United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R05-85/014
June 1985
SEPA
Superf und
Record of Decision:
Kummer Landfill, MN
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TECHNICAL REPORT DATA
(Please read instructions on the reverse before completing)
,. REPORT NO. 12. 3. RECIPIENT'S ACCESSION NO.
EPA/ROD/R05-85/0l4
4. TITLE AND SUBTITLE 5. REPORT DATE
SUPERFUND RECORD OF DECISION June 12, 1985
Kummer Landfill, MN 6. PERFORMING ORGANIZATION CODE
7. AUTHORIS) 8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
". CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency Final ROD Report
401 M Street, S. W. 14. SPONSORING AGENCY CODE
Washington, D.C. 20460 800/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The Kummer Sanitary Landfill occupies ~pproximately 40 acres in the southern
portion of Northern Township, Beltrami County, Minnesota. The site was operated
as a solid waste facility from 1971 until October 1, 1984. During the period of
operations, municipal refuse, demolition debris, and industrial waste were
accepted at the si te. However, the disposal of hazardous wastes was never docu-
mented at any time during operations. The landfill is situated above a shallow
;
surficial sand aquifer which serves numerous downgradient private wells east and
southeast of the landfi 11. At present, the Kummer Sanitary Landfill appears to
be the major source of volatile organic contamination found in private drinking
water wells in the area.
The selected remedial action includes provisions for an alternate water
supply. These provisions consist of constructing two wells in a deep uncontamin-
ated aquifer, a water tower and distribution system. Total capital cost for the
selected remedial alternative is estimated to be $1,624,850 with O&M costs
estimated to be an additional $28,440 per year.
17. KEY WORDS AND DOCUMENT ANAL YSIS
a. DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Record of Decision
Kummer Landfill, NM
Contaminated Media: gw
Key contaminants: VOCs
18. DISTRIBUTION STATEMENT 19. SECURITY CLASS (Tlris Repolr) 21. NO. OF PAGES
None 37
20. SECURITY CLASS (Tllis page) 22. PRICE
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EPA Form 2220-1 (Rev. 4-77)
PREVIOUS EDITION IS OBSOLETE
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E PA Form 2220-1 (Rev. 4-77) (Reverse)
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RECORD OF DECISION
Remedial Alternative Selection
Site: Kummer Sanitary landfill, Northern Township, Drinking Water Oper-
ab}e Unit; Beltrami County, Minnesota
Documents Reviewed:
I am basing my decision on the following documents describing the analysis
of the cost-~ffectiveness of remedial alternatives for the Kummer Sanitary
landfill, Northern Township, Drinking Water Operable Unit:
- Feasibility Study - Central Water Supply for Northern Township.
Beltrami County, Minnesota, Howard, Neeedles. Ta~en & Bergen-
doff, January 1985.
- Summary of Remedial Alternative Selection.
- Responsiveness Summary, April 1985.
Description of Selected Remedy:
- Provisions for an alternate water supply for the affected res-
dents in Northern Township, Minnesota consisting of construct-
-~ng two wells in a deep uncontaminated aquifer, a water tower
and distribution system. The location of the new wells will
be in an area unaffected by the landfill.
- First year Operation & Maintenance costs to provide the labor,
power and chemical supplies for the recommended alternative.
Declarations:
.
Consistent with the Comprehensive Environmental Response Compensation, and
liability Act of 1980 (CERClA), and the National Contingency Plan (40 CFR
Part 300), I have detenmined that the alternate drinking water supply at
the Kummer Sanitary landfill site is a cost-effective remedy and provides
adequate protection of public health, welfare, and the environment. The
State of Minnesota has been consulted and agrees with the approved remedy.
In addition, the action will require future operation and maintenance
activities to ensure the continued effectiveness of the remedy. These
activities will be considered part of the approved action and eligible
for Trust Fund monies for a period of one year.
I have also~detenmined that the action being taken is appropriate ~hen
balanced against the availability of Trust Fund monies for a period of one
year.
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The State of Minnesota will undertake an additional remedial investiga-
tion/feasibility study to determine the nature and extent of the threat
-presented by the release and evaluate proposed remedies.. If additional
remedial actions are determined to be necessary a Record of Dech"ion will
be "prepared for approval of the future remedial action.
(,~i~{ ~os V. Adomkus r- .
Regional Adminis or
I'
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SUMMAny OF REMEDIAL ALTERNATIVE SELECTION
KLMMER SANITARY LA~IOFILL
NORTHERN TOWNSHIP. DRI"~ING WATE~ OPERARLE UNIT. RELTRA~I COUNTY. ~IN~EsnTA
SITE LOCATION ANO DESCRIPTION:
Northern Township is loc~ted in Reltrami County and borders the city of
Be~idji (site ~aps attached. Fiqures 1 and 2). The township had an estiMated
population of 3.~Q7 in 1993 and ~ontains part or all of four lakes. inclurling
Lake Remidji. and is largely composed of single fa~ily homes. The township
also contains a large ~obile home park. The Kummer Sanitary landfill occupies
approximately 40 acres in the southern portion of the towns~iD and is ahout
750 feet from the nearest residence. The landfill is situated anove a shallow
$urficial sand aquifer which serves as a priMary source of drinking water for
an area in Northern Township east and southeast of the landfill with an p.sti-
mated current population of 960 persons. This area has been desiQnated as the
Paffected area" requiring an alternate water supply.
SITE HISTODY:
'fhe KUlTI'T1er Sanitary Landfill was pern1itted by the Minnesota P'ollution
Control Agency (MPCA) on April 26. 1971.
The site was operaterl as a solid waste
facility from 1971 until October 1. 1984 when Charles Ku~er voluntarily ceased
the disposal of ~unicipal waste.
