.m ground water extraction
system and NAPt. monitoring/extraction SystSll,. will minimize the
continued release beyond the Pit and will avoid the severe
safety risks and disposal problens faced with excavation.
A wide variety of capping alhmatives were evaluated. The
fact that the site is a fonner, but reeently active landfill,
necessitates the use of flexible, self-healing caps to cope
with differential settlenent. This condition Nlts out the use
of non-flexible covers (cement, asphaltic - concrete, soil
admfxtur-es). The fact that hazardous wastes were dispose<! at
the Site throughout the landfill justified the need for a cap
meeting RCRA r-equirements, thus Nling out conventional
27
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1 andfill caps. However'. the pnesence of UP to 8 feet of 1 ime
sludge over the Site poses difficulties in placing a new RCRA
cag. Removal of the 1 ime sludge would nesult in a disposal
pro~lem of the lime sludge and potentially expose waste. On
the other hand, the lime sludge has very low hydraulic conduc-
tivity (10-5 to 10-6 em/sec) and excellent self-healfng
properties. The~ is a tremendous advantage to incorporating
the lime sludge into a RCRA design ca~, The cap will consist
of a minimum of 36 inches of stabilized lime sludge, overlain
by a 12-inch sand 1 ateral drafnage layer, overlain by a 30- inch
layer of general fill, and completed with a 6-inch layer' of
topsoil that would be vegetated (see Attachment 17). The
Remedial Design will incorporate some adjustments in surface
slope, slope of drainage layer', grain size of fill, and
thickness of lime sludge in order to meet RCRA performance
standards.
The cap will completely cover the presently defined limi:s of
waste disposal (73 acnes) and will incorporate the existing
lime sludge that would otherwise have to be disposed. It will
minimize the migration of.liquids, provide excellent
rodent/vector control, el iminate exposed was:es and leachate
seeps. The fact that there ane wastes ~elow the water tat:l1e
and liquid lIIastes (bulk. and containerized) wene disposed
throughout the landfill necessitate the need for extensive
ground water extr'action and tneatment whiCh, in tum, may
provide some, flexibility in cap design and performance.
As noted earl ier, ground water in the Upper' Sand aquifer
is seriously contaninated and is entering Coon Cneelc, adversel y
affecting the quality of Coon Creek. Wastes are disposed belolll
the water table and liquid wastes (bulk and containerized) and
sludges were dumped throughout the landfill. Although the most
serious contanination detected to date fs associated with the
Pit, monitoring wells located within the landfill have
identified other, scattered -hot spots-. There are certafnly
expected tab.. many more",unidentified and. unlocated hot spots
buried in ug to .40 feet of waites. Because it is impractical
to locate and. control all potent.ill hot spots, an overall site,
grounc1 water renedyis required.
. .
The ground water extraction system is the only effective means
of prev.nting contol1linated ground water f/"Ol1l entering Coon
Creek. The us. of a drain system is not'as effective as
extraction wells (particularly for potentill NAPL) , more
difficult and costly to insta", and IlIOI"t prone to
deterioration and failure than extraction wells. Wells can be
installed quickly and easily, have a proven I"tliabil ity, I~
easily repajred or ~plac:ed if they do fail, can be us11y
adjusted in terms of performance, and do not pose the risk of
encountering wastes that exists with trenching.a drain system.
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Not only will the ground water extraction system prevent
cont~inated ground water from entering Coon Creek, it will
also inCr"!ase the difference of hydraulic potential between the
Lower Sand aquifer and Upper Sand aquifer and enhance the
upward gradient,. further minimizing the potential for
contaminants to migrate downward.
Excavation of the Pit has al ready been discussed. Excavation
of the enti re landfill (over 2.5 mill ion cubic yards of wastes)
was viewed as impracticable for laCk of disposal options,
extr-emely costly (S48 mill ion for excavation alone), and
extr-emely hazardous due to scatter"!d presence of the
equivalence of 60,000 to 100,000 barrels of hazardous wastes
plus unknown quantities of other special wastes or infectious
wastes.
VI I. Recommended AHemative
A. Descriotion
"
In order to control and prevent all existing releases from the
Site (Coon Creek discha~e, leachate seeps, exposed wastes) and
potential future releases (ground water contaminant migration,
'1:'PL generation/migration, gas migration), a number of
different remedial altematives are necessary. The
altematives include ground water extraction from the- Upper
Sand for the enti re Site. ai r stripping/carbon treatment of the
conta'llinated ground water and likely diseha~e- under an NPOES
pennit. slurry wall around the Pit with its own ground water
extraction system and NAPL monitoring syste"l, and a cap over
the entire Site incorporating the existing lime sludge covering
the Site and meeting RCRA r-equi renents, and long-tenn
monitoring of the Upper Sand and Lower Sand aquifers.
The ground water extraction systell w111 consist of six
eig ht- i neh well s. se r-eened- throughout the enti,.. saturated
thickness of th~ Upper Sand. pumping approximately 10 gallons
per minute c:ontinuously, and. located' betweeltth~.1andfi11 anc1
Coon Cr-eek (see Attachment 18). Th~ extraction systell w111
effectively intercept all c:ont511inated. grounc1. lIIater migrating
frail the Site in the Upper Sanc1 aquifer and c:urr-ently entering
Coon Creek. The grounc1 lIIater removed by the systtm would be
treated. using ai r stripping or activated c:arton or both
depending upon the actual hydraulic and c:hSllical loadings and
HPOES limitations (other pretreatment may be necessary). The
preferr-ed discha~e would be to Coon Creek meeting NPOES
pennit requirements. Final decisions on the tr-eatment and
disposal options must await detailed design. pilot testing.
and pennit requi rements. The extrac:tion system will be active
indefinitely. and will groeatl)' reduce. if not eliminate, an)'
loadings to Coon Creek and prevent contamination of those
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private wells north of Coon Creek. Nonnally, ground .ater
remedial systems are active until all ground water that is
moving beyond a Site boundary, at the very least, meets
drinKing water standardS. The ground water in the Upper Sand
is so severely contninated and the releases 101111 be ongoing
fl"Otlt scatteM!d sources in the Site for an indefinite period,
pM!cluding any chance of shutting down the system .ithin a
projected time frame.
The Pit is the current major source of contaminant loading to
the Uppel" Sand aquifer arrd to Coon Creek. The Pit also has the
highest potential for NAPL generation, although no NAPL has
been clearly detected to date. In order to provide confine'l1ent
of any potential NAPL that might be released and maximize
removal of heavi1y-contcJ1linated ground water, a slurry wall
will be installed c~pletely around th~ Pit (Attachment 19) and
keyed into the existing red-brown till. The slurry wall will
be a soil.bentenite mixtu~, at least 2 feet thick, having a
conductivity less than 1x10-7 ~/sec. The slurry .all is
designed to trap releases' from the Pit for recovery via the
extraction well, manhole pumpout., and NAPL recovery wells. An
8-inch extraction well will b~ installed on the- upg radient end
of the area. enclosed by the slurry wall,. will pump an estimated
90 gallons/day to maintain a lower piezometric level .ithin the
slul"I"Y wall and an inward gl"adient across the slurl"Y wall.
Maintaining ,the inward gradient will minimize the migration of
dissolved contaminants across the sl urry wall. Extracted
groundwater will be treated with the rest of the boundary
groundwater extraction system.
/
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The extraction ~ll will be screened about 10-15 feet below the
water ta~le. The existing manhole is completed to the bottom
of the Pit. Any liquids detected in the manhole will be pumped
out to minimize liql.lid reluses frpm the Pit. NAPL monitoring
wells (4 well nests. of' plit"td welis) will be locatede outside-
the Pit but wit~in the slurry will. The wells will be equiped
. with sumps for NAPe: detectio~anct recovery. On..' well of each
pair will b~ completed at the- top' of th. grlY till Ind the
othel" wen It the tOIT"of' the- red-till. My NAPt.will be-
recovered using these wells (see Attachment 20).
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The Clp over the entil"t' site. will consis,t of lime sludge that
largely covers the 73-acre site 11 ready. Tlle 1 ime sl udge has a
hydraulic conduc;t1vity on the order of 10-5 to 10-6 en/see.
The intent is to meet RCRA perfonnance standards. The 1 ime
sludge will be graded. stabilized. and cOft'lpacted to achieve I
thickness of at least 3 feet. overlain by a 12 inch Sind
drainage layer (hydraulic conduc:.tivity of greater than 10-3
em/sec.). I geotextile filter fabric. 30 inches of fill. and 6
inches of topsoil with a grass vegetation cover. Tlle surface
slope will be at least 3.5 percent. Altogether. 48 inches of
fill will cover the lime sludge zone. . The lime sludge is
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sel f-hea1 ing when it does not becO'lle dessicated; which is tMe
condition currently exist..ing in po~ions of the Site. The 48
inches of cover over the lime sludge will maintain adequate
moisture to maintain the lime sludge (just like a clay layer),
will prevent erosion of the fine grain lime sludge, and will
provide protection from frost heaving. The Rl!lIedial Design
will require fu~her permeability tes~ing, and adjustments to
surface slope, slope of drainage layer, grain size of fill, and
thickness of 1 ime sl udge in order to meet the RCRA performance
standards. Institutional controls (deed restrictions) will be
required to prevent installation of drinking water wells or
other action which could jeopardize the integrity of the cap.
Gas generation and migration (both for methane and for specifiC
volatile organics) has been doctJllented, pa~icularly west of
the landfill. Gas vents will be installed below the lime
sludge layer through to the surface. The gas vents will be
fitted with granular activated carbon filters to remove organic
contaminants (see Attachment 21).
In order to monitor the effectiveness of the response actions
and to ensure c:ontaninants do not migrate into Coon Creek,
beyond Coon Creek in the Upper Sand -aquifer, into the LOloler
Sand and gas does not migrate in tne unsaturated zone, an
extensive array of gas probes, ground water monitoring wells in
the Lower Sand aquifer and Upper Sand aQuifer, NAPL monitoring
wells in the upper Sand aquifer, the manhole in the Pit, and
sampl ing points in Coon Creek will be monitored. Any Coon
Creek di scharges would be monitor-ed as par-t of HPDES permit
reQuil"l!llents. Monitoring stations will be located on all sides
of and within the landfill and will include approximately 28
ground water monitoring wells, 10 HAPL monitoring wells, 3
surface water stations, 10 gas probes, the manhole in the Pit,
and selected, but as yet, undetermined nUllber of private ~lls
(see Attachment 21). The monitoring system will ,assess the
effectiveness of ' the response actions already discussed and
will monitor all routes of C4[l"!!nt I"l!leases (Pit I"!! 1 ease'
t,oward~ Coon Cl"!!ek and potential 1"l!1eases of NAPL).
In order to enhance the monitoring network for HAPL migration
,. beyond the Site) to deal with the' concem of multiple.
unlocated sources - .hot spots.). geophysical surveys will be
conducted along the perimeter of the landfill (SOO-foot radius
about the landfill) in order to identify low al"!!as in the till
for placement of NAPL monitoring wells.
A related response action involves filling wetland areas
between the, landfill - and Coon Creel: because they do receive
seepage intermittently from the Site. In order to discourage
migrating water fowl and other wildlife from inhabiting this
area, the wetlands will be filled in accordance with applicable
U.S. Army Corps of Engineering (COE) and U.S. Fish and Wildlife
31
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Service (F\lt,) requi r-ements, including mitigation. The actual
location(s) of any ne~ ~etlands must be negotiated bet~een the
City of Andover, AnoKa County, the Minnesota Oepartment of
Natural Resources, MPCA, FWt" COE and U.S. EPA.
B. Costs
-
The costs of the I"!commended altematives for response actions
are broKen down into capital costs (generally constr'\Jction or
requisition costs), operation and maintenance costs, and a
tot alp resent wo rth cost (10 pe rcent discount rate and 30 yea r
1 ife).
The costs are delineated for each comp:lnent of the response action
as follo~s:
Present Worth
Caoital Costs o & M Total Present Wo!",:h
Ca:oing of Site S8,196,500 S235,673 S8,432.173
Ground ....ater
Ex~ra': ion
Construct ion 812,000 41,478 853,478
Treatment
Ca roon i reatment 91,000 470,138 561,138
Air Stripping 84,000 44,306 128,306
Oi sposa 1
Coon Creek NPOES 28.700 - 381,789 410.489
" 'Sl u~ry Wall 'With ....,..r. - .. -~''''':.''.'...;'.'-''
Extraction Well 302.723 86.308 389.031
Site Monitoring 70.000 647,529 717.529
Fill i n9 of Wetl and 3,837 -0- 3,837
Total 9.504.796 1.862.915 11.367.675
(for carton treatment
and Coon Creek dhposal)
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VII. Aoplicabl@ or :ielevant and Aopreoriate Reauirements
A. Gen@ral Discussion
Section 121(d) of SARA requires that remedial actions ccrnply
..itn legally applicable or relevant and apprepriate
requi rE!T1ents (ARARs) of Federal envi rorrnental la..s and more
stringent, promulaged State la..s.
.Appl icable. requi r"ellents are cleanup standards, standards
of control and other substantive envi ronmental pretection
requi r-e:1ents, criteria or limitations promulgated under Federal
or State la.. that specifically address a hazanious substance,
poll utant conta'llinant, renedial action. location or other
cit"Cumstance at a site. A requirement is "applicable" if the
r?lIedial action or ci ro=lJlIstances at the site sati sfy all the
jurisdictional prerequisites of the requirement. .Revelant and
appropriate" requi renents are cleanup standards, standards of
cont rol and other envi ronmental protection r-equi rements,
criteria or limitations promulgated under Federal or State law
that, ..hil e not. appl icable. to the. remedial action or
ci f'ClJlIstances at the site, address problE!T1s or situations
sufficiently similar to those encounter-ed at the site that
their use is ..ell suited to the remedial action at the site.
Non-promulg'ated advisories or guidanc@ documents issued by
Federal or State govemnents do not have th~status of
potential "RARs; however, where AAARs do not exist, or for some
reason may not be sufficiently protective, non-pronulgated
advisories or guidance documents may be consider-ed in
determining the necessary level of cleanup for protection of
human health and the environment. See Int@rim Guidance on
Canpl i anc:e with Appl icable or Relevant and Appropriate
Requirements dated July 9, 1987. State of Minnesota
Recomended Allo..atlle Limits (RALs) fall into this cat@9ory.
