PB94-964130
EPA/ROD/R05-94/256
September 1994
EPA Superfund
Record of Decision:
Agate Lake Scrap Yard Site, MN
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.RECORD OF DECISION.
SITE NAME AND LOCATION
AGATE LAKE SCRAP YARD SITE
FAIRVIEW TOWNSHIP, KIHHESOTA
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the.AGATE
LAKE SCRAP YARD SITE in FAIRVIEW TOWNSHIP, MXHRBSOTA, chosen in accordance
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, to the extent practicable, the National Contingency
Plan (NCP) (40 CFR Part 300). This decision is also in accordance 'with the
Minnesota Environment.al Response' and Liabili ty Act (MBRLA), Minn. Stat ch.
115B(1992).. The decision is based on the~Administrative Record for the AGATE
LAKE SCRAP YARD SITE. The attached index identifies the items which comprise
the administrative record upon which the selection of the remedial action is
based.
The state of Minnesota and the United States Environmental Protection Agency
(U.S. EPA) concur with the selected. remedy.
ASSESSMENT OF THE SITE
Actual'or trzeatened releases of hazardous substances from this site, .may
present an imminent and substantial 'endangerment to 'public.health, welfare, or
the environment. .
DESCRIPTION OF SELECTED REMEDY
The selected remedial action for the AGATE LAKE SCRAP YARD site addresses. only
the groundwater contamination. This action is consistent with previous
interim response actions (IRA) taken for the site which included excavation
and .removal of contaminated soils and asbestos. The major components of the
selected remedial action include: .
REMEDIAL ACTIqN COMPONENTS.
*
Institutional contro~s that prevent installation of drinking water
wells within the vicinity of the contaminated ground water
boundaries and disturbance of fill material until health based
remedial action goals have been achieved.
Installation of four additional monitoring wells and a ground
water monitoring program to confirm the adequacy of the natural
attenuation of residual contami~ated ground water. .
.*
All factors considered,' the state .of Minnesota and U.S. EPA have determined
that natural attenuation of residually contaminated ground water is a viable
al ternati ve to treatment technology for ground water contamination. The
effectiveness of natural attenuation on ground water will be evaluated during
the five year review. Along with the institutional control for the
installation of any drinking water well in the area of the plume, this shall
provide for protection of. public health and the environment within U.S. EPA's
acceptable risk range. Based upon the five year review, U.S. EPA and the
state of Minnesota may determine that these health based goals have not been
achieved via natural attenuation, then they may determine that additional
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2
STATCTORY DETERNINATIONS
Consistent wi th MERLA cfud CERCLA as amended by Superfund Amendments and
Reauthorization Act of 1986 (SARA), 42 U.S.C. Section 9621, and to the extent
practicable, with the NCP, 40 CFR Part 300, the selected remedial actions are
protective of human health and the environment, comply with federal and state
requirements that are legally applicable or relevant and appropriate to the
remedial action,. and are cost-effective. The remedy utilizes permanent
solutions and considers alternative treatment (or resource recovery) .
technologies to the maximum extent practicable at this site.. The. remedy
relies in part, on institutional controls to protect human healthJuntil such
time health based standards are achieved at the site via natural attenuation.
The results of the Remedial Investigation and Feasibility Study (RI/FS)
indicate that the toxic~ty, ~bility and volume of the contaminants in th,e.
ground water are being addresse4 via natural attenuation within the same
timeframes as an active treatment technology could. Thus, treatment of the
ground water to permanently and significantly reduce the toxicity, mobility'
and volume of contaminants was not found to be necessary to protect human
health and the environment, or to be practicable at the site at this time.
Because this remedy will result in perchloroethene (PCB) remaining on-site in
the ground water, a hazardous substance, above health based levels, a review
will be conducted within 'five years after commencement of remedial action to
ensure that the remedy continues to provide adequate protection of human
'heal th and the environment. If, however, the analytical results generated as
a result of monitoring ground water. indicate the migration toward the nearby
lake at leve that may cause adverse impacts, a treatment system will be '
evaluated~ . . . . .
/;L/o?S/93
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I.
, II.
III.
IV. '
V.
VI.
VII.
VIII.,
IX.
x.
XI.
XII.
TABLE 1
3
SmDlAR.Y OF REMEDXAL ALTERNAT:IVE SELECTION
AGATE LAKE SCRAP YARD SITE
FAIRVIEW TOWNSHIP, laNNBSOTA
,******~ '
TABLE OF COR'l'EN'l'S
SITE NAME, LOCATION AND DESCRIPTION...................:.
SITE HISTORY AND ENFORCEMENT ACTIVITIES..........;......
CCMMONITY RELATIONS HISTORY................~............
SCOPE AND ROLE OF REMEDIAL ACTIVITIES...................
SUMMARY OF SITE CHARACTERISTICS.........................
SUMMARY OF SITE RISKS.... ,. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
DOCUMENTATION OF SIGNIFICANT CHANGES....................
DESCRIPTIONS OF ALTERNATIVES. .. . . . . . . . . . . . . . . . . .. . .' . . . . .
SUMMARY OF THE COMPARATIVE ANALY~IS OF ALTERNATIVES... ; .
THE SELECTED REMEDY......... . . . . . . . . . . . . . . . . . . . . . . . . . . . .
STATUTORY DETERMINATIONS SUMMARY........................
DOCUMENTS REVIEWED.......... . . . . . . . . . . . . . . . . . . . . . . . . . . . .
LIST OF TABLES
POLYCHLORINATED BIPHENYLS IN AGATE LAKE SEDIMENT
Page
4
4
7
7
.9
14
19
24
26
31
31
33
PCBS, MERCURY, TETRACHLORO-DIBENZODIOXIN,
, AND TOTAL TETRACHLORODIBENZOFURANS IN FISH FROM,
AGATE LAKE AND GULL LAKE ' , ,
SOILS CONTAMINANTS, HIGHEST LEVELS FOUND, AND CLEANUP LEVELS
TABLE 2
TABLE 3
TABLE 4
TABLE 5
, FIGURE 1
FIGURE 2
FIGURE 3
FIGURE 4
FIGURE 5
. ,
FIGURE 6
FIGURE 7
PERCHLOROETHENE (PCE) IN GROUND WATER AND ITS LOCATION, BY SAMPLING
DATES
COST COMPARISON OF THE GROUND WATER ALTERNATIVES
LIST OF FIGtJRES
SITE LOCATIpN
,-
AGATE LAKE SCRAP Y.ARP
AREA USED FOR SITE ACTIVITIES AT AGATE. LAKE SCRAP YARD
SAMPLING GRID SHOWING PCB IMPACTED SOILS AT AGATE LAKE
SCRAP YARD
LEAD DISTRIBUTION IN ROAD ALONG SMELTER AREA, AGATE LAKE
SCRAP YARD
POLYCHLORINATED BIPHENYL LEVELS DETECTED IN AGATE LAKE
SEDIMENT' " .
LOCATIONS OF SMELTER AREA, GULLY AND MONITORING WELLS, AND
GROUND WATER CONTOUR MAP AT AGATE LAKE SCRAP YARD
PROPOSED LOCATION OF NEW MONITORING WELLS AND OF DEED
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
AGATE LAKE SCRAP YARD. SITE
FAJ:RV:tEW TOWNSHIP, CASS COUNTY, MINNESOTA
I.
SI'l'E NAME. LOCATION AND DESCRIPTION
The Agate Lake Scrap Yard site (Site) is located in Fairview Township, Cass
County, Minnesota, on the southwest shore of Agate Lake (Figure 1). Agate
Lake is within one half mile on the west side of Gull Lake, which is located
approximately 15 miles northwest of the city of Brainerd.
The Site is approximately eight acres in size, and is located on land
surrounded on three sides by either open water or wetlands. This peninsular
land, which rises approximately ten feet above the surrounding water level, .~s
composed .of sandy glacial deposits, which extend to a depthof.200 feet or
more. There are thin lenses of gravel and clay interspersed in the top 100
feet of the soil profile. The surrounding land in the area is gently rolling.
The ground water flow on the Site is generally from the northwest to the
southeast. Ground water below the peninsular rise, near the middle of the
Site, fans out towards Agate Lake to the east and to the south. According to
the health assessment prepared by the Minnesota Department of Health (MDH)
dated June 27, 1989, and redrafted in August 1992~ the Site exhibits surface
water drainage to the three sides having surface water bodies: to the east
and to the south is. Agate Lake, and on the west is a wetland that appears to
drain into Agate Lake. . . .. ..
. .
The Site is surrounded by the Pillsbury State Forest, and is primarily wooded.
Near the Site are a number of houses and summer residences, as well as two
small resorts and a golf course. Nearly all are on the east side of the lake,
and the residents obtain their'water from private wells. The nearest city to
the Site is Lake Shore, located approximately five miles to the north on Upper
Gull Lake. The. city had a population of 699 in 1991 according to the State
Demographer.
II.
SITE HISTORY AND ENFORCEMENT ACTIv:rTY
In 1952, Mr. Pau;L.Kramer established a scrap yard On the farmland owned by. his
mother. The scrap yard operation consisted of buying and selling scrap yard
materials such as white goods,. scrap iron and metal and used cars. During the.
1970's, the scrap included drums of solvents and various oils, along with a
large number of transformers (approximately 1400) (Figure 2).
Mr. Kramer made use of the transformer oils in a smelter and a homemade
burner. In the smelter, he recovered aluminum and lead by melting and pouring
these molten metals into molds. He also recovered copper by burning the
insulation off copper wire. Mr. Kramer.operated the scrap yard until the end
of 1982, when Minnesota Pollution Control Agency (MPCA) staff ordered that he
cease moving, draining or burning any oils, transformers, transformer cases,
drums, ashes or soil, until all necessary testing for polychlorinated
biphenyls (PCBs) had been completed. The activities at the scrap yard came to
the attention of MPCA staff due to a confidential report to the regional
office in Brainerd.
According to Mr. Kramer, he obtained the pole-mounted transformers from the
Crow Wing Cooperative Power and Light Company (Crow Wing Coop) in Brainerd,
and the large transformers from Burlington Northern Railroad Company (BNRR),
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In January 1983, BNRR removed the transformers and drums attributed to BNRR
from the Site, and placed them in their Brainerd shops. The oils from the
transformers and'the drums were tested prior to their di8{.:>sal with Rollins
Environmental Services in Deer Park, Texas. In May and June 1983, a .
consultant for BNRR, Mr. Mel Davis of Chemical Ccnsultant Formulators, Inc.
(CCF), sampled soil and ground water at the Site and reported its findings in
a June 1983 report, entitled "Burlington Northern Railroad/Agate Lake Site."
Samples taken by MPCA staff from transformers and drums containing transformer
oils in November 1982 showed some samples to contain PCBs at concentrations in
excess of 300 milligrams per kilogram (mg/kg). Subsequent samples identified
transformer oils at the Site, with a concentration of PCBs as high as 67
percent by weight. .
Crow Wing coOp hired Mr. Davis as a consultant to remove the remaining
transformers from the Site, and "to clean up the Agate Lake.Site." .In early
~ugust 1983, CCF placed residual oils frOm the transformers into drums; had
the transformers .crushed on' site, and shipped the crushed transformers to .
North Star Steel Corporation in St. Paul, Minnesota. The collected oils were
analyzed and disposed of according to Toxic Substances Control Act (TSCA)
regulations at the location referenced above. CCF also removed parts from the
smelter, which reportedly rendered the smelter inoperable.
CCF took soil samples and removed approximately six inches of topsoil in the
areas where the transformers had been located around the smelter and burner,
and where scrap yard operations had taken place. The removed topsoil was
placed in a gully on the property, which CCF identified as a "microbiological
cell," suggesting that biological degradation of PCBs .and oils would occur. .
New.topsoil was placed over the areas where soils had been removed, and the
areas were seeded with rye grass. A report on these activities was issued by'
CCF in mid-September 1983, entitled."Kramer Agate Lake Scrapyard Site/Crow
Wing Cooperative."
None of the activities CCF performed for BNRR or for Crow Wing Coop were
conducted with MPCA knowledge, approval or authorization.
The Site was listed on the Minnesota Permanent List of priorities (PLP) in
October 1984., with a provisional Hazard Ranking SysteDi (HRS). score of 31.
Site was also listed on the federal National priorities List (NPL) in 1984
with a final HRS score of ,29.68. . .'
Based on lc3.borato%y results, a health advisory ~as issued by the'MDH, in'
December 1984, warning the Kramer family against the use of the well water for
drinking and food preparation purposes. Mr. Kramer refused an offer from the
MPCA to provide bottled drinking water, saying he had made his own
arrangements to obtain adequate water. Additionally, based on fish samples
obtained from Agate Lake and Gull Lake which determined the fish to have
significant mercury contamination, showing higher levels in the Agate Lake
fish samples, the MDH issued a Fish Consumption Advisory for both lakes in May
1985.
The
.In early 1985, the U. S. Environmental Protection Agency. (U. S. EPA) Field.
Inspection Team prepared a work plan through its consultant, Ecology and
Environment, Inc. (E&E), to install a number of ground water monitoring wells
and to monitor ground water. However, in September 1985, MPCA sought and
obtained funding from the federal Superfund under the Multi-Site Cooperative
Agreement to perform a Remedial Investigation (RI) and a Feasibility Study
(FS) at the Site.
The MPCA issued a Request .For Response Action (RFRA) to BNRR, Crow wing Coop
and to Mr. Paul Kramer on January 28, 1986. The RFRA directed the identified
..responsible parties (RPs) to take specific actions within specified timelines,
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actions included completion of an 1U on the Site, to develop an PS, to prepare
a Response Action Plan (RAP), and to implement the approved Response Actions
(RAs). Two RPs, BNRR and Crow. Wing Coop, indicated their willingness to
cooperate. and fulfill the requirements stated in the RFRA. Mr. Paul Kramer
indicated his willingness to cooperate, but the lack of funds prevented him
from participating financially in the work.
MPCA staff investigated other. potential sources of Solvents or transformers,
and was unable to identify other RPs. The BNRR and Crow Wing Coop hired
Conestoga-Rovers & Associates Limited (CRA) as their consultant to complete
the requirements of the RFRA. The RPs also clearly stated their intention not
to sign a Consent Order, unless the state would share a portion of the cleanup
costs and. the RPs would receive a complete release of liability. Currently,
there are no such contracts, agreements or orders between MPCA.and/or U.S. BPA
and the RPs.
In June 1986, CRA initiated the RI at the Site, and conducted a limited site
cleanup by removing large quanti ties of garbage and of scrap metal. CRA
completed the RI in January 1987, and submitted a Feasibility Study/Remedial
Action Plan (FS/RAP) in October 1987. The RPs and their consultant CRA stated
the intention to implement the RAs at the Site in November 1987, even though
nei ther MPCA nor U. S. U. S. BPA had yet approved the RAe. The RAe consisted
principally of the removal of the ash pile and a placement of a cap over the
Site. Yet,. when the RPs arrived at the Site to implement the RAe, Mr. Kramer
refused any further access to his property and further activities at the Site
were placed on indefinite hold.
During the follo~ing year, MPCAst~ff attempted arid failed to' reaCh an .
agreement with Mr. Kramer, to obtain access to his property. . In January 1989,
Mr. Kramer suddenly passed away. In January 1990, MPCA staff located Mrs.
Kramer to obtain her approval for access to the property. Due to a complex
property ownership including at least eleven family members, a legal access
agreement was developed to cover approval from all property owners. The
access agreement was signed by all parties on October 18, 1990.
At the request of U.S. BP."\, additional remedial investigations were undertaken
during 1991 and 1992. The investigation findings provided a better definition
of the PCBs distribution and levels over the site, as well as the occurrence
of lead along the access road in addition to the slag and ash piles. .
Additionally; .a.better understanding was obtainp.d of the localized pre~ence of
the solvent tetrachloroethene (PCB) identified at one monitoring well .
location.
The areas of soil contamina~~d by PCBs are shown in FigUre 3, and covered less
than a quarter acre. The highest level of PCBs found in soil was 89 mg/kg,
compared with a cleanup level of 1 mg/kg pranulgated by U.S. EPA. The areas
of soil contaminated by lead are shown in Figure 4 and covered nearly a
quarter acre. The highest level of total lead found in soil was 13,200 mg/kg
or 1.3 percent. The cleanup level of lead in soil was 300 mg/kg; U.S. BPA
standard is 500 mg/kg.
The s.lag and ash piles, which comprised about 75 tons,. had elevated lead
levels previously determined to contain 350 milligram per liter (mg/l) lead,
pursuant to the extraction procedure toxicity test. The elevated lead levels
led to the implementation of an interim response action (IRA) that resulted in
its treatment and disposal at an approved landfill. Additional IRAe were
approved for the treatment and disposal of soils with PCBs and lead
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U:I.