Since that ti~e. the site has only acceoted
demolition waste. During the period of operations. the landfill was ownerl and
operated by Charles and Jon Y.ummer. Primarily. municiDal refuse. demolition
debris and industrial waste were acceoted at the site. However. the MPCA files
do not dOCuMent the di sposal of hazardous wastes at any time duri ng ooera.ti oriS.
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. . - ~._-- --.. ~ --.-..- -' ._.
. - .... .... .-.
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-..- ....---.---.--...- ...---'.-''''
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- .--...- ..- '."
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The landfill is situated a~ove a shallow surficial sand aauifer w~ich serves
numerous downqradient private wells east and southeast of the landfill~. A clay
layer appears to be present in some areas separating the first. sand aquifer from
a second major aquifer.
However, there is no evidence that t~e layer is con-
tfnuous throughout the area or that the layer would prohi~it volatfle organic
hydrocarbon (VOH) co~pound miQration through 1t..
Therefore, the vertical
connection between the two aauifers 1s not known at this time.
Ground water contamination 1n the upDer sanrl aquifer resulting from the
landfill 1s docunented in the HPCA files hased upon MPCA sampling and analysis
of ground water from the site monitoring wells. Four Monitoring wells directly
downgradient from the landfill and one ad~itional well on the landfill property
have shown elevated levels of volatile organic co~pounds in addition to
increased levels of leachate indicating parameters such as chlorides and
specific conductance.
A review of monitoring data from two larger down-
gradient well users in the lower aauifer, a mobile home park and a television
station, has nQt identified any contamination.
On May 22, 19B4, MPCA staff sampled five downgradient private wells and
the television station well to assess off-site impacts and any imminent health
hazards. The results of the sampling showed elevated concentrations of volatile
organic paraMeters in the shallow residential wells.
.Due to the initial findings and the need to further define the area of
contamination, the MCPA staff conducted additional sampling events on June 11,.
1984 and July 5, 1984.
Five of the previously tested wells and 29 additiona'
-ftH's downgra-di~t fr~ ttTe lamtfiH ~ ~31'IT"ed. T~e test;~'~ult~+n-.-t~!.
issuance of sevenl~tte!"s.~y the Minnesotil Department of Health (MOH) advising
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the residential parties not to use their water for drinkin~ or Coo~ing Durposes.
Eleven additional parties were notified by the HDH that VOH cOMpounds had heen
.
detected in their wells but that the wells could still be safely used for
drinking or cooking purposes.
Due to the analytical findings. the lack 0' a clearly identified haffected
areah and the need to provide bottled water to those who were known to be
affected. the MPCA Executive Director signed a Oeterminatinn of Emergency on
.July 17. 1984 to authorize the expenditure of Statp Superfund monies in order
to provide affected residents with bottled water.
In order to define a well advisory area. the MPCA staff sampled 20 additional
residential wells on July 25. lQR4.
~ased upon the test results, the ~H anrl
MPCA delineaterl a three and one-half block well advisory area.
On AU(:JUst 2C1.
1984, the MDH notified 81 property owners within the well advisory area that
they should discontinue the use of their private wells for drinking and cooking
purposes. ,As a result. these parties were informed of th~ bottled water program
established by the MPCA, Beltram; County an1 the city 0' BeMirlji.
0n Au~ust 2~. 1984. the MPCA Roard approved a staff reQuest to expend up to
~o.noo frOM the State Superfund for the purpose of conducting a water supply
feasibility study for the well advisory area and a suitable buffer zone.
It
has been dete~ined by the U.S. Environmental Protection Agency (EPA) that this
feasibil1t.v study is consistent with the Natinnal Continqency Plan (NCP).
The feasibility study required the MPCA's consultant to review the well
--'-.--MY;'ory a~a a-nct based upon the hyr:frogeological data to itientifyan
appropriate buffer zo!'e which woul~ be serverl b.Y a central watersupDly
-'
~stelT\.
The ~PA conceotuall~ screened various alternatives to determine
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w~ic~ alternatives s~ould be studied furt~er in the feasibility study.
A
no action alternative as well as the temporary alternative of providing
carbon filters to the affected residents were evaluated and eliminated
from furt~er consideration (see p. 7, Alternatives [valuation). The
water supply alternatives that the MPCA required to ~e studied furt~er
included the construction of a distribution system which would be connected to
the city of Remi~ji water supply system; the construction of an independent
water supply system which would include wells, a water tower and ft distribution
system; and an independent water supply system involving a surface water
treatment plant and distribution system.
T~e Preliminary Alternatives
Evaluation Report dated November 21. 19R4 recommended t~e eliminatio~ of
the surface water treatment plant system from further consideration due
to excessive costs and operational requirements as comDared to the ot~er
two alternatives.
On January 23.1985. the MPCA staff received the Final Feasibility Stuc1y
Report which recommended the construction of a water suoply system consisting
of two deep wells. a water tower and distri~ution system. That action is the
subject of this Record of Decision.
This alternative provides a cost-effective
alternative when comoared to the other alternatives for supplyin9 a potah1e
water supply to the affected area.
~!~RENT SITE STATUS:
At present. the Kummer Sanitary Landfill appears to he t~e Major source of
volatile organic contamination found in private drinking water wells in the ~rea
{See Table 1).. The site. i5 currentlJ listed on the proposed National Priorities
list and a Remedial Investiqation/Feas1biHty Study (RI/FS) is scheduled to beein
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resin~nces an~ husinesse~ and 8n estimaterl population of 9fin perso~s.
ENFO~CEMENT HISTORY:
..'