This section identifies the requirements of environmental laws,
regulations and polices that aN! applicable or relevant and
approprhte standards for- the recOtllllended Iltemative for
remediating the site.
Ground water protection standards have been establ ished under
RCRA, at 40 CFR Section 264.94. RCRA regulat.ions apply to
facilities treating, storing and disposing of hazardous waste
as of November 19, 1980. Such facl1 itfes ..ere requi red to
apply for an operating permit by that date. Such facilities
are further requi red under Section 3004(u) of RCRA and 40 CFR
264.101 to institute .correctlve action. as set forth in the
permit, to remedy N!leases of hazardous ..ute and constituents
fran any .solid waste managE!T1ent unit. at the facility. The
g round water protection standards at 40 CFR 264.94 are to be
established in permits and apply to Iny solid waste management
33
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units ..hich received ..aste after July 26, 1982. The ground
..ater standardS serve both as a trigger for requi ring
corr-ecti...e action to remedy a release from such a solid dste
management unit, and as clean-up standards for the corrective
action. Ho..ever, because no hazardouS ..aste ..as placed in this
ar-ea after July 26, 1982, the ground water protection standardS
of 40 CFR 264.94 are not "applicaole"-under RCRA to this solid
..aste management unit. They may, ne...ertheless, be "rele...ant
and appropriate" as clean-up standards for this 9round ..ater
rem ed i alae t i on .
There are three types of standards established under 40 CFR
254.94: Sacl:ground levels, Listed Maxim~ Concentration Limits
and Altemate Concentration Limits (ACLs). The regulations
specify that the standard for concentrations of hazardOUS
constituents in ground ..ater in a facility permit must not
exceed the bac I:g round 1 e...e lor a 1 i sted max imum concent rat i on
limit or an ACL established by the Regional Administrator.
1. Listed Maximl1'l Contaminant Levels. To date, Ma):.im~ Concentration
L1m1ts under RCRA have oeen estaolished for fourteen Chemicals.
These limits are based on and a~ identical to the Safe Orinl:ing
Water Act MCLs for theSe chemicals. None of these listed Chemicals
are contaminants in the ground dter at the WOE site.
2. Bacl:ground Levels. The bacl:ground level is that level of a
cnemical 1n the ground water in an area not impacted by
cont/l'llinants in the ground ..ater at the WOE site.
3. ACLs. U.S. EFA may establ ish ACLs in lieu of bacl:ground level s or
listed maximum concentration limits of the ACL "will not pose a
substantial pr-esent or potential hazard to human health or the
environment as long as the [ACL] is not exceeded." 40 CFR
264.94(0). .
\,.,
Standards for specific contaminants have been promulgated under
the Sa'. Drinking Water Act r,sOWA) to protect public drinking
..aur systl!!llS. Standards set under the SDIlA are usually
relevant and appropriate when groundlolater is being cleaned up
at Superfund sites. Since this remedy creates an hydraulic
barrier to prevent movement of cont/l'llinated 9 roundlolater to off-
site ar-elS. the remedy would comply with. the SOWA and RCRA
corrective action requi renents. Under RCRA. the point of
compl iance woul d be set at the land fill bounda ry (at
groundwater extraction system). The SOWA standardS are not
AAARs for on-site areas in this case. since institutional
controls will prevent any potential use of the cont/l'llinated
groundwater.
The Federal Clean Water Act (CWA). 33 U.S.C. '1251. et. sea.,
as a'lIended. requi res U.S. EPA to establ ish water quail'ty-
criteria for bodies of water. based on effects of pollutants on
,
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human health and aquatic life. 33 U.S.C. 1314. Section 121
of CERCLA states that r-emedial actions shall attain these ..atH
Quality criteria whe~ they a~ r-elevant and appropriate under
the ci rcumstances of the ~lease, based on the usage or
potential usa;e :,f the ,tater r-eceiving the r-elease. By
el iminating contaminated grounddter discharges the selected
remedy will assur-e continued maintenance of these criteria in
Coon Cr-eeK and should result in attaimlent of these criteria in
the ground..ater north of Coon Cr-eeK (methylene chlorid~
presently exceeds criteria. The existing concentration of
contaninantS in Coon Cr-eeK should be brought well below the
10-5 risK levels and other freshwater criteria established
under the C\oIA.
ihe Federal Clean Water Act limits construction activities in
floodplains and ..etland through Section 404, The Army .COr-;lS of
of Engineers administers these r-equirements through permits.
Since the proposed response action will involve construction of
a cap in the floodplain and the filling of wetlandS, compliance
with appl icable permit requi rements establ ished by the COE, F\lL
and U.s... EPA, including mitigation, is appropriate.
(
The Federal Clean Water Act limits discharges to watenoays.
Individual discharges ar"! regulated through National pollutant
Discharge El imination System (NPDES) permits. (40 CF'R Part
122) the State administered water quality progr!'ll is
substanti ally equivalent to the Federal NPDES r-equi rements.
The discharge limits established in the NPDES permit process
are designed to preserve the present use designation of the
r-eceiving waters and potential do.."str-eam uses. Coon CreeK is
currently designated as a partial body contact, warm water
fiShery. The N?DES r-egulations a~ an ARAR for effluent from
Superfund site t~atment plants which discharge offsite. Water
quality-based NPDES permit limits will be based in part on
stre/lll criteria and may include mo~ stringent limits or whole
effluent toxicity limits to protect against interactive effect
of toxicants. NPDES permit limitations wnl be re~uired for
di scharges of treated groundwater to Coon Creek.
During the design phase of the project the potentiAl fo~
discharge to the PaTW wl11 be examined further. In order to
discharge from I Superfund site to I POTil. certain factors" must.
be considered which are identified in a policy memorandum dated
April 15. 1986. .Cischarge of Wastewater frem CERCL~ Sites into
POTWs. from Henry L.. L.ongest. Oi rector. Office of Emergency and
Remedi al Response. Rebecca Hanner. Oi rector. Offic. of Water
Enforcement and Permits. and Gene Lucero. Director. Office of
waste prograns Enforce'llent. to Waste Management Civision
Directors, Regions I-X. These factors are listed below.
(1) potential of pollutants to cause pass through or interference.
including a health hazard to e'llployees at the POTW.
.,~)
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(2) The ability of the POTW to ensure cO'llpliancE! with
acpl icablE! treatment standards and ~qui rements.
(3) The POTW' s ~cord of CO'llpl iancE! with the NPDES permit and
pret reatment prog ram requi rements.
(4) The potential for volatilization of thE! wastewate~ and its
impact upon air quality.
(5) The pountial for ground water contamination from
transpol"t of CERCLA .aste.ater to the POTIl, and the need for
ground water monitoring.
(6) The potenti al effect of the CERCLA waste.aurs upon the
POTW's discharge into receiving waters.
B. Site Discussion
(
The overall objective of any ~sponse actions a~ to
permanently or significantly /"'educe the vol\$l1e, toxicity, or
mobility of the hazardous substances, pollutants, o~
conta'llinants. However, dealing wiUt sites on the scale of the
WDE Site (equivalent of 60,000 - 100,000 barrels of hazardOUS
.astes within 2.5 million 'ubi, yards of solid waste) is
extremely difficult, pal"ticularly in regard to reducing the
volume and toxicity. Although excavation of the Pit may
potentially reduce the volume and toxicity of hazardous
substances, the Pit does ~present only an estimated 10 percent
of the hazardous substances disposed at the Site. The
t"l!'l1aining wastes are scattered throughout the 1 and fill. The
nature of the Site is such that ~sponse actions must deal with
the Site in its entirety and, therefore, focus on controlling
the mobility of the hazardous sub1tances. The lime sludge cap
is designed to isolate the wastes fnom di~t contact, to limit
the mobilizatfon of liquidS and generation of leachates. and
control gas migrat~ort. It sltould meet RCRA performance
requirements and will incorporate the existing lime sludge
cover at the Site. The cap does satisfy HPCA requi/"8'llents fo~
general landfill caps and Anoia County I"!quirements for cap
c1osur"fs. This cap will also need'to satisfy the Sutlc closure
requirements for the SW-ZS penuit issued in 1971.
If the 11me sludge cap we~ not utllzed IS a CIP. the
excavation and disposal of tht lime Sludge-will be I
significant problem in and of itself. in addition to concems
about exposed wastes and physical hazlrds.
The ground wate~ extraction system \till require carbon treat-
ment and/or air strippi"9. with I discharge of the treated
effl uent to Coon Creek. The ground \tater extraction cOntp:Jnent
is the primary mechanism for eliminating the mobility of
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hazardous subs~ances from the Site. These hazardous substances
are currently impacting Coon Creel: and SO'Tle ground .ater beyond
the cr-eel:. The ground water extraction system will prevent
contaminants from migrating beyond ~he no~hern fringe of the
Site, eliminated the contamination in the Creel: and beyond the
Site. The existing concentrations of contaminants should be
brought well below the 10-6 M sk Water Qual ity Criteri a for
contaminants in Coon Creel: and below ~he Maximl.ll1 Contaminant
Level s, Water OJal ity Criteria, and Minnesota RecolT1'Tlended
Allowable Limits for ground water north of the creek.
The ai r stripper will have to have cartlon treatment for the
exhaust because SO'Tle of the volatile organics aroe considered
car-:inogenic. Additional troeatment trains may need to be
evaluated and implemented to meet the Objectives of the NPQES
pe nn it requ i r-ements.
Spent cartlon from the ai r stripper as well as from the caroon treatment
of ground water will be handled as a hazardous waste under RCRA
reg ul at ions.
The discharge from the ground water extraction system will lil:ely go to
Coon Creel: unde r an NPDES pe nn i t requi renents estab 1 i shed by the MPCA
and with the approval of the Coon Cr-eel: Water5hed District.
Appropri ations approval from the Minnesota Department of Natural
Resour-:es f.or the extraction of contaminants wi 11 be requi red. The
wells must comply with the Minnesota Water Well Construction Code.
In the event that an NPDES pennit roequi r-ements cannot be achieved, t~e
option of disposal to the sanitary sewer must be seriously considered.
However, the Ci~y of Andover has strongly objected to this option and
the MWCC has expressed reservations about allowing long-tenn discharges
to the sanitary se~r systen because of the roelatively dil ute
wastewater (roelatively low sol ids.) and the proesence of a wide variety
of organics. This Record of Decision wilt be modified in the event
that discharge to the sanitary Sewer is recollTllended as a roesult of
future remedial design activities.
The slurry 'ltall 'ltith ground 'ltater extraction and KAPL monitoring
and extraction for the Pit do not n~essarny have any particular rules
or regulations that directly apply to the altemative other than those
already applicable to the overall ground 'ltater extraction systen.
The filling of the wetlands (about 2 ICroeS in total) south of
Coon Creek 'ltill be conducted considering appl icable IJ.S. Army Corps of
Engineers roequirenents and input ft'OCll the Department of Natural
Resources. Mitigation, such as roeplacenent, can be required by FWS,
according to ellA, section 404, provisions.
The construction of the ne'lt monitoring wells and extraction wells
must be in accordance to the Minnesota Water Well Construction
Code.
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I X. Enfo r:ement Status
The WOE Site is located within the city limits of Andover (fonne,.ly
Grow TO.rlShip), Anol:a County. Prior 40 1971, the WOE Site was operated
as a solid waste dUllp for at least nine years. The dump was
established by Leonard E. Johnson and was licensed by Grow Township.
The dUllP was purchased by WOE, Inc. in 1968. A pennit to operate
as a sanitary landfill was granted by the Grow Township Board
effective mid-year, 1968. In 1970, WOE, Inc. submitted a pennit
aoplication for the MPCA to operate a solid waste disposal system.
Included in this application was a proposal to dispose of
hazardous substances in a specially constnJcted trenc,,, in the landfill
(generally referred to as the .WOE Pit.). On March'3J, 1971, the MlleA
issued a pennit (5\0/-28) to WOE, Inc. to operate the WOE Site as a solid
waste disposal system including constnJction and operation of the WOE
Pit. Approval was also given by Anol:a County and the Metropolitan
Counc i 1 .
Const nJction of the WOE-Pit was completed in 1972. The MPCA ordered
the WOE Pit closed effective FebnJary I, 1974 due to changes in
regulations and because the MPCA detennined that a high potential for
ground water pollution existed at the WOE Site. That detennination was
based on the fact that: WOE Inc. submitted inadequate hazardous waste
disposal reports, WOE, Inc. did not subnit requi~ monitoring results,
and investigation indicated that WOE, Inc. did not foll~w the plans
approved by the MPCA for the WOE Pit disposal operations.
WOE, Inc. sent a notification of a Hazardous Waste Site regarding the
WOE Site to U.S. EPA in June, 19B1 in fulfillment of CERCLA 103(c).
Pursuant to section 105{b) of CERCLA, the WOE Site was listed on the
National Priorities L.ist by publication in the Federal Register on
September 8. 1983, 48 Fed. Reg. 40658-40682 (1983).
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The Minnesota Department of Health in January, 1983 issu~ a drinl:ing
water well advisory in portions of the city of Andover due. in part, to
haurdous substances disposal at the WOE. Site,. The well advisory WI$..
dropped following the ccrnpletion of the Rl!Illed1ll Investigation for the
Site in ()c;tober. 1985.
In March. 1984 the MPCA and U.S. EPA entered into I Consent Order with
9 cQ'llpanies. Three more canpanies joined the group Ind uecuted the
Consent Order in April. 1984. The twelve companies (t.nollfl IS the
-Respondents- in the Consent Order) I~ Econcnics L.aboratory. Inc.,
Ford Motor Canpany. Honeywell t Midland Cooperatives, Inc., Mineo
products, Onan Corporation, Sperry Corporation (Unisys). Thermo King
Corporation, Warden Oil, Control Dati Corporatfon, Comelius CQ'lIpany,
and FMC Corporation.
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ihe Respondents agr-eed in the Consent Qr-der to accOllpl ish the fo11o..ing
tasks:
1. Design, initiate and complete the landfill and pit ilemedial
Investigation/Feasibility Study (RI/FS);
2. Establ iSh a trust fund to pay for the RI/FS ..ork;
3. Estaolish a Sl million trust fund in the event the Respondents
do not implement the remedial actions as selected by the M?CA and
U.S. EPA;
4. Design the selected response action for the ilOE site designated in
the U.S. EPA Recor-d of Decision; and
5. Enter into good faith negotiations leading to an agreement to
addroess remedial and removal actions at the 'tiDE Site.
