United States
Environmental Protection
Agency
Office of .
Emergency and
, Remedial Response
EPAIRODIR05-91/170
September 1991
Cor' (
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oEPA
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Superfund
Record of Decision:
MacGiliis & Gibbs/Bell
Lumber & Pole, MN
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Hazardous Waste Collection
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80272-101
REPORT DOCUMENTATION 11. REPORTNO.
PAGE EPA/ROD/R05-91/170
1 ~
3. RedpIenI'. Acce88Ion No.
4. 1118 8IId SI8II8
SUPERFUND RECORD OF DECISION

MacGillis & Gibbs/Bell Lumber

First Remedial Action

7. AuIhor(.)
.
5. A8part D8t8
09/30/91
& Pole, MN
8.
8. PwformIng Org8lllz8ll0n RepL No.
e. PwfonIIIIIII 0rpInIatI0n ..... 8IId Add-
10. ProJectlT-*lWoril Unit No.
11. ConIract(C) 01' Gr8nt(G) No.
(C)
(G)
1~ SponeorIng Orgenlullon ..... 8IId AddN88
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
Agency
800/000
14.
15. Buppl8m8nt8ly No...
18. Abelr8ct (UrNt: 2110 wonI8)
The MacGillis & Gibbs/Bell Lumber & Pole site consists of two active, adjacent wood
preserving facilities, referred to as the M&G and Bell facilities, in New Brighton,
Ramsey County, Minnesota. Land use in the area is residential and commercial.
Several lakes, streams, and wetlands are located within 2 miles of the site. Most
local residents receive drinking water from 10 municipal wells the nearest of which
is located one-quarter mile southeast of the site. There are also a limited number
of residential wells existing in the area. This Record of Decision (ROD) addresses
the 24-acre M&G facility on the eastern portion of the site. Site features include a
disposal area in the west-central portion of the facility used to dispose of
PCP-contaminated wood chips, settled solids, spent treatment solutions, and copper
chromium arsenic (CCA) contaminated drum shells; onsite drums; and a storage area.
From the late 1920's to 1970, M&G used the site to treat wood poles with various
preservatives including creosote and PCP. Process wastewater from these activities
may have been discharged to the disposal pond. In 1970, M&G began using only CCA for
treatment and began recycling the process solution within the treatment system.
Investigations conducted by EPA have detected contamination of the onsite surface and
(See Attached Page)
17. Docum8nt An8Jy8I8 L D88cr1ptD18
Record o~ Decision - MacGillis & Gibbs/Bell Lumber & Pole, MN

First Remedial Action

Contaminated Media: soil, debris, sludge, gw

Key Contaminants: organics (dioxins, PAHs, PCP) metals (arsenic, chromium)
b. IdenIifter8/Open.Ended T8m18
c. COSA 11 FleldlGroup
18. AY8II8bl1ty SI8Iement
18. Security CI... (Thl. Report)
None

20. Sec:urtty CI- (Th18 P8ge)
Nonp
21. No. 01 Pages
38
~ Price
See ANSl-Z3I.1'
See lnalnlcdone on ReIlflt8t1
(FOI'III8Ity NTlS-35)
Depermwnt 01 Commerce

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EPA/ROD/R05-91/170
MacGillis & Gibbs/Bell Lumber & Pole, MN
First Remedial Action
Abstract (Continued)
subsurface soil and ground water, which is thought to be a result of leaking pipes,
drippings from treated poles, contamination from the disposal area, and an onsite spill
of 4,000 to 5,000 gallons of CCA in 1979. In 1988, M&G conducted initial clean-up
activities by overpacking and storing onsite approximately 200 deteriorated drums
containing PCP-contaminated soil and waste. In 1989, a thick layer of PCP-contaminated
oil, referred to as the LNAPL plume, was identified floating on the upper aquifer.
Subsequently, a pump was installed in an onsite well to recover the oil, which is
currently stored onsite in the drum storage facility. In 1988, EPA initiated pilot tests
for soil washing to remove PCP and PARs from contaminated onsite soil, and in 1989
initiated tests for a mobile biological ground water treatment system. EPA has divided
the site into two operable units (OUs) for remediation. OU1 will address remediation
within the onsite disposal area of the M&G facility. OU2 will address ground water
remediation for the entire site, as well as remediation of soil, process and storage
tanks, and waste containers outside of the disposal area. This ROD provides an interim
remedy for OU2. The primary contaminants of concern affecting the soil, debris, sludge,
and ground water are organics including dioxins, PAHs, and PCP and metals including
arsenic and chromium.
The selected remedial action for this site includes removing 100,000 gallons of PCP waste
oil and sludges from abandoned, above-ground and underground PCP process/storage tanks;
decontaminating, dismantling, and disposing offsite of the waste process/storage tanks;
separating PCP wastes and decontamination liquids into oil and water phases using an
oil/water separator; plugging a discharge line from one of the underground vaults to the
disposal offsite area; pumping ground water from beneath the LNAPL plume to enhance LNAPL
recovery via a groundwater depression/oil extraction process; containing and onsite
storage of PCP-contaminated oil and sludge from tanks, residuals from ground
water/wastewater treatment facility, and LNAPL oil from ground water; treating ground
water, and tank and tank decontamination wastewaters using an onsite bioremediation
wastewater treatment facility and, if necessary, a carbon adsorption polishing unit;
discharging effluent water offsite to a publicly owned treatment works (POTW); monitoring
the LNAPL plume; and implementing site access restrictions. The selected remedy may be
modified to include a technology referred to as the Contained Recovery of Oily Wastes
(CROW) process if the process proves successful in a pilot test. The estimated present
worth cost for this remedial action is $3,542,543, which includes an annual O&M cost of
$336,000.
PERFORMANCE STANDARDS OR GOALS:
this interim remedy.
Chemical-specific clean-up goals were not provided for

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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
MacGillis & Gibbs Co./Bell Lumber & Pole Co.
New Brighton, Minnesota
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected interim remedial
action for the MacGillis & Gibbs Co./ Bell Lumber and Pole Co. site
in New Brighton, Minnesota. This actiqn was chosen in accordance
with the Comprehensive Environmental Response, compensation and
Liability Act of 1980 (CERCLA) as amended by the Superfund Amend-
ments and Reauthorization Act of 1986 (SARA), and to the extent
practicable, with the National oil and Hazardous Substances Con-
tingency Plan (NCP). The decisions contained herein are based on
information contained in the administrative record for this site.
The state of Minnesota concurs with the selected remedy.
ASSESSMENT OF THE REMEDY
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action selected
in this Record of Decision (ROD), may present -an imminent and
substantial endangerment to public health, welfare, or the environ-
ment.
DESCRIPTION OF THE REMEDY
This interim remedial action operable unit is expected to reduce
risks by preventing the continued spread of contamination from
source areas into the soils and groundwater beneath the MacGillis
& Gibbs Co. portion of the site. This interim action will also
initiate restoration of the groundwater aquifer beneath the site
and will provide additional information on aquifer response to
remediation prior to the determination of final aquifer cleanup
levels. Subsequent operable units will address the final remedy
for all soils and groundwater contaminated by the site. This
interim remedial action operable unit will be consistent with the
final site remedy.
The major components of the selected remedy include:
Removal of Pentachlorophenol (PCP) waste oil and sludges
from abandoned, aboveground and underground PCP
process/storage tanks and vaults and all associated piping.
Sealing the discharge line leading from an underground
vault to the disposal area.

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2
Decontamination, dismantling and disposal of the
aboveground PCP process/storage tanks.
Implement access restrictions including fencing and
warning signs to reduce access to the remaining underground
vaults.
Separation of liquid PCP waste and decontamination
liquids from the tanks into oil and water phases through.
use of an oil/water separator. .

Extraction of a 'Lighter Than Water Nonaqueous Phase Liquid
(LNAPL) oil plume, contaminated with pCP, from the surface
of the water table using a groundwater depression
extraction process.
Containerization and on-site storage of oil and sludge from
the tanks and extracted oil from the contaminant plume.
Treatment of groundwater from the contaminant plume extrac-
tion process along with wastewater from the tanks and tank
decontamination procedures, in an on-site bioremediation
wastewater treatment facility.
Discharge of effluent water from the on-site wastewater
treatment facility to a Publically Owned Treatment Works
for final treatment and discharge in accordance with
National Pollutant Discharge Elimination System (NPDES)
pretreatment limits.
Monitoring of the contaminant plume thickness and movement
on a quarterly basis. .
STATUTORY DETERMINATIONS
This interim action is protective of human health and the
environment, complies with Federal and State applicable or
relevant and appropriate requirements for this limited-scope
action, and is cost-effective. This action is interim and is not
intended to utilize permanent solutions and alternative treatment
(or resource recovery) technologies to the maximum extent
practicable for this operable unit. Although this interim action
is not intended to fully address the statutory mandate for
permanence and treatment to the maximum extent practicable, this
interim action provides treatment of groundwater during removal
of the LNAPL plume, and thus is in furtherance of that statutory
mandate. Subsequent actions are planned to address fully the
threats posed by the conditions at this site.
Because this remedy will result in hazardous substances remaining
on-site above health-based levels, a review will be conducted to
ensure that the remedy continues to provide adequate protection

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3
of human health and the environment within five years
after commencement of the remedial action. Because this is
interim action ROD, review of this site and of this remedy
be continuing as EPA continues to develop final remedial
alternatives for this site.
an
will
~f!