On March 6, 197R, th~ ~CA ~taff issuerl a Notice of NoncomDliance to
Jon Kummer, operator of the Ku~er Sftnitary Landfill for violations of the
Minnesota solid waste rules.
nn May 1~, 1Q79, the ~PCA staff issued a Notice of Viola~ion to Jon Ku~er
for continuing to violate Minnesota solin waste rules.
On December 12, 1979, the HPCA entered into a StiDulation A~reement wit~
Jon and Charles Kummer i~ orner to UDgrade th~ landfill's operatinq conditiDns,
groun~ water monitoring system anrlto collect a civil penalty.
On August 6, 1982, the MPCA proposed a second Stipulation Agreement to
Jon and Charles Kummer in order to bring the landfill into compli~nce wit~ the
1979 Stipulation Agreement and MPCA solid waste rule~.
An. a~ree~ent could not
be reached.
1n April, 19A3, the State commenced legal action 89ainst Jon anrl Charles Kummer
in their individual capacities and Charles and Jon Kummer doin~ business 8S Kummer
Sanitary Landfill.
The compl~int alleged violations of State statutes, MPCA
solid waste and water Quality rules and the 1979 Stipulation Agreement.
On Novemher 4, 1q83 the State sent the KUmMer~ a proposed se~tle~ent agree-
ment, but the Kummers were not willing to si~n the settlement aqreement.
On June 26, 1984, the MPCA Board issued a State Su~erfunrl Request for
Response Action (RF~A) to ~harles, P.u~h an1 Jon Kummer which required a RIfFS
8nd re~edial action program due to ground water cont~mination It a~ around the
, 'andfill .
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On August Z8. 1984, the MPCA Board issued a State Superfund Uetermination of
Inadequate Response (DIR) to Charles. Ruth and Jon Kummer.
The document was
issued due to Charles and Ruth Kummer's statement that they we~e unable to fund
the work required in the RFRA and due to Jon Kummer's failure to respond to the
MPCA issued RFRA.
On January 14. 1985 the State sent the Kummers a proposed settlement
agreement.
On February 20, 1985 the MPCA received a response to the proposed
settlement agreement from Charles Kummer's attorney which indicafed that
the Kummers were unwilling to conduct any long term ground water monitoring
or pay any civil penalties for past solid waste violations.
The MPCA is
currently in the process of issuing the Kummers a notice of intent to revoke
the permit to operate the landfill and a closure order to outlinr. c.losure
activities and schedule at the landfill.
The MPCA files do not indicate the disposal of hazardous waste at the Kummer
Sanitary landfill. The MPCA sent 39 Requests for Information under the Minnesota
Superfund Act to businesses located in the landfill service area regarding their
waste disposal practices at the landfill. The responses received by the MPCA
have not identified any res~onsible parties other than the Kummers.
The Kummer Sanitary landfill has been classified by the EPA as a Category
1 site (fund lead from the beginning, no or marginal prospects for enforcement)
and therefore. federal funds should be utilized for the deslgn and construction
-~......._.,. -
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of the recommended water supply system.
...- ... . .
-.. .-.-. - ..
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- ALTERNATIVES EVAlUA"fION:'
.. lovember 7, 1984 the MPCA funded feasibility study was initiated by the
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consulting fi~s of Howard, Needles, Tammen 8n~ Bergen~off anrl the Barr
[ngineering C~P8ny. The purpose of the feas1hi1ity sturly was to evaluate
three wat,er supply a1 ternathes to serve the affected area which inc1urled:
1.
Construction of a distribution system and connection to the city
of Bemidji water sUPD1y systpm;
Construction of wells, a water tower and distribution syste~ and;
2.
3.
Construction of a surface water treatment p1antusinq w~t~r from
lake Bemidji, a reservoir (or other storage mechanisn) an~ distri-
hution syste",.
A no action alternative was considered prior to funding the project.
However, based upon the residential well data, the estab1ishnent of a well
advisory area by the MDH and the lack of information regardinq the source of
the release, the MPCA staff dete~ined that the public health in the area was
clearly threatened which is supported in the endange~ent assp.ssnent.
As a
result, the no action alternative which would have reQuired the puhlic to
remain on bottled water for an inM~f;n;te periorl of time was eliminated fro~
consitieration.
T~e temporary alternative of supplying the affected residents with carbon
filters was also considered prior to project fund1n~.
This alternative would
reQuire routine testing and Maintenance of carbon colu"Ins by hOl'1eowners on a
regul ar basis.
If t~e carbon columns were improperly maintained or neqlected
a posSibility of contaMinant breakt~rough would occur renderin9 the column~
ineffective and posin~ a threat to public health.
As a result, the HDH anri
MPCA did not consider the carbon filter alternative reliable and effective,
therefore, it was eliminated frOM further consideration.
The first phase of the feasibility stutiy involved the evaluation of
t~e available hydrogeologic data; establishMent Of an affected area (see
'-.fi91Jre 3)' which includes"the well 'advisory area Inti buffer zone tohe---'
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the water supply area and the evaluation of eac~ water supply alternative.
alternatives were each screened by using the follow~ng criteria:
T~e
1 .
Ease of implementation;
2.
3.
Rel iabi l1ty;
Ease of operation and maintenance;
4.
r;.
Effect on the conta~inant plume;
Effect on Bemidji's municipal wells;
6.
7.
Special requirements;
8.
Significant engineering;
Social impacts;
~.
Environmental effects;
10.
Long-term effectiveness; and
11.
Capital and operational costs
Upon comoletion of the initial evaluation of the three water supply a~ter-
natives and the submission of the Preliminary Alternative Feasibility ~eport,
the surface water treatment clant altern~tive was eliminated fro~ consideration.
This,decision was based upon excessive c~pital and oreration costs, the
difficulty of operation and maintenance, significant engineering requirpments
and the lowest reliability as compared to the other available alternatives.