Under the Consent Or-der the M?CA and U.S.E?A ag~ed to:
"
1. Identify additional potential r-esponsible pe~ons ..ho are not
currently parties to the Consent Order;
2. Issue ;lequests for Response Actions (RFilA's) to additional
roesponSible pe~ons; and
3. Issue Detenninations- of Inadequate Response (DIR's) to each of
the responsible pe~ons who have failed to respond or ..ho roespond
inadequately.
In partial fulfillment of obligations under the Consent Qr-der, the 1"?CA
issued a RFilA to seven responsible persons in July, 1984. These seven
included Melron, Inc. (property owner), Ronald Roth (part owner of
Mel ron, Inc. and operator of the 'tiDE Site), Waste Control, Inc.
(WCI.transporter), Art Willman & SOns, Inc. (transporter), Industrial
Steel Container (owned or possessed hazardous substances and arranged
for thei r disposal), and Whittaker Corporation (owned or possessed
hazardOUS substances and arranged for thei r disposal). Each of the
parties named as responsible persons in the July, 1984 RFRA fail ed to
talce the requested acttons and were subsequently issued a DIR in
October, 1984.' .
In April, 1987, the MPCA again issued a RFRA to seven addittonal
responsible persons. These seven included American Can Company, G & K
Ser"'t'ices, Inc., Gillette Company, H.B. Fuller Company, Minneapolis
Electric Stul Castings Oivision.Evans Product Company, 500 Line
Rail road Company and Union Brass and Metal Manufacturing Company.
These pareies were issued a RFRA because they owned or possessed
hazardous substances and Arranged for the disposal or transport for
disposal of thon substances at the WOE Site. Each of these compantes
have agreed, in writing, to talce the requested actions by notifying the
M?CA that they intend to n~otilte in good fatth regarding
participation in implementation of remedial actton at the WOE Site.
In September, 1987 the MPCA issued a RFRA to twelve additional
responsible persons. Thes. twelve included M1erican Hoist and Derrkx,
Brandtjen and Kluge, Dworslcy Barrel, Federal Cartridge Corporation
(Federal.Hoffman, Inc.), Foley Manufacturing Company (Foley.Belsaw
.,J
39
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C:l~pany), Frost Paint and Oil Corporation, Gl idden Paint, Mogul
Corporation, Hor-thwest Airlines, PaKo Corporation. Saxon Industries,
Inc. (Paper Corporation of Mlerica) and \lhi r1 pool Corporation.
'.
The MPCA and U.S. ErA shall intend to be;;n ne;otiations to enter into
a Consent Decree with the ~sponsible par-ties. The major uSK to be
accompliShed in the Consent Decree is the implementation of the
renedial actions.
X. Ooeration and Maintenance:
There a~ many operations in the proposed remedy which must be
maintained. These include the following:
A. Operation. maintenance, and monitoring of ground pump-out
we 11 s:
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1. in a line along the nor-them perimeter of the site
to conuin and r-emove cont.tninated groundwater. and whiCh
will also be beneficial in maintaining the upward gradient
between the Upper and Lower Sand aquifer"S at the Site, and
2. within the slurry wall around the Pit to maintain an
inward ,gradient and to remove cont.tn;nation 1f necessary.
B. Operation. maintenance, and monitoring of the extracted
g round water t ~atment systl!ll, wh; ch i $ expected to be c aroon
ab so rpt ion.
C. Mon i to ri ng of the discharge of the co 11 ect~ gl'Oundwate r,
expected to be to Coon C~eK in accordance with an HPDES permit.
l
O. Operation. maintenance, and monitoring of the landfill
gas vents to Ivoid gas accumulation under the landfill cap.
E. Maintenance'of the landfill cap to maintain a cover over
waste--mater1als, to eliminate seeps, to I"tduce infiltration through
. waste materials and .to prevent use of the underlying groundwater.
F. Monitoring of ground water, surface water, potential
NAPL routes, and gas within the landfill to assure the
effectiveness of the response actions.
G. Maintaining institutional controls prohibiting wells in the
Upper and Lower Sand aquifer"S near the Site to avoid use of
contaninated water and to maintain a vetical gradient across
the red/brown till is being recOll1l1ended IS a pr!cautionary
measu re. These act ions c an be imp1l!llented by the State throug h
the Minnesota Department of Health, through thei r approval
rights over installation of new drinking water wells.
~.,
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~I. C~unity Relations History:
Since 1983, the MPCA and U.S. EPA nave been involved in nu~enJus
COr:r.lunity r!lations activities associated with the WOE, Inc. Site.
The major cormtunity r!lation r!lations activities include the
following:
April 1983
May 1983
Oct. 27,1983
November 1983
Nov. 10, 1983
Mal". 23, 1984
June 18, 1984
June 1984
June 25, 1984
Sept. 27, 1985
Oct. 9, 1985
Oct. 25, 1985
Feb. 7, 1986
Mal'th la, 1986
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The HPCA conducted cOrmtunity interviews with local officials
and interesad residents.
The ~PCA p/"'!I:la/"'!d a COtTrnunity Relations Plan for the
anticipated fund-financed ilenedial Investigation/Feasibil ity
Study.
7he ~~CA issued a news release announcing a pUblic meeting
and the beginning of a Superfund project.
Tne HPCA prepared a fact sheet providing bacKgnJund on the
Site.
The U.S. EPA .and MPCA participated in a publ ic meeting at the
Andover City Hall and discussed the Superfund project.
The U.S. EPA issued a news roelease announcing t~at agreement
had been roeached on the terms of a Consent On:ler.
The MPCA issued a news release announcing a pUblic meeting
and the beginning of a responsible party investigation.
The MPCA prepared a revised fact sheet providing bacKgnJund
and hi story of the Site"
The MPCA sponsored a public meeting at the Andover City Hall
to discuss the Consent Order and investigation plans.
The MPCA issued a l'T!ws release announc.ing a public meeting
and completion of a draft Rsnedial Investigation report.
The MPCA sponsored I public meeting on the Renedial
Invest igat ion report.
The MPCA issued a news release regarding the revised Remedial
Investigation report.
The MPCA issued a news 1"!1ease I"'egarding the completion of a
draft Alhmative Reports.
Meeting on Altematives Report held with Anoka County
Commissioners and Andover City Council.
41
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May 1, 1986
The MPCA issued a news ~lease announcing a public meeting to
provide a project update.
May 1386
The ~P:A ~~e~a~d an updated fact sheet which included
investigation M!sults and a list of alternatives being
considen!d. The fact sheet (and a public meeting
announcement) was delive~d door-to-door by menbers of the
cOlTlllunity.
May 14, 1986 The MPCA spOnSOM!d a public meeting at the Andover City Hall
as a project update.
June 16, 1986 Tne MPCA p rov i ded an upda te to the staff and menoe rs of the
Coon CM!eK Watershed District.
act~oer IS, 1986 Meeting held with officials of th~ City of Andover, Anok.a
County. MPCA, and rep r-esent at i ves of the SW-28 G roup to
discuss the Detailed Analysis Report.
Sept. 3. 1987 The MPCA issued a news r-e1 ease announcing the n!colTlllended
alternatives and a public meeting.
Sept. 8, 1987
The U.S. EPA sponsored an ad in the Minneapolis daily paper
which included the meeting date and the necommended
a1 ternat ives.
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Sept. 14, 1987
The U.S. EPA and MPCA sponsoned a publiC meeting at the
Andover City Hall to discuss the M!colTlllended alternatives.
Throughout the project, M!ports and fact sheets weM! made available at
the Andover City Hall. During the latter half of 1985, when
investigation nesults ~ne coming in, 'a number of meetings were held
with city and county officials to M!spond to their questions on the
find i ng s.
c
Throughout the course of the RI/FS, the MPCA, Anoka County, and City of
Andover- officials. have discussedolt, art individual. basis with many
private citizens. Approximately 75 private citizens ~re- on a M!gular
mail ing 1 ist to reeeive all fact sheets and news ~leases and all
aspects of the. RI/FS and ~lated activities.
In apdition, a number of news publications have M!ported major
findings, develop-nents, or decisions throughout the RI/FS process.
City of Andover and Anoka County officials have been invited to and
actively participate in- discussions and meetings with the SW-28 Group
throughout the RI/FS process. They have also commented extensively on
the submittals related to the RI/FS process.
These actions will be implemented in accordance with applicable laws
and regulations.
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MH-EAPO...tS. M~SOTA
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PROPERTY OWNERSHIP MAP
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,
SCHEMATIC
figure 2. 7
CROSS SECTION OF COMPACTED LIME SU..oGE CAP
MEETING RCRA PERFORMANCE STANDARDS
WOE', Al1d()~~r, Minn~S()I()
U .,..,..
T.u~t 3.5
,1.
COMP~~ISON OF SOIL PROSt G~S ~~YSIS ~O TLV(ll v~utS.'
'-
.
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In~icator Chemicals and
Other Chemicall Re?o:~ed
in Ca. Probe sa~oles(2)
Hi9hut
Coneltration in
Soil Cas (po~l
,.
TLV (ClClrr,)
f
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1,1 D1chloroethane-
1,2 Dichloroethene"
1,1,2_Trichlorotrifluoroethane-
l,l,l-triehloroethane-
Methyl ethyl ketone
Methyl Isobutylketone-
Dichloroethane
Toluene-
Xylene-
Methylene ehlori~e
Aeetone
Tet rahydrofuran
1,1 Dichloropropene
Ben~ene
Di~romochloroDethane
1,1,2 trichloroethane
l,l,2,2-Tetrach10roethane
Triehloroethene
1,3 Dichloropropene
Ethyl~en%.ene
Cumene
Ethyl ether
200
200
1,000(3)
350
200
50
10
100
100
350
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200
10
1
50
1
100
50
400
NO (4 )
NO
1. 30
NO
0.16
0.37
0.12
9'.52
2.18
0.07
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0.17
0.74
2.47
0.93
0.92
5.4, 5
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1. 74
0.27
1.41
0.16
.
Indieator Chemical.
._ Thi. follow. .ethodo109ie. of Section 4.3 of the Manual
.
(1) TLV _ Threshold Li.it Value. fro. ~re.hold Li.it Values
and 110109ical Exposure Indices for 1985-86" American
Conferance of Coyernmental Industrial Hygienist.
(2) Highest concentrations 1n sample analy:ed.
(3) TLV aYail.~le for 1,1,2-trichlorofluoroethane.
(4) NO. Not detected in loil pro~e ga..s
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fi;ure 226
.
GROUNOWATER EXTRACTIOO
WELL LOCATION - LANDFILL
W 0 =, At'1d()Y~r, Minnesota
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EXTRACTON WELL LOCATION
, FOR GROUNDWATER
CUTOFF WALL - FIT
WD~, Ando.,,~r, Minn!sota
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LOCA TION OF GROUNDWATER
CUTOFF WALL-PIT
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~)
Responsiveness Summary for the Waste Disposal
Engineering Site in ~ndover, Minnesota.
1. Introduction
ihe United States Environ~!ntal Protection Agency (U.S. EP~) obtained
information on the types and extent of contamination, evaluated remedial
~easures, and recommended remedial actions for ground and surface water
con~~jnation, gas emissions, and direct contact concerns resulting from the
Waste Disposal Engineering Site in Andover, Minnesota. As part of this
process, U.S. EPA submitted its recommended alternative for public comment for
a twenty-one day period. Public participation in Superfund projects is
required under the Comprehensive Environmental Response, Compensation and
Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and the Hational Oil and HazardOUS
Substances Contingency Plan (HCP). A public meeting to discuss alternatives,
explain the proposed remedy and solicit publiC comment was held at the Andover
City Hall on September 14, 1987. Comments received by the pUblic are
considered in the selection of the remedial action for the Site. This
document summarizes the comments received and states U.S. EPA's responses to
those cOl'lTl1ents.
The responsiveness summary has four section:
a. Introduction. This section briefly explains this document.
,
b. Overview. This document briefly presents a history of community
relations at the Site.
c. Baclground on Community Involvement. This section briefly
presents a history of community relations.
d. Summary of ~blic Comments Received During the Public Comment
Period and U.S. EPA's Responses.
Z. Overview
Ouring the publi~ comment period, the U.S. EPA and the Minnesota Pollution
Control Agency (MPCA) held a pUblic lIletting to discuss the Site. The U.S. EPA
and MPCA recommended a solu~ion. similar to the pot.ntially responsible
parties. recommendation, through Semf additions to the feaSibility study
document entitled the -Detailed Analysis Report-. Tht r.commended solution
includes long-term (indefinite) ground water extraction through pump-out wells
in the Upper Sand aquifer between the landfill and Coon Creek to keep
contaminants from migrating off-site; a Resource Conservation and Recovery Act
(RCRA)-compliant lime sludge cap to cover the landfill, nfely vent and treat
landfill gases, and reduce infiltration through the waste; a slurry wall
around the Pit to contain the concentration of wastes within the Pit; a ground
water extraction well within the slurry wall to aaintain an inward hydraulic
gradient such that if the wall leaks the water will flow into the Willed area
and be extracted by the pump-out well thereby containing contaminants; filling
(
: ')
'-./
z
in a wetland area in the northeast corner of the Site and replacing it nearby;
treatment of extracted ground water by carbon adsorption; discharge of
extracted ground water to Coon Creek; and long-term monitoring of the remedial
activities (the cap, the extraction system, etc.), the contamination (ground
water, gas, etc.), and the receptors (Coon Creek, residents' wells, the Lower
Sand aquifer, etc.). In addition, the recommendation included consideration
of institutional controls to keep people fro~ placing new wells in the Upper
Sand aquifer just north of Coon Creek where contamination has been found and
in the Lower Sand aquifer around the Site in order to maintain the existing
upward water pressure between the Upper and Lo.er Sand aquifers. The addition
of municipal water to the area by the City of Andover is expected to reduce
the likelihood of new wells. The upper Sand aquifer just north of the creek
is near a sanitary sewer line, is in the floodplain, will be isolated from the
contamination by the extraction well system, and will, in the long-term,
cleanse itself. These conditions act to reduce the probablity of new wells
being placed in the area. The Lower Sand aquifer around the Site is expected
to continue to be stressed by the construction of new private drinking water
wells which would increase the likelihood of a downward water pressure between
the Upper and Lower Sand aquifers.. However, the municipal water will reduce
the stress on the ac;ui fers that waul d have been uPtcted due to the
construction of new wells and the monitoring will give warning if action is
needed to maintain an upward gradient. Consequently, although they are
considered prudent, the need for institutional controls beyond the Site Irea
(incl udes III land just south of Coon Creek) is not cri tical at this time.