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. .
RECORD OF DECISION SUMMARY
KacGILLIS , GIBBS CO./BELL LUMBER AND POLE CO.
I. SITE NAME, LOCATION, AND DESCRIPTION

The MacGillis & Gibbs (M & G) and Bell Lumber & Pole (Bell)
National Priority List (NPL) site consists of two adjacently
located wood preserving facilities. The Bell facility is located
on the western portion of the site and the M & G facility is on
the eastern portion of the site (See Figure 1). The M & G
facility comprises 24 acres in the City of New Brighton, Ramsey
County, Minnesota. Each of these facilities has been involved
in wood preserving activities since the 1920's, and both are
still active today. The M & G and Bell facilities were included
as one site on the NPL because of their adjacent locations and
similarities of processes and contaminants.
The elevation of the site is between 900 to 920 feet above mean
sea level. Surface drainage at the site is to the northeast
toward 5th Avenue and to the southwest toward the Minnesota
Transfer Railroad tracks and the pond in the disposal area of the
site. The site is surrounded by a combination of residential and
commercial development. Residences are located north and north-
east of the M & G facility and to the north, northwest and
southwest of the Bell facility. Commerci.al properties lie to the
south and east of the M & G facility.
A number of surface water bodies including lakes, streams and
wetlands are within 2 miles of the site. Several of the lakes in
the area are used for recreational purposes. There are no other
known uses of surface water in the vicinity of the site. Wetland
areas are located northeast of the M & G facility and northwest
of the Bell facility. These areas have some limited recreational
use. They are also ecological habitats for migratory and native
animal and plant species.
Groundwater is used as a drinking water source in the site area.
The City of New Brighton has a municipal water system which
supplies drinking water to the area. This system consists of ten
drinking water wells which are drawing water at a depth of 400 to
900 feet from the deep bedrock aquifers in the area. The nearest
drinking water is approximately 1/4 mile southeast of the site.

This interim remedial action is limited to the MacGillis & Gibbs
portion of the site. Accordingly, this Record of Decision (ROD)
is focused on the M & G facility.
The M &G facility has been divided into two operable units. The
west-central portion of the facility, which has been designated
as operable unit 1 (OU 1), was a disposal area for the facility.
This disposal area was a depression filled with scrap posts and
poles, wood chips, settled solids, and spent treatment solutions
from the pentachlorophenol (PCP) treatment process. Drum shells

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2"
which had formerly contained copper chromium arsenic (CCA)
solution were also reportedly placed in the disposal area. OU 1
addresses the remediation of the waste materials within this
disposal area. The MPCA is the lead agency for operable Unit 1.

Operable Unit 2 (OU 2) addresses the remediation of groundwater
. beneath the entire site, and also the soils, process and storage
tanks, and waste containers located outside of the OU 1 disposal
area. U.S.EPA is the lead agency for OU 2. The interim remedial
action described in this ROD will address the contamination in
OU 2.
Figure 2 shows the location of the Bell and the M
as well as delineating the boundaries of au 1 and
M & G facility. The general layout and pertinent
the M & G facility are also shown on Figure 2.
& G facilities
au 2 on the
features of
II.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
site History
M & G began wood treating operations in the late 1920's and has
changed its treatment process several times over the years. The
initial process involved dipping the "butt" ends (the section of
the pole inserted into the ground) of the wood poles into steel
dip tanks containing hot creosote, after which the poles were re-
moved and air dried. In the late 1940's, M & G converted to a
process that consisted of 5% PCP in a Provaline 4-A fuel oil
mixture. The process was also expanded to treat the whole wood
pole in larger rectangular dip tanks that replaced the original
square butt tanks. In the 1960's the process was again changed
by substituting a PCP/P-9 oil mixture for the PCP/Provaline 4-A
mixture. This is significant because the new PCP/P-9 mixture was
lighter than water, thereby trapping the water extracted from the
treated wood in the process solution, resulting in a substantial
increase in the volume of process water. It is suspected that
the PCP process wastewater was discharged to the disposal area
pond located in the west-central portion of the M & G facility.

In 1970, M & G phased out its use of PCP and introduced the use
of the CCA pressure treating process which is still being used
today. No process wastewater is generated from the CCA treatment
operation. The process solution not absorbed into the lumber is
contained and recycled into the treatment system.
Bell Lumber & Pole Company entered into an agreement with MPCA
under the Minnesota Environmental Response and Liability Act
(MERLA) in 1985 and retained a consulting engineering firm to
perform an investigation and cleanup at its facility. MacGillis
& Gibbs filed for protection under Chapter 11 of the U.S.
Bankruptcy Code and did not enter into a similar agreement.
Current investigations at the M & G site are being conducted by

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3
EPA and MPCA with funds from the Superfund program.

u.S. EPA sent "General Notice" letters to MacGillis & Gibbs
Company and Bell Lumber & Pole Company on November 30, 1989.
These letters stated that U.S.EPA had documented the release or
threatened release of hazardous substances at the site and had
initiated an Operable Unit Remedial Investigation/Feasibility
Study at the site pursuant to CERCLA. Both companies were
notified that U.S.EPA had information indicating that they were
potentially responsible parties. Both companies were offered the
opportunity to enter into negotiations to voluntarily undertake
the completion of any future remedial actions.
Initial Investigations and Removal Actions

The M & G facility has had several investigations beginning with
an investigation of a 1979 spill of 4000 to 5000 gallons of CCA
solution. All of these previous investigations have determined
the presence of pentachlorophenol, arsenic, chromium, and
polynuclear aromatic hydrocarbons in surface and subsurface soils
and als~ in groundwater.
In 1985, an investigation was performed by the MPCA to evaluate
site hydrogeology and to determine the extent of site
contamination in order to develop remediation alternatives for
the M & G facility. This report concluded that the site posed
serious risks, however, due to potential contamination of the
soils by dioxins, there were limited remedial alternatives
available. The report also concluded that the on-site groundwater
was heavily contaminated and that the disposal pond and
associated wastes and sediments should be treated. It was
recommended that further site characterization and treatability
studies be performed in order to obtain a more detailed
evaluation of alternatives and costs.
In 1988, U.S. EPA monitored "some initial cleanup activities being
performed by M & G. Approximately 200 deteriorated drums
containing PCP contaminated soils and waste were overpacked and
placed in a newly constructed storage facility. In 1989, a report
summarizing these cleanup activities indicated the presence of a
4 to 6 foot thick layer of oil containing significant
concentrations of PCP floating on top of the uppermost aquifer.
Contamination found in this form is referred to as a Light
Nonaqueous Phase Liquid (LNAPL). At that time a pump was
installed in a well in the north end of the PCP process area to
recover this oil. This well is still in operation and drums of
recovered oil are being stored in the drum storage facility.

In 1988, U.S.EPA initiated pilot tests of a soil washing system
and a mobile biological groundwater treatment system at the"M & G
facility under EPA's Superfund Innovative Technology Evaluation
(SITE) program. These tests showed effective removal of PCP and

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-4
PARs from soils and also effective removal of PCP from
groundwater. Results on removal of PARs from groundwater were
inconclusive due to low concentrations.
III.HIGHLIGHTS OP COMMUNITY INVOLVEMENT
Various community relations activities were conducted to solicit
public comment on the Proposed Plan for this Interim Remedial
Action. A fact sheet for the Proposed Plan was mailed out on
August 26, 1991. A notice of availability of the Proposed Plan
and announcement of the public comment period were published in
the New Brighton Bulletin and the New Brighton Sun Focus
newspapers on August 21, August 28, and September 11, 1991. The
Proposed Plan for this Interim Remedial Action was released to
the public on August 30, 1991 outlining remedial alternatives and
informing residents that the Focused Feasibility Study and all
other documents comprising the Administrative Record for the site
were available at the Arden Hills Public Library. The public
comment period extended from August 30, 1991 to September 28,
1991 and a public meeting wa~ held September 16, 1991. Questions
were asked during the meeting, however, no formal public comments
were made.
IV. SCOPE AND ROLE OP OPERABLE UNIT WITHIN SITE STRATEGY
The scope and role of this interim remedial action is to control
the spread of contamination from source. areas into surrounding
soils and groundwater and to initiate aquifer restoration. These
specific source areas are the abandoned PCP process/storage
tanks and the contaminated LNAPL plume located beneath the PCP
process area.
The current site field investigation has not yet provided
sufficient information to allow the initiation of a complete
remedial action for the facility. Additional investigation work
will be required to define the horizontal and vertical extent of
contamination from the PCP and CCA groundwater plumes, especially
to the northeast, west, and southwest of the site. Secondly, an
evaluation will be performed of the relationship between the
disposal area pond and the groundwater beneath it, in order to
assess the pond's level of contamination and its effect upon the
area hydrogeology. Potential water transport routes will also be
evaluated, including a subsurface drain that runs from the PCP
process area to the disposal area and also storm drains along 5th
Avenue. Further investigation will be necessary to. determine the
extent of soils contamination at the M& G facil~ty. A detailed
residential well search will also be conducted to determine if
there are any additional residential wells in the area. Finally,
additional studies will be performed to assess the extent of
contamination to the area ecosystems.