During the second phase of the feasibility study, a second, lower cost well
alternative was included in the evaluation process (Figure 4) at the reQuest of
t~e Northern Township Board. This ~lternative involved t.wo wells, a pressure
tank in lieu of a water tower and a distribution system with downsized
~t~~ai~s as compar~ to th~ erigt"al ~ll alt~rnative (rigu~ ~).
/
-=On.:.January 21,1985, the fiPCA staff received the Final ~eport -on-the---
Jelsibili~ Study whic~ recommended the elimination of the alternatives
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involving the construction of a distribution system to be connected to the
city of Bemidji 's water supply system (Figure 6) and the lower cost well
a1ternat ;'ve whi ch woul d ut i 1 he a pressure tank storage system.
The first
of these two alternatives cannot be implemented due to the city of Bemidji 's
policy that services will not be extended to areas outside of the city limits.
Northern Township is unwilling to petition the city for annexation, and
. therefore, the connection to the city is not feasible.
Besides this. the
city of Bemidji's water system has an insufficient water capacity to serve
the affected area.
Nonmally, an additional well could be drilled to alleviate
this p.roblem.
However, the city's distribution system includes a section
which is incapable of accepting additional water pressure.
As a result.
this section of watenmain. which includes a crossing under the Mississippi
River. would require replacement.
Although the cost of the distribution
system under the alternative was estimated to cost $1.367.512, the necessary
improvements to the Bemidji system would require an estimated $575.000.
As a result, the total cost of the connection alternative is greater than
that of the recommended alternative and therefore was eliminated in the final
report.
The lower cost well alternative ~as eliminated in the final report due to
its lower. reliability, social impacts, and its lack of long-term effectiveness.
This system does not meet accepted engineering practice.
The Recommended
Standards for Water Works as developed by the Great Lakes - Upper Mississippi
River Board of State Sanitary Engineers. specifically states that pressure
tanks when provided as the only storage facilities are only acceptable
when serving less than 50 homes.
The estimated number of residences or
~si-nessM' (36'3) ;s' clearly well above that limit, therefore some form of
tround or elevated storage is necessary. The system is also not as reliable
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as a system involving wells and a water tower due to the lacK of stor~.ge
Should a well require servicing.
The design of this system is such that
it is more susceptible to freezing during the long Minnesota winters.
Further, the report indicated that significant pressure fluctuati"ons
would occur in the system due to the pressure tank, thus adversely
affecting.the supply of water to the users of the system.
Also, water
discoloration is a common occurence in the area due to high iron and
manganese levels.
Since the water would come into greater contact with
air in a pressure tank than in a water tower, greater precipitation would
occur and the problem of discolored water would likely be exacerbated.
As.a result, the lower cost well alternative was eliminated from consideration.
The recommended alternative consists of two 17S ga110n per minute wells.
two well pumps. one well house, a 75,000 gallon water tower and distribution
system.
This alternative was evaluated using the same criteria as previously
described and was selected as the most cost effective water supply system
the concept of fi rm pumpi ng capacity and will provi de steady pressure to -
(F i gu re 7).
The system meets accepted engineering practice by fulfilling
the users.
Firm pumping capacity is defined as the capacity of a water
Accepted
system with the single largest well or pump out-of-service.
engineering practice dictates that a water system have a firm pumping
capacity equal to or greater than the maximum day demand.
Three potential wel' sites have been identified outside of the affected
~rea" Sampl1ng fTtmT staiPlle-ss steel wells placed into the shallow aquifer
~ve indicated that the water was free of volatile organic contamination.
- .
~ sites Ire located at a sufficient distance and the pumping volume of the -
~Tls is low enough to ensure that the contaminant pTume will not be drawn
. - .., ~.,.
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into the new municipal wells.
1n addition, the wells will be constructed
",
in a deep uncontaminated aquifer and the site will be verified for acceptability
during the design stage of the project through a pump test program.
Although the capital cost of the recommended alternative exceeds the capital
cost of the alternative having two wells and a pressure tank (See Table 3 for
comparison of capital and 0 & M costs for all the evaluated alte~natives),
it has been determined that the recommended alternative is cost-effective
and consistent with the NCP. This determination is based upon the
following factors:
1. The system will provide a safe water supply and adequately
protect public health;
2. The recommended alternative meets accepted engineering practices;
3. The system will minimize reliability impacts such as pressure
fluctuations and water discoloration.
CO~~UN1TY RELATION$:
Since the discovery of the contamination in the residential wells, the
MPCA staff has worked closely with the local units of government a'nd
three public meetings have been held to date. After the MPCA Director
declared and emergency, a public meeting was held in Bemidji.
meeting occurred prior to the start of the feasibility study.
this
A second
meeting was held after the Preliminary Feasibility Study Report was issued
in order to discuss the report results with pe~le in the community and
to answer their questions. A third public meeting was held upon completion
,Of the Final Report of the Feasibility Study in order to review the study
, '
conclusions, the estimated costs and the affect of the recommendation of
the residents of tne affected area.
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The MPCA provided an opportunity for the interested persons to comnent
on the feasibility study and the related endagerment assessment document through
a pUblic comment period.
The comment period was advertised in the local newspaper.
the Bemidji Pioneer.
The advertisement announced the availability of copies
of the two documents for public review and comment at the Bemidji Public
library, the i nformat i onrepos itory for the site.
No comments were received
by the MPCA during the comment period.
Throughout the discussions, the local units of government and affected residents
have expressed their belief that the ground water contamination is due to the
Kummer Sanitary Landfill and that the State should pay for the water supply
system since it was responsible for permitting the landfill.
In addition, the
local units of government have stated that the cost of constructing any of the
alternatives far exceeds their financial capabilities and that none of the
alternatives can be built without Superfund monies.