\
Comments were received at the public meeting on the Waste Disposal
Engineering Site held in the ~ndover City Hall in September of 1987, and
by the potentially responsible parties (PRPs) during the publiC comment
peri od.
l
3. Background on Community Involvement
Since 1983 the HPCA and the U.S. EPA h&ve been involved in numerouS
community relations activities associated with the Waste Disposal Engineering
Site. Numerous fact sheets and news re1eues were issued throughout the
remedial investigation/feasibility study (RI/FS) to, among others, approxi-
mately 75 private citizens on the regular .ailing list. Public meetings were
held at the beginning of ~ht project. on the remedial investigation report,
after t~e alternatives report, and on tht proposed reneey, and City of Andover
and Anola County officials were invited to and participated in discussions
with, and co~ented extensively on submittals of the SW-ZS Group (PRPs who
came: forward to conduct the RIfFS) throughout the RIfFS process.
On September 3, 1987, the "PCA issued I news release on the proposed
remedy and the public lIteting. On September 8. 1987. U.S. [PA sponsored
In Id in the ~inneapolis daily paper announcing the beginning of the pUblic
comment period, the availability of the RIfFS, as modified, for public
inspection, the meeting date, and the proposed remtdy, On September 14, 1987,
a public meeting was held in the Andover City Hall and public comments were
received. On September 29, 1987. the public con=ent period w.s closed.
~)
4
b. Corrment:
spec' f1e~.
~esoon5e: The Sa:ional ~llutant Discha~;e Elimination Syst~ (HPDES) pennit
~equlrements under the Fede~al Clean Water Act are an applicable or relevant
Ind IPp~opriate requi~enent (ARAR) which will ~e Iddressed It this Site. The
permit ~equi~ements define the actual levels of contaminants that can ~
discharged to the C~eek, IS well IS the conditions under which discharges can
occur. Factors considered in making these requirements include the flow. in
the creek, the dilution given to th~ discha~ge by the creek, Ind Water Quality
Criteria. In other wo~dS, the creer. condit ions It the Si te are cons i dered in
conjunction with the concentrations of the contlminants to determine the
approp~iate discha~ge levels thlt will not adversely impact the creer. and its
uses. Specific effluent limitations will be defined for the discha~ge
during the remedial design and IS part of the HPDES p~ocess.
The levels of toxicity in the discha~ge water have not been
It should also be unde~stood that the ground wate~ in the Uppe~ Sand aquifer
ultimately discha~ges to the crur.. The~efore, by removing and treating the
ground wate~ before it enters thecruk, the total contaminant mass that
enters the creer. is reduced.
c. Corrment: The standards change as lIlQre information becomes available and
the~e IS no real assu~ance from the scientific cOtll'llunity that the levels are
safe.
Resoonse: It is a fact that standa~ds can change as new information becomes
aval laole. However, the standa~ds are generally conservatively applied such
that factors of safety are built in to the process. Further, under the
Supe~fund Amendments Ind Reauthorization Act of 1986 (SARA). Section 1Zl(c),
:he U.S. EPA is required to reevalute I Site whe~ contiminants are left on-
site no less often than every five years If tel" initiation of the remedial
action to assure that human hellth and the environment a~ being protected by
the remedial action being implemented. The ~evaluation will consider any new
potential health impacts which .IY havt been identifitd dut to scientific
advances.
-
d. Comment: looking at I thirty-yell" plln fo~ monitoring wells. there Ire
concerns acout well brelkdowns. improper felding of th~ wells. contlmination
of samples. Ind poor laborltory results.
Response: The monitoring wells Irt expected to be in operltion indefinitely.
The tn1rty-yelr period is. used fo~ cost complrisons becaus~ after thlt period
of time the present worth value of the costs tend to be negligible. As part
of the operations.lnd maintenance of the proposed remedial action. provisions
Ire made to assure that proper ca~ is taken in the implementltion of the
monitioring program. If the wells break down, they will ~ repaired or
replaced. There will be I sp~ific plan for the =ethods to be used in
sampling Ind Inllysis of samples. There will also be cheeks built into the
proc!du~es to assure adequate sampling Ind analysis is performed (blanks,
split samples, calibration checls, etc.). The Site will also undergo periOdic
review by the U.S. EPA under SARA.
\' )
'~/
3
Du~in; tne comment pe~iod, comment was ~eceived f~om tne SW.28 G~ou~. ~o
other pu~lic comments were received.
,
4. Summa~y of ~u~lic Comments Received During tne Public Comment PeriOd
The follo~ng are comments from the Septembe~ 14, 1987 pu~lic ~eting in the
Andover City Hall.
I. Comment: Why does it talce so long for anything to happen? The Site nas
~een known since 1968 and twenty years later we are still tal Icing a~out it.
Resconse: Although the Site was purchased by Waste Disposal Enginee~ing,
Inc.. 1n 1968. it was I permitted Ind operating landfill in the 1970's and
early 1980's. The framework for the U.S. EPA to Idd~ess tnis Site ~egan with
the passage of the Comprehensive Envi~onmental Response, Compensation, and
Lia~ility Act (CERCLA) on December 11. 1980. Once the autnority was
establiShed by CERCLA. I process had to be established to find potential sites
and decide which ones should be add~essed first with limited Federal
resources. USiRg this proc,ss the Waste Disposal Engineering Site was
announced as I potential Superfund site on July 23. 1982. Initially,
baclc9~ound information on the Site and potentillly responsible put;es (PRPs),
those persons that may 0. liable for pro~ltms at the Site, was compiled.
Us i ng the background i nformati on. statements of work that gene~lll y desc~i be
the kind of studies that are necessary to charlcterize the Site were prepared,
and the ~RPs were notified tnat tney we~e ~Ps, that tne U.S. EPA intended ~o
do wo~1c at the Site.; and thH they might be liable fo~ the U.S. E?A. costs of
tnat wo~k. In March of 1984. a written ag~tement. called a Consent O~de~. was
signed in which the PRPs committed to conduct a remedial investigation/
feasi~ility study (RI/FS) based on statements of work contained in tne Consent
Order. The RI/FS is to characterize the Site and analyze various solutions
such that the cost.effective solvtion that protects the public health, weHare
and the environment cln be chosen. .Thl infonnation Obtained durin9 and
presented in th, RI/FS ~ust be obtained in a Danner that will stand up in a
court of law. OnCI the U.S. EPA. in consultation with the HPCA. designates
its chosen solvtion in I Rlcord of Decision (ROO). the PRPs will design the
solution IS part of the Consent Order. Negotiations will then occur to
determine if the PRPs will conduct the construction. If not. the U.S. EPA can
either conduct the action itself Ind sue for its costS liter, or it can seek
t~ have. the court require thlt the PRPs do the clelnup. If so, the HPCA.
U.S.EPA. Ind PRPs cln sign I Consent Decree, In agreement lodged with a court.
to have the PRPs do the cleanup. In summary, ~uch of the time the Site was in
operation-. it wls not. known IS a problem to be.addressed. by Superfund (i .e.,
1960's Ind 1970's). When the Site WIS recognized. it WIS put into the
Superfund remedill action process. The process is deliberate. but it does
lIlove forward along establ1shed lines toward Site cleanup. Two problems which
have taken more time than originally expected were establishing analytical
procedures and finding a laboratory capable of conducting the work as
specified, and detenDining and incorporating the additional requirements of
the Superfund Amendments Ind Reauthorization Act of 1986 (SARA).
l
\
5
:~) .
e. Comment: A special assessment on a house was to suppo~t I holding pond to
teep .a~er out of Coon CreeK. Putting more .ater 1nto Coon CreeK should be
Ivo1ded.
~esoonse: Since the Upper Sand aQuifer discharges into Coon Creek anyway, the
dlscna~ge of extracted ground wate~ is not the same as discharging an
independent source of water into the c~eeK. Furthennore, the analysis of
alternatives indicated that the creek discharge would be favorable compared to
the discharge which would involve removing the water from t~ creek area,
discharge to the sanitary se.er and ultimately to the sewage treatment plant.
As discussed in the pUblic meeting, discharge to the sanitary sewer would
reduce available sewer capacity, which would limit growth, which would ~eduee
the available tax base for the community. The proposed discharge is expec~ed
to be limited such that adverse impacts to the creeK resulting from such
discharges will be mitigated (It is one of the considerations of the NP~ES
process). "
f. Comment: The local community is paying for municipal water to p~otec:
them ana tnat investment is not being addressed by the people who created the
prob 1 em.
Response: The private drinking water wells in the area Ire not no. being
aaversely affected by the Site. . With the implementatio~ of the. proposed
remedy, those wells a re not expected to be impacted by the 5i te.
.'
J
"
g. Comment: The economic losses to the community are staggering al~eady and
not a arop of .ater.~as been purified.
Resoonse: The proposed remedy is designed to contain contamination from the
51te ana to t~eat contaminant d1scha~ges befo~e they are discharged into the
environment. Upon implementation of the proposed remedy, water is expected ta
be treated.
h. Comment: Cln tids go in Coon Creet wading Ind swimming, and not be
hanned?
Response: The Minnesota "Department of Health Ind the pUblic health evaluation
of current conditions in the Detlil.d Analysis Report indicate that the
existing health rists in Coon Creet are not such that those activities need to
be prohibited. The proposed remedy is primarily to aSsure thlt the potential
for a significlnt prOblem resulting from the volumes of'wastes that went into
the llndfill is nlver realized in th, creek.
i. Comment: How fir down from the Site WIS Coon Creek sampled?
Response: As part of the remedial investigation, Coon Creek sediments were
slmpled up to three and I hllf Diles downstrelD of the Site.
J. Comment: When discharging to Coon Creek will the qUIlity of Coon Creek
water be better than with leachate discharging 1nto 1t?
.)
.-
6
Resoonse: Overa", since it is expected that the Upper Sand aQuifer
Q1SCnarges entirely into Coon Creek from the Site, the contaminant loadings to
Coon Creek ~ill be reduced, the water Quality improved, and the potential for
significant contaminant discharges into the creek from the Site through the
ground water eliminated by the proposed remedy.
k. ,Comment: Is Coon Creek going to be dealt with in terms of the volume of
the dlscharge into it?
Resoonse: Yes. Based on discussions wit~ th~MPCA, it is not expected t~at
tne proposed disc~arge of around 60 gallons per minute ~ill adversely impact
t~e creek. This will be considered further in terms of NPOES requirements.
The following are comments from the SW-28 Group (t~e PRPs who volunteered to
come forward and conduc~ t~~ RIfFS and remedial design under a Consent Order
with the U.S. EPA and MPCA) as expressed in their September 10, 1987 letter.
1. Comment: For U.S. EFA to issue its Record of Decision (ROO) before the
end of lts fiscal year, September 30, 1987, would be inappropriate.
Resoonse: Since t~e public CQm'llen.t period. did not end until Septem~er 29,
1901, U.S. EPA agreed with the comment and did not publish the ROO ~fore the
end of the fiscal year.
m. Comment: The SW-28 Group reserves the right to supplement the record
beyono tne 21-day public comment period.
Resoonse: Under 40 CF~ Part 300.67(dl of the NC?, the feasibility study must
be provlded to the public for review and comment for I period of not less than
21 calendar days. This was done for the Waste Disposal Engineering Site in
that the publiC comment period was 21 days. Further, since the SW-28 Group
prepared the feasibility study and has discussed issues at the Site .ith the
U.S. EFA and the MPCA extensively throughout the previous ~nths, it was not
considered appropriate to extend the public comment period for undefined
reasons for an indefinite length of time.. The public comment period closed on
September 29. 1987.
The following is I comment from th. Sf-29'Group IS expressed in their
September 24. 1987 comment letter.
n. Comment: The Idditional six inches of drlinage llyer Ind six inches of
fill requlred by U.S. EPA and MPCA ~dificltions to the Detailed Analysis'
Report' ar~ not requi red to lIleet' th.. technical perfonnance, standards of I
Resource Conservltion and Recovery Act (RCRA) landfill closure cap.
Resconse: RCRA landfill closure (set' 40 CFR Part 264-). which is an ARAR.
requlres five elements be addressed. T~ey art: 1) provide long-tenD
minimization of migration of. liquids through the closed landfill: 2) function
with minimum maintenance; 3) promote drainage and minilllize erosion or
abrasion of the cover: 4) accommodate settlin9 and su~sidence so th.t the
'-.
o
~
7
cover's integrity is maintained; and 5) have a permeability less than or
equal to the permeability of any bottom liner system or natural subsoils
present. Items 1),2), and 3) were of concern due to the original design of
the lime sludge cap. 8y allowing the open field frost penetration in the area
of four feet to penetrate a foot into t~ lime sludge, the impermeable layer,
the ability of the cap structurally to continue to support the rest of the cap
(function with a minimum of maintenance) and to maintain long-tenn
minimization of liquidS through the landfill is put in doubt because heaving
could both weaten and allow more infiltration through the lime sludse. This
is especially significant ~cause the lime sludge is not being placed in six-
inch lifts as is normally expected to assure the integrity of the impenneaole
layer and because the history of lime sludge as an adequate impermeable layer
is lac{ing. The surf.ce layers of the lime sludge are structurally
significant and must be protected from frost penetration. The need to promote
adequate drainage requires that a one foot drainage layer be constructed. The
proposed six-inch layer is not considered adequate, considering construction
techniques, .to drain and not be clogged. With these mOdifications. and the
testing to be required during design of the cap, it is expected that the lime
sludge cap will be construete~ to be generally consistent with RCRA
perfo~ance standards.
ft j,J c. ~4o 1:' .. ,. .., ""^
':'l7:'~/SUBJ tC!'
At.:7HOR
C ~::::
NO. Of' PA:~;
1. P.~I
1. p~.limina~y Assessme~t USEPA 7/1981
and Site I~vesti~ation
(Tne~e a~. t~O site inspee-
tio:'l repon.s)
2. Natio:'lal P~iorities US~PA none
Checklist (NPL)
3. Ouality co~t~o1 Notes Mie~ael Gifford 8/10/82
4. t:'lfo:eement Summary USEPA none
and Status Re?O~t
S. Conditio:,:s a:-:d Ke~ry St~ut 1983
Status Re~o~:'
6 . ;.;~::,k shee:.s Cou; Cay 9/1 Onl
to ~~aQe the site Joh:': E. Aho
23
1
25
5
1
5
II. PASI APPE~OIX
,
-.