COMMUN':ITY RELAT:IONS H:ISTORY
Listing the Site on the PLP generated very little community interest. Bach
year since the listing in 1984 a brief description of the Site with the
actions taken by the MPCA has been sent out to daily newspapers throughout the
state of Minnesota, as part of the PLP requirements. The only contact
resulting from the PLP updates was with a seasonal resident on the southeast
side of Agate Lake, concerned' about the Site having contaminated her well. It
was determined by MPCA staff that the seasonal resident's well had not'been.
impacted by Site contamination, since this well was located on the .east side
of Agate Lake at a distance to far to be impacted by site contaminants.
As part of the public participation process, MPCA staff held two public
meetings to pres~nt the findings on the Site, to discuss the proposed cleanup
plan for the Site., and to encou]:'agepublic. comment on those proposed.
activities. One meeting was held ~ith the Lake Shore City Council, and
. another was held with. the Agate Lake Association, which is composed of the
residents living around the lake.
As part of the meetings held on May 26 and 30, 1992, MPCA staff distributed a
fact sheet on the findings at the Site, and discussed the proposed interim
response actions of removal of the slag and ash piles and soils contaminated
by lead, as well as the soils contaminated by PCBs. News releases of the
public meetings were sent to all daily aad weekly newspapers, radio and
television stations, public officials, environmental groups, lake associations
and others. .
. .
prior'to the. public meetings, an Administrative Record was established and
placed in' an Information Repository located in the Brainerd Public Library.
Consistent with Section 113 of CERCLA, the ~nistrative Record included all
relevant documents' available at the time, including work plans, data analyses,
remedial investigations and other relevant information. The public was
invited to review all information and raise their questions and concerns with
MPCA staff. No concerns or questions fran the public have been raised with
MPCA staff, other than the dates when the interim response actions would be
undertaken.
The proposed plan wal;J presented formally to the community in a' public meeting
on June 1., '1993. The comment period began May 19,19.93 and ended June 18,
i993~ The responsiveness summary resulting from. that meeting is shown in.
Part VII of this document. .
'IV .
SCOPE AND ROLB OP OPERABLE UNITS FOR :INTERXM RESPONSB ACT:IONS
The RI identified as the principal Site threats to public health and the
environment the following site conditions:
2)
The slag and ash piles as ,well as the surrounding soils, which had
been contaminated by the high lead levels, to the west of the
Kramer house (see Table 3); similarly, the access roa~ ~d also
been impacted by varying levels of lead, as shown in Pigure 4; the
total area impacted was nearly one quarter acre and about 260 tons
of soils were removed, of which 75 tons were from the slag and ash
piles.
The soil areas contaminated by PCBs, located north of the location
of the Kramer house (see Figure 3); the total area impacted was,
approximately one quarter acre and the volume of contaminated soil
was about 200 t.ons, which were removed.
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3)
The small pile of about 3 cubic yards of asbestos containing pipe
insulation, located directly south of the residence; and,
Topsoil cover and revegetation over areas where contaminated soil.
was removed containing lead and PCBs.
4)
5)
The localized presence of the solvent perchloroethene (PCB) found
in ground water samples obtained from one monitoring well near the
smelter and burner location. .
To address the first three items of site contamination, which may be
considered as a soils operable unit, interim response actions. (IRAs) were
undertaken to remove and to eliminate to the extent practicable those sources
of contamination from the Site. The slag and ash piles were removed~ing
September 1992. . The remaining IRAs. to remove PCB soils ~d.remaining lead.
contaminated soils were delayed in their implementation due to the necessary
permit requirements, but were cCXllpleted in Hay 1993. The cleanup levels
applicable to the soils were 300 mg/kg or 300 parts per million (ppm) of lead
in soil, and 1 ppm PCBs in soil.
The slag and ash pile, as well as the soils contaminated with lead were placed
in the Chemical Waste Management, Inc. (CWM) RCRA Subtitle C Adams Center
Landfill in Fort Wayne, Indiana, where they were stabilized to prevent
leaching of lead. The soils containing -PCBs above 50 ppm were disposed at the
USPCI TSCA Landfill in Grassy Mountain, Utah, while soils with PCBs below 50
ppm were disposed in the USPCI Industrial Landfill in Rosemount, Minnesota.
Asbestos, subsequently discovered in pipe, was also 'disposed at the'USPCI .
facility in Rosemount, . Minnesota. Visual. observation confirmed that. all the.
asbestos was removed. The fourth item, top soil cOver and revegetation of the
excavated areas, will be implemented in the Spring of 1994, .when the weather
is more favorable.
The remaining contamination at the Site, since the soils operable unit has
been completed, is a ground water operable unit. PCB was found in the shallow
ground water, only at the location of monitoring well OW-6 (see Figure 6),
which exceeded both the maximum contaminant level (MCL) promulgated by U.S.
EPA of 5 micrograms/liter (~g/l) and the Recommended Allowable Limit (RAL)
promulgated by the Minnesota Department of Health (MeH) of 7.0 ~g/l. This
well is 10cate4 west of. the smeltering activities and has been sampled eight
times;. The levels .of PCB. changed over time from 18'~g/1 in July 1986 to 44.
~g/l in January 1992, prior to the initiation of an aquifer pump test (see
Table 4). After seven days of pumping, at a rate of about five gallons per
minute (gpm), the PCB level found in the ground water at OW-6 was 9 p.g/l. The
aquifer test demonstrated that PCB level observed represents a "pocket II of
higher contamination within a possible plume. Therefore the possible plume
would have a lower PCB concentration. No additional ground water sampling has
been done, since the ground water monitoring will be initiated following
approval of the remedy with installation of four additional monitoring wells
for long term monitoring.
None of the other on-site monitoring wells.have shown any levels of PCB
throughout the sampling period. only the Kramer well evidenced PCB at a level
of 4.6 p.g/l during a sampling event in August 1987. In 1991, the utilities 14
necessary to operate the Kramer well were texminated, so the well is no longer
functional. All of this indicated that the PCB contamination of ground water
is a very localized occurrence, and no plume was identified. Similarly, the
levels of PCB are low, which suggests that it would take a very large volume
of water removing very small quantities of PCB to try to remediate this
contaminant. During the seven-day pump test, about 50,000 gallons were pumped
but the calculated amount of PCB extracted was less than 8 grams (gm),
assuming that the maximum concentration of 44 ~g/l had remained constant
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9
Four alternatives were reviewed in the FS to deal with the localized ground
water contamination. The al ternati ves were screened and compared to each
other and to the remedial objectives, to determine their abi],.ity to achieve
the objective of reducing PCB below MCL and RAL concentrations.. The .
alternatives included: 1) No-Action, 2) Monitoring, 3) Ground water
extraction (pump and treat), and.) Institutional controls. The monitoring
alternative would depend essentially upon natural attenuation to reduce PCB
levels, while monitoring thecbanges of PCB levels in ground water over time.
The ground water extraction with spray irrigation as. treatment would. try to
achieve the PCB reduction by the means of' acti ve removal of ground water, as
occurred under the aquifer test.' . .
In view of the limited effectiveness of a .pump and treat. alternative, i.e.,
significantly less than 8 gm PCB removed per 50,000 gallons under the aquifer
test, the final rule of the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP) Section 300.430 (1990) allows the ~loymentof 'natural
,attenuation as a substitute, for treatment. Such natural attenuation would be
c~ined with institutional control, which would prevent the installation of
. any well in the affected area to be used for obtaining drinking water. The
selection of this remedial action for this Site will eliminate the threats
associated with direct contact with the contaminated medium.
The role of the remedial action selected, when combined with the several IRAs,
is expected to. be a complete site remedy~ When the remedial action is
completed, no further remedial action at the Site other than ground water
monitoring is envisioned. The monitoring of ground .water will be conducted to
assess the ability of the ground water to naturally attenuate. Since
hazardous substances above health based levels' will remain on site, a.five.
ye~r review will be necessary. '
v.
SUMMARY OP SITE CHARACTERISTICS
A.
Site Characteris~ics
The nature and extent of the contamination at the Site, as identified in the
RI, is described below.
1.
Chemical Consultant Formulator Investigations
''n1e ,first investigation conducted by CCF in 1983" included soil and .
ground water samples, in which heavy metals, PCBs, and some
solvents were fOW1d. The sampling locations could not be
retraced, causing the validity of the results to be dismissed.
2.
Transformer And Drum Oils Analyses
MPCA and BNRR independently obtained oil samples in 1983 from
several transformers and from drums, which confirmed the presence
of PCBs. Six samples showed concentrations between 61 and 400
milligram per liter (mg/l) PCBs, while four samples tested at
concentrations ranging. from 37 to 67 percent. All other samples
tested at concentrations below. 5 mg/l.
3.
Soil Samples In The Smelter/Transformer Storage Areas
Several investigations were carried out in the general area of the
operations of the smelter and burner, as well as in areas where
transformers and drums containing oils from the transformers were
stored (see Figure 2). Ten soil profile samples were obtained
during 1986, in the main transformer storage area, which were
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10
Additionally, the characterization included 24 samples obtained
according to a grid pattern of surface soil as well as subsoil,
that were analyzed for PCBs i~ 1991. Forty surface soil samples
were also obtained in the access road to the Site, which were
analyzed in the field for lead levels with the use of an X-ray
fluorescence spectrometer (XRF).
The August, 1991, analytical results indicated that an area of
less than a quarter of an acre north of the 8tIIe1ter/burner area
had been contaminated by varying levels' of PCBs, as shown in
Figure 3. The highest concentration of PCBs detected was 89
mg/kg, in the top six inches of surface soil, at a location of
about 200 feet from the smelter, with other levels of 15 and 29
mg/kg found at two other surface soil locations. No PCBs were
found below the top six inches depth. Another location exhibiting
PCBs contamination was in the immediate vicinity' and just south of
the smelter/burner area, at a level of 7 mg/kg in the topsoil and
3 mg/kg at a depth of 1 to 2 feet. One other surface soil sample
showing appreciable PCBs levels was within the smelter/burner.
area, showing a PCB level of 4 mg/kg. All remaining soil samples
detected either no PCBs or levels below 0.2mg/kg. .
Seven surface soil samples were collected and analyzed for
chlorinated dibenzodioxins (CDD) and dibenzofurans. (CDF), which
were analyzed for the various congeners. No tetrachloro- .
dibenzodioxins (TCDD) were found in any of the samples, although
. ,low levels of the penta- through octa- CDD congeners were
identified. Relating those det~cted concentratiOns to an .'
equivalent toxicity level of the tetra-CDD congener resulted only
for the worst case scenario in exceeding the one (1) microgram per
kilogram (J'g/kg) level of concern. The more likely case of the
TCDD toxicity equivalent was less than a tenth of the worst case
scenario. Results for the CDF analyses indicated their presence
in the various congener forms. Based on the evaluation process
proposed by t~e U.S. EPA ~ancer Work Group (risk-based), as
provided in its Policy Document, the conclusion was that,the
levels found were not levels of concern. The Policy Document was
updated,in 1989 and was entitled "Interim Procedures for
Estimating Risks Associated with Exposures to Mixtures of
Chlorinated Dibenzo-p-Dioxin and Dibenzodifurans (CDDs an~' CDFs)
and 1989.Update,n U.S. EPA/625/3-89/016, March 1989. Under the
worst-case scenario the CDDs equivalent concentrations were, 0.8
pg/kg as TCDD.
In September, 1992, soil samples were obtained along the access
road located next to the smelter/burner area, to determine if
there were areas affected by heavy metals, in particular lead.
The soil samples were collected along a stretch of about 750 feet
of road, with samples taken at various intervals (5, 10, 15, 25
feet away from the road) perpendicular to the road, up to a
distance of approximately 100. feet. TheXRF results indicated that
ash containing lead was distributed from the area of operations in
both directions, which eventually decreased in concentration to
less than 300 mg/kg concentrations (Figure 4). The highest
concentration in the road itself tested at 13,200 ~g/kg, while a
sample taken nearby and analyzed in a laboratory showed a
concentration of 9,900 mg/kg lead concentration.
Soil samples were also obtained at the 5 to 7 feet depth and
analyzed for VOCs. While some VOCs were detected, principally
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11
detected in the' laboratory blanks. Employing the data evaluation
method outlined in Chapter 5 of the U.S. SPA Risk Assessment
Guidance for Superfund,. Volume I, concentration cauparisons were
made between the blanks and the sample results. As a result,
those findings were dismissed as constituting non-site-related
contamination. .
4.
Slag and Ash pile
One sample was 9btained from the slag and ash pile, which was
analyzed for PCBs, CDD, CDF, and heavy metals. No PCBs were
detected in the ash sample, and essentially no CDD was found,
although a very low level of CDF was noted, ranging from 1 to 2
pg/kg. The heavy metals indicated that the sample contained high
levels of lead, as detected by the Extraction Procedure Toxicity
(EP Toxi~ity) test, at 350 mgjl.
5.'
Gully Disposal Area
CCF has indicated that it layered the gully along the access road
in 1983 with soil that was scraped up from around the
smelter/burner area. The oil soaked soils from the smelting area
was supposedly layered wi th native uncontaminated soil by CCF. No
dimensions were provided by CCF of the width, depth or length of
the filled gully area.
During 1986 three borings were .made into the area of the former
g\.\lly. Soil samples were obtaine.d at two different depths., 1 to 2
feet, and.3 to4 feet, and the samples were analyzed for. PCBs,' .'
CDD, CDF, VOC and heavy 'metals. None of the analyses revealed
elevated levels of any of the compounds tested.
During 1991, at the request of U.8. BPA, concerned that the oil
stains in soil indicated the likelihood of the presence of PCBs, .
two additional excavations were made between the previous sampling
locations. Soil samples were taken in . the fill areas that showed
the highest level of staining, as well as in the native soil of
the original gully; as close to the bottom of the fill as could be
determined. Those samples were analyzed for PCBs, VOCs and total
concentrations of heavy metals. The.samples showed that the
nati ve . soil had not been contaminated by any of. the compounds
tested, and the fill materials showed levels of PCBs of 0.5 ppm of
less, and metals below regulatory concern, even if those levels
were to be detected in ground water.
6.
Asbestos Insulation Pile
Among the clutter of the Site during the.RI, a small pile of pipe
insulation was discovered southeast of the Kramer residence. Two
different types of insulation were present in the pile: .
Thermo-bestos and T-l2. The consultant contacted the U'cnms-
Manville. Corporation to determine if either of .those.tyPes of.
insulation contained any asbestos. The insulation labeled T-12
contained a calcium silicate, but no asbestos, while the product
Thermo-bestos did contain asbestos. The pile of insulation was
handled according to the asbestos abatement regulations in the
state and disposed at USPCI facility in Rosemount, Minnesota.
7.
General Scrap and Garbage
A visit to .the Site in early 1986 evidenced a large accumulation
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B.
12
engines, electric wires, steel scrap, several trailer homes filled
with miscellaneous scraps, as well as a garbage dump at the
entrance to the Site near the gully. During 1986 large amounts of
steel scrap were removed fr~ the Site, as well as a portion of
the garbage. This allowed better access to the Site during the
RI.
Subsequently, Mr." Kramer resumed his activities of bringing more
scrap to the Site,' as well as his garbage disposal practices along
the entrance road. During 1991', the Cass County solid waste
officer issued various notices to the Kramer family to remOve the .
scrap, garbage and other miscellaneous waste that had ,accumulated
on the Site. By the summer of 1992, essentially all the scrap was
removed, all the garbage had been hauled away, and most of the"
trailers and other unsafe buildings, except for the old residence
had been removed. ' , " " ,
Surface Water. Sediments and Fish
1.
Surface Water
Samples were taken by the MPCA staff during winter 1986 in Agate
Lake, for analysis of VOCs, -to determine if the lake had been
impacted by the solvents used at the scrap yard. Sampling in
wintertime would enhance the potential concentrations in the lake,
since the ice' cap would prevent the loss of VOCs to the
atmosphere. "Other than the laboratory contaminant chlorof9rm, no
other VOCs were' detected." The data evaluation method outlined in
the U.S. EPA Risk Assessment Guidance was used to determine that
the chloroform constituted non-site-related co~tamination.
The consultant, CRA, also took lake water samples in October 1986
at location where potentially contaminated ground water would
discharge to Agate Lake. Of the four samples taken, only one
sample detected VOCs, but their presence in the laboratory blanks
caused those results to be considered invalid.
2.
Agate Lake Sediment
MPCA'staff~ollected sediment samples from Agate "Lake at five
different locations in 1983 near the shore surrounding the Site,
150 yards away from the shore and on the opposite side of the lake
(see Figure 5). The samples were analyzed only for PCBs, the only
contaminant of concern. Only the forms 1242 and 1254 of PCBs were
detected, with total concentrations ranging from 0.21 to 0.51
milligrams per kilogram (mg/kg), as shown in Table 1. The cleanup
level for soil is 1 mg/kg. Half this amount is promulgated for
sediment.