Generally, the residents
support the recommended alternative since it will deliver potable water under
sufficient pressure.
However, there is concern regarding the potential for
discolored water due to the use of deep ground water as has been experienced
in Bemidji.
The use of a water tower and the addition of polyphosphate should
minimize this problem.
The corm1Unity has rejected the lower cost well alternative which would not
have significant storage capacity and would likely have pressure and water
discoloration problems.
The residents feel that they did not have these problems
prior to the development of the ground water contamination situation and that the
~lution-to the water supply problem should provide a potable and reliable water
supply.
-------
-14-
A final concern involves real estate values in the affected area w~ich
reportedly have been impacted by the ground water contamination.
Several
residents have stated that their homes Cftnnot be sold at any price anrl that
realtors will not s~ow houses for sale in the area to prosop.ct1ve buyers.
A
Iftember of the ~pltralTli County ~oard stated durin9 the final public' meetinq that
the county assessor was being directp.d to look into the situation an~ reaopraise
the properties accordingly. The local units of government and the resirl~nts
firmly believe that reducp.d propp.rty values will relT1ain until the new water
syste~ has been constructed and placed into operation.
CONSISTENCY WITH OTHER ENVI~ONMENTAl LAWS: -
The activities involved in the design and construction of t~e recommended
water suoply system are not significantly s"~ject to current State or federal
environmental laws.
Since the project involves the design anrl construction of a municipal water
supply system. the design and opp.ration of the 5ystelTl is suhject to reg~'ations
by the ~DH. This is consistent with Section 1413 of the Safe Drinking Water
Act: S!>ecifically. the final plans and specifications are subject to ..,O~
review and approval under Minn. Rules Chapter 472n.
These rules also
dictate the sampling frequencies of the future municipal wells and provide the
water quality standards which must be ~et by the system.
In addition to these require~~nts. the MOH regulations reouire that the
future operator(s) of the water system be certified under Minn.. Ru.les
Chapter 9400. a grounrl water appropriation pe~it will be reQuire~ from the
.-. ""Minnesota DepartJl1ent of Natural Resources prior to t~e installation of the new
.. municipal wel1s.lnd cOlTlpliance with ippliclhle OSHA regulations must be
.-quire~ from all desiqn and construction contractors.
-------
-15-
RECOMMENDED ALTERNATIVE:
The recorTr.1ended water supply alternative has been determined to meet,.the
requirements of 40 CFR Part 300.68(j).
The EPA considers the alternative
involving the wells and water tower to be the most cost-effective means
of providing a reliable water supply to the affected a~ea. The r~commended
alternative is technically feasible, meets accepted engineering practices and
standards including provision for fire protection and effectively protect~
the public's health and welfare.
Although the capital and operational costs of
the recommended alternative exceed the costs of the well and pressure tank
alternative, the recommended alternative will more effectively supply a potable
water supply to the area.
The lower cost ~f the well and pressure tank system was
developed by replacing the water tower with a pressure tank, downsizing the water-
nains and reducing the amount of watermain looping.
These limitations, the lack
of adequate water storage capabilities, the potential for watermain freezing, as
well as the anticipated pressure fluctuations and water discoloration due to pre-
cipitated iron and manganese, render the-system ineffective and unacceptable.
The pressure tank system does not meet sound engineering practice, and the area
would likely experience significant water supply problems not encountered
previ ous ly.
The alternative involving the construction of a distribution system to be
connected to the city of Bemidji system is not cost-effective when the necessary
improvements to the city's system are taken into account.
Further, this alter-
native ~ay not be feasible since the city has refused to consider the extension
of services beyond the city limits without the area petitioning for annexation.
Altl'tottgh thts alterrrat'ive would be highly reliable and would protect the public
health, the need for additional capacity and for watermain improvements
-------
-16-
inclurling a river crossin~ increase the total project costs beyond the recom-
~ended alternativp..
The surface water treatment plant alternative which would draw water froM
Lake Bemidji was eliMinated from consi~eration in the early sta~e of the
feasibility study due to excessive canital an~ operational costs, much greater
engineering and operational requirements and less reliability as COMDared to all
af the other evaluate~ alternatives.
The operation and maintenance (0 & M)
costs of the surface water treatment alternative is approxinately three times
greater than the 0 & M costs of the other alternatives.
As a result, the EPA
has determined that the alternative was not a cost effective ~eans of supplyinq
water to the affected area.
T~e capital costs of the reco~pndp.d alternative are out'inerl in Ta,1e 4.
As
may be noted, the costs include:
1. Two wells, which for estimation purposed were ~ssu~ed to ~e of
100 feet in length and each hav;nq 17S gallon per minute capacities.
Actual depths to be detenmined during pump test;
2. Two well pumps;
3.
A well house which includes all of the electrical components anrl
chemical feed equipment;
4.
5.
A 15,000 gallon water tower;
A distrihution system (See Figure 5) composed of 6, R, and 10
inch water mains;
6.
Service lines from the watermain to the existing residences or
businesses;
1. Fire hydrants;
8. The cost of acquiring sites for the wells an~ water tower; and.
. ":. . . ... .'
9.
Surf.c~ restoration costs.
, ..' ..
11'1 Iddition, the c~ital cost estimatp-includes a ten percen~ conti~f!ncy fund
-------
-17-
and a ten percent figure for engineering, legal and fiscal activities.
The
cost of ~roviding service to vacant lots for future growth is specifi~ally
excluded.
The MPCA has decided to take the lead on this project with federal
funds.
The site has been classified as a 90% federal and 10% State cost-sharing
site for remedial implementation activities.