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5
Information obtained to date has pointed to the need for an
interim remedial action to control the spread of contamination
from the abandoned process/storage tanks and the LNAPL plume.
High concentrations of PCP (up to 60,100 mg/kg), polychlorinated
dibenzo-p-dioxins, and polychlorinated dibenzofurans (con-
centrations up to 87 mg/kg for the octa-chlorinated dibenzo-
p-dioxin isomer) were detected in the PCP process tanks and in
the LNAPL plume floating on top of the water table. Migration of
these contaminants into the soil and groundwater will continue to
occur while these source areas persist. Downgradient monitoring
wells in the New Brighton Aquifer indicate that PCP in the.
groundwater is migrating in the direction of groundwater flow.
These sources are also the most completely defined areas of
contamination located on the facility in terms of both
concentration and location. Based on the field investigation the
LNAPL plume.extends from the northernmost dip tank to the
northeast, encompassing an area of approximately 150 feet by 150
feet with a maximum thickness varying from 4 to 6 feet. (See
Figure 3). .
The field investigation and analysis of alternatives for. the
interim remedial action are detailed in a report entitled
"Focused Feasibility study Report". The interim remedial action
will be consistent with the final remedy which will address the
remediation of all groundwater and soils contaminated by the
site. This interim remedial action will also provide additional
information on aquifer characteristics and the effectiveness of
treatment technologies which will aid in determining the overall
groundwater remedy. In addition, the removal of the abandoned
PCP process/storage tanks will provide better physical access for
later remediation efforts.
v. SUMMARY OF SITE CHARACTERISTICS
Wood preserving operations at the facility have resulted in
discharge of contaminants to the soils. Potential contaminant
source from past operations include spills and leakage from waste
PCP materials remaining in the abandoned PCP process/storage
tanks and process piping. Spilled solution from the current
chromated copper arsenic treatment process and the dripping of
solution from staged lumber remain as potential contaminant
sources from present operations. The disposal area is another
source of contamination. The disposal area was filled with wood
chips, debris, and spent treatment solutions from the PCP
process. A drain line from the PCP process area discharges water
collected in piping vaults to the pond in the disposal area. It
is likely that some of the process water from the PCP wood
treating operations was also discharged via this line. Drum
shells which had formerly contained copper chromium arsenic
solution were also reportedly placed in the disposal area. PCP

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,
solution was also reportedly used as an herbicide for weed
control at the facility from 1940 to 1974.
Groundwater is used as the source of drinking water in the site
area. The City of New Brighton has ten wells which supply
drinking water to the area. These municipal wells draw water
from the deeper aquifers including the prairie du Chein
formation, Jordan Sandstone, Mt. Simon Sandstone, and the Hinkley
Sandstone. These wells are between 400 to 900 feet deep. Seven
of the municipal wells are located within 1 1/2 miles of the'
site, to the northwest, west and south. The majority of the
residences in the area are served by the municipal wells;
however, there are a 'limited number of private residential wells.
Only a partial inventory of wells has been obtained because it
appears that not all wells in the area have been registered with
the Minnesota Department of Health. Most of these residential
wells are located in aquifers beneath the uppermost aquifer. .
Some of these wells are used as a source of drinking water, but
most appear to be used for auxiliary purposes such as fllling
swimming pools, watering lawns and gardens or washing cars.

The fate of contaminants at the site is dependent in part on the
geology underlying the site. The near surface geology consists
of approximately 167 to 335 feet of unconsolidated glacial
deposits overlying bedrock. These unconsolidated deposits can be
divided into three distinct formations. In descending order,
these formations are the New Brighton Formation, the Twin Cities
Formation, and the Hillside Sand Formation. The New Brighton
Formation contains two distinct layers. The uppermost layer is a
fine-to-medium sand, and the lower is a silty clay to clayey silt
layer. Below the New Brighton Formation is a silty and sandy
clay representing the Twin City Formation. . Underlying this clay
till is a fine-to-coarse sand comprising the Hillside Sand
Formation.
The hydrogeology at the site is characterized by a two-aquifer
system within the glacial overburden. The uppermost aquifer con-
sists of the unconfined New Brighton Sands and the lower aquifer
consists of the Hillside Sands which is confined by the Twin
Cities Till Formation. Groundwater flow direction in these
aquifers has been approximated based on several investigations in
which groundwater elevations were taken. Groundwater elevations
measured in monitoring wells in the New Brighton Aquifer indicate
that there is a groundwater divide which trends east to west in
the vicinity of the disposal pond. Under average climatic
conditions, groundwater north and northeast of the disposal pond
flows to the northeast, groundwater to the west flows to the
west, and groundwater south of the pond flows to the south.
During heavy' rainfall, however, recharge from the disposal pond
creates a radial groundwater flow effect around the pond. In the
confined Hillside Aquifer, groundwater elevation measurements
indicate the groundwater flow direction is to the north.

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7 .
Nature and Extent of Contamination
U.S.EPA began the first phase of a Remedial Investigation /
Feasibility study (RI/FS) of OU 2 in October 1990. The objective
of Phase 1 was to determine a remedy for the groundwater
contamination at the site and also to perform an initial
investigation of the level of contamination in on-site and off-
site soils and area ecosystems. The Phase 1 RI field
investigation included the collection of waste samples,
surface and subsurface samples, groundwater samples, residential
well samples, and surface water and sediment samples.
These samples were analyzed for the contaminants of concern
identified in the previous site investigations which are.
pentachlorophenol (PCP), polynuclear aromatic hydrocarbons
(PAH's), metals including arsenic and ch~omium, and semivolatile
organics. In addition, a limited number of samples were analyzed
for dioxins and furans (PCDDs/PCDFs), volatile organics, and.
pestici~es/ polychlorinated biphenyls (PCBs) in order to identify
other potential contaminants at the site. The Phase 2 RI will
include additional ecological. studies, as well as any sampling
that. will be required to fill data gaps found in the Phase 1.
sampling effort.

Routine Analytical Service (RAS) Lab Analyses were performed on
most of the contaminants sampled for, however, Special Analytical
Services (SAS) Lab Analyses were performed on PCP, PAHs, and PCDD
/PCDFs. SAS analyses are used to provide data with the highest
confidence levels and the lowest contaminant detection limits.
Because PCP and PAHs are normally included in semivolatile (RAS)
analysis, PCP and PAH concentrations were obtained in both
semivolatile (RAS) and SAS analyses.
Waste/Contaminant Source Characterization

A total of ten waste samples were collected. during the field
investigation. Nine waste samples were collected from abandoned
process/storage tanks in the PCP process area and one sample was
taken from oil recovery well TCT-3D which is currently pumping
oil from the LNAPL plume beneath the site. The abandoned tanks
still contain PCP / oil waste product, residues and/or product
sludge. .
In the semivolatiles (RAS) analysis, PCP was detected in the
highest concentration in all the waste samples collected.
Fourteen other semivolatile compounds were detected,. including
PAHs. PCP was present at a concentration of 13,468 mg/kg. PCP
was also detected along with tetrachlorophenol (TCP) in the SAS
analysis. The maximum concentration of PCP detected in the SAS
analysis was 60,100 mg/kg in the sample taken from the LNAPL
pumping well. Seven to eleven isomers of PCDD/PCDFs were detected
in the waste samples. PCDD/PCDFS are known byproducts from the

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.
manufacturing of PCP. For risk assessment purposes the many
PCDD/PCDF isomers 'are often expressed in terms of 2,3,7,8-
tetrachlorodibenzodioxins (TCDD) equivalents. The 2,3,7,8- TCDD
isomer is the most toxic and carcinogenic PCDD/PCDF isomer. The
2,3,7,8-TCDD equivalent for the LNAPL pumping well sample was
79.95 ug/kg. The maximum 2,3,7,8-TCDD equivalent collected from
the abandoned tanks was 37.40 ug/kg.
Surface soi18 Charac~eriza~ion
Surface soil characterization was obtained by taking 21 surf,ace
soil samples from the M & G site and the surrounding area.
Semivolatile RAS analysis indicated the presence of 15
semivolatile compounds including PCP and PAHs.As was the case
with the waste samples, PCP was the ,most prevalent contaminant
detected with a maximum concentration of 2,600 ug/kg from an on-
site sample. PCP and TCP were also detected in the SAS analysis.
The maximum concentration of PCP detected in the SAS analysis was
2310 ug/kg from a sample in the PCP process area. It appears
that PCP and PAH contamination in surface soils is widespread
across the facility.
The analysis of metals detected arsenic, chromium and copper at
maximum levels of 53 mg/kg, 82 mg/kg, and 73 mg/kg, respectively.
Although elevated levels were detected throughout the site, the
highest levels were detected in the CCA process area. No volatile
organics were detected in surface soils. One sample in the PCP
process area showed the presence of a pesticide, 4,4-DDT, at 21
ug/kg. PCDD/PCDFs were sampled for but these analyses are not
available at this time.
Subsurface Soils
Subsurface soil samples were taken in both the CCA and PCP
process areas to determine the extent of the migration of
contamination from facility processes into the soil. A total of
74 soil samples were taken at various depths from 15 soil borings
completed in the process areas. As was the case with other media
sampled, PCP was the most prevalent constituent detected in the
semivolatile analysis. PCP contamination was detected in samples
located at the ground surface to a depth of 37 feet. The highest
concentrations ranging from 1,000 ug/kg to 1,100,000 ug/kg were
located between ground surface to just below the water table.
A similar pattern was found for 18 other semivolatiles including
PAHs. PCP and TCP were both detected in the SAS analysis with
the maximum concentration of PCP being 178,000 ug/kg at a depth
of 5 to, 7 feet.
Subsurface soils analysis for metals found arsenic, chromium, and
copper present at concentrations of 221 mg/kg, 171 mg/kg, and 146
mg/kg. These metals were found throughout the site with the
maximum concentrations found at a depth of 0-2 feet. PCDD/PCDFs