3.
Agate Lake Fish
MPCA staff collected fish from Agate Lake in 1983, and had fish
fillets analyzed for PCBs, mercury, heavy metals, dioxin and
furans. The fish samples consisted of both walleye and northern
pike, both averaging more than two pounds.
All fish samples analyzed for PCBs were below the sample detection
method, except for one walleye sample, for which the PCB 1242 "
level was just above detection 'limit of 0.05 mg/kg or ppm. The
total PCB levels in walleye were estimated at 0.11 mg/kg, and less
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13
dioxin and furans, but neither forms were detected in the fish
samples. The findings showed elevated levels of mercw:y in both
pike and walleye, at 0.76 and 0.89 mg/kg respectively. Canpanion
samples of fish obtained in Gull Lake also evidenced'elevated
mercw:y levels in those fish samples, although at about one-fourth
the levels noted in Agate Lake (see Table 2) .
As a result of those mercury findings, the MDH issued a health
advisory on the consumption of fish from both lakes, to restrict
the intake by the public to fish containing mercury. The HPCA .
staff does not believe that the mercury concentrations detected in
the fish, causing the fish consumption advisory, are the results'
of the Site acti vi ties. MDH proposes that the merCury is coming
from Canada. . .
c.
. . .
Ground Water and Hvdroaeo1oav
1.
Area Hydrogeology
According to the RI report, the stratigraphy encountered at the
Site, based on a boring to a depth of 80 feet, consists of fine to
medium grained sands with occasional and unrelated seams of gravel
and silt, typical of lacustrine deposits. The ground water table
beneath the Site. ranges from 5 to 14 feet below ground surface.
Ground water flows in a southeast to easterly direction towards
Agate Lake, although the flow is also influenced by marsh areas
around the Site, both. in the northwest and south and' southwest
directions of the Site (Figure'6). .
Ground Water Quality
2.
As stated previously, t1'1e area of the smelter cpld burner was among
the highest elevations of the Site proper. Six monitoring wells
were installed in and around this area of operation, with a
seventh monitoring well installed to the northwest of the gully
area (see Figure 6). These monitoring wells were sampled twice in
1986, again in 1987, and sampling was resumed in 1990, 1991 and
1992, after access to the Site was obtained in 1990.
. .The first'sampling round in July 1986 was 'analyzed for PCBs, heavY
metals and'VOCe. The results indicated that no PCBs were present
in the ground water samples, while heavy metals were present at
levels that did not exceed any drinking water criteria, either
federal or state.
The VOCs found in the ground water samples included
trichloroethene (TeE), benzene, toluene, ethylbenzene, and
perchloroethene (PCE). Some of these VOCs were also noted in the
laboratory blank, making their presence suspect. Other VOCs
detected were at levels below drinking water criteria; the results
.are located in appendix E of the FS. Only PeE was detected in one
. well (OW"'6), at the location near the smelter/burner, at levels
which exceeded drinking water standards. Thereafter, all samples
obtained from the monitoring wells were analyzed only for VOCs.
The subsequent samples obtained in 1986 and in 1987 also included
Mr. Paul Kramer's private well, while access was available. When
access was again obtained in December 1990, the household water
system had been disconnected, and no more samples could be
obtained. Furthermore, the condition of disrepair of the house
itself made it dangerous to try to locate the well, either for
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14
Throughout the various sampling events, only PCB showed up
repeatedly in the well by the smelter/burner area. The levels of
PCB found, throughout the sampling period, fluctuated between 18
and 44 micrograms per lite.r (~g/l). Because PCB was found in Hr.
Kramer's well, a well advisory was issued by MeR against
consumption of the water fran his well. Hr. Kramer refused the
offer to provide him with bottled water, since he had made his own
arrangement to obtain an adequate water supply for drinking and
cooking purposes.
To assess the possible extent of the PCB distribution in the soil
and ground water around the most contaminated well, an aquifer
test was performed in January 1992 for a duration of seven days.
The pumping rate was 4.6 gallons per minute, and samples were
obtained prior to pumping, seven hours after the start of pump~ng,
ar..,d seYen ~ys" after. the start of pumping. The PCB concentration.
at each of the" stated intervals decreased fran"44 ~g/l to 18.~g/1
after seven hours, and to 9 ~g/l after seven days. The conclusion
of the results, based on the rapid concentration decrease, was
that the presence of PCB was a very localized contaminant, because
a significant source would be expected to maintain a relatively
constant concentration of PCB throughout the pumping period. The
RI establishes that ground water at the site migrates at a range
between 1 tQ 10 feet per year. Using the Zheng equation, it is
estimated that the localized contamination will naturally .
attenuate in 14 years with a ground water migration rate of 10
feet per year.
" No subsequent ground water sampling has happened. Sampling is not
expected to resume until the new monitoring"wells, proposed in the
selected remedy, will have been installed. .
VI.
SUMMARY OF SITE RISKS
The MeR performed a health assessment on the Site in June 1989, for the Agency
for Toxic Substances and Disease Registry (ATSDR). The evaluation was
performed using the monitoring data collected during the RI. MeR also
included, in its considerations, the results reported by CCF in 1983, which
MPCA staff did not consider" since "the data is of questionable "quality and"
" validity." " . " .
The public health assessment was redrafted in December 1992, to incorporate
the new developments which had occurred at the Site. The summary of site"
risks will be based upon the latest version of the health assessment.
To summarize, the contaminants of concern at the Site include a slag and ash
pile containing elevated lead levels, lead contamination in surface soil, PCBs
in surface soils, PCB in ground water and potentially also in sediment" and
fish in Agate Lake.
A.
Bnvironmental Assessment
1.
Soils
The main activities carried out at the scrap yard ~ere
transferring transformer oils, some of which contained PCBs, from
the transformers to the smelter, burning the oil at a temperature
too low to canpletely destroy the PCBs and thereby potentially
creating dioxins and furans,and also skimming ash and slag from
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2.
15
products, which could be deposited on soils, were found in various
locations at low levels.
As stated above, some of the oil soaked soils were excavated in
1983 and deposited in the gully area to the west of the Site. The
oils penetrated the top four inches of the soil where they became
deposited, but the oils would not be expected to be found moving
through the subsoil, or reach the ground water. Due to the
potential presence of PCBs in the oil soaked soils that were
placed in the gully area, gully soils were investigated twice.
Neither of the 'samples taken of the three soil borings, nor in the,
two trenches, exhibited PCBs above a level of 0.5 ppm, while the
U . S. SPA PCB cleanup level was 1.0 ppm. Therefore, no remediation
was indicated for the gully soils. Furthermore, soils with lead
and PCBs levels above 'cleanup levels have been excavated fran the
smelter/burner operation area, transformer and drums storage area
and the slag and ash pile to ~low specified cleanup levels, ,
thereby reducing or eliminating the original risks.
Ground Water
3.
Solvents were used during the operation of the scrap yard and can
be assumed to have been spilled on the grOUDd. While a portion of
the spilled solvents volatilized into the air, a portion of the
solvents also leached through the soil to reach ground water.
Thus, chlorinated solvents as well as non-halogenated solvents,
such as petroleum products, could be expected to be found under
.the scrap y,ard, site, and some solvents were encountered in ground.
water. samples. ' ,,'. . ,
Surface Water
Agate Lake, and its associated wetlands, is the surface water body
which surrounds most of the Site. There is no record of any
direct discharges or spills into the lake or the connected
wetlands of any products used on the Agate Lake Site. Three other
mechanisms by which any of the contaminants could reach the
surface waters are through discharge of the contaminated ground
water, surface run-off or by deposition of air borne contaminants
from ',the 'burning activity at the Site. .
4.
. . . .
Surface wa.ter samples from Agate Lake obtained by MPCA staff were
analyzed for VOCs. No VOCs were detected. in the three samples,
except that one sample showed a trace of chloroform, which the
MPCA staff believes to have been a laboratory contamination. The
applicable federal and state aquatic life standard for chloroform
for chronic exposure for surface water not protected for drinking
water is 1.2 and 0.2 mg/L respectively, considerably higher than
levels detected in surface water by a factor of at least 200.
Sediments
Sediments in Agate Lake and its associated wetlands are a
substrate which can be a pathway for the long term release of
contaminants into the environment. Contaminants could becane
deposited in the sediments through ground water discharge, direct
discharges or spills, or depositions of the airborne contaminants.
Sediments collected by MPCA staff and analyzed for PCBs found that
the PCBs 1242 and 1254 were found in some sediment samples at
trace levels below 0.3 ppm, (see Figure 5). PCB 1260 was not
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16
detection levels, which were taken as one-half the reported
detection limits, did not exceed 0.51 ppm.
Aquatic Fauna
5.
After the Site had been identified, MPCA staff requested that a
hazardous waste scan be made of Agate Lake in 1983. Walleye and
northern pike were collecte
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C.
17
2.
Ground Water
3.
Mr. Kramer's residence is served by a private shallow well which
. was found to contain 16 p.g/l and 8 p.g/l of PCB during two'
successive samplings in 1984. Subsequent sampling of the
residential well did not show any additional detection of PCB,
even though PCB was detected in a nearby monitoring well. During
1984, MPCA staff offered to provide the residents with drinking
water but this offer was declined by Mr. Kramer, who said he had
made his own arrangements for a water supply. Additional ways of
exposure to potential PCB concentrations can occUr from other
water uses such as bathing and washing. The resident complained
about a scum found in the water, which was identified as
iron-sulfur bacteria. The residence has been abandoz?,ed for the
past four to five years, and. is in significant ~srepair. . .The
well has been disconnected and 'is no longer functional, thereby
. reducing this potential exposure route~
Surface Water
As previously indicated in the Environmental Assessment Section,
.the surface water does not appear to be impacted by the Site.
4.
Sediments
5.
Some very low levels of PCBs have been detected in sediment
samples from Agate Late. It is. generally unlikely that humans.
'wil.l experience much exposure from this source, since '.sediment is.
not generally ingested and dermal eXposure is negligible. The
respective action level for soils is above 1 mg/kg or two times
higher than found in the sed~ments.
Aquatic. Fauna
The fish advisory issued by the MeH addresses consumption' of fish
taken from Agate Lake and is based on the mercury level found in
fish samples. The mercury contamination is bot believed to be
connected with scrap yard activity.
6.
Air
Fugitive dust may have been a potential source pathway leading to
inhalation of 'soil particles containing metals or PCBs. As
previously indicated, the soil at the Site has a reasonably dense
vegetative cover, which keeps the potential dust to a minimum, and
the slag and ash piles have been removed from the Site to below
cleanup levels promulgated by U. S. SPA and MPCA.
Comoarison to ARARs
1.
PCBs Levels
The levels for cleanups of PCBs have been set by U. S. SPA in its
PCBs Spill Cleanup Policy, Final Rule issued in 1987 (40 CPR Part
761). According to that pOlicy, spills in unrestricted access
areas must be cleaned up to 1 ppm PCB or less, or 5 ppm PCBs or
less, with at least a 10 inch cover, while. for industrial and
other restricted access areas spills must be cleaned up to 10 ppm
PCB or less. .
The Interim Response Action (IRA) undertaken in the spring of 1993
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.3.
, '
4.
18
level of 1 ppm. Furthermore, the area of the excavation will be
covered by a soil cover of at least ten inches. With the
implementation of the IRA for soils with PCBs, the Site achieves
, the cleanup level specified by U.s. EPA. '
2.
Dioxins and Furans
Dioxin and furans are chemicals found as impurities in industrial
products and are formed during incomplete combustion of
chlorinated phenols and PCBs. Both contaminants are large groups
of chemicals or isomers with varying degrees of chlorine
substitutions called congeners. The dioxins are chemicals that
have been studied more extensively than furans, and the tetra- and
hexa- forms of dioxins have shown the most acute and'chronic
effects. No fi~ly established limits have been set for soils,
'cont~ination, but a gUidelineof1 parts per billion (ppb) TCDD
(2,3,7,8 TCDD) in soil has been identified'as a health risk for
residential areas. Contamination below 1 ppb TCDD is not
considered of concern.
The various congeners of dioxin are included in the 1 ppb level by
using the, toxicity equivalence factors (TEPs), which convert them
into TCDD equivalent concentrations, as developed by the Dioxin
Work Group of the Center for-Disease Control. The levels of
dioxin found at the Site do not exceed the threshold level of
concern, even at the theoretical worst case scenario, at which the
dioxin level is almost 0.8 microgram/kilogram (pg/k'!l orppb).
, Heavy Metals in Surface Soils
The maximum concentration levels for lead left in soils and still
be considered as protective, suggested by the Resource
Conservation and Recovery Act (RCRA), is 1000 mg/kg total lead.
This level has been adjusted for exposure to sensitive populations
such as children to between 500 to 1000 mg/kg. Minnesota Rule
4750 provides requirements for soil cleanup levels contaminated by
lead in bare soil on residential property' and playgrounds. Such
soils must not contain lead in a concentration exceeding 300 ppm
by weight.
Soil and wetland sediment samples were analyzed~forheavy metals~
Soil samples from the central area along the access road located
near the slag and ash pile exceeded the action level in excess of
300 mg/kg soil for lead (see Figure 4). The 'soil in the road,
which exhibited the elevated lead levels, was removed during the
IRA undertaken in the spring of 1993. In soil samples taken in
and around the access road along the smelter/burner area after
excavation and removal, where lead had been found in elevated
levels in the surface six inches, the remaining lead detected in
laboratory analysis was below 51 mg/kg, significantly less than
the action levels.
Sediment samples showed the presence of metal ions but these were
at levels well below soil cleanup levels for any heavy metals.
Heavy Metals in Slag and Ash Piles
The slag and ash piles exceeded the above-indicated cleanup level
for lead significantly. The IRAs undertaken at this Sit,e resulted
in the removal of the ash and slag piles. Thus, the cleanup has
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19
Samples taken in the area where the slag and ash piles were
located showed lead levels below 51 ppm.
VOCs in Ground Water
5.
The levels of VOCs acceptatlle in ground water are well
estatllished, both by the federal Ma.y;mum Contaminant Levels (HCL),
the drinking water standards set by the Safe Drinking Water Act
(SDWA), and the state Reccmnended Allowable Limits (RALs) for
drinking water contami~ts.
The only significant ground water contaminant at this site was
PCB. The MeR has set RALs at 7.0 1l9/l; while the federal HCL is
set at 5 1l9/l PCB. PCB was identified in ground water samples
co~lected at the Site dqring 1986 and 1987 as well as in s~le8
taken in' 1990, 199i and 1992, atIove the RALs in samples from one
, monitoring well near the location of the smelter (OW-6). None of
the other monitoring wells evidenced any VOCs in the samples taken
during the cited years.
PCE was found in the residential well, below the RALs, during
samples taken in 1987. Since that time, no additional samples
were taken from that well, since it has been disconnected.
0'
6.
Heavy Metals in Ground Water
Heavy met~ls such as lead, nickel, copper, cadmium are regulated
as 'drinking water contaminants. The U. S. EPA National Interim .
'Primary Drinking Water Standards (NXPDWS) and the HDRRALs for
same of the heavy metals are as follows:
NIPDWS RALs
Cadmium 10 '1l9/l and 5 1l9/l
Copper 1000 1l9/l and 1300 1l9/l
Lead 50 1l9/l and 20 1l9/l
Nickel 150 1l9/l and 150 "g/l
Mercury 2 1l9/l and 1.1 1l9/l
Nqne of the gro~d water samples exceeded the drink~ng water
standards or the ~s~ '
7.
PCBs in Gr9und Water
The MCL level of PCBs in ground water according to the SD~ is set
at 0.5 1l9/l, while the RALs have not set a SPecific level for
PCBs. No PCBs were found in any of the samples taken in 1986 or
in 1992.
,VJ:I.
DOCUMEN'l'A'l'ION OF SIGNZFICAHT CHANGES AND RBSPONSIVEHBSS SUMMARY FOR TIm
AGA'l'E LA1tE SCRAP YARD SUPERPUND SI'l'B
This community responsiveness summary has been developed to document community
involvement and concerns during the Remedial Investigation/Feasibility Study
(RI/FS) and the proposed plan phases of the Agate Lake Scrap Yard Superfund
Site (Site) in Cass County, Minnesota, and to respond to ccmnents received
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20
OVERVIEW
Based upon the findings of the RI/FS, the U.S. Environmental Protection Agency
(U. S. EPA) and MilUlesota Pollution Control Agency (MPCA) recoamended a
three-part cleanup plan. It included removal of lead-contaminated ash, slag
and soils; removal of soils contaminated with polychlorinated biphenyls
(PCBs); and regular monitoring of shallow and deep ground water at the Site,
as well as a deed restriction that prohibits well installation in the area in
which ground water contamination has been found. Two parts of 'the plan, the
removal actions, have been completed. .