Biblio~ra?hy for
Coc~~e:':t ~hich ra:':Ks
the sitl.
(I~eludes refere:':ces)
us E?A
6/26/82
16
II ! . 'riO RKP LA.1
US~PA
4/19a4
4/l9a4
4/1984
32
70
1. Land:ill RI/FS
2. La:,:dfi11 a:,:d pit
Safety Pla:':
3. tvaluatio:'l Re?Ort
Landfill and Pit.
R:/ F S
4. S.c~=ity Pla:':
Landfill RIIFS
S. s.curit.y Plan
Pit. RurS
6. RI: pit. RI/TS
IV. WORKPLAN CORRtSPONOEsCt
US::?A
US E:?,l,.
80
OSt?A
OSEPA
4/19134
4/1984
4/1984
6
6
tlstPA
..
35
\.
1. Lette~ to t.A. Hickok
f::,o~ Mi:'lnlsoat Po11utio:'l
Control Aqency (MPCA)
requestin~ modificltions
to the tvaluation Report,
Landfill and Pit RI/FS.
2. Letter to t.A. Hickok from MPCA
MPCA r.~uestinQ modifie.tio~s
to the OA/OC Pl~:'l a:,:d Safety
Plar:.
MPCA
6/13/84
3
6/19/84
13
V I. OA/OC DA':'A
AV AILABLE: A':'
536 S. Cla:,k
Chi~&go, Ill.
VII. RI/FS: Rt~tOIAL
INV ES':"IG'\TION
AND 8IBt.ICXiAAPHY
VIII. SUPPt.EME~T~ CRA
REMEDIAL INVESTIGATION
IX. DE':'AIt.!:D ANAUSIS CRA
REPORT
1. This 1s a fi:'lal
draft of the
feasi~ility study.
(also PP" 104-160
have bee~ ~ulled
out a~d placed in
the Pu~lie E~d&~;e:-
ml!:'lt file.)
_ 2. Ap~e:'ldien CRA
,.- '\ .
,_..)
"-
,-)
.Z7t.t/SUBJ E:C.
IV. WORKPL~~ CORR~SPONOE:NCE:
3. Letter to Kerry St:'eet
f:,o~ Ona~ .tati~9 that
the ~ew consultant is
Co~estoga-Rove:s , Ass.
~. Lette: to WOE fro~ MPCA
S~ Lette:, to Pat:ieia
Li:'ldquist, City Admi:'l.
of k~dove:, Minn. from
MPCA regarding the
testing of reside:'ltial
water wells.
6. Letter fro~ MPCA to
Elldfard Briese~eister
M~gr of M4~uf., ro1ey
Bels&w
7. Let:er f:o~ CRA to MPCA
:e;a:di:'lq .a~pli:'l;
cha:':Qes.
8. Lette:, from CRA to MPCA
regarding changes in
a a.::p 1 i:,:q.
V. OAPP (3)
l. Letter which approves
the three QAPP pla:,:s.
2. OA/OC
La:':cfill a:-:d Pit R:/FS
3. Letter from MPCA to US!?A
reqardi:'!; report modifi-
c4tions.
~ . OAP?
S . OArP
AU.HOR
CATE
NO. Of P";~~~.
B:u~. Do:Qe:di~q 7/27/84
ONAN Co:p.
2
Thom&s K&litowski 8/1/84
MPCA
3
Clifford ~~derson 7/30/84
MPCA
1
Alan W. VanNor:an 8/30/84
eRA
Richard G. Shepherd 9/17/84
CRA attorney
:3
6
US!?A 2/22/87
No~a:'l R. Niede:;a~q
Hiekok , Ass. ~/19a4
3
95
M?':A
6/1/84
100
CRA
CRA
2/22/85
8/7 /86
<405
80
CRA
3/19a6
142
,2.57
37
275
9/19a6
10/19S6
10/1986
275
TI!'t.!:/SUBJ tCT
x. pua~IC HtAt.TK
r:v At.UATION
XI. DtCISION DOCUMtNTS
1.. AlternAtive seleetion
(pull.~ fro= rS)
XII. ~OO NOT AVAIt.ABt.t ~ET.
XIII. COMMUNI~ REt.A~IONS
WE: ARt WAITING FOR ACOITIONAL
DOCUMENTS FROM THE STATE OF
K1NNtSOTA.
1 .
%.
3.
Co~~unity Relations plan
PresS Release-
t.etter from Bo~1n and
Bowman to KPCA
C~ty.of ~~o~~ to UStPA
Letter froCl MPeA to
HO:"lorable Albert A.
~ordiak, ~~o~a C~ty.
Brd. of Comaiss.
Cano~ie t~;rs to USE?A
MPCA to Kayor of Ar.~oyer
Ne..,s Release
MPCA Letter to USEPA
, .
5 .
6.
7.
8.
9.
10.
ll.
Valda. V. Ada~kus to
s.nato~ Rudy SO.cowit:
Request for Informatio~
from Minneapolis Star
Tribune
Valda. V. Ada=kus to
Sen&to~ Rudy soscowit:
Vald.s V. Ma.=kus to
s.nator Rudy 5oscowit:
Valdas V. Adamkus to
Senator Rudy 5oschwit:
Copy of NP~ sent to-
Ire~" Lund.
12.
13.
u.
15.
XIV. ENrORCE.'''tN't''
1. Con..~t O~d.r
(si;natu:es. ar.
miss in; ) .
l
AUTHOR
CRA
CRA
KPCA
?
C&vid Graves
Albert ~or~iak
T. UlitowsH
Ca:':onie E~;rs.
Oou~lu N. Cay
EPA
Susan K.
Brus u&n
Val~u Adamkus
Xerry Street
Valdu Adamkus
ValdU M~u'
.
.
.
~e::ry Street
OSE?A
OATE
10/1986
10/1986
7/l8/83
3/23/S"
3/29/SS
1/22/85
2/26/85
5/24/S'
5/22/S-t
3/23/84
12/2/83
11/28/83
11/29/83
11/15/83
5/17/83
5/1%/83
5/17/83
?
PActS
103
13
5
2
S
2
3
1
2
2
2
3
,
6
11
3
2
50
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APPE::IJIX F
':J
Remedial Action Plan for the
Remedial Design/Remedial Action at the
Waste Disposal Engineering in
Andover, Minnesota
I. Puroose
The purpose of the Remedial Action Plan (RAP) at the Waste
Disposal Engineering, Inc., is to implement the Record of Decision
(ROD) as modified by the approved Response Action Final Design
(RAFD) Report for the Facility. The ROD documents contamination
releases in various environmental media and defines thirteen
exposure routes and subsequent risks to public health and the
environment for which remedial objectives were. derived. Various
methods of mitigating the threat posed by Facility conditions were
developed and analyzed in the Feasibility Study. This Remedial
Action Plan (RAP) outlines the procedures and performance standards
that will be required in order to implement the remedy that was
selected in the ROD as modified by the approved RAFD Report. In
designing and implementing the Remedial Action at the Facility, the
Respondents shall follow this RAP and this Order, the ROD, the
approved RAFD Report, the approved Remedial Design (RD) and
Remedial Action (RA), the RD/RA Work Plan, the United states
Environmental Protection Agency (U.S. EPA) Superfund Remedial
Design and Remedial Action Guidance and all other applicable
guidance.
II. Ob'iectives
The response objectives of this Remedial Action are to
protect public health and the environment through implementation of
a remedy designed to:.
1. Control potential dust and/or volatilized chemical
emissions:
2. Control contact with lime sludge;
3. Control contact with exposed waste/leachate;
4. Minimize contaminant releases to Upper Sand Aquifer;
5. Eliminate or minimize contaminant releases to Coon
Creek:
o
6. Reduce the probability of incompatible waste
reactions;
7. Control the effects of possible reactions that may
occur;
8. Control future exposure to the contaminated Upper Sand
Aquifer;
9. Protect the Lower Sand Aquifer by controlling the
vertical gradient and the i~pact of heavier-than-water
non-aqueous phase liquid (NAPL) accumulation;
10. Control landfill gas migration; and
11. Eliminate or minimize contaminant releases in wetland
areas and possible exposure to migrating waterfowl
and other wildlife.
III. Remedial Action
A. Introduction
Respondents shall design, construct, operate and maintain
the Remedial Action as modified by the approved RAFD Report. The
following are the major components of the Remedial Action:
1. Multi-layer cap over the landfill and pit
2. Groundwater extraction well/treatment system
in the Upper Sand Aquifer
3. Slurry wall to the Gray silt, and extraction
well/NAPL detection and removal system for the
areas that exhibit possible NAPL accumulation
4. Filling in wetlands
5. Groundwater, surface water, landfill gas and
NAPL monitoring programs
6. Institutional controls
7. Operation and maintenance of response actions
taken pursuant to this RAP and Consent Decree.
The Respondents shall initiate and complete and/or
accomplish these remedial action components within the time periods
specified herein and are required to submit reports as identified
in the Order and herein.
B. Scoee of the Remedial Action
The Respondents shall design, construct, operate and
maintain the following design criteria for each component of the
Remedial Action:
1. The multi-laver cae over the landfill and Pit.
The cap shall meet the requirements of 40 crn
264.310 and the RCRA Subtitle C Technical Guidance Standards. The
cap shall include but not limited to:
3
C)
a. vegetative Top Cover, which shall:
Support and sustain vegetation that minimizes
erosion without continued maintenance;
Be planted with persistent species having roots
that will not penetrate beyond the vegetative
layer;
- Have a top slope after settling and subsidence of
between 3-5%;
Include a surface drainage system which promotes
run-off across the cap with minimal erosion,
infiltration, or ponding;
. - Consist of at least 6 inches of topsoil over 30
inches of clean fill that meets all appropriate
federal, state and local requirements.
b. Middle Drainage Layer, which shall:
Be at least 12 inches thick with a saturated
conductivity not less than 1xlO-3 centimeter
per second;
Hava a bottom sloge of at least 2%;
Be overlain by fabr~c filter to preveh~ plugging
of porous drainage media with the fine earth
particles carried down from the vegetative layer;
c. Barrier Layer, which shall:
Consist of at least 2 feet of clay recompacted
to a saturated conductivity of not more than
lxlO-7 centimeter per second;
()
Have a final upper slope of 2%;
~ located wholly below the average depth of
frost penetration (4 feet);
d. Gas Venting System, which shall:
Be designed to release landfill gas from below
the barrier layer to minimize lateral gas
movement, to prevent migration of gas beyond
the boundaries of the Facility and avoid
4
excessive build-up of gas generated from the
landfill:
, \
At no time shall the level of landfill generated
explosive gas exceed 5% by volume at or beyond
the WDE Site:
At no time shall the level of landfill
generated explosive gas exceed 1.25% by volume in
any confined area or structure, such as a
building, whether located on or off the Site.
At no time shall landfill generated gas released
to the environment contain hazardous substances,
pollutants or contaminants that are not
protective of human health and the environment:
consist of at least a passive gas venting system
within the landfill, and where necessary and
appropriate to comply with the operating design
criteria for the landfill gas venting system as
provided herein, the installation of an
active/passive intercepter trench or vents
around the perimeter of the landfill and/or the
addition of active gas venting system within the
landfill.
Be fitted with granular activated carbon
filters and replaced as necessary to effectively
remove organic contaminants from vented landfill
gases: and a
e. Foundation Layer, which shall:
Provide a stable platform on which to construct
tne cap by removing and disposing, as
appropriate, the existing lime sludge, compacting
and regrading the existing landfill contours and
placing and compacting clean fill necessary to
achieve final grade.
2. Groundwater extraction well/treatment svstem for
the Upper Sand Aauifer
The groundwater extraction well system required
pursuant to this Order and RAP shall provide a hydraulic barrier
between the contaminated groundwater below and near the landfill in
the Upper Sand Aquifer and Coon Creek. The groundwater extraction
well system shall prevent or minimize migration of contaminants to
the Upper Sand Aquifer and Coon Creek and to prevent the migration
of contaminants to the Lower Sand Aquifer.
,:.J
r \
o
5
The groundwater extraction well system for the
Upper Sand Aquifer shall consist of ground water pump out wells
along the northern perimeter of the landfill, installed in
accordance with the final design specifications set forth in the
approved Final Design Document and consistent with the ROD and the
approved RAFD Report.
Extracted groundwater shall be pumped to the
groundwater treatment system for treatment to meet required
effluent limits prior to discharge. Discharge of treated
groundwater shall be to Coon Creek. However, as an alternative,
Respondents may pump extracted groundwater to a POTW provided that,
as part of the Final Design Document: 1) an agreement has been
reached with the POTW authority ....here the sewer and POTW will
accept the extracted groundwater and 2) the discharge will comply
with all established and appropriate pre-treatment requirements
applicable to any such discharges.
Prior to discharges of extracted groundwater to
Coon creek, Respondents shall obtain from U.S. EPA an authorization
to discharge. Discharges of treated groundwater shall comply with
all substantive requirements of the Clean Water Act, 33 U.S.C.,
Section 1251 et seer., including application of best available
technology economically achievable, ....ithin the meaning of Section
301 (b) (2) (A) of the Clean Water Act, 33 U.S.c., Section 1311
(6) (2) (A) as well as any more stringent effluent limitations
necessary to meet applicable water quality standards. The
treatment system shall include air stripping or activated carbon,
or both, depending on the actual treatment system hydraulic and
chemical loadings, Coon Creek hydraulic and chemical loadings, and
discharge criteria. The treatment system shall also provide
treatment fer heavy metals as necessary to meet the legally
appropriate requirements.
Any air emissions from an air stripper shall be
treated in accordance ....ith the Clean Air Act, 42 U.S.C. 7401 ~
~ and Minn. Stat. ch. 116 and any rules thereunder.
Final decisions regarding the ground....ater treatment
system will be based on treatability studies specified in the RO/RA
Work Plan and/or detailed plans and specifications. Any residuals
from the groundwater treatment system shall be handled according to
RCRA regulations.