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9
were detected in all 7 samples taken. The maximum TCDD-
Equivalent was 10.866 in a sample collected at a depth of 0-2
feet.
Three volatile organic' compounds (ethylbenzene, toluene, xylenes)
were detected in the subsurface samples taken from depths of 10
to 17 feet. In addition, one boring had four tentatively
identified compounds classified as benzene isomers, detected at
maximum concentrations of 13,000 ug/kg. One sample contained
four pesticides with a maximum concentration of 60 ug/kg at a
depth of 15 to 17 feet. .
Both organic and inorganic contaminants have been detected in
surface and subsurface soils in a widespread horizontal .
distribution. In addition, vertical contamination has been found
ranging from the ground surface to beyond the water table into
the New Brighton Aquifer.
Groundwater Characterization
A total of 37 groundwater samples were collected from 34 newly
constructed monitoring wells and 3 existing monitoring wells.
Fourteen wells were screened to intercept the water table (17 to
30 feet) in the shallow New Brighton Aquifer. Thirteen basal
wells were screened at the base of the New Brighton Aquifer at
depths of from 25 to 73 feet. Seven additional wells were
screened in the deeper Hillside Aquifer at depths ranging from 80
to 141 feet.
As noted above, samples in the New Brighton Aquifer were taken
from both shallow (water table) and deep (basal) wells. The
semivolatile analysis detected PCP along with numerous PAHs. As
was the case with the waste and soil samples, PCP was the
constituent most frequently detected and in the highest
concentration in groundwater samples. PCP was detected in a
basal monitoring well (MW 08B) in the PCP process area at a
concentration of 42,000 ug/l. PCP was found in all but one of
the SAS samples and TCP was found in all but 5 of the samples.
The maximum concentration of PCP found in the SAS samples was
96,000 ug/l, also in MW 08B. PAHs were detected
in all monitoring well samples at concentrations ranging from
.003 ug/l to 1600 ug/l. Napthalene was detected at 1600 ug/l in
monitoring well MW03 B. The greatest numbers of PAHs were found
in well nests MW 03, MW 07 and MW 08. (See Figure 4 for
monitoring well locations.)
Metals were detected at elevated levels in many of the New
Brighton monitoring wells. Two water table monitoring wells
exceeded Maximum Contaminant Levels (MCL) for arsenic and 11
wells exceeded the MCL levels for chromium. The maximum
concentration of arsenic was 293 ug/l in MW 08B and the maximum

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~o
concentration of chromium was 5,830 ug/l in MW 13B. Five
PCDD/PCDFs were detected in monitoring well MW 08W which is
located in the PCP process area. The total TCDD equivalent for
this sample is .00229 ug/l. Three volatile compounds (toluene,
ethylbenzene, and xylene) were detected in 2 wells in the
vicinity of the process area. This is in the same proximity where
these compounds were found in the waste samples. The maximum
concentration found was 10 ug/l. No pesticides or PCBs were
detected in any of the wells.
The laboratory analysis of groundwater samples for the New
Brighton Aquifer indicates that PCP contamination is present in
the areas around the disposal pond area and also the PCP process
area. Based on present information on groundwater flow direction
in the aquifer, it appears as if the disposal pond and the PCP
process area may be acting as separate sources of PCP
contamination. Arsenic and chromium contamination are heaviest
in the CCA process area and to the north ~long the railroad
tracks. However, chromium concentrations in the water table and
basal wells in well nest 14 indicate chromium is moving off site
in the qirection of groundwater flow.
The Hillside Aquifer laboratory analysis showed PCP and TCP in
five of six wells tested. PCP concentrations ranged from .841
ug/l to 6.22 ug/l while TCP concentrations ranged from .012 to
.366 ug/l. However, PCP and TCP were also found in field blanks
and laboratory method blanks at concentrations up to .228 ug/l
(PCP) and .732 ug/l (TCP). Metals analysis detected arsenic in
all well samples, with a range of from 4.6 ug/l to 9.4 ug/l.
Chromium was not detected in any of the samples. No
semivolatiles or pesticides/ PCBs were detected in any of the
samples.
It cannot be determined, from existing data, whether
contamination in the Hillside Aquifer is a result of site
processes. PCP levels in the laboratory method blanks are an
indication that the levels of PCP in the Hillside wells may be
attributable to laboratory contamination. The arsenic
concentrations detected in the monitoring wells is similar to the
arsenic concentration found in a residential well approximately
one mile upgradient of the site, and may be representative of
naturally occurring, or background concentrations in the area.
Further sampling will need to be performed before a determination
can be made as to whether site processes are, in fact,
contaminating" the Hillside Aquifer.
Residential Wells
Six residential wells were sampled during the RI field

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. 11 .
investigation (See Figure 5 for residential well locations). PCP
was detected in four of six samples at concentrations ranging
from .012 to .046 ug/l. TCP was detected at concentrations
ranging from .018 to .050 ug/l. Eight PAHs were detected in one
sample, RW 06. Concentrations range from .004 ug/l to .05 ug/l
with the greatest concentration of. 05 ug/l being Acenaphthene.

Chromium was detected at 18.6 ug/l in residential well RW 6 which
is located approximately 500 feet northeast of the facility.
The groundwater flow to the northeast and a chromium
concentration of 1170 ug/l in nearby monitoring well MW 14W, in-
dicate that the contamination in RW 6 is a direct result of the M
& G facility. The PAHs which were found in RW 6 also appear to be
attributable to the facility. The full extent of the spread of
off-site contamination will be further evaluated in the second
phase of RI field work.
Arsenic was detected at 42.4 ug/l in residential well RW 1 west
of the site. The well was located in the Hillside Aquifer.
Monitoring well samples taken. from the Hillside Aquifer had
maximum arsenic concentration of 9.4 ug/l. In order for the site
to be the source of arsenic contamination in this residential'
well, there would have to be a conduit through the confining
layer of clay from the M & G facility to the well. Because
existing data is insufficient to analyze this situation,
additional study of the potential interconnections between the
two aquifers will be done as part of the phase 2 RI. After the
sampling of residential well RW 1, this well was abandoned by the
owner and filled with cement. This residence is now connected to
the public water supply system.
Arsenic was also detected at lower concentrations in ~hree other
residential wells. Residential WellRW 5 located approximately
one mile southeast of the site, had an arsenic concentration of
2.9 ug/l. This well is considered to be upgradient of .
groundwater flow at the site and may be representative of
background levels of arsenic in the area. Two residential wells
east-northeast of the site, RW 4 and RW6, had arsenic
concentrations of 4.9 uq/l and 4.6 uq/l, respectively. RW 4 is
used for drinking water, while RW 6 is used for lawn and garden
watering.
USEPA has established an MCL for arsenic of 50 ug/l. This MCL is
currently under review by the Agency. Both RW 4 and RW 6 are
well below the current MCL for arsenic. In addition, both of
these wells have arsenic levels similar to residential well RW 5
which is unlikely to have been contaminated by the M & G site.
The arsenic levels in these wells are also similar to arsenic
concentrations found throughout the state in a study conducted by
the MPCA in 1987. A total of 248 samples from aquifers of
varying depths were evaluated in this study. The study
determined that the mean level of arsenic was 3.4 ug/l with a

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~
standard deviation of 8.3 ug/l. Since the arsenic concentrations
in residential wells RW4 and RW6 are similar to background
arsenic concentrations in the state and in the area of the site
itself and are also below the current MCL for arsenic, these
wells are considered to be safe for current use.
Ecological Samplinq
Preliminary ecological sampling was performed as a part of
this RI field work. This involved the collection of 24 surface
and 24 sediment samples in 8 separate ecosystems (See Figure 6
for ecosystem sampling points). Surface water samples taken
northeast of the site at Farrel's Lake showed concentrations
greater than background for PCP, arsenic and chromium. Elevated
levels of PCP and chromium were also found in sediments at
Farrel's Lake and Farrel's Marsh, respectively. As previously
noted, the groundwater flow in the surficial aquifer i~ to the
northeast and thus there is a strong possibility that the
contamination in the ecosystems may be coming from the facility.
Data gaps regarding groundwater flow and groundwater discharge.
rates will be evaluated as part of the Phase 2 RI fie~d work in
order to accurately assess the impact on the area ecosystems.
VI. SUMMARY OP SITE RISKS
As a part of the Focused Feasibility Study for this interim
action, a preliminary human health and environmental risk
assessment was prepared. A conceptual site model was developed
for the M & G facility as part of the remedial investigation.
The purpose of the conceptual site model was to determine the
exposure pathways that would have the greatest potential to
produce adverse human health effects. The conceptual site model
concluded that the exposure pathway of greatest concern was the
migration of contaminants via groundwater to residential wells.
The majority of the residences in the area are connected to the
City of New Brighton public water system which draws its water
from deeper aquifers in the area. The aquifers which supply the
water to the New Brighton public water supply are not
contaminated and thus, residences connected to the City system
are not at risk from groundwater contamination from the site.
Most of the residential wells appear to be used for auxiliary
purposes such as watering lawns and gardens, filling swimming
pools, and washing cars. There are, however, some residential
wells which are used for general domestic purposes such ~s
drinking, cooking and bathing.