Residents had been notified before the interim remedies, and many of their
concerns about the Site were aired during the previous public information
process. This included issuance of a news release, a public meeting at the
Lake Shore City Hall, a more informal mee~ing at the Agate .Lake Association
(Lake AsSociation) meeting, and the establishment of an Administrative Record'
a the Brainerd PuPlic Library. Results of the RI were discussed thoroughly,
as well as the likely proposed plan for the Site as a whole. The proposed
plan public meeting was more sparsely attended, by many of the same citizens
who attended the previous meetings.
Residents and local officials in the community near the Site found the.
proposed plan to be acceptable, as long as ground water monitoring does not
show any impacts on either Agate Lake or- local drinking water supplies. They
continue to be interested in the future. use of the property, an issue outside
of the authority of either U.s. EPA or MPCA.' However, the future use scenario
e~loyed t9 determine the remedy WaS that of residential/commercial. A br~ef
tour' of the Site, 'p!3rmitted by members of the Kramer family, provided
interested residents with a better understanding of how the removals were
completed and more comfort with Kramer family members. Four residents
requested copies of the tape of the public meeting, and these were provided to
residents and to the Administrative Record.
BACKGROUND ON COMHCNITY INVOLVEMENT
The Agate Lake scrap Yard is located in Fairview Township, Cass County,
Minnesota on.the southwest shore of Agate Lake. It is 'approximately 15 miles
northwest of the city of Brainerd, and within a half mile of the west side of
Gull Lake, a popular resort area. The Brainerd Lakes area is one of tne more
popular resort and. fishing areas in'. ~he . state, and the community is ;both proud'.
and protective of its pristine environment and natural beauty. . .
The Site is eight acres, 'located on land surrounded on three sides by open
water and wetland. It is perhaps the most scenic piece of land on the small
lake, as neighbors attest. This is one reason why the residents who live
around Agate Lake (many year-round) and the two small resort owners have shown
great concern about the Site's Superfund problems. Their expressed concerns
early on in the Superfund process included worry about degradation of Agate
Lake, impacts on neighboring private wells, and damage to the lake area's
reputation. The fact that the Site was named "Agate Lake Scrap Yard," putting
it alphabetically at the top of the state Superfund list (Permanent List of .
Priorities) was objectionable to some residents during early days of the Site.
Because the Site is surrounded by the Pillsbury State Forest and is primarily
wooded, many of the activities that had taken place on the Site were outside
of plain view. This fact has had both positive and negative consequences in
terms of public opinion. Residents living on the lake could not see some of
the scrap and junk on the site that might have made Agate Lake Scrap Yard an
eyesore. However, residents also may have magnified the potential hazards of
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21
Paul Kramer, who established the scrap yard in 1952 on farmland owned by his
father (who died six months within moving to the property), constructed a
homemade incinerator and had a smelter fran which he recovered metals. The
air quality impacts on the surrounding community are unknown, but it is likely
that neighbors who used burning barrels for their trash wouldn't have thought
about the air quality impacts early on. Because the scrap yard closing
predated awareness among communities about ai~ pollution, air qua~ity impacts
of the Site have never been of great concern to the residents. ,
However, the scrap dealing and collection of transformers (some of which
contained PCBs) was another story. The MPCA Brainerd Regional Office received
an anonymous complaint about Mr. Kramer in late 1982, resulting in an order
. from the agency to cease operations. The MPCA sent out a news release when
the PCBs were discovered on Mr. Kramer's property.
It is not clear how the community regarded Mr. Kramer, whose behavior .during.
Site investigations and mOst cleanup activities remained cooperative. It was
only during later stages, during which Mr. Kramer lost control of the
property, that any resistance was encountered. Mr. Kramer refused bottled
water when his family well received a drinking water advisory from the
Minnesota Department of Health (MDH). in 1984. He cooperated after being.
issued an MPCA Request for Response Action in 1986, but denied access to his
property in 1987 when the potentially responsible parties (Crow Wing
Cooperative and Burlington Northern Railway) planned an unapproved cleanup
. attempt in 1987. In general, Mr. Kramer seems to have been an independent.
personality and his family may have been somewhat isolated from the community
at large. .
Mr. Kramer died in January 1989, leaving behindcCllq:llex questi6ns . ~ut who'
owns the property, an issue still not completely resolved and complicating
acti vi ty on site. The MPCA, U. S. EPA and responsible parties have experienced
difficulties in knowing whom to work with on cleanup' concerns. However, tnese
difficulties have not unduly affected the community, since citizens most often
contact MPCA Brainerd staff or the MPCA Project Manager for information.
The Lake Association and officials of the city of Lake Shore (City) contacted
the MPCA at regular intervals, concerned about the length of time that
. investigation and cleanup actions have taken. However, most residents were
not concerned un~uly.with health impacts of the scrap yard. MOst questions
have focused on the potential environmental impacts on the lake. .
In May 1992, the u.S. .SPA and MPCA approved interim actions for soil cleanuP
at Agate Lake. The agencies scheduled two public meetings, one at the City
and another at the Agate Lake Resort during a Lake Association meeting, to
provide all of the information about the RI and an overview of the cleanup
actions.
The timing of the May 1992 meeting was fortunate, as the MDH was preparing an
update of the MPCA for Toxic Substances Disease Registry public health
assessment at the time of the interim response actions. MDH staff joined the
MP~ staff at the in~ormalpublic meeting held for the Lake Association,
giving community members the added sense of security that a second opinion
from a health perspective can provide.
Local public officials, media representatives, Lake Association members, and
other interested community members (both within the immediate vicinity of the
Site and from the outside) attended the City meeting. Lively questioning took
place during the meeting and afterward, and residents seemed relieved at the
limited nature of the soil contamination and its imminent removal. Members of
the local news media were present, and the resulting coverage provided
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22
The MPCA and U. S. EPA placed an ad in the Brainerd Dispatch, sent fact sheets
to all the interested citizens and public officials mailing list, and updated
the Administrative Record. The meeting, held again at the Lake Shore City
Hall, drew many of the same residents fran the previous meetings . with the
permission of the Kramer family, the MPCA and U.S. EPA provided a brief Site
tour, allowing local citizens to see what cleanup actions had been taken and
meet the family members. The camnunity members seemed satisfied with the Site
remediation and that it was Close to completion.
StDlllARy OF PUBLIC COIIMBR'l'S AIm DCA RESPOIIS.
On the ground water proposed plan:
Comment: The Lake Association chairperson asked whether it was possible for.
the ground water contamination i.n the .shallow ground water could migrate
beneath the Sit~ to re~idential wells.
MPCA Response: The ground water contaminants have been found only in the
shallow aquifer, which discharges into the wetland and Agate Lake. No ground
water contamination has been discovered in the deeper ground water. However,
the MPCA and U. S. EPA plan to sample both shallow and deep aquifer as part of
the long-term monitoring, which will make sure that this continues to be the
case.
. Comment:
One resident asked at what depth the test wells had been installed.
MPCA Response: The shallow monitoring wells were installed at a depth of up. .
to 20' feet.' The deeper wells will be screened ,at up to a 50 foot depth. . The
. water table, at the Site is at approximately ten feet below the. ground surface.
Comment:
detected.
MPCA Response: Most of the ground water contamination has been detected in.
one monitoring well, at approximately 10-12 feet. No contamination has been
detected in wells screened at 30 feet.
A City official asked how deep ground water contamination had been
Comment:
Residents wanted to know how often the Site would be monitored.
MPCA Response: The fir.st year, 'the Site will, be monitored quarterly. It will
.bemonitored once. a year thereafter. . If any changes are detected during the .
moni toring process, the MPCA and U. S. EPA will take another look at the
. remedy. In addition, the U.S. EPA requires that Superfund sites receive a
five-year. review to make sure that the cleanup plan continues to be
protective.
Comment: One Agate Lake resident wanted to know if the discharge of the
concaminated ground water. was hurting the lake.
MPCA Response: Agate Lake has been sampled, and the contamination was not
found t~. have had an adverse impact on lake quality. This is because the
contaminant was found in one'monitoring well at a level only marginally'
greater than the MDH's Recommended Allowable Limits for drinking water. Also,
as the ground water migrates toward Agate Lake it diffuses, reducing the
contaminant concentration. Finally, the volatile organic compound tends to
volatilize when exposed to air, so that any trace amounts potentially entering
the lake would soon volatilize.
Comment: One resident wondered when or if institutional controls on ground
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23
MPCA Response: If ground. water monitoring shows a steady decrease in levels
of contaminants, institutional controls could eventually be removed. However,
this is unlikely to happen in the. next five years. "
Other ~spects of site remediation:
Comment: One resident asked whether the agencies had investigated an area
where oily soils had been buried. He was concerned about PCB contamination
left behind.
MPCA Response: The. gully area, in which oily soils had been deposited during
an unauthorized attempt at cleanup in 1983, has been tested. The soils buried
in the gully were not found to be contaminated with PCBs.
Comment: One resident asked if anyone was paying a fine or penalty for the
pOllution probl~ at the Site.. .
MPCA R:esponse: Although penalties can be imposed at Superfund sites, they
were not appropriate in the enforcement process used at the Site. The two
potentially responsible parties and Hr. Kramer disposed of most of the wastes
long before laws existed prohibiting such disposal. Also, potentially
responsible parties have cooperated with the agencies in site investigation
and cleanup, making penalties unnecessary.
However, residents should be aware that under today's laws and rules, disposal
of hazardous wastes such as those deposited at the Site would lead to
penalties up to and including criminal prosecution. In the intervening years
between Mr. Kramer's disposal practices and today, regulators and businesses
have le.arned a great deal about the harm such wastes pose to pUblic health and
the environment.
Comment:
One resident wondered how the Site could be used in the future.
MPCA Response: Institutional controls on part of the Site will preclude any.
drinking water wells to be installed. However, since soil contamination has
been removed, no other construction activities will be prohibited. The Kramer
family, now in the process of resolving who owns the property, will have
authority over how the Site is used in the future.
Comment: Residents asked for information about what regulatory agencies were
"doing about mercury in the Brainerd.Lakes region and the fis~ advisory for.
Agate Lake. .
MPCA Response: Mercury has been detected in the tissues of fish at both Agate
Lake and Gull Lake, resulting in a fish-consumption advisory for both lakes.
This contamination is not related to the Site, since it occurs in both lakes,
but it is a source of concern to Brainerd Lakes residents.
The MPCA had provided a report on the problem of mercury contamination of
northern Minnesota lakes to the chair of the Lake Association. Since .mercury
constitutes a contamination of fish and is a wide-ranging problem i~ the
northern half of the state, the MPCAhas established a task force to look .at
possible sources of mercury in Minnesota lakes and solutions.
Remaining Concerns
Residents were comfortable with the proposed plan, as long as ground water
monitoring continued to show that contamination has a minimal impact on Agate
Lake and no impact on drinking water supplies. However, there were a few
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2.
3.
24
1.
Residents wanted to see the pile of asbestos insulated pipes and
some of the junk on the Site removed. Consultants for the
potentially responsible parties plan to remove the asbestos when
installing additional wells for long-term monitoring. Kramer
family members have been working with the Cass County solid waste
officer on cleaning up site scrap, and pledge to continue those
efforts.
The community is interested in how the Site will be used in the
future and is opposed to any 'industrial use of the property.
Zoning on the prope'rty has been changed, prohibiting industrial.
use, but a resort or private hane would be acceptable uses for the
property, although the water supply would have to cane from
outside the well restriction area. The MPCA and U.S. SPA have no
authori ty to control the Kramer family's decision about t~e
property's eventual' use. . ' .
The community has some confusion about who owns the land. This is
an issue currently being resolved by the Kramer family members.
Resolution is not dependent on either the MPCA or U.S. EPA.
However, the MPCA staff will continue to provide information to
any interested family member or other local resident without
regard to property ownership.
Community Relations Activities Timeline
December 1982: The MPCA discovers PCB transformers at the Site.
release ,is issued to local media, officials. .
October 1984: The Site 'is proposed for the state Superfund list (Permanent
List of Priorities) and the National Priority List- A news release is issued.
February 1990:
A news
The MPCA establishes an Administrative Record for the Site.
May 1992: The MPCA and U.S. SPA approve interim response actions for the
Site. The agencies issue a news release, fact sheet, and attend two public
meetings to inform local residents about the Site activities.
June 1993: The MPCA and U.S. EPA issue a proposed plan for the Site. A paid
ad is ,inserted in the ,~rainerd Dispatch, the Administrative' Record is updated,
a fact sheet is issued to all media, local representatives," and interested
citizens. The MPCA and U.S. SPA conduct a public meeting and an informal tour
of the Site for interested residents. Audiotapes of the public meeting are
provided to those requesting them.
vn::I. DESCR:IP'l':ION' OPO AL'1'BRN'A'l':IVES
In October 1987, CRA submitted to MPCA and U.S. SPA a Peasibility
Study/Remedial Action Plan (FS/RAP). The PS/RAP was designed to address the
cleanup and removal of certain hazardous wastes from the Agate Lake Site, and
reduce the exposur~ risks. from the hazardous wastes, pollutants and
contaminants remaining on the Site.
A redrafted FS was submitted to U.S. SPA and MPCA staffs in March 1992, which
included the results of the additional field work undertaken during 1990, 1991
and 1992. Following the implementation of the IRAs during 1992, the FS was
revised and modified pursuant to U. S. SPA and MPCA comments. The final .
version was submitted on February 26, 1993. The alternatives presented in the
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25
at the site due to the actions taken. The description of the alternatives
considered in the 1993 FS are discussed herein:
Description of Ground Water ~ternatives
The only contaminant remaining on the Site, following the implementation of
the lRAs, is the contaminated ground water that has been, detected at one
monitoring well near the center of the smelter/burners activities area. Thus,
the alternatives presented discuss options available to deal with the PCB.
The alternatives evaluated in the FS are the following: '
Al ternati ve 1:
, Al ternati ve 2:,
Al ternati ve 3:
Al ternati va 4:
No Action
Monitoring
Ground Water Extraction
In~titutional Controls
The evaluation of those'alternatives was based on the scenario that the
on-site aquifer is not being used currently as a potable water supply source, ,
but that it could be used in the future.
Alternative 1.
No Action
No active remedial treatment would be implemented, and no costs would be
in9Urred, since the cleanup actions undertaken at the Site have been adequate
for the purposes of this property. Only a monitoring well has ~een impacted.
No dr~nking ~ater supply would be affecte~ by the Site conditions. Natural
attenuation ,would, over time, reduce the'current PCB concentration to levels
which would be below regulatory concern. Therefore, an active remediation,
which may not be more effective than natural attenuation, does not appear to
be warranted in this instance. The reason for the lack of effectiveness of an
acti ve remediation, such as a pump and treatment system, is that PCB appears
to be of very limited extent (at monitoring well OW-6 only) and no distinct
plume has been noted.
Alternative 2.
Monitorinq
~is alternative, requires that the ,ground water be monitored over a certain,
period of time, with ,pe;riodic reviews of the data collected. Additionally,
several monitoring wells'would be added at the Site, to further define any
impact, over time, of the remaining contamination at the Site. The
approximate location of the four new monitoring wells are shown in Figure 7.
The purpose of the location and placement of the monitoring wells would serve
to observe the movement and natural attenuation of the existing PCB
contamination, and to determine if there is a vertical effect in the ground
water from the PCE.
The only contaminant identified in grpund water is PCB, which will be
moni tored over time. Studies have demonstrated that a "pocket" of PCB exists
with a concentration of 1.8 pg/l. This "pocket" of PCB will be flushed by
natural attenuation down to the RAL of 7 pg/l over 14 years. Breakdown
products could also appear, such as trichloroethene (TCE), dichloroethene
(DCB) and vinyl chloride (VC). These breakdown products are also monitored
through the analytical method. Sampling will happen quarterly during the
first year, following installation of the monitoring wells, and may be reduced
subsequent years until the five-year review. At that time, the natural
attenuation will be reassessed. Since, the extent of contamination at the
Site is limited, an active pump and treat system would not reduce the PCB more
effectively than natural attenuation. However, if a PCB' dispersion develops,
it would cover a larger area, and be expected to naturally attenuate within 20
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26
Alternative 3.