OPERATION AND MAINTENANCE COSTS:
The Final Report of the Feasibility Study outlined the operation and
maintenance cost for the recommended alternative.
These estimated costs are
presented in Table 5.
The final 0 & M costs will be based on the final 0 & M
plan developed during the design phase.
The EPA has determined that the estimated 0 & M costs, which will be paid by
the users of the water system after the first year, sufficiently reflect the 0 & M
activities which the system will require over time.
The total federal funding
will include first year 0 & M costs.
SCHEDULE:
t~i1 estones .
Date
Sign Record of Decision
June, 1985
Amend CA for Design and Construction
NPL Update 12 Finalized
June, 1985
June, 1985
Complete Design
July, 1985
August, 1986
Complete Construction
System Start Up
August, 1986
... _. - .~
fUTURE ACTIONS:
lnJ.une, 1985 an EPA funded RI/FS is scheduled to be initiated for the
~er Sanitari Landfill under the MPCA/EPA Superfund Multi Site Cooperative.
-------
AgreelTlent.
, andfill .
-1R-
The RIfFS activities will be conducted at and aroun~ the
Upon cOMpletion of the RIfFS. another ROD will be prepare~ to
address the following possible actions:
---... --
1-
2.
Management of miqration to control contaminated ground water.
Source control ~easures to minimize the release of hazardous
substances from the site.
. ", - -' n- _.. .. ,
." .".'-....--
. - .--0 ~ .. -.'~
-------
TARLE 1
COMPARISON OF VOH CO'1POUNOS OETECTED AT K~MER SAmTARY lANDF'ILL
MONITOr.ING WELLS AND NORT~E~N TOWNSHIP PRIVATE WELLS
"........_....,
COITIPounr1 K """"e r Lan t1f;" Priva':e Well s
Ett,vl Ether X X
Benzene X X
Tetrahydrofuran X X
Methylene chloride X X
1,1 Oichloroethane X X
Cis 1,2 Oicnloroethylene X X
1,2 Dichloroethane X X
1,1,1 Trichloroethane X X
1,1 Oichloro-l-propene --- X
1,1,2 Trichloroethylene X X
Tricnlorofluoro~ethane X X
1,1 Dichloroethylene X X
Chloroform X X
1,2, Dichloropropane .X X
Carbon Tetrachloride --- X
1,1,2,2 Tetrachloroethylene X X
1,2 D1brolTloett,ane --- X
Ethyl Benzene X ---
Toluene X ---
1'1'-." 1 erre - - . -- X - -.
p -+ 0 - xyl ene X ---
ttethyl Isobutyl K!tone '( ---
-------
TABLE 2
NORTHERN TOWNSHIP
VOLATILE ORGANIC COMPOUNDS FOUND IN RESIDENTIAL WELLS
10-6 Excess L ifet ime Range Found 'in
Compound Cancer Risk levels (ug/l) Residential Wells (ugll)
Ethyl Ether 0 - 49.0
Benzene 0.66 0 - 2.30
Tetrahydrofuran 0 - 83.0
Methylene chloride 0.19 0 - 46.0
1.1 Dichloroethane 0 - 5.40
Cis 1.2 Dichloroethylene 0 - 27.0
1.2 Dichloroethane 0.94 0 - 3.80
1.1.1 Trichloroethane 22.0 0 - 6.10
1,1,2 Trichloroethylene 2.7 0 - 3.70
Trichlorofluoromethane 0.19 0 - .5.60
1,1 Dichloroethylene 0 ~ 1. 70
Chloroform 0.19 0 - 1. 80
1,2.Dichloropropane 0 - 1. 20
Carbon Tetrachloride 0.4 0 - 0.20
1,1,2,2 Tetrachloroethylene 0.8 0 - 25.0
1,2 Dibromoethane 0 - 0.40
NOTE: Health risk limits adapted from 1) U.S. [PA, 1980, Water quality
-"'''''-- - . ..- criteria documents. 45 FR79318-79379. Nov. 28.1980.; and 2) U.S. [PAt .
1984. Relative carcinogenic potencies among S4 chemicals evaluated
by the Cancer Assessment Group as suspected carcinogens. EPA-600/
8-84-014A. .
'.
-------
TABLE 3
ESTIMATED CAPITAL AND OPERATIONAL COSTS OF EVALUATED ALTERNATIVES
Alternatives
Capital
Cost
Annual
Operation and
Maintenance Cost
No Action
o
o
Surface Water Treatment Plant
Storage, Distributin System
$2,296,183
$78,250
Connection to the ci;y of
Bemidji, Distribution System
1,367,512
+
575,000*
33,814
2 Wells, Pumps, Well House,
Water Tower, Distribution System
1,624,850
28,440
2 Wells, Pumps, Well House,
Pressure TanK, Downsized
Distribution System
1,280,363
25,!>60
* Bemidji System Improvements
NOTE:
Capital costs include ten percent engineering/legal/fiscal cost
and ten percent contingency.
-------
TABLE 4
CAP IT AL COSTS
RECOMMENDED NEW WELL ALTERNATIVE
Site Aquisition
Wells and Pumps
Well House
Water Tower
Water Distribution System
1.
Watermain
2. Fittings, Hydrants and Valves
3. Surface Restoration within
Right-of-Way (ROW)
4. Servi ces:
a.
From Main to ROW
b. From ROW to House
SUBTOTAL
CONTINGENCY (10~)
SUBTOTAL
ENGINEERING, LEGAL and FISCAL (1~)
TOTAL
$19,000
99,000
58,000
121 ,800
520,229
141 ,568
115,720
82;244
185,291
$1,342,852
134,285
$1.477 ,137
147,713
$1,624.850
NOTE: Table adapted from HNTB Final Report of the Feasibility Study,
January 21, 1985.