Based on the RI field work conducted at the site, the chemicals
of potential concern are arsenic, chromium, PCP, PAHs and
PCDD/PCDFs. The risk assessment evaluated potential risks from
these chemicals for both auxiliary and general domestic use of

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. 13 .
groundwater. Two exposure levels were evaluated, one
representing the reasonable maximum exposure (RME) likely to be
experienced under existing conditions, and the other representing
the RME that might occur in the future should current levels of
contamination in on-site monitoring wells reach residential
wells. RMEs. are the highest exposures that would reasonably be
expected to occur at a site and represent exposure levels well
above the average case.

Chemicals are categorized as either carcinogenic (cancer causing)
or noncarcinogenic, although some chemicals may exhibit both
carcinogenic and noncarcinogenic effects. U.S.EPA has
established the policy that acceptable exposure levels are those
that represent an excess lifetime cancer risk to an individual of
between 1 x 104 (1 in 10,000) to 1 x 10~ (1 in 1,000,000). It
should be noted that these risks are in addition to the normal
risk of cancer posed by everyday life. Arsenic is a known human
carcinogen while PCP, a number of the PAH.compounds, and the
PCDD/PCDF isomer are probable human carcinogens. For
noncarcinogens, risk is determined by calculating a hazard index
which is the ratio of estimated exposure to the acceptable daily
intake. A hazard index greater than 1 indicates that adverse
ef.fects may be possible while a value less than 1 means that
adverse effects would not be expected. All of the contaminants
of concern exhibit non-carcinogenic effects.
The risk assessment determined that swimming in pools filled with
water from residential wells would be the exposure pathway of
greatest concern for auxilIary or nonpotable uses of the water.
Swimming in pools filled with water from residential wells is
estimated to pose carcinogenic risks in the 10~ range due to
arsenic and would not currently pose a risk to human health. If
contamination concentrations present in the groundwater
underneath the facility were to reach nearby residential wells,
the carcinogenic risks of swimming in pools filled with this
water would be in the 10~ range and would be due primarily to PCP
and 2,3,7,8 TCDD.
The use of water from residential wells for domestic purposes,
including drinking and bathing would pose higher potential risks.
The Reasonable Maximum Exposure (RME) to residents currently
using this water for domestic purposes could pose an excess
cancer risk in the 104 to 10~ range due to arsenic contamination.
The RME is based on the arsenic concentration of 42.4 ug/l found
in residential weIll. As previously indicated, this well has
been filled with concrete and is no longer used. The sampling of
other known residential wells in the area found low levels of
arsenic that would appear to be representative of background
concentrations in the area and the State. Thus, no known
residential well users are currently exposed to unacceptable
carcinogenic risk levels.

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1"4
If in the future, contaminant concentrations present in
groundwater underneath the facility were to reach nearby
residential wells, general domestic uses of water would pose an
estimated carcinogenic risk in the 10.2 to 10.1 range, due to PCP
and 2,3,7,8 TCDD contamination. These risk levels were based on
an individual consuming 2 liters of water per day for a period of
30 years at this level of contamination. Risk calculations for
children consuming this water resulted in similar risks.
The risk assessment also analyzed potential noncarcinogenic
effects. swimming in pools filled with water from residential
wells is not expected to pose any significant noncarcinogenic
effects under existing conditions. However, if concentrations of
contaminants present in the main plume area on site reach the
residents' wells, the estimated hazard index for children
swimming in the water would be 1, primarily due to PCP and
chromium.
General domestic use could pose potentially significant risks of
noncarcinogenic health effects. Under existing groundwater
conditions, the estimated hazard index would be between 1 and 2
based on arsenic contamination. As noted in the discussion above
on carcinogenic risks, the RME is based on the arsenic
concentration found in residential well 1 which is no longer in
use. Based on the sampling of other known residential wells there
are not any known residential well users currently exposed to
unacceptable noncarcinogenic health risks. If in the future,
contaminant concentrations present in the groundwater beneath the
facility reach residential wells, the estimated hazard index for
general domestic use rises to 30 - 45 based on PCP and chromium
contamination.
The ecological field investigation identified the presence of
high concentrations of PCP in surface water and sediments in
Farrel's Marsh and Farrel's Lake northeast. of the facility.
These contamination levels detected in the Phase. 1 RI indicate
the need to obtain sufficient data during Phase 2 activities in
order to perform a detailed risk characterization for the
potentially threatened ecosystems. .
The risk levels discussed above are preliminary levels based on
the sampling done to date. Final risk levels will be determined
at. the completion of the Phase 2 Remedial Investigation/Feas-
ibility study. This interim remedial action will reduce site
risks by substantially eliminating the LNAPL plume and abandoned
PCP process tank source areas. Contaminants from these source
areas would otherwise continue to spread contamination into the
groundwater beneath the site and ultimately to the residential
wells in the area. The interim remedial action will achieve a
degree of risk reduction by eliminating these sources while a
final remedial action is being developed for the entire site.

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lS -
The final remedial action for soils and groundwater at the site
will mitigate the final risks determined for the site to within
U.S.EPA's acceptable risk range. .
VII. DESCRIPTION OF ALTERNATIVES
Based on the findings discussed above, the following primary
remedial action objectives were developed for this interim
remedial action at the Site:
- Minimize further degradation of the environment by removing/
controlling the primary sources of contamination in the PCP
process area;
Minimizing further expansion of the LNAPL plume beneath the
PCP process area;
- Reducing and/or controlling the mobility and volume of the
contaminants of concern in the waste PCP material and LNAPL
plume; and
- Initiating restoration of the aquifer.

The secondary objective for implementing an interim remedial
action for the site is:
Providing additional information and data concerning aquifer
characteristics and the effectiveness of treatment tech-
nologies which will aid in determining the overall site
groundwater remedy.
A focused-feasibility study was conducted to develop and evaluate
remedial alternatives for this interim remedial action which
satisfy the objectives specified above. Remedial alternatives
were assembled from applicable remedial technology process
options and were initially evaluated for effectiveness,
implementability, and cost. These criteria were used to
eliminate those process options which are unproven, not
applicable to the site conditions, not expected to achieve an
acceptable level of performance, or prohibitively expensive. The
interim remedial actions retained for further comparison are des-
cribed below.
Interim Action Alternative 1: NO ACTION
The National Contingency Plan requires that the "No Action."
alternative be evaluated at every site to establish a baseline
for comparison. Under the No Action alternative, waste PCP
material in the abandoned tanks and LNAPL would remain in their
present state and continue to spread into the soils and the
groundwater. The No Action alternative would, however, include

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16
monitoring of the LNAPL plume on a quarterly basis during the
remediation process to monitor its thickness and movement.
capital Costs: $ 6,300
Annual 0 , M Costs: $ 5,600
Present Worth Value: $61,711
Interim Remedial Action Alternative 2: WASTE REMOVAL AND LNAPL
EXTRACTION
Includes: Groundwater Monitorinq; Removal of waste from abandoned
tanks; Cleaninq of tanks; Pluqqinq of discharqe line; Removal and
off-site disposal of aboveqround tanks; Oil and water separation;
LNAPL extraction; containerization and on-site storaqe of
qenerated wastes; Treatment and disposal of wastewater.

Interim Remedial Action Alternative (IRAA) 2 includes two main
components. The first component is the removal of PCP waste from
the abandoned process/storage tanks. The tanks and associated
piping would be emptied of all liquids and solids (sludges). The
aboveground tanks would then be decontaminated, dismantled and
transported off-site to be scrapped and dismantled (if" "
decontaminated in accordance with tank closure requirements) or
to be landfilled in accordance with RCRA requirements. The
underground storage vaults would remain in place and would be
further evaluated as part of the final site remedy. The discharge
line leading from one of the underground vaults to the disposal
pond will be plugged to prevent further discharge. The liquid
PCP waste from the tanks and the tank decontamination liquids
would be separated into oil and water phases via an oil/water
separation process.
The second component of this alternative is extraction of the
LNAPL plume from the top of the water table. An extraction well
would be installed in the LNAPL plume to extract the product as
it accumu"lates in the well. It is estimated that approximately
10 gallons of oil would be extracted per day under this IRAA.