Ground Water Extraction
A ground water extraction, well would be installed,near the monitoring well
OW-6, known to have been impacted by PCB. The extraction well would be
installed 30 feet below ground surface, i.e., approximately 20 feet below the
water table. This well would be pumped at an approximate rate of 5 to 10
gallons per minute (gpm). The treatment of the extracted ground water would
consist of the spraying of the water through an irrigation system at three
locations on the site. Such spray irrigation would achieve a more uniform
distribution of ground water. containing PCE over the spraying areas, while
providing a reduction of the PCE levels in the ground water. Such spray
irrigation activities would be performed dur~ng the summer m9Dths of Hay
through September, to optimize photodegradation and hydrolysis along with an
anticipated volatilization effect. Ground water monitoring would allow for
the determinat!on of t~e ef~ectiveness of such an al~ernative. This'
alternative reduces the ~esidual risk within 16 years.' . ,
Alternative 4.
Institutional Controls
This alternative consists of restrictions that shall be applied to portions of
the property to restrict use of it for certain purposes (Figure 7). Chapter
4725 of Minnesota State Law, concerning placement of drinking water wells,
will be implemented and non-essential wells will be abandoned. This chapter
governs where drinking water wells can be placed. The MeR will be notified
regarding the restriction to install drinking water wells in the area of the
PCE plume. The county government will be notified of the need to include on
the deed a description of the scrap yard activities. which were carried ,out and
to notify' potential'purchasers of th~ property, history. ' . , .' . .
Furthermore, the development around Agate Lake is now also restricted by Cass
County's Shore land Classification System and Land Use Districts Ordinance.
IX.
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
A.
The Nine Evaluation Criteria
The FS examined four alternatives, and evaluated them according to
technical feasibility, environmental protectiveness,. public health
. . protectiveness, ins~itu~ional issues and cost: effectiveness.
The alternatives were evaluated according to the following nine criteria
which are used by the U. S. EPA to provide the rationale for the'
selection of a remedy for the site:
1)
Overall Protection of Human Health and the Environment addresses
whether or not a remedy provides adequate protection and describes
how risks posed through each pathway are eliminated, reduced or
controlled through treatment, engineering controls, or
institutional controls.
2)
, . .
Compliance with State and Federal 'Regulations (ARARs) addresses
whether or not a remedy will meet all the applicable or relevant
and appropriate requirements of federal and state environmental
statutes and/or provides grounds for invoking a waiver.
Reduction of Toxicity, Mobility, or Volume is the anticipated
performance of the treatment technologies a remedy may employ.
3)
4)
Short-Term Effectiveness addresses, the period of time needed to
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5)
6)
B.
27
the environment that may be posed during the construction and
implementation period until cleanup goals are achieved.
Long-Term Bffectiveness and Permanence refers to the ability of a
remedy to maintain reliable protection of human health and the
environment over time once cleanup goals have been met.
7)
Implementability is the technical and administrative feasibility
of a remedy, including the availability of materials and services
needed to implement a particular option. '
Cost includes estimated capital and a;peration and mai~tenance
costs, and net present worth costs.
8)
State Acceptance indicates whether, based on its review of the ,
RI/PS and , the proposed Plan, the state, concurs with, opposes, or'
has no comment'on the preferred alternative at the present time.
Community Acceptance will be assessed in the Responsiveness
Summary of the Record of Decision following a review of the public
comments received on the RI/PS report and the Proposed Plan.
COtnDarative Analvsis of Altenlatives for Ground Water
9)
- '
Bach of the alternatives was evaluated using the nine criteria. The
regulatory basis for these criteria comes from the National Contingency
Plan and Section 121 of CERCLA. Section 121 (b) (1) states that, " ,
, : BRame'dial actions in whiCh treatment which permanently and signifi,cant1y
reduces the volume, toxicity or mobility of the hazardous ,substances, ,
pollutants, and contaminants is a principal element, are to be preferred
over remedial actions not involving such treatment. The off - si te
transport and disposal of, hazardous substances or contaminant materials
without such treatment should be the least favored alternative remedial
action where practicable treatment technologies are available." Section
121 of CERCLA also requires that the selected remedy be protective' of
human health and the environment, cost effective, and usepe~ent
solution~ and alternative treatment technologies or resource recovery
technologies to the maximum extent practicable.
,Each ,alternative. is compared to the nine crit,eria in the following
section:' ,,'"
1)
Overall Protection 'of Human Health and the Environment
The three alternatives, with the exception of the No Action
Alternative, would provide, with varying degrees of efficiency, an
increased protection of human health and the environment, with
respect to e~isting conditions. The increased protection is
achieved by observing the movement over time of the detected
levels of PCB in the ground water, thereby preventing the
, placement of a drinking water well in the potential path of the
PCB' as it 'is being attenuated by natural forces. Alternatives 2;
3, and 4 would achieve such overall protection of human health and
the environment.
2)
Compliance with Applicable or Relevant and Appropriate
Requirements (ARARS)
Pederal ~
SARA requires that remedial actions meet legally applicable or
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28
"Applicable requirements" mean those cleanup standards, standards
of control, and other substantive environmental protection
requirements, criteria, or limitations promulgated under federal
.or state law that specifically address a hazardous substance,
pollutant, contaminant, remedial action, location, or other
circumstance at a CERCLA site. These laws include, but are not
limited to the following: the Toxic Substances Control Act, the
Safe Drinking Water Act, the Clean Air Act, the Clean Water Act,
the Marine Protection, Research and'Sanctuaries Act, or the Solid
Waste Disposal Act as amended by the Resource Conservati~' and '
Recovery Act (RCRA), and any' state environmental law that has more
stringent requirements than the corresponding Federal law.
"Relevant and appropriate" requirements are cleaQup standards,
standards. of control, and other substantive environmental
prote.ction requirements, criteria or limitations promulgated under
federal or state law that, while not 'legally ."applicable" to a' '
hazardous sUbstance, pollutant, contaminant, remedial action or
cirCUmstance at a CERCLA site, address problems or situations
sufficiently similar to those encountered at the CERCLA site that
their use is well suited to the particular site.
"A requirement that is judged to be relevant and appropriate must
be complied with to the same. degree as if it were applicable.
However, there is more discretion in this determination: it is
possible for only part of a requirement to be considered relevant
and appropriate, the rest being dismissed if judged. not to be
relevant,andapprbpriate in a. given case" (Interim Guidance on
~ompliance with Other Applicable. or Relevant and,~ropriate
Requirements, S2 CFR 32496, August 27, 1987).
In addition to legally binding laws and reguiations, many federal
and state environmental and public health programs also develop
criteria, advisories, guidance and proposed standards that are not
legally binding, but that may provide useful information or
recommended procedures. These materials are not potential ARARs
but are evaluated along with ARARa, as part of the risk assessment
conducted for each CERCLA site, to set protective .cleanup levels.
Chemical' specific "To Be Considered" (TeC) values such as health
. advisories and reference doses will be used in the absence of '
ARARs or where ARARsare not s'.,Ifficiently protective to develop
cleanup goals. Other TeC materials such as guidance and policy
documents developed to implement regulations may be considered and
used as appropriate where necessary to ensure protectiveness. If
no ARARs address a particular situation, or if existing ARARs do
not ensure protectiveness, to-be-considered advisories, criteria,
or guidelines should be used to set cleanup levels.
The federal requirement regarding the need for water quality
planning and management found in 40 CFR 130, indicates that a
state's water quality standards must be followed. Federal ambient
water quality criteria are also potential chemical specific ARARs
which apply to acute or chronic exposures of freshwater aquatic
life. Such ARARs will be considered along the state's criteria
and the most stringent will be employed to decide if surface water
was impacted. This requirement has been implemented in the state
rules for determining water quality standards, that are applicable
to surface waters of the state. This ARAR is not addressed in
alternatives 1 and 4, while alternatives 2 and 3 seek to keep a .
monitoring program. If ground water conditions deteriorate over
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29
3 may have to be modified to include surface water monitoring or
cleanup. CUrrently, the surface water does not pose a risk to
human health or the environment. .
The level found to be a health risk for PCB of 5 I-&g/l has been
published in the National Primary Drinking Water Regulations found
in 40 CFR 141. 'l11e MCL for PCB is thus an ARAR. 'l11e MCL for PCB
in the ground water was exceeded in one monitoring well.
'l11e land disposal restrictions (LDRs) are a series of restrictions
found in 40 CPR 268, which were promulgated under RCRA and govern
what substances may be disposed on land and under which
conditions. According to subpart C under the. California list of
wastes, specific criteria are set for the disposal of .water
contaminated by halogenated volatile organic caupounds (HVOC) on
land. Thus, although this portion of the LDR is an ARAR, no soU:
disposal method is proposed by any alternatives, and thus the. .
requirements of this ARAR are met.
State of Minnesota ARARs
'l11e Minnesota Rules Chapter 7050 require the classification of the
state's surface waters, and the development of aquatic life
standards for various classe~ of waters. The state has classified
Agate Lake as a Class 2B/2Cwater, i.e., warm and cool water
stream and lake, not protected for drinking water. For such a
water body, a chronic standard has been set for the maximum level
.of PCB at a level of 8.9 p..g/L . This is an ARAR for the purpo$es
of determining surface, water cleanup levels. No water, samples' '
from Agate Lake have been found to detect any PCB concentrations.
None of the alternatives would create a situation that would
result in degradation of the surface water to the point that it
would exceed that standard. Therefore, all the selected
alternatives will meet this requirement.
'l11e ground water cleanup levels are s'et by the RALs developed by
the MDH. The RALs for PCB is 7 I-&g/l, which constitutes an ARM
with which to assess the attenuation of ground water by natural
forces.
State of Minnesota "To Be consideredft Reauirements(ftTBCs")
'l11e Minnesota Rules Chapter 7001 establish rules for the issuance
of permits for the construction, installation or operation of a
disposal system. Such a disposal system may consist of a spray
irrigation system which discharges to a land surface. 'l11us, in
the case of the spray irrigation system proposed in ~ternative 3
as treatment of the extracted ground water Minn. Rules Ch. 7001
would be considered a state TBC. ~ternati ve 3 will meet the
requirements of this TBC rule. '
'l11e Minnesota Rules Chapter 7045 establishes 'classifications of
certain wastes on the basis of nonspecific sources, specific
sources, discarded commercial chemical products, and on the basis
of its constituents, to determine the wastes to be hazardous. At
the Site, the PeE identified in the ground water was a discarded
conunercial chemical product. On that basis, and given the
hazardous waste number 0210 applied to PCB, this rule is
considered a state TBC. As such, the contaminant will be handled
according to the appropriate requirements, and both ~ternatives 2
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30
3.
R.eduction in Tozicity, Mobility or Volume
Neither alternative 1 (No Action), alternative.2 (Monitoring) or
alternative 4 (Institutional Controls) would address the reduction
of toxicity, mobility or volume. Alternative 3 (Ground Water
Extraction) would be the only alternative which, by pumping the
ground water and applying it on the land surface, would serve to
expose the PCB to photochemical degradation and hydrolysis,
thereby reducing toxicity or volume of PCB. An active pump out
BYBtem, where levels of P~ are drawn fran the aquifeJ;' to the
well, would also. serve to reduce its mobility. .
4.
Short-Term Bffectivene.8
Alternative 1 would not result in a short-term effectiveness
regarding cOUllllUnity protection, or worker protection, or ..
minimizing the environmental impacts, or the time needed to
achieve RA objectives of the ground water remediation.
Alternative 2, 3 and 4 would serve to either monitor the ground
water quality, provide treatment or notify potential users of the
resource of areas to be avoided, thereby preventing exposure.
However, the spray irrigation proposal would present a short-term
exposure risk during spraying operations to workers or others who
' may venture onto the site wi~out authorization. .
5.
Long-Term Bffectivene.8 and Performance
The No Action and the Deed Restriction alternatives provide no '
. treatment, or reduction or destruction, of the' PCB, other thari. what
natural attenuation would' cause over time. No info:rmation would
be available regarding what performance is being achieved in the
long term. .The Monitoring and the Ground Water Extraction
alternatives would provide an assessment of effectiveness and
performance in the long term, while recognizing that the
Monitoring alternative would depend upon natural attenuation for
its effectivenass.
6.
~lementability
All of ~he ground water alternatives for the'Site are. '
'impl,ementable i without requiring any new teclinology, are not
dependent on any unproven assumptions, or create technical
difficulties.
7.
Cost
The cost estimates presented for each alternative were developed
from the 1988 Means Cost Data guides and unit prices fran similar
remediation projects. Operation and maintenance costs were
estimated for a five year period, after which there will be a
five year review of the project. A discount rate of 10 percent,
oyer, a five year period was used for present worth calculations of
capital and operating costs. The estimates provide a cost range
of -30 to +50 percent of overall implementation costs. See Table
5 for the Alternatives Cost Summary.
The present worth cost range of the alternatives are as follows:
Al ternati ve 4:
Al ternati ve 3:
Al ternati ve 2:
Al ternati va 1:
$7,800
$ 239,400
$ 108,000
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31
8.
State Acceptance
MPCA staff prepared this ROD.
remedy. .
Therefore, it accepts the selected
9.
Community Acceptance
The community accepted the proposed plan.
x.
THE SELECTED REMEDY
The U. S. EPA and the MPCA staff have concluded separately that .the
implementation of Alternative 2 in conjunction with Alternative 4 would be the
most appropriate .combination for. the. ground water remedy at t~e Site.
. .
Alternative 2 involves. the. long-term monitoring of the shallow sand aQuifer at
the Site, by means of existing monitoring wells and the installation of four
additional wells in selected locations. Alternative 4 consists of instituting
specific deed restrictions to a portion of the property, whereby no drinking
welles) would be allowed to be installed in the area of concern. Chapter 4725
of Minnesota State Law, concerning placement of drinking water wells, will be
implemented and non-essential wells will be abandoned. This chapter governs
where drinking water wells can be placed. The MDH will be notified regarding
the restriction to install drinking water wells in the area of the PCB plume.
The county government will be notified of the need to include on the deed a
description of the scrap yard activities which were carried out and to notify
potential purchasers of the property history. The long-term monitoring w~ld .
serve. to.documen~ the natural atten~tion occurring. to the remaining. low
levels of PCB present in ground water at the Site.
Alternative 2 is implementable and will provide an indication of the levels of
PCE that might reach Agate Lake. The institutional control regarding the
placement of drinking water wells found in Alternative 4 will provide the
additional reduction of risk to human health.
Insofar as the costs of the alternatives, it is anticipated that for the
combination of Alternatives 2 and 4, the costs should not exceed $116,000 at
present worth. These costs will include the installation of four wells,
sampling for a period of at least five years, and institutional controls.
regarding the installation of drinking water wells.'. .
Therefore, the sele~ted alternatives are expected to provide the best
protection with respect to the nine evaluation criteria. Based on the
information available at this time, U. S. EPA and !!PCA staff believe that the
selected alternatives will be protective of human health and the environment,
will comply with ARARs, will be cost effective, and will provide short-term
and long-term effectiveness and protection.
xx.
STATUTORY DBTERMmAT:IONS SUMMARY
1.
Protection of Human Health and the Environment
The selected remedy provides an overall protection of human health
and the environment, by monitoring the water quality in and around
the area of detected ground water contamination. Institutional
controls will be implemented during remediation to assure
additional protection against ground water use from the area of
ground water contamination, until confirmation sampling and
analyses indicate that a health based clean-up has been achieved.
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5.
32
drinking water wells, will be implemented and non-essential wells
will be aba.'"1doned. This chapter governs where drinking water
wells can be placed. The five year re'view required by CERCIoA./SARA
will provide additional assurance and potential controls, if
necessary, that measures 'taken for the protection of human health
and the environment are sufficient.
2.
Monitoring of ground water quality will demonstrate the
effectiveness of the natural attenuation over time. As the ground
water quality improves, the risks to both human health and the
environment are reduced concomitantly within approximately 20
years. The combination of low levels of PCE in the ground water,
institutional control to prevent the use of ground water that is
and potentially may be contaminated with PCE, and natural
attenuation of those low levels of PCE provide a necessary
reduction of risk to human health and the environment. '.
Attainment of ARARs
The selected remedy will attain all federal and state applicable
or relevant and appropriate requirements as described in Section
IX of this ROD. In addition, the selected remedy will attain all
state "To Be Considered" requirements, as described in Secti.on IX
of this Record of Decision.
3.
Cost-Effectiveness
. The selected remedy provides overall cost-effectiveness because
. with the installation of the four additional monitoring wells and'
the periodic ground water sampling, a high degree of certainty
will be achieved knowing where the ground water contamination is
being naturally attenuated.' The selected remedy can be
implemented at a cost far less than the cost of installing an
active. pump out system, which could not assure complete removal in
spite of significant financial outlay, at least double the cost of
the remedies selected.
4.
Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies. to the Maximum
Extent Practicable.