3. SlurrY ....all to the Grav silt and extraction
....ell/NAPL detection and removal system for areas
that exhibit NAPL accumulation
The slurry ....all system shall provide long-term.
containment of hazardous substances, including NAPL, ....ithin the
area surrounded by the slurry ....all system. To meet this objective
a slurry wall shall be installed around the WOE Pit consistent ....ith
6
the RAFD Report and Final Design Document, embedded at least three
feet within the gray silt layer identified in the RI and RAFD
Report. The slurry wall shall have a wall thickness of at least two
feet. Respondents shall achieve a wall hydraulic conductivity of 2
x 10-7 centimeters per second. The slurry wall shall be tested
periodically in accordance with the approved operation and
maintenance plan (O&H Plan).
An extraction well shall be installed consistent
with the RAFD Report and Final Design Document and shall be located
within the Upper Sand Aquifer within the area surrounded by the
slurry wall. The internal extraction well shall maintain an inward
gradient at all points across each wall of the slurry wall system.
Extracted water shall be treated in the groundwater treatment
plant.
Additionally, NAPL monitoring and removal wells
shall be installed inside and outside of the area surrounded by the
slurry wall system and other areas that exhibit NAPL accumulation.
All NAPL monitoring wells shall be equipped with a sump for
possible NAPL recovery. NAPL monitoring and removal wells shall be
installed consistent with the RAFD Report and Final Design
Document, and shall be located within the upper and lower parts of
the Upper Sand Aquifer, both within the area surrounded by the
slurry wall system and outside and downslope of the slurry wall
system and any other areas that exhibit NAPL accumulation. Any NAPL
recovered shall be handled in according to RCRA regulations.
4. Wetlands.
The wetlands located between the landfill and Coon
Creek will be filled in accordance with applicable substantive
requirements of the U.S. Army Corps of Engineers, U.S. Fish and
wildlife Service, U.~. EPA, and the Minnesota Department of Natural
Resources. as specified in accordance with the approved RO/RA Work
Plan and consistent with the RAFD Report.
5. Groundwater. surface water. landfill qas and NAPL
monitorina proaram.
A ground water, surface water, landfill gas and
NAPL monitoring program shall be designed to assess the performance
of the Remedial Action and operation and maintenance including but
not limited to changes in contaminant characteristics and increases
and decreases in the concentration of hazardous substances,
pollutants and contaminants at and near the Facility. Monitoring
frequency, locations and analytical methods for all media shall be
in accordance with this RAP and approved O&H Plan, and consistent
with the RAFD Report, and shall include, but not limited to the
following:
7
()
a. Hydraulic drawdown in the Upper Sand Aquifer
i. At least five additional piezometers shall be
installed in the Upper Sand Aquifer for purposes of
adequately monitoring hydraulic drawdown. All ne.... and
existing piezometers, monitoring ....ells and groundwater
extraction ....ells shall be used for quarterly ....ater level
measurements. Water level measurements shall be used to
prepare ground....ater contour maps to be submitted as part
of quarterly monito~ing reports under Section IV, Task
IV, B .
b. Water quality in Coon Creek.
i. Samplinq Locations - sampling locations in Coon Creek
shall be as follows but not limited to:
1. The upstream side of the Crosstown Boulevard
bridge (sample location CC-S)
2. Directly south of monitoring well nest W-21
(sample location CC-6}
3. Directly north of monitoring ....ell W-19 (sample
location CC-7)
4. The downstream side of the Hanson Boulevard
bridge (sample location CC-S)
The sedimentation pond discharge to Coon Creek shall be
downstream of sampling location Cc-s. Sampling location
Cc-s shall be the sampling location for background
concentrations in Coon Creek unless a compound listed in
Table 1 is. detected in a sample taken from CC-S. In such
an event, a ne.... background sampling location(s), as
approved by U. s. EPA, shall be included in every sampling
event thereafter and shall be the sampling location(s)
for background concentrations for Coon Creek.
.'"
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i1. Samolinq Frequencv and Analvsis - Sampling frequency
and analysis of water from Coon Creek shall be in
accordance with the following requirements:
1. Quarterly monitoring of VOCs and General
Chemistry parameters listed in Table 1;
2. Quarterly Monitoring of cadmium, iron, nickel,
aluminum and zinc for at least t....o years of full
operation of the groundwater extraction well system
and continuing until the concentrations remain below
Minnesota water quality standards for chronic
toxicity to aquatic lIfe for four consecutive
quarters.
3. Except for quarterly monitoring as provided in
i1. 2 above, or a monitoring frequency determined
necessary or appropriate by u.s. EPA, annual
monitoring for metals and semivolatiles listed in
Table 1.
4. Respondents shall use analytical methods in
accordance with the QUality Assurance project Plan
that are necessary to adequately assess the
performance of the Remedial Action including but
not limited to Method MDH 465C or equivalent EPA
Drinking Water Method(s) for VOCs and low level
semi-volatile analytical methods, including Special
Analytical service (SAS) routinely used under the
Contract Lab Program.
iiL Stream Flow - stream flow shall be measured in
accordance with the United States Geological Survey
(USGS) procedures outlined in "Discharge, Measurements at
Gaging stations", Book 3, Chapter A8 in "TeChniques of
Water Resources Investigations of the USGS", Thomas J.
Buchanan and william P. Somers (1969) or "Measurement and
computation of Streamflow: Volume 1, Measurement of stage
and Discharge" (USGS Water supply Paper 2175, S.E. Rantz
, II lie (1982)). Flow monitoring shall be measured at
the upstream side of the Crosstown Boulevard bridge over
Coon Creek by measuring the water velocity at ten
permanently identified stations on the bridge. Stream
flow shall be calculated by using the USGS "midsection"
method by multiplying the measured average water velocity
by one tenth width of the stream and by the average depth
of flow in the section where the average velocity is
measured. Total stream flow shall be the sum of the flows
measured in each section. Stream flows shall be measured
on the same day that water quality samples are taken, and
shall be representative of stream flow at the time water
quality samples. are taken.
c. Groundwater monitoring in the upper Sand Aquifer shall be
in accordance with the following requirements.
1. All current Upper Sand Aquifer monitoring wells
including those installed beneath the landfill, Upper
Sand Aquifer and NAPL monitoring and extraction wells
installed as part of Remedial Action and any future
monitoring wells deemed necessary by U.S EPA shall be
9
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used to monitor the performance of the Remedial Action.
ii. Quarterly monitoring shall be required for general
chemistry and VOCs identified in Table 1.
iii. Annual monitoring or a monitoring frequency deemed
necessary or appropriate by U.S. EPA shall be required
for semi-volatiles and metals parameters identified in
Table 1.
~v. Respondents shall use analytical methods in
accordance with the Quality Assurance Project Plan that
are necessary to adequately assess the performance of the
Remedial Action includinq but not limited to Method MDH
465C or equivalent U.S. EPA Drinking Water Method for
VOCs, and semi-volatile low detection limit analysis that
utilize Special Analytical Service (SAS) routinely used
by U.S. EPA.
d. Groundwater monitoring in the Lower Sand Aquifer shall be
in accordance with the following requirements:
i. All current Lower Sand Aquifer monitoring wells, Lower
Sand Aquifer monitoring wells installed as part of the
Remedial Action and any other Lower Sand Aquifer wells
determined necessary by U.S. EPA shall be sampled.
ii. At least five residential wells shall be measured.
The exact locations shall be approved by U.S. EPA in the
O&M Plan.
iii. Quarterly monitoring shall be required for general
chemistry and VOCs identified in Table 1.
iv. Annual. monitoring or a monitoring frequency deemed
necessary or approp~iate by U.S. EPA shall be required
for semi-volatiles and metals parameters identified in
Table 1.
6~ Institutional controls.
Institutional controls, including deed restrictions
and ordinances, shall be implemented in accordance with the
approved RAFD Report, on the Site and on real property within 500
feet of the landfill owned or controlled by any Res.l;!.on~nt.
Respondents shall also utilize cest efforts to implement
institutional controls on the Site and any real property within 500
feet of the landfill which is not owned and controlled by any
.- ~ Respondent.
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10
7. Operation and maintenance plan.
An O&M plan conforming to the requirements of Part
IV, Task II, B, below, shall be implemented to maintain the
integrity and effectiveness of the Remedial Action, including but
not limited to, making repairs or replacements to the cover, slurry
wall system, gas venting system, groundwater extraction well and
treatment system, and correcting the effects of settling,
subsidence, erosion, or other events.
IV. Tasks
The Remedial Design and Remedial Action (RD/RA) shall consist
of six tasks:
Task I:
Task II:
Task III:
A.
B.
C.
D.
E.
F.
G~
Task IV:
A.
B.
RD/RA Work Plan
Pre-Design
Remedial Design
Design Plans and Specifications
Operation and Maintenance Plan
Project Schedule
Quality Assurance Project Plan
Site Safety and Security Plan
Design Stages
Community Relations Support
Remedial Action Construction
Responsibility and Authority
Construction Quality Assurance Personnel
Qualifications
C. Inspection Activities
D. Sampling Requirements
E. Documentation
Task V: Reports
A. Progress Reports
B. Quarterly Monitoring Reports
C. Other Reports
D. Remedial Action Construction Report
E. Approval of Remedial Action Construction Reports
F. Completion of Remedial Action Report
G. Acceptance of Completion of Remedial Action
Report
Task VI: Schedule for RD/RA Implementation
11
,~
Task I: RD/RA WORK PLAN
The Respondents shall prepare and submit to U. S. EPA and
MPCA, in accordance with the schedule set in Task VI below, a RO/RA
Work Plan which shall document the overall management strategy and
implementation schedule for performing the RD/RA, to include pre-
design, design, construction, operation, maintenance and monitoring
of the RO/RA consistent with the ROD, the approved RAFD Report, and
this RAP and Order. The RD/RA Work Plan shall also include a plan
for satisfying all permit and access requirements. The RD/RA Work
Plan shall document the qualifications, responsibility and
authority of all organizations and key personnel involved with the
implementation of the RO/RA including contractor personnel.
Task II: PRE-DESIGN
Pre-design activities shall be conducted prior to submission
of the 'p'~efinal Design Document. Pre-design actiyities shall
include ~roundwater treatment treatability studies,~a geophysical
survey in order to properly locate NAPL wells, and, if necessary,
,~Upper Sand Aquifer pump tests, as well as any additional studies
proposed by Respondents and/or deemed necessary by U.S. EPA.
Task III: REMEDIAL DESIGN
The Respondents shall prepare and submit to U. S. EPA and MPCA
in accordance with the schedule set forth in Task VI below,
construction plans and specifications to implement the Remedial
Action.
A. Desian Plans and Specifications
The Respondents shall develop clear and comprehensive
design plans and specifications which include but are not limited
to the following:
1. Use of currently acceptable construction
practices and techniques.
2. Compliance with all applicable and all relevant
and appropriate environmental and public health
standards.
:3. Use of currently accepted environmental control
measures, designs and technology.
'~J
4. Description of assumptions made and detailed
justification of these assumptions.
12
S. Discussion of the possible sources of error and
references to possible operation and maintenance
problems.
6. Detailed drawings of the proposed design including:
a. Qualitative flow sheets ~ and
b. Quantitative flow sheets.
7. Tables listing equipment and specifications.
8. Tables giving material and energy balances.
9. Appendices including:
a. Sample calculations (one example presented and
explained clearly for significant or unique design
calculations)~
b. Derivation of equations essential to
understanding the report; and
c. Results of laboratory or field tests.
B. oceration and Maintenance (O&Ml Plan
The Respondents shall prepare and submit to U.S. EPA
and MPCA a separate O&M Plan to cover both implementation and long
term maintenance of the Remedial Action. The O&M Plan shall be
composed of, but not limited to, the following elements:
1. Description of normal operation and maintenance:
a. Description of tasks for operation;
b. Description of tasks for maintenance including
replacement~
c. Description ot prescribed treatment or
operation conditions; and
d. Schedule showing frequency of each O&M task.
2. Description of potential operating problems:
a. Description and analysis of potential
operation problems~
b. Sources of information regarding problems~
:~
13
c. Common and/or anticipated remedies; and
d. Useful life analysis of significant components
and replacement costs.
3. Description of routine monitoring and laboratory
testing:
a. Description of monitoring tasks;
b. Description of required laboratory tests and
their interpretation;
c. Required Data Collection Procedures and
Quality Assurance;
d. Schedule of monitoring frequency and dates; and
e. Identification and rationale of the location of
monitoring points.
4. Description of alternate O&M:
a. Should systems fail, alternate procedures to
prevent releases or threatened releases of
hazardous substances, pollutants or contaminants
which:
i. may threaten public health, welfare or
the environment; or
ii. threaten non-compliance with any ARAR;
and
b. Analysis of vulnerability and additional
resource requirements should ~ failure occur.
S. Action required when any component o~ the
Remedial Action is not performing:
a. Description of action to be implemented upon
detection or confirmation of improper
performance of the any component of the Remedial
Action;
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b. Schedule for implementing the action.
6. site Safety and Security plan:
a. Description of precautions, necessary
equipment and other similar requirements for
site personnel;
14
b. Safety tasks required in event of systems
failure; and
c. Procedures for limiting access during
operation and maintenance.
7. Equipment:
a. Equipment identification;
b. Installation and monitoring components;
c. Maintenance requirements and schedules for
site equipment; and
d. Replacement schedule for equipment and
installed monitorinq components.
8. Records and reporting mechanisms required:
a. Daily operating logs;
b. Laboratory records;
c. Records for operating costs;
d. Mechanism for reporting emergencies;
e. Personnel and maintenance records; and
f. Each of the reports required in Task V,
including progress and monitoring reports.
An initial Draft OkM Plan shall be submitted
simultaneously with .the Prefinal Design Document submission. The
Final O&M Plan shall be submitted with the Final Cesign Document.
C. proiect Schedule
The Respondents shall develop and submit to U.S. EPA
and MFCA a Project Schedule for construction of the Remedial
Action. The Project Schedule shall identify timing for initiation
and completion of all critical path tasks. Respondents shall
specifically identify dates for completion of each phase of the
project and major interim milestones. An initial Project Schedule
shall be submitted simultaneously with the Prefinal Design Document
submission. The Final Project Schedule shall be submitted with
Final Design Document.
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D.
Oualitv Assurance proiect Plan
Respondents shall develop site-specific Quality
Assurance Project Plans (QAPPS) for the Remedial Action. The site-
specific QAPPs for Remedial Action activities shall be developed in
accordance with the Order and based upon applicable U. S. EPA
guidance. The QAPPs shall at a minimum include:
* Project description
* Project organization
* Project responsibilities
* Sampling and custody procedures
* Calibration procedures
* Quality assurance objectives
* Analytical procedures
* Data analysis and reporting
* Internal QC checks
* Performance and' system audits
* Preventive maintenance
* Method specific procedures for assessing data
precision, accuracy and completeness
* Corrective actions
* QA reports
* Quantification Limits for all parameters
A draft QAPP shall be prepared and submitted to U.S.