Oil and sludge from the tanks and extracted oil from the LNAPL
plume would be transferred into drums and placed in an on-site
storage facility. The storage facility would be an enclosed
building which would protect the drums from weathering and also
restrict access to them. The storage facility will sit on a
bermed concrete pad to prevent leaks and spillage.
The handling, storage and disposal of the waste PCP materials
from the abandoned PCP process/storage tanks, the tanks"
themselves, and the extracted LNAPL plume materials would" be
subject to Applicable or Relevant and Appropriate Requirements
(ARARS). ARARs are those Federal or state environmental laws
that would be applicable, or if not applicable, then relevant and
appropriate, to the action being undertaken at the site. ARARs

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17
that address handling, storage and disposal of these materials
for IRAA 2 as well as IRAAs 3 and 4, would be the Resource
Conservation and Recovery Act (RCRA) and the parallel State of
Minnesota regulations.
Specifically, 40 CFR 261 "Identification and Listing of Hazardous
Waste" under RCRA, and Minnesota Hazardous Waste Rules 7045.0020
through 7045.0135(4) (f) classify the waste PCP materials as a
"listed" hazardous waste. As a "listed" hazardous waste, the
handling, storage and disposal of the PCP waste materials and the
tanks would be conducted in accordance with 40 CFR 262 .
"Standards Applicable to the Generators of Hazardous Waste" and
40 CFR 264 "Standards for Owners and Operators of Hazardous Waste
Treatment, Storage and Disposal Facilities." Minnesota
Regulations that parallel these federal ~egulations are Minnesota
Hazardous Waste Rules 7045.0211 through 7045.0304 and 7045.0450
through 7045.0539(4). The on-site storage prohibitions of 40 CFR
Part 268 Land Disposal Restrictions and Minnesota Waste Rules
7045.1300-7045.1380 would also apply.
In addition, any air emissions resulting from the removal of. PCP
waste material, cleaning/removal of PCP process/storage tanks or.
treatment of waste PCP material, LNAPL or residue/byproduct
thereof would be subject to 40 CFR 50, National Ambient Air
Quality Standards of the Clean Air Act.
Wastewater from the oil/water separation process would be treated
on-site with carbon adsorption units to remove organic
contamination. Discharge water from the treatment process would
be transported in batches for final disposal to a Publically
Owned Treatment Works (POTW). The local POTW would be the Metro-
politan Waste Control Commission (MWCC). The discharge water
from the site will be required to be in compliance with the
general provisions and pretreatment standards of 40 CFR 401 and
403 of the Clean Water Act as well as MWCC's pretreatment
standards. .
Capital Costs: $1,390,000
Annual Operation and Maintenance Costs: $27,000
Present Worth Value: $ 1,661,886
It should be noted that none of the Interim Remedial Action
Alternatives provide for final disposal of either the oil and
sludges from the process tanks or the extracted oil from the
LNAPL plume. Treatment and disposal options for these materials
are currently limited. .
At this time, no commercial incinerators have permits to burn
wastes contaminated with PCDD/PCDFs. Possible disposal options
include dechlorination of PCDD/PCDFs and PCP in the oil (e.g.
using a potassium polyethylene glycolate [KPEG] or alkaline
polyethylene glycolate [APEG] dechlorination process currently

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18
under development>. followed by incineration in an existing
facility or on-site storage of the wastes until an incinerator
permitted to burn PCDD/PCDFs is permitted (estimated to be within
two years).
Another disposal option may be on-site incineration in an
incinerator owned by Bell Lumber and Pole Co. MPCA has reached
an agreement with Bell to use this incinerator to perform a test
burn of contaminated soils from OU1 of the M & G facility. If
this .test burn is successful, a test burn of the LNAPL/Process
Tank materials would be considered, i~ it is feasible to use the
incinerator and an agreement could be reached with Bell to use
its incinerator.
Regardless of the option ultimately chosen for the final disposal
of the wastes, the disposal must comply with RCRA Land Disposal
Restrictions, 40 CFR 268 and Minnesota Hazardous Waste Rules
7045.1300 through 7045.1380.
Interim Remedial Action Alternative 3: WASTE REMOVAL; LNAPL EX-
TRACTION; GROUNDWATER DEPRESSION; AND CARBON ADSORPTION
GROUNDWATER TREATMENT .
Includes: Groundwater monitorinq; Removal of waste from tanks,
pipinq, and vaults; Pluqqinq of discharqe line; removal and off-
site disposal of aboveground storage tanks; oil and water
separation; containerization and on-site storage of generated
wastes; LNAPL extraction through the use of groundwater
depression; wastewater/qroundwater treatment using carbon
adsorption units; disposal of effluent from carbon adsorption at
POTW.
This IRAA differs from IRAA 2 in that groundwater would be
extracted from directly beneath the LNAPL plume at a rate of 5 to
10 gallons per minute. Groundwater extraction would lower the
aquifer in the vicinity of the extraction well, creating a "cone
of depression" that would draw LNAPL material towards the
extraction facilities. This would enhance the rate of LNAPL
extraction to 100 gallons per day. As in the case of IRAA 2,
the LNAPL material would be containerized and transported to the
on-site waste storage facility.
Under this IRAA, the extracted groundwater, along with wastewater
from the tanks and from decontamination procedures, would be
separated in the oil/water separator and then be treated by the
carbon adsorption process to remove organic contaminants. The
carbon adsorption units will be enclosed to protect the
facilities from the effects of weather and to restrict access.
Spent carbon generated from this process would be considered a
.RCRA hazardous waste and would require appropriate regeneration,
treatment and/or disposal. The discharge water from the carbon

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19 .
adsorption facilities would be discharged to the municipal sewer
system for final treatment at the POTW. Effluent discharge from
the carbon adsorption units will be monitored to ensure that the
POTW pretreatment sta~dards are met.

Capital Costs: $1,625,000
Annual Operation and Maintenance Costs: $346,000
Present Worth Value: $3,626,178
Interim Remedial Action Alternative 4: WASTE REMOVAL; LNAPL
EXTRACTION; GROUNDWATER DEPRESSION; TREATMENT OF GROUNDWATER
WITH FIXED FILM BIOREACTOR .
Includes: Groundwater monitoring; Removal of waste from tanks,
piping, vaults; Plugging of discharge line; Removal and off-site
disposal of aboveground tanks; Oil/water separation; .
Containerization and on-site storage of generated wastes; LNAPL
extraction using groundwater depression; wastewater/groundwater
treatment using fixed film bioreactor; and disposal of effluent
from bioreactor at POTW
This IRAA is identical to IRAA 3 except that the wastewater and
extracted groundwater would be treated by a fixed film bioreactor
rather than carbon adsorption units. As in the case of the
carbon adsorption units, the bioreactor will be housed in a
building to protect the facilities from the weather and to limit
access. The bioreactor system will consist of fixed film
bioreactor vessels, aeration equipment, storage tanks for
untreated (influent) and treated (effluent) water, storage tanks
for nutrients, and a heat exchanger to maintain temperatures for
biological activity. A small amount of residual biomass will be
generated as a result of the treatment process. The SITE program
biological groundwater treatment treatability study conducted at
this site, indicated that this residual material would contain
PCDD/PCDFs. This residual material will be filtered from the
effluent stream prior to discharge to the POTW. The effluent
stream discharged to the POTW should be in compliance with POTW
pretreatment standards. A carbon adsorption polishing unit may
be required to remove constituents such as PCDD/PCDFs, which may
not be affected or removed by the bioreactor treatment process.
Capital Cost: $ 1,584,000
Annual Operation and Maintenance Costs: $336,000
Present Worth Value: $3,542,543
VIII. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
The National Contingency Plan (NCP) 40 CFR Part 300 requires that
the alternatives be evaluated on the basis of the following nine
evaluation criteria:
1.) Overall protection of human health and the environment

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20
2.) Compliance with applicable or relevant and appropriate
requirements (ARARs)
3.) Long-term effectiveness and permanence
4.) Reduction of toxicity, mobility or volume through treatment
5.) Short-term effectiveness
6.) Implementability
7.) Cost.
8.) State Acceptance
9.) Community Acceptance
See 40 CFR 300.430(e) (9) (iii) (A)-(1).
This summary discusses how the selected alternative compares to
the other alternatives with regard to these nine evaluation
criteria.
Threshold Criteria
Overall Protection of Human Health and the Environment
lRAA 1, the No Action Alternative is not protective of human
health and the environment. Because the RI field investigation
and risk assessment have demonstrated a threat to human health
and the environment, the No Action Alternative would not be
appropriate. lRAA's 2, 3, and 4, while not comprehensively
protecting human health and the environment from all site
contamination, would be effective in removing the source
materials which are the focus of this interim action. The removal
of the source materials will prevent their migration into ground-
water beneath the site which will ultimately reach nearby
residential wells. lRAAs 2, 3, and 4 would also exert control
over the further migration of theLNAPL plume. However, lRAAs 3
and 4 would exert greater control of the LNAPL plume than lRAA 2
because of their greater extraction rates lRAAs 2,3, and 4
will also initiate the restoration of the New Brighton Aquifer
which could be used as a potential drinking water supply in the
future.
Compliance with ARARS