The RALs, the combinatio~ of the installation of additional
monitoring w~lls, the periodic Sampling, institutional controls
and natural attenuation to reduce ground water contamination, will
assure that permanency will be achieved through alternative
treatment technology.
Preference for Treatment as a Principal Element
The selected remedy eliminates the principal threats at the site,
through restrictions of ground water usage. This remedy utilizes
permanent solutions and alternative treatment technologies,' to the .
maximum extent practical for the ground water at this Site.
However, because treatment of the principal remaining threat at
the Site was not found to be practicable, due to the relatively
low levels of ground water contaminant, PCE, this remedy does not
satisfy the statutory preference for treatment as a principal
element.
The remedy for soil contamination at this Site used removal as a
principal element. Interim Response Actions (IRAs) were used to
-------
33
and placement in either TSCA, RCRA or industrial landfills. The
implementation of those IRAs removed soils conta~ing lead, PCBs
and asbestos franthe site. These IRAs significantly reduced or
eliminated the principal threats. from this medium.
XII.
DOCUMEN'l'S REVIEWED
The ROD is based upon the documents contained in the Administrative Record;
indexed in attachment A of this document. These documents described site
conditions, investigations and proposed response actionsr~viewed by the MPCA
-------
A'1'TACJDIBN'1' A
-------
ADMINISTRATIVE RECORD INDEX: Attachment A
Agate Lake Scrap Yard, Cass County, Minnesota
Correspondence file:
Pp. Title Author Recipient Type
1 7131n5 response to request for E. M. Lalli, Louis Breimhurst letter
infonnation Brainerd Water Director, Water
& light Quality, MPCA
1 1018n5 request for reply Crow Wing letter
Cooperative
Power & Light
1 11/18/82 "Paul Kramer - scrap yard, Dick Kable, Head Russ Felt, Chief memo
Agate Lake, "Cass.County" MPCA MPCA 'Water
Emergency Quality Division
Response Unit
2 12110/82 "Paul Kramer Transformer Don Adams, Larry Shaw, memo
salvage Operation, Cass MPCA Regional MPCA Regional
County Specialist Director
I 12114/82 "Agate Lake landowners" Steve Lee, Dale Newton, memo
MPCA Strike MPCA Public
Force Infonnation Off.
2 Dec. 82 "Cramer Scrap Yard Steve Lee file file notes
Agate Lake"
1 12115/82 Disposition of transformers Breimhurst Arne Carlson, memo re:
near Gull Lake . Minnesota transformers
State Auditor
12/22/82 ~'Oil'~ Steve Lee Paul Kramer, . certified
Rt 6, Box 372 . letter re:
Brainerd, MN sample
56401 results
2 1/6/83 "Kramer Scrap Yard Steve Lee Thomas Patnode certified
Burlington Nonhero" Burlington No. letter re:
330 2nd Ave S transformers
Mpls, MN 55401
2 1/6183. ~'Kramer Scrap yard . Steve Lee Thomas Ryan certified
Crow Wind Co Elecuical Ryan, Ryan, & letter re:
Cooperative" Eben transformers
217 S 4th St.
-------
Title Coresspondence file
Pp. Date Author Recipient Type
1 1/6/83 "Kramer Scrap Yard Steve Lee Alben Kramer certified
Agate Lake" 4301 E 64th St. letter re:
lover Grove Hgts. transfonners
MN 55075
2 1/12/83 Sandra Arne Carlson, response to
Gardebring, request for
MPCA Exec. information
Director
1 1/14/83 R.G. Annala, Larry Shaw. . letter re:
Chief Engineer, removal of
Burlington transfonners
Northern
1 . 1/17/83 MJM Alben J Steve Lee letter re: .
Kramer . Agate Lake
propeny &
history
1 1/17/83 T J. Patnode Dick Kable Letter re: .
- Steve Lee to
handle Agate
Lake matters
..
3 1/18/83 Request for. comprehensive John McGuire; Gordon Meyer, inspection
biological & sediment stUdy Chief MPCA Michael TibbettS, repon:
for PCBs & other toxics at Water Quality Steve Lee, Solid. Kramer
Agate Lake (11-216) Division & HazardOus scrap yard
Cass County Waste Division
2 1/21/83 R.G. Annala Steve Lee response
letter about
transfonners
..
1 1/25/83 Kramer St.rap Yard Gordon Meyer, . Russ Felt memo re: .
Agate Lake MPCA Chief Steve Lee to
Regulatory handle Agate
Compliance Lake matters
2 2/10/83 MPCA requirements for MPCA policy
spill procedures involving statement
PCBs and electrical
equipment
1 2118/83 R.G. Annala and Steve Lee Letter and
Capsule Labs sampling
results
6 Feb.83 AgateLake Scrap Yard Steve Lee file' memo re:
Minimun Oeanup - proposed
preliminary cleanup
-------
Title Coresspondence file
Pp. Date Author Recipient Type
1 2121183 Lee Hoffman MPCA letter re: concern
about PCB
contamination
2128/83 Larry Shaw Lee Hoffman response letter
2 2/28/83 R.O. Annala Steve Lee letter re: barrel
samples
5 3/21/83 Steve Lee Thomas Ryan. certified letter re:
Paul Kramer. cleanup
Barry McGrath. objectives!
Dave Grannis ~mendations
I 4/13/83 Kramer Agate Lake Barry McGrath Steve Lee confirmation
Scrap~ard Burlington letter re:inabilitY
Nonheni 'of paniesto .
respond by 4115
2 4/21183 Thomas Ryan Steve Lee acknowledgment
& response
letter
2 4/29/83 Barry McGrath Steve Lee response letter
1 512183 Kramer Estate ,. Agate D~vid Grannis S~ve Lee response le~
. Lake Scrap yard-
4 519183 Steve Lee Barry McGrath. letter re: site
Thomas Ryan. diagram and
David Grannis discussion of .
cleanup
objectives
3 6116/83 Agate Lake matter Criston Drake' Steve Lee summary letter
Ryan. Ryan. re: meeting on
Ruttger & Drake 6/14/83
2 8/15/83 Paul Kramer Junkyard Bob DUllinger, f1le memo re: phone
MPCA calls wi Mel
Davis
(consultant)
I 9114/83 Agate Lake Bob Dullinger f1le. memo re: phone
call wi M Davis
1 9/16183 Bob Dullinger Paul Kramer letter re: to set up
meeting
I 9127183 Agate Lake Bob Dullinger me memo re: phone
call wi M Davis
-------
Coresspondence file
Pp. Date Title Author Recipient Type
10114/83 Bob Dullinger Tom Fitzpatrick letter re:
Box 631 requested repons
Brainerd
1 10/17/83 Bob Dullinger Mel Davis letter to postpone
Chemical meeting
Consultants
Formulators, Inc
2 10/17/83 Information request: Gary . Pulford, Paul Kramer request for
Agate Lake Scrap Yard Chief Site . infonnation
Response, MPCA
3 10/17183 Bob Dullinger Paul Kramer letter reque$ting
cooperation
2 10120/83 Douglas Kuehl. Dan Helwig, letter re: fish '&
US/EPA MPCA Water tunIe samples
Quality Division
1219/83 Bob Dullinger Paul Kramer lencr: request for
response
1 5/10/84 Bob Dullinger me memo re: phone
.request from .
Tom Fitzpatrick
1 5/11184 Foldenauer - Kramer T. Fitzpatrick Bob pullinger confinnation
Fitzpatrick, letter re: phone
Larson &. call
Fitzpatrick
5120/84 Bob Dullinger EPA letter requesting
public notice of
site listing on .
NPL ...
9 6/18/84 Agate Lake: Investigation &. Barry Schade Dave Wikre memo: on fish &
Preliminary Result sediments
8128184 Kramer/ AgateLake site .T. Fitzpatrick Bob Dullinger confirmation
letter re phone
call
1 9/11184 Paul KramerlLake Agate site David Grannis . Gary Pulford letter. re:
representation of
Kramer estate
3 9128184 Barry Me Grath Jan Falteisek, letter re:
MPCA comments OD
site listing in
PLP
-------
Coresspondence file
Pp. Date Title Author Recipient Type
2 10/11/84 Bob Dullinger Bmy McGrath response
letter re: listing
onPLP
11/5/84 Bob Dullinger Paul Kramer confirming letter:
with test results
2 1215/84 Russ Wyer, EPA Bmy McGrath letter re: HRS
scoring & listing
on NPL
- 12/12184 Paul Kramer well Michael Kanner. David Gray, memo re: well
MPCA Site Minn Dept of . samples
respo~se unit Health
12/21184 David Gray Paul Kramer letter re: well
contamination
1/3/85 Foldenauer - Kramer T. Fitzpatrick Bob Dullinger letter re: request
for water
sample results
1/11185 Bob Dullinger T. Fitzpatrick letter w/water
sample results
1 1/11/85 Bob DuUmger Paul Kramer colifirmatioil
letter: re phone
call about well
advisory
7/11185 monitoring well installation Jan Falteisek file memo re: phone
program call wlRoman
Kock. MDH
-7112/85 Agate, Lake sit~ Jan Falteisek.' file memo re: phone
call w/CIarence
Bieze re: NPL
1 7/15/85 monitoring wells, Agate' Gary Englund. C.F. Bieze letter re: plans
Lake Scrap yard MDH Ecology & Env. for monitoring
wells
2 11/15/85 Barry McGrath Donna Pormer. lenet re: response
MPCA to i10tice of PLP
listing'
2 11122185 Mike Convery, Bmy McGrath response letter:
MPCA PLP listing
1 1/6/86 legal representation for Enrique me memo re: phone
Paul Kramer Gentzsch. MPCA call wI
Kramer's legal
rep
-------
. Coresspondence file
Pp. Date Title Author Recipient Type
Inl86 RFRA to response panies Enrique file memo re: phone
Gentzsch call w/Crow
Wing Coop.
In 186 Paul Kramer Enrique file memo re:phone.
Gentzsch call wlKramer re
RFRA
1/17/86 MPCA Board Meeting, E. Gen~ch Paul Kramer letter w!boud.
Jan. 28, 1986 agenda: RFRA
1 1/17/86 MPCA Board Meeting, Enrique Crow Wing letter wI board
Jan. 28, 1986 Gentzsch Cooperative agenda: RFRA
1 1/17/86 MPCABoard Meeting, . Enrique Tom Patnode letter wI bOard
Jan. 28, 1986 Gentzsch agenda: RFRA
1/29/86 E. Gentzsch Paul Kramer letter re: Board
issuance of
RFRA
1 1129/86 E. Gentzsch Tom Patnode, letter re: Board
Burlington issuance of
'Northern RFRA
1. 1129/86 . E. Gentzsch Bruce Kramer, letter're: BOard
Crow Wing issuance of
Cooperative RFRA
1 1130/86 Agate Lake Scrap Yard E. Gentzsch Patricia Welle, letter re: RFRA;
of E. Kramer request access
estate
1 1/30/86 Agate Lake Scrap Yard E. Gentzsch D. Hallamek, letter re:, RFRA;
of E. Kramer request access
estate
1 1/30/86 Agate Lake Scrap Yard E. Gentzsch Kenneth Kramer, lener re: RFRA;
of E. Kramer request access
estate
1 1130/86 Agate Lake Scrap Yard E. Gentzsch Judith Kramer, letter re: RFRA;
of E. Kramer request access
estate'
I 1130/86 Agate Lake Scrap Yard E. Gentzsch Richard Kramer, letter re: RFRA;.
of E. Kramer request access
estate
I 1/30/86 Agate Lake Scrap Yard E.Gentzsch Joseph Kramer, letter re: RFRA;
of E. Kramer request access
estate
-------
. Coresspondence file
Pp. Date Title Author Recipient Type
1/30/86 Agate Lake Scrap Yard E. Gentzsch K. Foldenhauer, letter rc: RFRA;
of E. Kramer request access
estate
1 1/30/86 Agate Lake Scrap Yard E. Gentzsch E. O'Leary,. . letter rc: RFRA;
of E. Kramer request access
estate
1 1/30/86 Agate Lake Scrap Yard E. Gentzsch. Alben Kramer, lencr rc: RFRA;
of E. Kramer requcst access
estate
1 2/11186 R.G. Annala E. Gentzsch letter rc: Board
action
1 2/13/86 RFRA and. CO w/respon. E. Gentzsch file memo rc: phone
patties call wI Paul R.
Johnson, Crow
Wing Co. Coop.
2115/86 Agate Lake Scrap Yard Tillitt. McCanen, E. Gentzsch letter rc: Crow
Johnson & Wing intent to
Drummond, Ltd. comply wlRFRA
.Paul Kramer ..
I 2/19/86 E.Gentzsch ' letter rc: intent to'
comply wlRFRA .
1 2127/86 Agate Lake. Scrap Yard E. Gentzsch file memo rc: phone
call wI J. Lynch
of ReTec
I 3/4186 TJ. Patnode E.Gen~ch letter rc: BN
intent to comply
2 4/2i86 Agate Lake, ~crap yard . Paul Johnson, E. Gentzsch letter rc: Crow
Tilliit, McCanen, Wing Coop. '
Johnson & 'responsibility
Drummond, Ltd.
4 4/15/86 Agate Lake Scrap Yard E. Gentzsch Paul Kramer letter rc: 4n 186
Roseville mtg. follow-up meeting
4 4/15/86 Agate Lake Scrap Yard E. Gentzsch Bruce Kramer, lencrrc: 4n186
Roseville mtg. follow-up Crow Wing mec=ting
Cooperative
4 411 5/86 Agate Lake Scrap Yard E. Gentzsch John Lynch, lencr rc: 4n 186
Roseville mtg. follow-up ReTec meeting
4 4/15/86 Agate Lake Scrap Yard E. Gentzsch Barry McGrath lencrrc: 4n186
Roseville mtg. follow-up meeting
-------
Coresspondenc:e file
Pp. . Date Title Author Recipient Type
4 4/15/86 Agate Lake Scrap Yard E. GentzSch Paul R. Johnson letter re: 4n 186
Roseville mtg. follow-up meeting
4 4/15/86 Agate Lake Scrap Yard. E. GentzSch Tom Patnode letter re: 4n 186
. Roseville mtg. follow-up meeting
2 4/21/86 Agate Lake Scrap Yard E. GentzSch Paul R. Johnson letter in response
Crow Wing Coop. to Johnson's
letter of 4f1,
4/30/86 Mass Balances of M. Convery file memo re: phone
Transfonner Contents call wlJohn
Lynch
. .
1 5/1/86 . Agate.LakeScrap Yard Paul R. Johnson E. GentzSch letter re: .CRA as
consultant
5/9/86 Kramer Agate Lake Scrap Barry McGrath E. Gentzsch letter re: . meeting
Yard confinnation;
retention of
consultant
5/15/86 Agate Lake-RI Work Plan Ron Frehner, Timothy R letter wI copy of
CRA Thornton, Hart, work plan
Bruner, O'Brien.
& Thornton
1 5/22/86 Agate Lake Scrapyard - Ron Frehner E. Gentzsch letter wI copies of
QAPP QAPP
1 5123/86 Tom Patnode. E. Gentzsch letter re: CRA as
consultant
3 5128/86 Agate Lake Scrap Yard E. GentzSch Ron Frehner letter re: 5f1,O
SecQnd Roseville meeting . meeting
follow-up
2 5/29/86 Agate Lake Scrap removal Ron Frehner Gordon Carrol letter confirming
Proctor, MN phone call of
5128186
1 5/29/86 Agate Lake site clean-up E. Gentzsch file phone memo re:
call to R. Frcbncr
on site cleanup
1 6/2/86 Agate Lake Scrap Ingrid Verhagen E. Gentzsch note re: phone
Evacuation call from R.