.,-.-.... .
. Service to vacant lots and associated costs are not federally
fundab1e and have been deleted. .
-------
'TARLE 5
ANNUAL OPERATION AND "'tAINTENANCE COST '*
RECO~ENDEn NEW WELL ALTERNATIVE
Labor S ~,440
Postage 20n
Power 2,900
Chem; eals 750
Fue' (heating) 25n
Vehicle Cost 2,5r)O
Reserve Requirement 13,4nn
TOTAL $2~,44f)
NOTE: Table from ~NTB Final ReDort of the Feasibility Study.
January 21, 1985.
.Cost to be federally funded for the first year of service.,
. .
-------
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WITH THE E'J(CEP"ON .1
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CONSTRUCTEO-OEPENDS
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distribution system
a I te rna t he .
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-------
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-------
~
F i gu rt;.
NORTHERN TOWNSfHP, HI NNESOTA
Capita1 Annua1
Cost 0 3. H Pub1tc Hea1th Environmental Technical Pub 1t c
l\1tern,t'vl (1,000) Cost Considerations Cons I derat Ions Considerations COImIent Other
-
1. No Act I on Unacceptable exposure Continued mlgra- High
to volatile organic tfon of contami - Resistence
compounds from private nated groundwater
water supp 11 es. Residents to add i t i on a 1
would require continued downgrad i ent
bottled water. we11 sand
ultimately lake
Berni dj i
~. Hook up to 1,367
8emidji and $33,814 Reduces pubtic hea 1th SAHE as 1 Re1tes on High City has maintained
Dtstrlbu- + 515'" threat to less than simple Reslstence that It will not
tlon System 10-6. technology extend services
outside the city
limits. Township
unwilling to peti-
tion for annexa-
tion. Has second
highest O~H cost.
H3. Drill 1,625 $28,440 Reduces public health SAME: as 1, 175 Relies on Acceptable Provide safe and
Deep threa t to 1 ess than. gallons per proven reliable water
Wells 10-6 mi nute we11 w111 construction supply, meets
Water- not reverse technology accepted engi-
tower, shal10w ground neering practice,
Distri- water flow provides steady
button direction or pressure ~nd re-
System a nect Oemi dj i duces potential
we 11 s. water discolora-
t ion. ,;
.,
-------
4. Dr11l Deep
We1 h.
Pressure
Tank end
Distribu-
tion System
5. Surface
Water
Treatment
Phnt Dis-
tribution
. System
i, ~
;
,
i
I
I
1,2~0
i
2,296
$25,560
$78,250'
2
Ff gure 7
NORTHERN TOWNSHIP, MINNESOTA
Reduces pub1ic hea1th
threat to less than
10-6
SAME as 3
Reduces pub1ic hea1th
threat to less than
10-6
SAME as 1
{
I
* Money required by cHy system for improvements.
**Recommended a1ternative
Re1f es on
proven
construction
techn010gy.
larger we 11
needed since
instantaneous
peak demand
cannot be met
'wi th absence
of water tower
Moderate System does not
Resistence meet accepted
engineering prac-
tice, pressure va-
riations expected
at tfmes, water
subject to df s-
coloration due to
iron and manganese.
less watermain
looping, potential
for main freezing.
Signiffcantly
greater
engi need"g
required than
other options
None
A1ternative e1imf-
nated at prelfmi-
nary stage of
feasibility study
due to highest
capita land 0.\'1
costs.
-------
COt1'o1UNITY RELATIONS RESPONSIVENESS StJM!1ARY
K~MER SANITAP.Y lANOrILL
NORTHERN TOW~SHIP, O~IN~ING WATER O~ERABLE UNIT, 8ELTRA~I COUNTY, MINNESOTA
CONCERNS RAISED PRIOR TO THE FEASIRIlITY STI~Y cn~HENT PERIOO:
Since the discovery of the residential well contamination in May, ~q~4, t~e
Minnesota Pollution Control Agency (HPCA) staff has worked closely wit~ the
local units of government and three public meetings have been held to dat~. The
first pu~lic meetin~ with approximately 100 people was held after the MDCA
nirector's Determination of Emergency, but prior to the feasi~ility study while a
second public meeting with 40 people was held upon completion of the feasibility
study's preliminary report.
In adrlrtion, the MPCA staff sa~pled 71 residential
wells prior to the completion of the feasibility study which all~wed for
discussions wit~ residents on an individual basis.
involved:
The comnunity's concerns prior to the c~pletion nf the feasibility study
1.
T~e belief that the contamination is from the KUMMer Sanitary
landfill and that since t~e landfill was permitted by t~e MPCA,
the federal anri/or Statp. Superfund should be used to pay
for any necessary studies and remedial action;
2.
The loss of property values due to the contaMinaterl wells an~
the inability of the property owners to sell their homes;
The high cost Of designinq and constructing any of the wat~r
supply alternatives in lig~t of the communities limiterl tax
base and the need for Superfunrl monies;
3.
4.
The desire tn understand the health effects, particularly cancer
risks posed by drinking the contaminated ground water; and
The means by which the HPCA would monitor the noveMent of the
contaminant plume.
5.
.. .~.' .-,- . -
Upon compl~tion of t~~.~easibi1ity~tudi.. a third public. meeting with.
approximately 30 people, was held to discuss the alternatives studied, th~
~ommended alternative anrl the as~ociatp.d costs.
Ouring t~is ~eting, the
t80 major concerns involved:
-------
( -
-2-
1. The availability of Superfund ~onies to design and construct ,-
,the water supply systeM; and '
2. The anticiplte~ pressure fluctuations and the potential water
discoloration (laundry staining) proble~s anticipated if the
lower cost well and pressure tank syste~ were cnnstructed~
Several residents indicated that water discoloration in the Re~idji water supply
has caused laundry tn be stained.