No ARARS were identified specifically for lRAA 1, the No Action
Alternative. The remaining lRAAs would comply with action-
specific ARARs including POTW pretreatment standards, land
disposal restrictions for hazardous wastes, requirements for on-
site storage of hazardous wastes, and regulations governing
residual material (e.g. air emissions, solids) generated during
the course of remedial action. The laws governing these actions
include, but are not limited to: the Resource and Recovery Act
(RCRA), the Clean Water Act, the Clean Air Act, the Safe Drlnking
Water Act, and any State laws that have more stringent
requirements than the corresponding federal laws. MCLs for the

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. 21
contaminants of concern in groundwater need not be attained in
this interim remedial action, since the primary purpose of this
remedial action is to control the release of source material and
to initiate aquifer restoration rather than to achieve a final
cleanup of the aquifers. See 42 U.S.C. Sec. 9621(d) (4).
Balancina criteria
Long-Term Effectiveness and Permanence

While this criterion is not strictly applicable to the intent of
an interim remedial action, the proposed activity will
permanently reduce source material and is therefore expected to
be consistent with any final remedy.
Reduction. of Toxicity, MObility, or Volume through Treatment

IRAA 1, the No Action Alternative, provides no reduction in the
toxicity, mobility, or volume of contaminants. IRAAs 2,3,and 4 do
not provide for treatment of waste material or extracted LNAPL.
material. There is, however, some reduction in the volume of
contaminants from the treatment of the groundwater collected in
conjunction with LNAPL extraction. IRAAs 2, 3, and 4 do reduce
the mobility and volume of source materials in the LNAPL plume
and the abandoned tanks even though the materials are not being
treated. The removal of these high concentration source materials
will reduce the potential for these contaminants to migrate from
the site.
Short-Term Effectiveness
IRAA 1, The No Action alternative provides no short-term
effectiveness in meeting the objectives of the interim remedial
action. IRAAs 4, 3, and 2 would provide equal short-term
effectiveness in removing source material from the abandoned
tanks. IRAAs' 4 and 3 would have greater short-term effectiveness
than IRAA 2 in controlling the LNAPL plume. IRAAs 4 and 3 have
an estimated duration of operation of 7 years while IRAA 2 has an
estimated duration of 14 years. In addition, IRAAs 4 and 3 would
provide more information regarding the aquifer response to
pumping, which would meet the secondary objectives of this
interim remedial action.
Spent carbon material from the carbon adsorption process in IRAA
3 would need to be routinely replaced and disposed of as a
hazardous waste. lRAA 4, which has been pilot tested at the M &
G facility should produce considerably less residuals which would
have to be handled as hazardous wastes. Therefore, IRAA 4,the
preferred alternative, would have greater short-term .
effectiveness than IRAA 3 in terms of protectiveness of human
health and the environment. IRAA 4 would also provide further

-------
22
information regarding the use of fixed film'bioreactors and its
potential applicability to fina,l site groundwater remediation.

Implementability
All of the IRAAs can be readily implemented from both technical
and administrative perspectives.
Costs
The costs of the various alternatives are presented above. IRAA
2 has a capital cost which is about $200,000 to $300,000 less
than IRAAs 3 and 4. IRAA 2 has a present worth value less than
IRAAs 3 and 4. However, IRAA 2 will take 14 years to remove the
LNAPL plume or twice the time that IRAAs 3 and 4 would take to
remove the plume. IRAAs 3 and 4 have approximately the same
present worth values.
Modifyina criteria
state Acceptance

The state of Minnesota supports the selection of the selected
alternative, that is, IRAA 4 described below.
Community Acceptance
One formal comment was received from the public. See the attached
responsiveness summary. The members of the community that
attended the public hearing supported the remedy.
IX.
THE SELECTED REMEDY
Based on the information collected and'developed in the RIfFS
process, and using the comparative analysis of alternatives
described above, U.S.EPA, in consultation with MPCA have selected
Alternative 4 as the most appropriate interim remedial action for
addressing the PCP wastes in the abandoned process fstorage tanks
and the LNAPL PCP contaminant plume. This remedy is made up of
the following components:

LNAPL Plume Monitoring: To monitor the plume, two additional
piezometers would be installed which along with the existing
piezometers and monitoring wells will be used to assess the
thickness and movement of the oily material on a quarterly basis
during the remediation period.
Removal of PCP Waste from Abandoned PCP Process/Storaqe Tanks:
The tanks and associated piping would be emptied of all liquids
and solids (sludges). It is estimated that these tanks contain
approximately 100,000 gallons of liquid and sludge material. The,

-------
23
aboveground tanks would be decontaminated, dismantled, and
transported off-site. The tanks would either be scrapped if the
decontamination procedures meet tank closure requirements or be
landfilled in accordance with RCRA requirements if the tanks
cannot be completely decontaminated. The discharge line leading
from one of the underground vaults to th~ disposal pond would be
plugged to eliminate further discharge. The liquid PCP waste and
the tank decontamination liquids would be separated into oil and
water phases via an oil/water separator.
Access Restrictions: Access restrictions will be implemented
including fencing and/or warning signs to limit access to the
remaining underground vaults.
Extraction of LNAPL Dlume: Groundwater will be extracted from
directly beneath the LNAPL plume at a rate of 5 to 10 gallons per
minute. Groundwater extraction will lower the aquifer in the
vicinity of the extraction well, creating. a "cone of depression"
that will draw the LNAPL material towards the extraction
facilities. This will enhance the rate of LNAPL extraction to
100 gallons per day. It is estimated that the LNAPL plume
consists of approximately 75,000 to 100,000 gallons of product
material.
containerization and On-site storaae of Contaminants: oil and
sludge from the abandoned PCP process/storage tanks, extracted
oil from the LNAPL plume and also residual material from the
groundwater/wastewater treatment facilities will be containerized
in drums and transported to an on-site storage facility. The
storage facility will be enclosed to protect the drums from
weathering and also to restrict access to them. The storage
facility will have a capacity for 3000 drums (each 55 gallon
capacity). The storage facility will sit on a bermed concrete
pad to prevent leaks and spillage and will comply with all the
RCRA storage requirements contained in 40 CFR Part 268.
Treatment Facilities for Groundwater and Tank Wastewater/Decon-
tamination Water: Groundwater from the LNAPL contaminant plume
extraction process along with wastewater from the process/storage
tanks and tank decontamination procedures will be treated in an
on-site bioremediation wastewater treatment facility. The
bioremediation treatment system would generally consist of
bioreactor vessels, aeration equipment, storage tanks for treated
and untreated water, a filter press for solids removal and other
ancillary equipment. An optional carbon adsorption unit may also
be required to remove Dioxin/Furans if these constituents are not
affected or removed by the bioremediation process. The
bioremediation facilities will operate at a capacity of
approximately 10 gallons per minute for 10 hours per day.
Treatment process residuals shall be handled in accordance. with
all ARARs pertaining to the site.

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24
Discharqe of effluent water from the on-site wastewater
treatment facilitv to a Publicallv Owned Treatment Works (POTW):
The on-site bioremediation treatment facility will be discharging
to the Metropolitan Waste Control Commission (MWCC) which is the
local POTW. The discharge of effluent to the MWCC facility will
be in compliance with the pretreatment requirements of 40 CFR 403
as well as MWCC's pretreatment requirements.
The selected remedy may be modified to include a technology
currently being pilot tested at the Bell Lumber and Pole
facility. This technology is referred to as the contained
Recovery of Oily Wastes (CROW) process. This process is designed
to enhance the removal of the oily LNAPL material by injecting
hot water into the LNAPL material which makes the oil less
viscous and thus easier to remove. If t~e CROW process does
prove successful and effective at the Bell facility, it will be
included as part of the preferred alternative at that time. The
addition of the CROW process would appear to be readily adaptable
to the current preferred alternative and if included, would
result in minimal change to the design.
x.
STATUTORY DETERMINATIONS
u.s. EPA's primary responsibility at Superfund sites is to select
remedial actions that are protective of human health and the
environment. Section 121(d) (2) of CERCLA also requires that the
selected remedial action for the site comply with applicable or
relevant and appropriate environmental standards established
under state and Federal environmental laws with respect to
contaminants remaining on site at completion of the remedy unless
a waiver is granted. with respect to ongoing work at the site,
it is u.S. EPA's policy to comply with State and Federal
environmental laws. The selected remedy m~st also be cost-
effective and utilize permanent treatment technologies to the
maximum extent practicable. The statute also contains a
preference for remedies that include treatment as a principle
element. The following section discusses how the selected
interim action remedy for source removal and groundwater
remediation at the site meets these statutory requirements.