Frchner on lack
of scrap removal
-------
Title Coresspondence file
Pp. Date Author Recipient Type
6/3/86 Agate Lake Scrap Yard E. Gentzsch file Memo re: phone
Clean-up call wI Ron
Frehner on site
inspection 612
2 6/4/86 Agate Lake Scrap Yard Site Timothy E. Gentzsch letter re:
ThorntOn comments on
Consent Decree
3 6/11186 Submittals... Tom Kalitowski Ron Frehner letter re: work
Exec. Dir, MPCA plan & QAPP
apProval wI
modifications
6/16/86 Evaluation repon.... Ron Frehner.. Eo. Gentzsch letter. re: delay of
evaluation repon
2 6/17/86 TImothy E. Gentzsch letter & reprint on
Thornton mixed funding
settlementS
"2 6/18/86 East Bethel Landfill Barbara Jackson, Greg Halben, letter re: staff
MPCA Larkin, Hoffman, contact for
D~y &Lindgren Agate.Lake
3 6120186 Submittals.... Tom KalitOwski Ron Frehner letter re: response.
to site security
plan
2 6120186 Proress of Phase I remedial M Convery rue memo re: phone
investigation call w/Kevin
Neitzke, CRA
1 6123/86 Agate Lake Scrap Yard E. Gentzsch Ron Frehner letter re: agree
Evaluation repon & (0 new report
Alternatiyes list" schedule
2 6/26/86 Addendum to RI Work Plan Tom Kalitowski Ron Frehner letter re: approval
QAPP - Agate Lake of the addendum
I 7 n 186 Ron Frehner E.Gentzsch letter re: Broce
Craemer to mail
list
1. 7nI86.. EPA method 8280, dioxin! Ron Frehner E. Gentzsch letter w/copyof "
Furan Analysis of soil EP A's proposed
samples method 8280
1 7/11186 Agate Lake Scrap Yard Ron Frehner E. Gentzsch letter re: Phase 1
field work done
2 7128/86 Agate Lake Scrap Yard RI E.Gentzsch Ron Frehner letter re: EP A
contaCt, Melinda
Gould, RPM
-------
. Title Coresspondence file
Pp. Date Author Recipient Type
4 7128/86 Evaluation reponIRFRA Tom Kalitowski Ron Frehner letter re:
comments on
report
2 7128/86 access agreement MPCA Paul Kramer signed
access agreement
1 7128/86 Agate Lake Scrap Yard E. Gentzsch Melinda Goul~ letter w/copies of
RI repons EPA . RI repOrts
2 8/4/86 EP A method 8280. . . . Mike Convery Ron Frehner letter re: approval
of QAPP
2 8/11186 cum:nt events at Agate Ingrid Verhagen. file phone memo rc:
Lake scrapyard call wlIrene
Johnson on media
coverage
2 9/8/86 Evaluation repon - response Mike Convery Ron Frehner letter re: response
to 8127 letter .
2 9/16/86 payment by BN & Crow E. Gentzsch fIle memo re:
Wing Coop for expenses phone call wI
inc~ . Barry McGrath
3 11l4l86 Mike Convery Ron Frehner letter & map re:
dioxin/furan
screening data
2 11/5/86 Agate Lake Site E. Gentzsch Melinda Gould letter re: public
Public Access to site . access &
exposure
1 11/12186 dioxin.sampling. . . . E. Gentzsch . file. . memo re: .
meeting wlRon
Prehner on
dioxins/furans
1 11117/86' Agate Lake scrap yard RI Ron Prehner E. GentzSch letter re: soil
sampling
2 1215/86 Phase II dioxin/furan Tom Kalitowski Ron Prehner letter re:
sampling approval of Phase
fiR!
1 1219/86 revision of dioxin/furan Mike Convery file memo re: phone
data call wfferry
Obal, CRA on
data
descrcpandes
-------
Coresspondence file
Pp. Date Title Author ' Recipient Type
12/11/86 analyses for Taras Obal. CRA Mike Convery letter re:
dibenzo-p-dioxin/furan confinning
descrepancies
1 215/87 nature of RFI responses Mike Convery file memo re: phone
call w/CamI
Cove. Croford
&Co
1 2111187 Manifest listing for BN Mike Tibbetts. Mike Convery computer
tie plant MPCA .'
pnntout
2117/87 Uniform Haz. Waste copy of BN's '
Manifest manifiest dated
10/15186 .
2 2117/87 Don Adams. Darrell Sears. letter re:
MPCA Brainerd purchase of
property
3 3/4/87 Agate Lake Scrapyard Melinda Gough E. Gentzsch letter and
recommendations
re dioxin data
1 4/3/87 ,Agate Lake Scrap yard RI Kevin Neitzke,' E. Gentzsch leqer re: photos
, CRA of test pits' .
2 4115/87 sampling results of Mike Convery 'Paul Kramer letter re: well
private well testing results
2 4/23/87 Agate Lake Scrap Yard RI - E.Gentzsch Ron Frehner letter re Gough's
EPA comments comments on
3/4/87
2' 5/8/87" MPCA Bo~ Meeting Dave Richfield. Don S,nyder. letter &. copy of '
, 5/19187 . MPCA Crow Wing Board agenda
Cooperative
1 5118/87 notice in Filter Mike Convery "The Filter," announcement re:
MPCA staff missing file
newsletter
4 6/16/87 Agate Lake Scrap Yard Tom Kalitowski Ron Frehner letter and
site RI Final Repon approval of final
repon with
mc.difications
1 711 0/87 Agate Lake Scrap Yard Michael Kanner, Barry McGrath, letter re:
Legal Action to recover MPCA Paul Kramer, authorization to
delinquent expenses Don Synder commense legal
action
3 10/22/86 MDH Chemical MPCA lab repon re:
lab volatile
hydrocarbons
-------
Title Coresspondence file
Pp. Date Author Recipient Type
I 10/16/86 water analysis MDH Organic E. Gentzsch lab repon re:
Chemistry Unit water samples
from wells
2 10/23/87 Agate Lake Scrap yard Therese. Gioia E. Gentzsch letter re:
EPA RPM comments on
FSIRAP
2 10/27/87 Meeting w/ R. Frehner - Mike Convery file memo re:
discussion of FS/RAP comments on
FSIRAP
10/28/87 Agate Lake Response Ron Frehner E. Gentzsch letter re:
Action instruction to
begin RAP .
10/30/87 Response Action at Agate E. Genrzsch file memo re: phone
Lake site call w/John
Christopherson.
CRA on PCBI
dioxin cap and
site survey
2 10/30/87 Agate-Comments on FS/ E. Gemzsch Timothy letter re: request
. RAP repon Thornton for repon~. . ..
. I 11'12187 Reimbursement of . E.Genrzsch file memo re:
expenses and RAP/RA meeting wlBN &.
Crow Wing Coop
on RAP/RA
1. 11/41187 Completed P~B samples Donna Oman. Orbbie Webber, memo re: PCB
MDH MPCA samples to be
discarded
I. 1115/187 Agate Lake RAp. Ron Frehner . Timothy lett~r re: access
Thornton refusal by. Paul
Kramer
3. 1116/87 EPA comments on FSIRAP Ron Frehner E. Genrzsch letter re:
response to
EPA's comments
12/11/87 Agate Lake - photographs Mike Convery Ron Frehner letter and photos
12/23/87 Agate Lake scrap Yard Timothy E. Gentzsch letter re: access
Thornton refusal by Paul
Kramer
1/4/88 Agate Lake Scrapyard Jeffery Melby. Tim Thornton letter re:
CRA sampling on hold,
Kramer refuses
access
-------
Title Coresspondence file
Pp. Date Author Recipient Type
2 1/5/87 Agate Lake Scrap Yard Rod Massey, Gerald Willet, memo and
MPCA MPCA summary of site
Commissioner activities
4 3/15/88 Access decision - Agate E; Gentzsch Paul Kramer certified letter re: access
Lake Scrap Yard pennission;
pennission/
denialleners for
Kramer,to sign'
4/11/87 Agate Lake Scrapyard T. Thornton E. Gentzsch letter re:
site access
1 4118/87 Agate lake Scrapyard Thomas Spence. E. Gentzsch letter re: site
Thomas W. access,
Spence Law
Office
4/20/87 water analyzed for volatile Minn. Valley A W Research cover sheet for
organic hydrocarbons Testing Labs lab results
2 4/25/87 Agate Lake Scrapyard Steve Shakman. E. Gentzsch letter re: site
AGO access under the
Consent Order
2 5/4/88 Access '. . . for RA David Seep, BN Bob pullinger hmer re: site
and access
Broce Kramer
5 6/2/88 Adminstative Record index
1 7 n 188 Terrence Quirk. E. Gentzsch letter re: draft
DPRA Adm. Record at
EP A-Chi~ago
'7114/88 discussions w/Joan Mike Corivery file memo re: phone
Sullivan call on propeny
across from site
2 7/19/88 letter explaining sampling, Alan Cibuzar, Terry Christensen letter re: PCB
results, including lab results A.W. Research ERA analysis results
from Roben Nelson, A W Laboratory,
Research (6/18/87) Brainerd
1 7126/88 ' lener followup Mike Convery' ' Joan Sullivan, lener Ie: lab
Brainerd results
12/22/88 Agate Lake Thomas Spence Bob Dullinger letter re: site
access
1 2114/89 Agate Lake included in Brainerd Daily news clip
fish advisory list News
-------
Title Coresspondence file
Pp. Date. Author Recipient Type
4/28189 death certificate: P. Kramer file death certificate
6/19189 Receipt of reinbursement of E. Gentzsch David Seep letter re:
expenses acknowledging
reimbursement
7/5/89 Agate Lake Ronald Schutz, E. Gentzsch letter re:
Robins, Kaplan. reinbursement
Miller & Ciresi
2 8/25/89 Agate Lake Scrap Yard Site John Knoepfler. E. Gentzsch letter re: site
Robins. Kaplan. access and a
Miller & Ciresi response to the
RAP
2 9/12189 Heidi Hartmann. Ella May Kramer letter re: health
MDH assessment
1/18/90 A TSDR health assessment David Gray, Gary Pulford, cover memo for
MDH MPCA health .assessment
2/21190 Katherine Rosann Saunder. letter re:
Carlson. MPCA Ii brarian, . information
Brainerd library . repository
1 2/23190 BN:' Agate Lake John Knoepfler E. Gentzsch letter re: site
accesss
2 3/2/90 Agate ~ake Scrap Yard site E. Gentzsch Ella May Kramer letter re: FS/
access for sampling & RA RAP reports,
human tissue
testing, site
accessibility
319190 . Agate Lake Hazardous '. Don Adams. E. Gentzsch memo re: public,
waste site MPCA concern about
site's effects on
tourism
1 3/25190 Don Adams Howard Hanji, letter re: update
Lakeshore Mayor on MPCA
involvement
2 5/31190 K. Carlson Howard Hanji letter re: ,site
update
2 7/16190 Udpdated mailing list for MPCA file mailing list
Agate Lake letter re: site
2 819190 Don Adams Donald Hoger,
La1ceshore , background
-------
Coresspondence file
Pp. Date Title Author Recipient Type
8/30/90 Jim Pennino. Bev Conenon. memo re: new
MPCA AGO address for Betty
O'Leary
2 - affidavit affidavit of E.
Gentzsch
1 10/18/90 Access agreement E. Gentzsch Gerald Willet memo requesting
signature. . . . signature for
site access-
3 11/5/90 Agate Lake Scrap Yard Kevin Turner, E. Gentzsch - letter re: RI &
EPA FS documentS
inadequate
2 11/9/90 Re: EPA letter on Agate E. Gentzsch Kevin Turner letter re: phone
Lake- call on 1115; -
request for
clarification;
project delays
17 11/9/90 Agreement to access E. Gentzsch Alben Kramer, letter and signed
David Seep, access agreement
Bruce Kramer-
2 11/15/909Agate Lake- Scrap yard Kevin Turner E. Gentzsch letter in response
to E. Gentzsch's
letter of 1119;
need to review
draft ROD
2 12/10/90 Sampling Plan. . . E. Gentzsch Kevin Turner letter re: need for
additonal
sampling
E. Gentzsch - .
1 -1110/91 Access agreement Paul Johnson, letter re: access -- - -
John Knoepfler agreement copies
10 2/28/91 Draft ROD review Kevin Turner E. Gentzsch letter and
suggestions
2 3n /91 Gary Pulford . E. Gentzsch memo on: EPA's
ROD suggestions
11' 3/18/91 Sampling Plan Suggestions E. Gentzsch David Seep, - letter re: EP A's
Bruce Kramer sampling
suggesions and
water sample
results
-------
Title Coresspondence file
Pp. Date Author Recipient Type
4111/91 Sampling plan for ..Gully E. Gentzsch Kevin Turner letter re: request
area for gully
sampling
proposal
4/12/91 meeting agenda
1 4/16/91 Sampling plan-gully area Kevin Turner E. Gentzsch letter re:
enclosing gully
sampling plan
4/22191 Paul Fairbanks, Ella May Kramer letter re:
Cass County apology; repon ,
of SW Violations, '
1 5/28/91 Rod Massey David Seep and letter re:
Broce Kramer additional
investigation &
revised FS
3 6114191 work plan Stephen E. Gentzsch work plan for
Mockenhaupt, MPCA review
CRA
1 6/21191 'additional siteinvesrigation E. Gentzsch ' Kevin Turner' ,letter wi copy of
work plan
7/1/91 Jim Pennino file memo re: CRA
work plan
2 7/1/91 Review of. . . '''ork plan Kevin Turner , E. Gentzsch letter re:
cOmments on
CRA's work
,plan
4 '7/17/91 Supplementary Investigation E. Gentzsch David Seep, letter re: EPA's
work plan Broce Kramer comments on
work plan;
modifications [0
work plan
1 Aug. '91 ,Ella May Kramer MPcA staff note te: site
access
9/30191 Lee Wangstad, Don Adams letter re:
Agate Lake Association
Association frustrated at
lack of progress
2 lOn191 E. Gentzsch David Seep, certified letter re:
Broce Kramer results of ground
water samples
-------
Coresspondence file
Pp. Date Title Author . Recipient Type
11/4/91 Don Adams Lee Wangstad letter responding
to Wangstad's
of 9130
2 11/11/91 Brian Sandberg, E. Gentzsch letter re: plan for
CRA aquifer study
3 11/12/91 Interim Response Action s. Mockenhaupt .E. Gentzsch letter re:
Work Plan: ash pile submittal of
. RA/WP
2 11/15/91 H Humphrey III Lee Wangstad . letter re: site
background
1 11/18/91 Jim Pennino me memo re:
commentS on .
IRAP
2 11/19/91 Agate Lake Scrap Yard S. Mockenhaupt E. Gentzsch letter re: phone
call on 10130:
schedule of
activities
2 11/25/91 Agate Lake Scrap yard E. Gentzsch . Lee Wangstad letter re: site
update & impacts
on' Agate.Lake;
fish advisory
1 1213/91 Agate Lake Scrap Yard John Knoepfler E. Gentzsch letter of thanks
for response to L.
Wangstad
12/4/91 Agate Lake Scrap Yard 1. Pennino E. Gentzsch memo re: aquifer
Aquifer study study acceptable
12/1.3/91 Agate ~ake. Scrap Yard. Jim.Pennino E. Geittzsch memo re: extent
Interim RA work plan - of excavation
PCB soil needed; more
sampling needed
3 12120/91 Proposed activities and Jim Warner S. Mockenhaupt letter re: .schedule
proposed aquifer study reasonable;
modify aquifer
study; mods.
attached
4 12126191 Interim RA work plan - PCB Jim Warner S. Mockenhaupt letter re:
soil conditional
approval for
work plan;
modifications
-------
Coresspondence file
Pp. . Date Title Author Recipient Type
5 12126/91 Interim RA work plan - ash Jim Warner S. Mockenhaupt letter re
pile modifications
needed before
implem~ntation;
mods. and
comments on
safety plan
attached
3 1/8192 Proposed aquifer study S. Mockenhaupt. E. Gentzsch letter re:
response to mod.
. requests
2 1/14192 Interim actions. . . . Anita Boseman E. Gentzsch . letter re: agree .
W/MPCA
approach; some
questions; new EP A
contact
1 212/8/92 Agate Lake Jim Peninno E.. Gentzsch memo re: phone
call w/MDH re
publi,? meeting
in April
3123192 . Feasibility study. . .. .
1 S.Mockenhaupt. E. Gentzsch cover letter for 2 . .
copies of FS
1 4/17192 Lee Wangstad E. Gentzsch. letter re: request
for presentation
at Association
meeting
4 5n 192 review of Feasibility Study Jim Pennino E. Gentzsch letter re:
commenJS on FS .
'2 5/11/92 Feasibility Study S. Mockenhaupt J. Pennino letter and
attachment re:
correction to FS
6 8/18/92 Feasibility Study Anita Boseman E. Gentzsch letter &
comments on FS
11 9/10/92 Feasibility Study review Jim Warner David Seep, letter, MPCA &
Broce.Kramer . EPA commentS .