The residents e~pressed t~e belief ~hat they
did not have pressure fluctuation and water discoloration probleMs prior to the
contamination nf their private wells and that the water supply system to he
'built should not impose such problems on the~.
They further stated that even
thouqh a ,potable water supply would be provided through the lnwer cost well
alternative, the problems with the system would prevent real estate values from
rising to their previous levels.
CONCERNS RAISED DURING nfE COMMEtIT PERH'IT'\:
The MPCA provided an opportunity for interested parties to co~ent on. the
feasibility study an~ the related endangerment assess~ent document through a
two-week Duhlic comment period which hegan on March 26, lQ85 and enrled on
Apri1 B, 19B'5.
The comment period was advertised in the local newspaper, the
Bemidji Pioneer. The advertisement announced the availahility of copies of the
two documents for public review and comment at the Renidji Pu~lic library, the
information repository for the site.
However, no comments were received hy the
MPCA durin9 the comment perio~.
RESPONSE TO CO~1UNITY CONCERNS:
The MPCA staff responded to the many resident and local government concerns
._~.,._,..-t'tfrottgh t"'~ use of publfc meet1ngs; by conducting discussions with-individuals '.-.
,duri~g the sa~pling of residential wells and through regular telephone
-------
-3-
conversations. The MPCA staff attempted to allow these parties to have a
significant role during the establishment of the bottled water program and
throughout the feasibility study.
The MPCA utilized the local units of government in establishing sources of
uncontaminated water for affected residents as well as the distribution of
bottles. In addition, local officials provided the MPCA staff with well
logs and other valuable information used to select residential wells for the
sampling program.
The MPCA and Minnesota Department of Health (MDH) addressed the community's
concern regarding the cancer risk associated with consuming the contaminated
ground water through: -
I. The MPCA Director's Detnmination of Emergency;
2. The establishment of a bottled water progra~;
3. The delineation fo a well advisory area and the notification of
people within the area to not use their water for drinking and
cooking puposes; and
4. The funding of water supply feasibility study.
The concern-throughout the feasibility study regarding the cost of the water
supply system was shared by all of the involved parties.
Upon completion of the
preliminary feasibility study report, it became clear that all of. the alternatives
being evaluated involved significant capital costs for construction. As a result,
the MPCA staff directed its consultant to develop and evaluate a lower cost
alternative which would rely on municipal wells as the water supply. This newly
added alternative referred to as .Option 2 of the New Well Alternative" alternative
the was under consideration. However, the final feasibility study report did not
recommend the construction of the lower cost new well alternative due to its
lower reliability, but recollltlended the construction of the higher cost well
,-,._--:..._&.1ternative.wAJcb.. utilizes.... water tower for stora..ge. .In...response to the.
community's expressed concern that it was unable to finance the system and
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that the monthly user costs would be exorbitant (as outlined in the feasibility
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study), the MPCA staff co~itterl itself to seekinq federal and/or State Superfun~
monies for the design and construction of the water supply system.
In addition to ~ealth and cost concerns, several residents and the local
units of government expressed their concerns regarding the monitorin9 of the
contaminant plume.
Although a well advisory area and an affected area have been
. delineated, their is a continued desire by the local units of government and the
residents that the erlpe of the contaminant olume he monitored to track its
I'Iovef'lent.
The MPCA and MDH staff's share this concern with the comnunity and
have been conductinq groun~ water monitoring from selected orivate wells on a
quarterly basis since the HPCA Director's Determination of Emergency. The data.
which is shared with the local' units of govern~ent and. the well owners. has
alleviate~ the cOMmunity's concern that the conta~inant plume may move without
detection.
The HPCA staff believes that written comments were not received during t~e
noticed comment period due to the previo.us community relations activities.
The
public meetings, discussions with residents during sampling events, regular
telephone conversations with local officials and responses to inQuiries by the
press ~ave proven to he effective opportunities for the expression of concerns
by the c~unity and a means for the HPCA staff to co~unicate ongoin~ activities
to respond to these concerns.
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June. 1985 with the U.S. Environmental Protection Agency (EPA)- funding
under the MPCA/EPA Superfund Multi Site Cooperative Agreement.
Unt i1 the
RI/FS is completed. the HPCA staff is unable to determine whether minor
sources in addition to the landfill are responsible for the contamination.
However. due to the emergency water supply problem in the affected area.
the State proceeded with the water supply feasibility study with State
Superfund monies prior to the landfill's RI/FS.
The MPCA's testing of residential wells downgradient of the landfill has
revealed the presence of 18 different volatile organic compounds in the ground
~ater. The HPCA has collected samples from 71 private wells since May of 1984.
The testing has shown that many of the wells contain several (up to 14) different
volatile organic compounds.
The types of compounds. their established health
risk limits and concentration ranges found to date are listed in Table 2.
Several o~_the compounds exceed the established 10-6 health risk ljmits while
a number of compounds do not have established limits.
In many cases, the resi-
dential wells contain numerous compounds which do not have established health
risk limits or are below such limits and the actual health risk -to the water
user cannot be determined.
However. the endangerment assessment has identified
a 3.3 x 10-4 excess cancer risk (approximately 3 excess cancers per 10.000) in
the affected area.
As of February. 1985. the MPCA's well advisory area consisted of a three
and one-half block area east and southeast of the Kummer Sanitary Landfill.
However. an additional area between the well advisory area and Lake Bemiaji
is-downgradient of the 1andfnrand "the potential contamination of wells
-_inihat -area is ve!"..Y high.
As a result. the entire area,as outl~ned in-
figure "j-nas_been- included for the water supply system.- The area- has 363--
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