Protection of Human Health and the Environment
This interim remedial action while not comprehensively protecting
human health and the environment from all site contamination,
would be effective in removing the source materials which are the
objective of this interim action. The removal of source
materials from the abandoned PCP process/storage tanks and the
LNAPL plume will prevent their migration into soils and
groundwater beneath the site which could ultimately reach
residential wells. This interim remedial action will also
initiate restoration of the New Brighton Aquifer which could be

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25 ~
used as a potential drinking water source in the future.
Comprehensive protection of human health and the environment will
be achieved when the final site remedy for groundwater and soils
is determined.
Compliance with ARARs
The selected remedial action will meet all identified applicable
or relevant and appropriate Federal and more stringent state
requirements. ARARs for the selected remedy are listed below.

1.) RCRA Definition and Identification of Hazardous Waste (40 CFR
Part 261)
Minnesota Hazardous Waste Rule 7045.0020 -7045.0135 (4) (f)
(Minnesota Equivalent Regulation)
2.) RCRA Standards for Generators of Hazardous Waste (40. CFR Part
262) .
Minnesota Hazardous Waste Rule 7045.0211- 7045.0304 (Min-
nesota Equivalent Regulation)
3.) RCRA Standards for Owners and Operators of Hazardous Waste
Treatment, Storage, and Disposal Facilities (40 CFR Part 264)

Minnesota Hazardous Waste Rule 7045.0552- 7045.0642
(Minnesota Equivalent Regulation)
4.) RCRA Land Disposal Restrictions (40 CFR Part 268) (with
partic~lar reference to on-site storage prohibitions)

5.) Clean Water Act General Provisions (40 CFR Part 401)
6.) Clean Water Act General.Pretreatment Regulations (40 CFR Part
403)

7.) Clean Air Act National Ambient Air Standards (40 CFR Part 50)
Cost Effectiveness
U.s. EPA believes that the selected remedy is cost- effective
in removing sources of contamination from the site and also
initiating the restoration of groundwater, within a reasonable
period of time. Section 300.430(f) (ii) (D) of the NCP reqQires
U.S.EPA to evaluate cost- effectiveness by comparing all the
alternatives which meet the threshold criteria: protection of
human health and the environment; and compliance with ARARs,
against three additional balancing criteria: long term effect-
iveness and permanence; reduction of toxicity mobility or volume
through treatment; and short-term effectiveness. The selected

-------
26
remedy meets these criteria which are appropriate to an interim
remedial action and provides for overall effectiveness in
proportion to its cost. The estimated present worth cost for the
selected remedy is $3,542,543.

Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the Maximum
Extent Practicable
This remedial action is interim and as such is not intended to
utilize permanent solutions and alternative treatment (or
resource recovery) technologies to the maximum.extent
practicable. However~ it will foster a permanent solution in the
final remedy. The final site remedy shall fully address this
statutory criterion.
Preference for Treatment As a Principal Element

Because this interim action does not constitute the final remedy
for the site, the statutory preference for remedies that employ
treatment that reduces' toxicity, mobility, or volume as a
principal element is not a criterion. Nonetheless, while this
criterion will be addressed by the final site remedy, treatment
of. contaminants from the groundwater during removal of the LNAPL
plume will have the effect of reducing volume to a degree.

-------
Mac:Glllis & Gibbs I
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-------
MacGillis , Gibbs co./ Be~l Pole' Lumber site Co.
New Brighton, Minnesota
******************************************
Responsiveness Summary
Introduction
,The United states Environmental Protection Agency (U. S. EPA),
undertook a Remedial Investigation/Feasibility study (RI/FS)
to determine the nature and extent of contamination at the Mac-
Gillis & Gibbs Co. portion of the site and to develop appropriate
remedial actions for cleanup of the site. A Proposed Plan was
finalized by U.s. EPA, in consultation with the Minnesota Pollution
Control Agency, which recommended an alternative for an interim
remedial action at,the MacGillis & Gibbs Co. portion of the site.
The interim action alternative was to remove several source areas
on the site which are continuing to spread contamination into the
soils and groundwater beneath the site. Additional investigation
will be concurrently performed with this interim action in order to
determine a final site remedy.
A 30 day public comment period was conducted from August 30, 1991
to september 28, 1991 to allow interested citizens to comment on
U.s. EPA's Proposed Plan and RI/FS. On September 16, 1991, U.S.
EPA presented its Proposed Plan at a public meeting. The purpose of
this responsiveness summary is to document the comments received
during the public comment period, and the U.s. EPA's responses to
the comments. All of the comments summarized in this document were
considered prior to U.S.EPA's final decision embodied in the Record
of Decision for the MacGillis & Gibbs Co./Bell Pole & Lumber Site.
The respon~iveness summary is' divided into the following sections:
I. ResDonsi veness Summary Overview. This section briefly outlines
the proposed remedial alternatives as presented in the Proposed
Plan, including the recommended alternative.
II. Summary of Public Comments Received Durinq the Public Comment
and U.s. EPA ResDonses.
I.
Responsiveness Summary Overview
On August 30, 1991, U.S. EPA submitted the RI/FS and the Proposed
Plan for the MacGillis & Gibbs Co. portion of the site to the
, public for review and comment. The interim remedial action
alternatives described methods for removing two source areas of
contamination on the site. These two source areas are abandoned
Pentachlorophenol process/storage tanks and a LNAPL contaminant
plume floating on the water table beneath the site. U. S. EPA's
Proposed Plan described four interim remedial action alternatives
which will remediate these source areas and initiate restoration of
the aquifer. The proposed interim remedial action alternatives

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(IRAAs) included the following:
. IRAA 1 -
No Action
IRAA 2 - Waste removal from tanks; Cleaning of tanks; Disposal of
aboveground tanks; oil and water separation; LNAPL extraction;
containeriza.tion and on-site storage of generated wastes; Treatment
and disposal of wastewater; LNAPL plume monitoring.
IRAA 3 - Waste removal from tanks; Cleaning of tanks; Disposal of
aboveground tanks; oil and water separation; LNAPL extraction
through the use of groundwater depression; Containerization and on-
site storage of generated wastes; Treatment of wastewater/ground-
water using carbon adsorption units; Final disposal of effluent
from carbon adsorption treatment units at a Publically Owned
Treatment Works (POTW); LNAPL plume monitoring.
IRAA 4 - Waste removal from tanks; Cleaning of tanks; Disposal of
aboveground tanks; Oil and water separation; LNAPL extraction
through the use of groundwater depression; Containerization and
on-site storage of generated wastes; Treatment of wastewater/
groundwater using the bioremediation process; Final disposal of
effluent from the bioremediation process at a POTW; LNAPL plume
monitoring.
After careful consideration of the RI and FS, U.S. EPA recommended
IRAA 4 as the preferred alternative.
II. Summary of Comments Received During the Public Comment Period
and u.s. EPA's Response to Comments
No formal comments were received at the public meeting held
September 16, 1991. Two written comments were received during the
Proposed Plan comment period.
Comment Dennis and DeAnn Werner - Citizens
- We are concerned that the site will be cleaned up properly
because we have a well and use it for drinking, washing and
bathing. We also enjoy fishing in nearby lakes.
Response
- The use of water from residential .wells in the area is the
exposure pathway of greatest concern for the site. This interim
action will prevent the continued spread of contamination from
source areas into 'soils and groundwater beneath the site which
could ultimately spread to residential wells. The site will
continue to be studied while this interim action proceeds in order
to obtain the necessary information to determine the fina.l site
remedy for soils and groundwater. The final site remedy will
provide for complete protection of human health and the

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environment.
The additional site study will include further investigation of
area ecosystems such as streams, lakes and wetlands to identify any
potential threats to plant and animal species or to humans using
the ecosystems for recreational purposes. .
Comment Linda S. Nichols, Williams Pipe Line (WPL) Company
-Temporary storage of waste material on or near the pipeline
easement should not be allowed as this may prohibit access to
operate or maintain the pipeline as the case may be during the
period of time the interim remedial action is in progress.
Response
- Waste materials obtained from the abandoned PCP process/
storage tanks and the LNAPL plume will be placed in drums
immediately upon removal and will be stored in the drum storage
facility to be constructed on site. There should be no reason to
store waste materials on other portions of the site. This interim
remedial action will not involve the excavation of any soils which
would. need to be temporarily stored on-site. There will, however,
be removal of the abandoned aboveground tanks from the site. Should
these tanks require temporary on-site storage, they will not be
placed on the pipeline easement.
Comment
- WPL should be informed immediately of any findings which
potentially affect the health and safety of pipeline workers.
would enable WPL to properly equip our people if work needs
done on the pipeline in the area.
would
This
to be
Response
- U.S. EPA will provide WPL any information 'it obtains which would
be relevant to the protection of pipeline workers. WPL is
encouraged to consult with U.S.EPA or the MPCA at any time if there
are concerns regarding the health and safety of its employees
working in the site area. .
Comment
- WPL strongly encourages the remedial action administrator that
any contractors used to remediate the site have adequate general
liability coverage should damage occur to the pipeline. .
Response
- Contractors performing remedial action activities under the
Superfund program are required to have general liability insurance.

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Comment
- Before any digging, drilling or excavation takes place near the
M & G property line, please contact WPL.
ResDonse
- Any contractors performing work at the site will coordinate with
all utility companies in the area to avoid unnecessary damage to
the utilities.

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