EPA and MPCA simultaneously with the Prefinal Design Document. The
final QAPP shall be submitted to U.S. EPA with the Final Design
Document. The Final QAPP shall incorporate any required corrections
or modifications to the draft QAPP.
The QAPP for Remedial Action activities must provide
guidelines for project organization and responsibility including
identification of quality assurance/quality control (QA/QC)
responsibilities for the construction contractor, lead design party
and other appropriate agencies during- construction. The final
design QAPP shall be used as a guide by the contractor to develop
a Contractor Quality Control Plan (CQCP) which must be approved by
U. S . EPA before Notice to Proceed is given. Quali ty control
procedures applicable to installation of the landfill cover shall
be consistent with applicable guidance.
E. site Safetv and Securitv Plan
"
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Respondents shall develop a site-specific site Safety
and Security Plan for the Remedial Action. The site-specific Site
Safety and Security Plan shall be designed to protect on-site
personnel and area residents from the physical, chemical and all
other hazards posed by the Remedial Action. The site safety and
Security Plan shall address but not limited to the following:
16
~ General requirements
~ Personnel
~ Levels of Protection
~ Safe work practices and safeguards
* Medical surveillance
* Personal and environmental air monitoring
* Personal protective equipment
* Personal hygiene
~ Decontamination - personnel and equipment
* site work zones
* contaminant control
* contingency and emergency planning
* Logs, reports and record keeping
* Limitation of access during Remedial
Construction
The Site Safety and Security Plan shall follow U.S. EPA
guidance and all OSHA requirements as outlined in 29 C.F.R. 1910.
A draft Site Safety and Security Plan shall be submitted
simultaneously with the Prefinal Design Document. The final Site
Safety and Security Plan shall be submitted with the Final Design
Document. The final Site Safety and Security Plan shall incorporate
any required corrections or modifications identified by U.S. EPA's
review of the draft site Safety and Security Plan.
F. Desian Staoes
The design of the Remedial Action shall include the
stages outlined below.
1. Prefinal and Final Desion
The Respondents shall submit the Prefinal/Final
design documents in two parts to U.S. EPA and MPCA. The Prefinal
Design Document for the Remedial Action shall be submitted at 95%
completion of design. After approval of theprefinal submission,
the Respondents shall execute the required revisions and submit the
Final Design Documents at loot completion of design with
reproducible drawings and specifications.
The Prefinal Design Documents shall consist of, but
not limited to, the Design Plans and Specifications (95% complete),
drafts of the O&M Plan, Capital and Operating and Maintenance Cost
Estimate, Project Schedule, Quality Assurance Plan and Site Safety
and security Plan for the Remedial Action.
The Final Design Documents for the Remedial Action
shall consist of, but not limited to, the Final Design Plans and
Specifications (lOOt complete), the Settlinq Defendants I Final
Construction Cost Estimate, the Final O&M Plan, Final Quality
Assurance Plan, Final Project Schedule and Final site Safety and
17
o
security Plan for the Remedial Action. The quality of the final
design documents shall be such that the Respondents are able to
include them in a bid package and invite contractors to submit bids
for the construction project.
2. Correlatina olans and soecifications
General correlation between drawings and technical
specifications is a basic requirement of any set of working
construction plans and specifications. Before submitting the
project specifications, the Respondents shall:
a. Coordinate and cross-check the specifications
and drawings; and
b. complete the proofing of the edited
specifications and required cross-checking of
all drawings and specifications.
These activities shall be completed prior to
submission of the Prefinal Design Document to the Agency.
3. Eouioment start-uD and ooerator traininq
The Respondents shall prepare, and include in the
technical specifications governing treatment systems, contractor
requirements for providing: appropriate service visits by
experienced personnel to supervise the installation, adjustment,
startup and operation of the treatment systems, and training
covering appropriate operational procedures once the startup has
been successfully accomplished.
4. Additional studies
'~J
Remedial Actions may require additional studies to
supplement the available technical data. At the direction of the
U. S. EPA for any such studies required, the Respondents shall
furnish all services, including field work as required, materials,
supplies, plant, labor, equipment, investigations, studies and
superintendence. Sufficient sampling, testing and analysis shall be
performed to optimize the required treatment and/or disposal
operations and systems. There shall be an initial meeting of all
principal personnel involved in the development of the program. The
purpose will be to discuss objectives, resources, communication
channels, role of personnel involved and orientation of the site,
etc. The interim report shall present the results of the testing
with the recommended treatment or disposal system (including
options). A review conference shall be scheduled after the interim
report has been reviewed by all interested parties. The final
report of the testing shall include all data taken during the
testing and a summary of the results of the studies.
18
G. Community Relations Suooort
A community relations program will be implemented by
the U.S. EPA. The Respondents shall cooperate with the U.s. EPA,
participate in the preparation of all appropriate information
disseminated to the public, and in public meetings that may be held
or sponsored by the U.S. EPA to explain activities at or concerning
the Facility including the findings of the RI/FS.
community relations support will be consistent with
superfund community relations policy as stated in the "Guidance for
Implementing the Superfund Program" and "Community Relations in
superfund - A Handbook."
TASK IV: REMEDIAL ACTION CONSTRUCTION
Within thirty (30) calendar days after U.S. EPA approval of
the Final Design Document and retainment and approval of the
Remedial Action Contractor, the Respondents shall develop and
implement a construction quality assurance (CQA) plan for the
Remedial Action to ensure; with a reasonable degree of certainty,
that the completed Remedial Action will meet or exceed all design
criteria, plans and specifications. The CQA plan for the Remedial
Action is a facility-specific document which must be approved by
U.S. EPA prior to the start of the construction of the Remedial
Action. At a minimum, the CQA plan shall include the elements which
are summarized below.
A. Resoonsibility and Authority
The responsibility and authority of all organizations
( i. e. technical consultants, construction firms, etc.) and key
personnel involved in the construction of the Remedial Action shall
be described fully, in the CQA plan. The Respondent I s proj ect
Coordinator or his or her designee shall act as the CQA officer.
B. Construction Qualitv Assurance Personnel Qualifications
The qualifications of the CQA officer and supporting
inspection personnel shall be presented in the CQA plan to
demonstrate that they possess the training and experience necessary
to. fulfill their identified responsibilities.
C. Insoection Activities
The observations and tests that will be used to monitor
the construction and/or installation of the components of the
Remedial Action shall be summarized in the CQA plan. The plan shall
include the scope and frequency of each type of inspection.
Inspections shall verify compliance with, but not be limited to air
quality and emissions monitoring requirements, waste disposal
19
.~ requirements (~, RCRA transportation manifests), etc. The
inspections shall also verify compliance with all health and safety
procedures. In addition to oversight inspections, the Respondents
shall conduct the following activities for the Remedial Action:
1. Preconstruct ion inspection and meeting
The Respondents shall conduct a preconstruct ion
inspection and meeting with a representative of U.S. EPA for the
Remedial Action to:
a. Review methods for documenting and reporting
inspection data;
b. Review methods for distributing and storing
documents and reports;
c. Review work area security and safety protocol;
d. Discuss any appropriate modifications of the
construction quality assurance plan to ensure
that site-specific considerations are
addressed; and
e. Conduct a site walk-around to verify that the
design criteria, plans, and specifications are
understood and to review material and equipment
storage locations.
The preconstruct ion inspection and meeting for the
Remedial Action shall be documented by a designated person and
minutes shall be transmitted to all parties.
2. Prefinal inspection
Upon preliminary project completion for the
Remedial Action, Respondents shall notify U.S. EPA and !filCA for the
purposes of conducting a prefinal inspection. The prefinal
inspection shall consist of a walk-through inspection ot the entire
project site by a representative ot U.S. EPA and Respondents. The
inspection i. to determine whether the proj ect is complete and
consistent with the contract documents and the approved Final
Design Document. Any uncompleted construction items discovered
during any inspection shall be identified and noted. Additionally,
treatment equipment shall be identified and noted. Treatment
equipment shall be operationally tested by Respondents. The
Respondents shall certify that the equipment operates consistently
with the plans and specitications. Retesting will be completed
where deficiencies are revealed. The pretinal inspection report
shall outline the uncompleted construction items, completion date
for these items, and proposed date for final inspection.
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20
3. Final inspection
Upon completion of any outstanding construction
i '=ems, t.~e Respondents shall notify U. S. EPA and MFCA for the
purpose of conducting a final inspection. The final inspection
shall consist of a walk-through inspection of the project site by
a representative of U.S. EPA and Respondents. The prefinal
inspection report will be used as a checklist with the final
inspection focusing on the outstanding construction items
identified in the prefinal inspection. Confirmation shall be made
that outstanding items have been resolved.
D. Samclina Requirements
The sampling activities, sample size, sample locations,
frequency of testing, acceptance and rejection criteria, and plans
for correcting problems in achieving the project specifications
shall be presented in the CQA plan and carried out according to the
Sampling Plan.
E. Documentation
Reporting requirements for CQA activities shall be
described in detail in the CQA plan for such phase. This shall
include such items as daily summary reports, inspection data
sheets, problem identification and corrective measures reports,
design acceptance reports, and final documentation. provisions for
the final storage of all records shall be presented in the CQA
plan.
TASK V: Recorts
The Respondents shall prepare and submit to U. 5. EPA and MFCA
the plans, documents, and reports as set forth in Tasks I through
Task IV to document the pre-design, design, construction,
operation, maintenance, and monitoring of the Remedial Action. All
plans, documents and reports submitted under the RAP are subject to
review and approval by U.5. EPA. Reports submitted pursuant to the
Order and thi5 RAP shall be signed by the Respondent's project
Coordinator and shall include the following statement: ~ I certify
that the information contained in or accompanying this document is
true, accurate and complete". The documentation shall include but
not limited to the following:
A. Proqress Recorts
The Respondents shall at a minimum provide the U. 5. EPA
and MPCA with signed, monthly progress reports during the design
and construction of the Remedial Action. Upon issuance by U. 5. EPA
of the Certificate of Completion of Remedial Construction, progress
reports for operation and maintenance of the Remedial Action shall
be submitted with the quarterly monitoring reports. Progress
, '.
21
,_-> reports shall include but not limited to:
1. A description of the actions which have been
taken toward achieving compliance with the
Order during the previous reporting
period, attaching copies of appropriate
supporting documentation such as invoices,
contract documents and photographs;
2. Results of sampling and tests and all other data
during the previous reporting period which have
passed QA/QC procedures;
3. All plans and procedures completed under the
RD/RA during the previous reporting period;
4. A description of all actions, data and plans
which are scheduled for the next reporting period
and other information relating to the progress of
construction;
5. A description and estimate of the percentage of
the RD/RA completed;
6. Summaries of all changes made in the RD/RA during
the previous reporting period;
7. A description of all problems including
unresolved delays encountered or anticipated that
may affect the future schedule for implementation
of the RAP or RD/RA and of actions taken to
rectify such problems or to mitigate such delays
or anticipated delays;
8. Summaries of all contacts with representatives of
the local community, public interest groups or
State government including the MPCA during the
reporting period;
9. Changes in key personnel during the previous
reporting period; and
10. Upon request, copies of daily reports, inspection
reports and similar documentation.
B. Quarterlv Monitorina Recorts
~)
The Respondents shall submit to the U.S. EPA and the
MPCA quarterly monitoring reports. The first quarterly monitoring
report shall be due 45 days after the end of the calendar quarter
in which the Respondents commence operation of the groundwater
22
extraction well system and due 45 days following each successive
calendar quarter thereafter. The quarterly monitoring reports
shall include at a minimum:
1. Results of water level measurements for all
monitoring wells, groundwater extraction wells and
piezometers, and Coon Creek during the previous
quarter, together with a water level contour map
prepared from the water level measurements. The
map shall demonstrate sufficient hydraulic barrier
that eliminates flow into and beyond Coon Creek.
2. Laboratory analytical reports, data sU1lllllary
tables, field data sheets and quality assurance
documents for all monitoring wells sampled during
the previous quarter;
3. Laboratory analytical reports, data sU1lllllary
tables, field data sheets and quality assurance
documents for all monitoring locations in Coon
Creek; and
4. Laboratory analytical reports, data sU1lllllary
tables, field data sheets, field analyses and
quality assurance documents for all landfill gas
sampling during the previous quarter.
C. other Recorts
Respondents shall submit to U.S. EPA and MPCA other
reports deemed necessary by U.S. EPA to demonstrate adequate
performance of all components of the Remedial Action and that all
response objectives and other requirements in the ROD are met.
D. Remedial Action Construction Recort
Within thirty (30) days. of: the- completion of the
construction of the Remedial Action specified in the approved Final
Design Documents a Remedial Action Construction Report shall be
submitted to U.S. EPA and MPCA. The report shall be prepared and
certified as true, accurate and complete by a registered
professional engineer and the Respondents Project Coordinator and
shall include but not limited to the following:
1. The data and results ot the Remedial Action
construction.
2. The follow-up actions, if any, which will be
taken in the following one year period.
3. A certification that all work plans,
23
.~
4.
specifications and schedules have been
implemented and completed in accordance with
Final Design Document as approved by U.S. EPA.
A demonstration that all equipment and
components of the Remedial Action are fully
operational as intended in the Final Design
Document.
5.
An identification of difficulties encountered
during the Remedial Action construction which
may impair or otherwise reduce the
effectiveness of the Remedial Action in
meeting cleanup or performance standards under
the Order or which may require
unanticipated operational or maintenance
actions to maintain the effectiveness of the
Remedial Action.
E. Approval of the Remedial Action Construction Report
The U. S. .EPA shall review the Remedial Action
Construction Report submitted pursuant to Task IV. E. above, to
determine whether the Respondent's remedial construction
obligations have been satisfactorily completed. U.S. EPA, in
consultation with the MPCA, shall notify the Respondents of U.S
EPA I S conclusions with respect to construction of the Remedial
Action. If it is determined that the Respondent's remedial
construction obligations have not been satisfactorily completed,
the Respondents shall correct any report and/or construction
deficiencies and resubmit the Remedial Action Construction Report
within thirty (30) calendar days of the notification of the U.S.
EPA determination, or as otherwise provided by U.S. EPA.