& modifications
toFS
2 9124192 Paul Johnson Ron Frehner letter re: changes
to MDH fact
sheet
13 9/25/92 Clarification of PCB E. Gentzsch David Seep, letter and field
cleanup Bruce Kramer resultre:PCB
soil
-------
Coresspondence file
Pp. Date Title Author Recipient Type
13 10/6/92 Sue Lautt. Ruth Lewis. lab results
Pace Labs CRA
1019192 comments on MDH Jim Peninno. E. Gentzsch memo re:
health assessment comments
3 10/10/92 Ruth Lewis, Scott Hallstrom, lab results
CRA Pace Labs
3 10119/92 Surface soil results S.Mockenhaupt E. Gentzsch letter re: lab
results: lead
cleanup
1119192 Revised Feasibility Study S. Mockenhaupt E. Gentzsch cover letter for 2
copies of revised
FS
11/12/92 J. Pennino E. Gentzsch memo re:
comments on
surface soil lead
results
2 11/25/92 Surface soil lead results. & Jim Warner. David Seep, letter re: disposal
disposal options Bruce Kramer approv~
pending TCLP
results; request
'. notification of
completion
1211192 PCB remediation Ron Frehner for E. GentzSch letter re: need
S. Mockenhaupt for written
approval for PCB
disposal
1 12/4/92 Surface soil PCB Gary Pulford for David Seep and letter re:
remediation and disposal. Jim Warner Bruce Kramer approval for PCB .
disposal
2 12/8192 Jim Peninno E. Gentzsch memo re:
comments on
revised FS
4 1/13/93 comments on revised FS Anita Boseman E. Gentzsch fax of comments
3 1/13193 Modifications &. comments E.Gentzsch Anita Boseman comments
on revised FS
2 1/18193 Surface soil removal S. Mockenkaupt E. Gentzsch letter re: ash
removal; lead &
PCB surface soil
removal in spring
1 In.0I93 E. Gentzsch Anita Boseman fax re: comments
& modifications
to revised FS
-------
Coresspondence file
Pp. Date Title Author Recipient Type
211193 Agate Lake soil.sample Jim Pennino S. Mockenhaupt cover letter for
soil sample data
from gully
18 2/1'2193 . Revised FS Ron Frchner E. Gentzsch, letter re:
Anita Boseman modifications to
FS
1 2/22/93 Jim Pennino file comments on
revised FS
2 2/26/93 Agate Lake Scrap Yard Ron Frchner E. Gentzsch letter re: revised
FS FS incorporating
changes of .
2123 meeting
1 3/8/93 Comments on final revised Jim Pennino file memo re:
FS recommending
approval of FS
1 . 3/30/93 Feasibility Study for Agate Anita Boseman E. Gentzsch letter re:
Lake Scrap Yard site concurrance wI
FS
. .
4 5/14193 . Public meeting/comment.. K. Carlson Brainerd Daily. . public itotiecre:
sought Dispatch public meeting &.
comment
1 5124193 David Seep E. Gentzsch letter re: new
mailing addiess
2 5/28193 FS repon approval . Gary Pulford for David Seep &. letter re:
Jim Warner Broce Kramer approval of 2193
FS; public mtg:
611/93 . '.
1 6/11193 Ralph Pribble, librari~, letter re: health
MPCA Brainerd Public assessment to
Library Administrative
Record
1 6121193 K. Carlson Ella May Kramer letter re: copy
of public mtg .
. . tape .
1 6121193 K. Carlson Sandy Kramer lencr re: copy
of public mtg
tape
I 6/21193 K. Carlson Lee Wangstad letter re: copy
of public mtg
tape
-------
Coresspondence file
Pp. Date Title Author Recipient Type
1 6/24193 Multi-site enforcement Chas. Willaims Valdas Adamkus. faxed letter:
cooperative agreement MPCA EPA request for
Commissioner amendment of
agreement
2 6/25.93 second notice letters Gary Pulford Site Response memo re: no
staff payment for FY
92
7/6193 Crow Wing Power & Light Paul Johnson E~ Gentzsch letter re: CRA
Company retained as
consultants
16 7/14193 Draft ROD Anita Boseman E. Gentzsch letter and
comments on
. draft ROD
8/26/93 revised draft ROD E. Gentzsch Anita Boseman cover letter for
revised ROD
3 9/21193 PCE attenuation at Agate R. Frehner E. Gentzsch letter re: natural
Lake - attenuation
3 10/1193 Multisite CA Jim Warner.
MPCA
Valdas Adamkus, letter re: request
EP A to extend budget
period .
u
-------
Dates
213/83
1986-1991
6/89
8192
5.93' .
5/86
1987
1/87
. 1/87
9/87
10187
10/13/87
3192
ADMINISTRATIVE RECORD INDEX:
Agate Lake Scrap Yard, Cass County, Minnesota
Title
Transfonner data
Water analysis repons .
Ground water monitoring reports
Soil Analysis repons
Soil and ground water results
Soil boring logs
HRS scoring packet
Preliminary assessment and si~ investigation reports
Request for infonnation letters and responses
Citizens Board items
Health risks - PCBs
Risk and danger assessments
A TSDR health assessment
MDH health assessment'
. MDH health assessment
. Site safety and security plans
Remedial investig~tion: work plans
RI amendment
RIlFeasibility Study
RI final report
FSlRemedial Action Plan
Final FSIRAP
FS
-------
.2/26/93
8129193
FS
Remedial Action repon for Burlington Nonhem
RA repon for Crow Wing Cooperative
Interim RA work plan and repon
IRA work plan - site safety
Record of DeCision
Quality Assurance Project Plan and QNQC - chemical analysis: soil dioxin
-------
ATTACBMENT B
-------
TABLES
TABLE 1
POLYCHLORINATED BIPHENYLS (PCBs) IN AGATE LAKE SEDIMENT (in ppm)
Location (See Figure 5)
PCBs
1~42 1254 1260 Total
0.13 0.09 <0.05
0.31 0.17' <0.05
0.11 (L08 <0.05
0.2,9 0.14 <0.05
0.28 0.12
Agate Lake, 20 yards of Kramer's Pt.
0.2
Agate 'Lake, 30 yards 'SE of Kramer's Pt.
0.51
, Agate Lake, 30 yards NE of Kramer's Pt.
0.21
Agate Lake, 150 yards HE of Kramer's Pt.
0.46
Agate Lake, NE Side
<0.05 0.43
1 = Sum of PCB Aroclors 1242, 1254, and 1260. "Less than" values, when
summed '
were. taken ,as one-half of the reported detection limits.
< = less than'
ATTACHMBN'l' B
-------
A'l"1'ACHMImT B
TABLES
TABLE 2
PCBs, MERCURY (Hg), TETRACHLORO-DIBENZODIOXIN (2378-TCDD),
AND TOTAL TETRACHLORODIBENZOFURANS (TCDF) IN FISH FROM
AGATE LAKE AND GULL LAKE
Mean 2378
Species Weight t Lipid PCBs (ppm) Hg TCDD
TCDF
1242 1254 1260 Total (ppm) (ppt)
(ppt)
Agate Lake
Walleye 2.1 0.7 <0.05 0.06 <0.05 0.11 0.89
Northern Pike 2.4 <0.5 <0.05 <0.05 <0.05 <0.08 0.76 <5
none
Gull Lake
Walleye 1.8 0.7 <0.05 <0.05 <0.05 <0.08 0.23
Northern Pike 3;2 <0.5 <0.05 "<0;05 <0.05 <0.08 0.18
1 = Sum of PCB Aroclors 1242, 1254, and 1~60." Less than values when summed,
were taken as one-half of the reported detection limits.
-------
A"l'TACBMBHT B
TABLES
TABLE 3
SOILS CONTAMINANTS, HIGHEST LEVELS FOUND, AND CLEANUP LEVELS
Soil .
Contaminant
Highest .
Level (MG/KG)
Location
Cleanup ,
Level (MG/KG)
Lead (P~)
13,200
RA1 (Figure 4)
300
. Polychlorinated
Biphenyls (PCBs)
89
S18 (Figure 3)
-------
ATTACHMENT B
TABLES
TABLE 4
PERCHLOROETHENE (PCE) IN GROUND WATER AND ITS LOCATION, BY SAMPLING DATES
Date
Perchloroethene in Micrograms Per Liter (~g/l)
.Kramer's Well*
July 1986
October 1986
August 1987
December 1990
August 1991
January 23, 1992 (Pump
Before Pump Test
Six Hours After Start
January 30, 1992
Test)
u. S. EPA Maximum Contaminant Level:
Safe Drinking Water Act:
Minnesota Recommended Allowable Limits:
OW-6
18
ND
39 .
32
22
44
18
9
5.0 ~g/l
5.0 ~g/l
7.0 ~g/l
*ND means Not Detected
NS means Not Sampled
NSP means No Sampling Possible (Well Disconnected)
NS
ND
4.6
NSp.
-------
ATTAcmmNT B
TABLES
. TABLE 5
COST COMPARISON OF THE GROUND WA~R ALTERNATIVES
Description
Monitoring Wells
Extraction Well
Spray Irrigation
Fence/Spray Curtain
"Site Grading. .
Dismantle/Site Restore
Permits/Reports
Annual O&M/Sampling
Deed Restriction
Notify MN Health Dept.
Five-Year SARA Review
Contingency (20%)
TOTALS
. '
ALTERNATIVES
No Action
Monitoring
$ 20,000
60,000
10,000
18,000
$108,0.00
Pump Out .
$
7,000
11,000
6,500
10,000
15',000
30,000
110,000
10,000
39,900
$239,400
Deed
$6,000
500
7,.800
-------
~
ATTACBHENT C
-------
Q
"'--.--
-------
~_.-"- -
-------
---- ..--
-- ---
--..8..,.. .-
. -.- --""""'I.
- .... (? ..- -"~3::-
::..:<1:.' /.
'U"" ~.;
<:~~: -:\l
, ,.. ,
. '\
..-1ooJo"";a ~
._-~
'_a_a> _& t
-
.-..
. '.
:::~: ::
...i;z:::::;ij
; i
";:ir:r
;::~-~~~~l
- . I
,-..~=-
,-,L. .
,.
LAKE -L:}
j...lt-r'J
? '1[-:-
-_..__.. .....
o
2
3
.
8
1 2 Mile.
o
2 3
.
8
12
16 Kilometers
FIGURE 1.
-------
. .
I"
1
1
I .
I
~ 1"111.1-
's
~
. '0 GO
;P
,.
. ,
. ,
~;-:J
/I \5~
-.n,.
CD8", -rc...... . nlY
~-"--,.---
Acaw. ,..,......... ".... - ....... ....
. . ......... ...
-------
"'-.
~ 8521 . aSZZ S524
~~~~~ .. .' .0.13
, ~z '" ". NO SZ6S ~S ~ 8528
\ . """ NO CB-4.. 0.38 "'-..... NO
NO ,,\ \ N;'O " ~
'\ ..CB-3 . ~NO
. SZ9 0./9 CB-7... "
( \ ~~~ \532 , eS33 534 GARAGE\\ /)
" . .-J ~-==-0.19 . NO ~1O"1 . .\ . (/
~ "'--- <-~ \ . eS3~ eS36 A~a;;J
'----- -- ~ '-- NO NO,./ .J
--- ---- . .,/
.OWZ - - -' --- "
~
i
I.
I
.~5
,"r'D
13313
NO
6S14
110
ffiSI5
0.14
. .53
1'/0
8S2~
110
13:316
O.O:!8
519
S 0.05/
SZZO
110
..CB-B
110
.510
NO
S9
NO.
.OW3
LEGEND
.
MONITORING WELL LOCATION
CHEMICAL BORING LOCATION
~
...
.
SURFACE SOIL SAMPLING l.OCATION
(6-23-86)
SURFACE SOIL SAMPLING LOCATION
(6-15-91) ,
PCB CONCENTRATION IN mg/kg
NOT DETECTED
SCALE: (: 60'
eI
29
110
,CRA
KRAMER
HOUSE
.OW46
.OW4A
.57
NO
.S8'
NO
o
FIGURE 3.
Sampling Grid, with PCB Impacted Soils, Agate Lake Scrap Yard Site
figure 2.2,
PCB IMPACTED SOIL
EXCAVATION AREAS
-------
, .
CAA
FfGURE 4.
, :I.A3 t
.,. ,
I'U!
I !
/ ::: \ '::~
( ~ \,.r:o~~J8 '
, AAJ \ "-'I
(~::2 of ,:\'JI,
,,:- C~I2C
"-'128 tau
\ :\.. RA2 ::JIMI
\ TV ~, ~47 '0 ~12A ,'"1110,
" "\.J;oJI ItA 8 0" .
\ \ . O~ 'o~~o3~.s
Jf1(J C1I"-'Z4A ~ .szu 01iA108
\. \ 41M ., a 4U" ,
CS-I'" R40 RAIa... ,
JJ A It.U5 . '::::!...'s. """
\ \ In ~t.tZ«J CNO
\ ~18 c:: 4414
\ \
\ \
\ \ ~.~
J I
/ /
/ /
I /
. { ( "'C:;'
ItA8 .
l~ ~ ~~.. ) ~I
" " /
" ",
" "" "'c:;:
.~~~, '- /
'~-J
~o
'" CS-II
tr
.I.~-.
,
l~~ENO
....
.
CHo.c... 10111"" ux..nc..
""C4-U" ~ u:IC4:1C.. (8-'21
=
"PCA-IIIT tAowPU; Loc:...:-.c... (9-92)
\DO CCHComIAncN IN ~/\.
"on:: '!lIfT a...TA~:-C IT
F'I£tD ..tASURo.~~ ","0
IS ~-n:.
77
;-ORMER ASH PIL£
I
-------
'"
Kramer's Scrap Yard
1.
I
FIGURE 1.
"PCS" LEVELS r:1 AG.:.iE LAKE SEDIMENT (;J\:r.t)
N
i
Agate L~ke Resort
c::J c::I r:::J CJ
0.43
"
. 0.46
\
\
\
!
.
I
\
.
. / I
! .1
!
i
.
.
/
./
I
/
:-:- ...'
\r Y yY'r
Bullrush Reef
y l' '1' 'v
0.24 .::
"
R
.
I
I
I
1 ~IINNESOTA POLLUTION COIITI
-------
~
. .
LEGEND
. MONITOR WEL.L.S
a Si~FF G~UG£ .
-92./ -GROUNDWATER CONTOURS
II( I3ROUNOWATER FLOW DIRECTION
!I2./2 RELATIVE GROUNOWATER ELEVATION
(JULY 2. 1586)
A~TE
.\~
\ "f .
\0z
\\\
.OW~ \\ ~
52.25...... ~.
,.." \ - --' 0)
( Q~ '\ \\;"--
\ ./''''0. \ \ .
\\~ \\\ .
. :'\ .\\ \
'-'<) . .
\
~
UKE
\Y
-
C\i.
0).
<::)
C\i
0').
KRANER
HCIUS£ 9/.99
. OW~8
. .OW4A
51.!I6
(.
I.~
\
\
!to'
I
--
"-
"
".
.~.... \\
fi :0' 100' \
. I t
/
/
/ /-0 .
<---- . ./7.i 9LSr:GArE
. " /. . L4KE'
" .
" I
", /.:t.
- . figure 1.6
GROUNDWATER CONTOUR MAP
. Agate Lake Scrapyard-
(?
.::fL
~
MARSHY AREA
CRA
-t
-------
:10'
.
LEGEND
. MONITOR WELL$
a S7"-FF G"-UGE
e P~OPOSE() WELL L~C:'TION
..!.GAT£
LAKE
---
'"
'"
".
"\t';
.~
o' :0'
,
\j/
-
.-t
-.;-
3L
~
Ioo&AASHY AREA
4
.",oc:;J!f!j/:k:. figure 4.1
. . PROPOSED MONITORING
WELL LOCATIONS
Agate Lake Scrapyord
CRA
-------
..\~EO lOt..>
,..:! "'..
~ ft u
$~~
o c
~ ..
~1-", ..l
..( PRot~c.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 5 '
77 WEST JACKSON BOULEVARD
CHICAGO. IL 60604-3590
JAN: 1 ~ ~~';;.J
REPLY TO THE ATTENTION OF:
RA-19
Mr. Charles W. Williams
Commi~ioner
Minnesota Pollution Control Agency
520 Lafayette Road
St. Paul,. Minnesota 55155
Dear Mr. Williams:
The United States Environmental Protection Agency (U.S. EP A) hereby concurs with the
remedy selected pursuant to Minnesota jaw by ~e Minnesota Pollution Control Agency
. (MPCA) for the Agate Lake Scrap Yard Site in Brainard, Minnesota. MPCA signed
and forwarded a Record of Decision (ROD) to U.S. EPA for concurrence on December
2~, 1993. Our concurrence is in accorm.nce with 40 CFR ~OO.515(e)(2)(i) and (ii) and is '
, based on our review of the documents listed in Attachment A of the ROD. .
,U.S. EPA's concurrence stems from.the following conclusion: the response action
selected will reduce risks to human health and the environment.
In concurring with the ROD, U.S. EPA understands that implementation of the ROD
will, begin in the Spring of 1994.
, We look forward to, our continuing, involve~ent in, the Agate Lake Scrap Yard Site.
, Sincerely yours,
ORIGiNAL SiGNED BY
DAVID KEf
Valdas V. Adamkus
Regional Adminiqrator
. u.s. GOVER."1iD/T PRINTING OFFIC!: 1994-386-541/03073
''':''\,
-------
|