TASK VI: Schedule for RD/RA Imclementation
Respondents shall design and implement the Remedial
Action in accordance with each of the deadlines set forth below in
this Task. In addition, the Respondents shall submit a Project
Schedule identifying key milestones for construction, operation and
maintenance of the Remedial Action and establishing a schedule for
implementation of such milestones. The schedule shall include time
frames for submittal of document packages to U.S. EPA for review
and approval and time frames for meetings to discuss the
submittals.
':-J
Action are:
Key milestones for the Remedial Design and Remedial
*
q(
Submit RD/RA Work~lan, for the Remedial Action
within thirty (~~alendar days after the
effective date of the Order.
.
Submit first draft of the QAPP, Site Safety and
security Plan, project Schedule, and O&M Plan
for the Remedial Action with the Prefinal Design
Document.
*
Submit final draft of the QAPP, Site Safety and
Security Plan, Project Schedule, and O&M Plan
for the Remedial Action with the Final Design
Document for the Remedial Action.
*
Conduct any Pre-design activities and prepare and
submit Prefinal Design Document for the Remedial
Action 180 calendar days after approval of the
RD/RA Work Plan.
Submit Final Design Document for the Remedial
Action thirty (30) calendar days from receipt of
approval of the Prefinal Design Document for the
Remedial Action.
*
*
~etain approved Remedial Action Contractor for
the Remedial Action sixty (60) calendar days after
receipt of approval of the Final Design Document
for the Remedial Action.
*
Initiate construction of the Remedial Action twenty
(20) calendar days from the latest of the following
events: approval of the Remedial Action Contractor
or approval of the CQA Plan for the Remedial
Action.
*
Complete construction of tha.Remedial Action and
initiate pumping of all groundwater extraction
wells in accordance with the approved Project
Schedule.
'j
\.~
TABLE 1
Volatiles
1. Chloromethane
2. Bromomethane
3. Vinyl Chloride
4. Ol.loroethane
S. Methylene Chloride
6. Acetone
7. Carbon Disulfide '
8. l.l-Dichloroethene
9. l.l-Dichloroethane
10. 1.1-Dichloroethene (Total)
11. Chloroform
12. I.1-Dichloroeth.ane
13.2-Butanone
14, l.l.l-Trichloroethane
IS. Carbon Tetrachloride
16. Vinyl Acetate
17, Bromodichloromethane
18. 1,1.2,.2. T etr:ichloroethane
19. 1.1-Dichloropropane
20. trans-I.3- Dichloropropene
.;Z 1. Trichloroethene
22. Dibromochloromethane
23.1,1,.2-Trichloroethane
24. Benzene
25. cis-l,3-Dichloropropene
26. 2-Chloroethyl Vinyl Ether
27. Bromoform
28.2-Hexanone
29.4-Methyl-2-pentanone
30. Tecrachloroethene
31. Toluene
32.C1Uorobenzene
33. Ethyl Benzene
34. S cyrene
35. Total Xylenes
"
~ )
~
page 1 of 5
Semi-Volatiles
36. Phenol
37. bis(2-0110r0ethyl)ether
38.2-ClUorophenol
39. l,3-Dichlorobenzene
40. l,4-Dichlorobenzene
41. Benzyl Alcohol
42. l,2-Dichlorobenzene
43.2-Methylphenol
44. bis(2-Chloroisopropyl)ether
45. 4-Methylphenol
46. N-Nicroso-Dipropylamine
47. Hexachloroethane
48. Nicrobenzene
49, Isophorone
50.2-Nicrophenol
51. 2,4-Dimethylphenol
52. Benzoic Acid
53. bis(2-ChloroethoxY)IIlethane
54. 2,4-Dichlorophenol
55. 1,2,4- Trichlorobenzene
,-...
,
56, Naphthalene
57.4-~~oroaniline
58. Hexachlorobutadiene
59.4-Chloro-3-IIlethylphenol
(para -ChlOI'O-IIleta -cresol)
60. 2-Methylnaphthalene
61. Hexachlorocyclopentadiene
62. 2,4.6- Trichlorophenol
63. 2,4,5- Trichlorophenol
64. 2-Chloronaphthalene
65. 2-Nicroaniline
66. Dimethyl Phthalate
67. Acenaphthylene
68. 3-Nicroaniline
69. Acenaphthene
70. 2,4-Dinitrophenol
71. 4-Nicrophenol
72. Dibenzofuran
73. 2.4-Dinitrotoluene
74. 2.6-Dinitrotoluene
:..lJlLE 1
page 2 of 5
,)
DELE 1
(
Semi.Volatiles (cont)
75. Diethylphthalate
76. 4-Ollorophenyl Phenyl Ether
77. F1uorene
78.4-Nitroaniline
79.4,6-Dinitro-2-methylphenol
80. N-nitrosodiphenylamine
81. 4-Bromophenyl Phenyl Ether
S2, Hex.achlorobenzene
83. Pentachlorophenol
84,Phenanthn:ne
85. Anthracene
86. Di-n-butylphthalate
87. F1uoranthene
88.Pyrene
89, Butyl Benzyl Phthalate
90, 3.3' -Dichlorobenzidine
91. Benzo(a)anthracetle
92. bis(2-ethyIhexyl)phthalate
93. Chrysene
94, Di-n~tyI Phthalate
95. Benzo(b)f1uoranthene
96, Benzo~)f1uoranthene
97, Benzo(a)pyrene
98. Indeno(l.2.3-cd)pyrene
99, Dibenz(a.h)anthra.cene
100. Benzo (g,h.i)perylene
[,' )
~-
page 3 of 5
Metals:
1. Aluminum
2. ~ti!nooy
3. Arsenic
4. Barium
5. Beryllium
6. ('Jll"Imium
7. Calcium
8. Chromium
9. Cobalt
1 O. Copper
11. Iron
12. Lud
13. Magnesium
14. Manganes.e
15. Mercury
16. Nickel
17. PotaSsium
18. Selenium
19. Silva
20. Sodium
21. Thallium
22. Tin
J 23, Vanadium
24. Zinc
25, Cyanide
T,~l.E 1
pa~e 4 of 5
:_)
,- .)
'-
TABLE 1
GENERAL CHEMISTRY:
1. BOD
2. COD
3 . Hardness
4 . Alkalini ty
5. Specific Conductance
6. pH
7. Total Suspended Solids (TSS)
8. Total Dissolved Solids (TDS)
9. Nitrate/Nitrite/TKN/Ammonia
10. Sulfate/Sulfide
11. Chloride
12. Fluoride
13. Total Organic Carbon (TOC)
14. Iron
15. Total Phenols
page 5 of 5
~
CITY of ANDOVER
-:.J
CITY OF ANDOVER
COUNTY OF ANOKA
STATE OF MINNESOTA
NOTICE OF PUBLIC HEARING
The Planning and zoning Commission of the City of Andover will
hold a public hearing at 7:30 p.m., or as soon thereafter as can
be heard, on Tuesday, November 26, 1991 at the Andover City Hall,
1685 Crosstown Blvd. NW, Andover, MN to review the proposed major
amendment to the Andover Comprehensive Plan that would add the
property known as the Waste Disposal Engineering, Inc. sanitary
landfill to the Metropolitan Urban Services Area. The Site is
located in Sections 27 and 34, Township 32, Range 24, Anoka
County, Minnesota and includes the following described property:
(1) the south half of the Southeast Quarter of Section 27,
Township 32, Range 24;
(2) all that part of the Northwest Quarter of the Southeast
Quarter lying southerly of the center line of Coon Creek in
Section 27, Township 32, Range 24;
(3) all that part of the Northeast Quarter of the Southwest
Quarter of Section 27, Township 32, Range 24, that is
described as follows: Commencing at the Northeast Corner of
said Northeast Quarter of the Southwest Quarter; thence west
along the north line thereof for 58.6 feet and to the center
line of County State Highway No. 18; thence South 32 degrees,
55 minutes west for 550.17 feet along said center line;
thence South 44 degrees, 11 minutes West for 342.85 feet
along said center line; thence South 45 degrees, 26 minutes
East for 872 feet and to the Southeast corner of said
Northeast Quarter of the Southwest Quarter; thence North
along the East line of said Northeast Quarter of the
Southwest Quarter and to the point of commencement;
(4) the North 200 feet of the Northeast Quarter of the Northeast
Quarter of Section 34~ Township 32, Range 24;
(5) the North 200 feet of the Northwest Quarter of the Northeast
Quarter of Section 34, Township 32, Range 24 and that portion
of the Northwest Quarter of the Northeast Quarter of Section
34, Township 32, Range 24 lying within 200 feet of the toe of
the existing landfill;
o
(6) the East 200 feet of the Southeast Quarter of the Southwest
Quarter of Section 27, Township 32, Range 24 lying within 200
feet of the toe of the existing landfill; and
(7) all that part of the Northeast Quarter of the Southeast
Quarter of Section 27, Township 32, Range 24 lying southerly
(_ of the center line of Coon Creek.
~Z-~ j~
V1ctor1a Volk, City Clerk
publication dates: November 15, 1991
November 22. 1991
34-32-24-11-0001
Ronme1 Inc.
Wasteco Inc.
95 W Ivy Ave
St. Paul, MN 55117
26-32-24-32-0007
,~~;,ntree Realty, Inc.
025 Hwy 65 NE
Blaine, MN. 55434
27-32-24-42-0004
David E.&L.M. Overbaugh
1826 Andover Blvd. NW
Andover, MN. 55304
27-32-24-42-0008
Mike & Tammy Hollister
1816 Andover Blvd NW
Andover, MN. 55304
27-32-24-13-0017
Don & Audrey Ramsey
14570 Martin Ct.
Andover, MN. 55304
27-32-24-31-0040
Leonard & Doris Johnson
14440 Crosstown Blvd
Andover, MN. 55304
27-32-24-31-0035
Dale Mashuga
14330 NW Osage St.
Andover, MN. 55304
27-32-24-31-0016
Jim & Sherri Mastenbrook
14395 NW Partridge St.
Andover, MN. 55304
27-32-24-31-0013
Leroy & Audrey Mueller
14335 Partridge st. NW
Andover, MN. 55304
27-32-24-34-0012
Occupant
2069 142nd Lane NW
Andover, MN. 55304
,--.J
35-32-24-22-0004
Occupant
2326 NW 140th Ave
Andover, MN. 55304
27-32-24-41-0002
William G. & K.M. Hupp
1650 Andover Blvd NW
Andover, MN. 55304
27-32-24-42-0005
Dan K. & Jennifer Barnes
1836 Andover Blvd NW
Andover, MN. 55304
27-32-24-42-0002
Marvin & Evelyn Nelson
Wicht E. Paul
Route 3
Verndale, MN. 56481
27-32-24-24-0002
Carl & Marie Erickson
14610 Crosstown Blvd NW
Andover, MN. 55304
27-32-24-31-0020
Robert Katvala
14380 NW Osage St.
Andover, MN. 55304
27-32-24-31-0004
Scott & Sherry Zerk
14352 Crosstown Blvd NW
Andover, MN. 55304
27-32-24-31-0016
James & Jody Lis
14375 NW Partridge st.
Andover, MN. 55304
27-32-24-31-0012
Mike & Sue Hayes
14315 NW Partridge st.
Andover, MN. 55304
27-32-24-34-0013
Kirby & Theresa Vannote
2057 NW 142nd Lane
Andover, MN. 55304
26-32-24-33-0029
Hills Inc.
2619 Coon Rapids Blvd.
Coon Rapids, MN. 55433
27-32-24-42-0003
Gloria M. Freyholtz
1806 Andover Blvd. NW
Andover, MN. 55304
27-32-24-42-0006
Eric Vangstad
1876 Andover Blvd NW
Andover, MN. 55304
27-32-24-13-0016
Thorval & Helen Vig
14520 Martin Ct.
Andover, MN. 55304
27-32-24-31-0001
Wallace & Ruth Paschke
14430 Crosstown Blvd ~
Andover, MN. 55304
27-32-24-31-0019
Conrad R. & D.E.
Groshong
14354 Osage st. NW
Andover, MN. 55304
27-32-24-31-0009
David & Marilyn Hays
14360 NW Partridge st.
Andover, MN. 55304
27-32-24-31-0014
Lars & Eileen Andersor.
14357 NW Partridge st.
Andover, MN. 55304
27-32-24-34-0011
Gerry & Carol
Winds chi tl
3640 152nd Lane NW
Andover, MN. 55304
27-32-24-34-0024
Bill & Jill Heck
2078 NW l42nd Lane NW
Andover, MN. 55304
27-32-24-34-0025
steve & Sandra Nelson
2066 142nd Lane NW
Andover, MN. 55304
27-32-24-34-0074
/" 'cupant
',-/'79 142nd Ave NW
Andover, MN. 55304
27-32-24-34-0078
Occupant
2068 142nd Ave NW
Andover, MN. 55304
27-32-24-34-54
Occupant
2101 141st Lane NW
Andover, MN. 55304
27-32-24-34-71
" D & D Davis
2083 141st Ave NW
Andover, MN. 55304
27-32-24-21-0056
Occupant
14043 Nightingale st NW
Andover, MN. 55304
27-32-24-21-0059
Occupant
14011 Nightingale St NW
Andover, MN. 55304
, '\
,~J
27-32-24-34-0026
Occupant
2054 142nd Lane NW
Andover, MN. 55304
27-32-24-34-0075
Occupant
2067 142nd Ave NW
Andover, MN 55304
27-32-24-34-55
Dennis & Lora Rutt
2089 NW 141st Lane
Andover, MN. 55304
27-32-24-34-57
Occupant
2094 141st Lane NW
Andover, MN. 55304
27-32-24-34-0076
Occupant
2092 142nd Ave NW
Andover~ MN. 55304
27-32-24-21-0057
Occupant
14031 Nightingale St NW
Andover, MN. 55304
27 =-3-2-24=-34-0072
Gerry & Carol
Winds chi tl
3640 152nd Lane NW
Andover, MN. 55304
27-32-24-34-0077
Occupant
2080 142nd Ave NW
Andover, MN. 55304
27-32-24-34-56
Shawnon & Janelle
Nelson
2082 NW 141st Lane
Andover, MN. 55304
27-32-24-34-70
Occupant
2095 141st Ave NW
Andover, roN. 55304
27-32-24-34-0073
Occupant
2091 142nd Ave NW
Andover, MN. 55304
27-32-24-21-0058
Occupant
14021 Nightingale ST K
Andover, MN. 55304