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PB94-964145
EP AIRODIR05-941272
July 1995
Superfund
Record of Decision:
Waite Park Wells,
OUt, 2, and 3, MN
7/14/94 .
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Hazardous Waste Collection
Information Resource Center
US EPA Region 3
Philadelphia, PA 19107
EP A Report Collection
Information Resource Center
US EP A Region 3
Philadelphia, PA 19107
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DECLA.RATION FOR THE RECORD OF DEOSION
SITE NAME AND LOCATION
. Burlington Nonhern Car Shop Site
Waite Park, Steams County, Minnesota.
STATEMENT OF BASIS AND PURPOSE
. This decision document presents the selected remedial action for the Burlington Northern Car Shop'
site (Site) in Waite Park, Minnesota. The ,\~ision was chosen in accordance with Minnesota .
Environmental Response and Liability Act, Comprehensive Environmental Response,
Compensation, and Liability Act., as amended by the Superfund Amendments Reauthorization A~
and to the extent practicable, the National Contingency Plan. This decision is based on the
adminiStrative record file for this Site.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous subStances from the Site, ifnot addressed by
implementing the response action selected in this Record of Decision (ROD), may present an
imminent and substantial endangerment to public health, welfare, and the environment.
DESCRIPTION OF THE SELECTED REMEDY.
This ROD presents the selected remedial action for three operable units for the Site. The first
operable unit, OUl, addresses the remediation of former lagoons where liquid and solid wastes
were disposed of, resulting in soil contamination. The second operable unit, OU2, addresses the
remediation of contaminated sandblast sands. The selected remedy for both operable un,its will be
Stabilization/solidification and on-site containment.
The third operable Unit, OU3, addresses shallow ground water contamination. No response action
will be taken for OU3 at ~s time. However,.a ROD amendment may be necessary for OU3 in the
future, ifit is deteimined by ground water monitoring that ground water remediation is necessary..
Once the material in .the lagoons has been removed th~ threat of additional contaminants to the
ground water will be removed. This may'reduce the contaminant concent...~ci.ons in the ground
water so that ground water remediation may not be necessary. A ground water monitoring plan
will be implemented after source removal is complete. If the concentrations of contaminants
increase, remain the same, or do not meet regulatory levels specified in Table 2 to the ROD as a
result of the source removal, the Minnesota Pollution Control Agency (MPCA) staff will evaluate
whether ground water remediation is necessary. The MPCA staff will make its detennination on
ground water remediation within three years after removal ofd1e source has occurred.

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DE CLARA TION
The selected remedy is protective of human health and the enviromnent, complies with state and
federal requirements that are legally applicable or relevant and appropriate to the remedial action,
and is cost-effective. The remedy selection process considered pennanent soiutions and alternative
treatment technologies to the maximwn extent practicable. This remedy satisfies the statutor)~
preference for remedies that employ treatment which reduces toxicity, mobility, or volume as a
- principal element. .

Because this remedy allows on-site containment of the stabilized and solidified waste, contamiDated
soil, and sandblast sands, continued groUnd water monitoring and operation and maintenance will
be conducted in accordance with state and federal regulations. In addition, ground water
monitoring will be used in determining whether ground water remediation will be required after
removal of the source materials. A review of the ground water monitoring.Jata will be conducted
'within three years after the removal of the source to determine whether ground water remediation is
necessary. A review of the entire Site remedy will be conducted within five years after .
commencement of the remedial actions to ensure that the remedy continues to provide adequate

z:g:::du~mt

t-ChaTleS W. Williams. .
Commissioner
Minnesota Pollution Control Agency
. ~LII'I; /17 ~-L

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RECORD OF DECISION
DECISION SUMMARY
BURLINGTON NORTHERN CAR SHOP SITE
WAITE PARK, MINNESOTA
SITE NAME. LOCATION. AND DESCRIPTION
The Burlington Northern Car Shop site (Site) is located in Waite Park, Steains County, Minnesota.
The Site is rectangular in shape and includes approximately 200 acres of land in Section 8 and 9,
T124N, R28W, of the SW/4 St. Cloud .15' Quadrangle. The location of the Site is shown in Figure 1.

. The Site is located m the city of Waite Park (City) and the city of St. Cloud .is. djacent to the northern .
boundary of the Site. The Site is bounded on the north by the Electric Machinery (EM) site, an .
industrial park, and a trailer park; to the south by Third Street, then a residential neighborhood; to the
east by residential homes and a commercial park; and to the west by the Sauk River. Tenth Avenue'
runs north-south through the Site and separates AIeaA from Areas B through H. The City municipal
wells are located on the northeastern edge of the Site. The features on the Site and in the vicinity of the
Site are shown in Figure 2.
The Site property and its surroundings are fairly flat. Most of the Site is vegetated. Large pieces of
concrete, old rait yard parts, abandoned rail beds, and some heavy equipment are present on portions of
the Site. Area A is partially wooded and public recreation facilities are located in the southern side of
this area. Other structures noted on the Site are 7,000 cubic yards of stockpiled, fenced, and covered
contaminated sandblast sand located at the.east end of the Site inArea H. Four fonner waste Jagoons,
now covered with sandblast sand, debris and soil, containing approximately 17,500 cubic yards of .
contaminated material are present in Areas A and C.
. The Sauk River forms the west property boundary and joins the Mississippi River approximately three
miles to the northeast of the Site. The Mississippi River flows south through St. Cloud, Minnesota.
Shallow ground water typically flows in the same direction as the surface drainage; therefore, the
general ground water flow direction at the Site is in a northeasterly direction.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
In the early 1880's, the Gr~t Northern Railroad purchased the Site to construct wooden box cars. A
box car construction and repair shop was built in 1894 followed by a paint shop in 1896. Throughout
the years, other types of railroad equipment were built and/or repaired on the Site. A steel shop was
built in 1955 and new steel box cars were constructed on the Site until 1963. From 1963 to 1982 the
steel shop was used to repair freight equipment. From 1950 to 1970, approximately 10,000 gallons of
waste oil, paint, waste, and solvents were allegedly disposed of at the Site. In August of 1986, the
Burlington Northern Railroad Company (BN) deeded a majority of the land and buildings to the City.
Figure 2 shows the boundaries of the BN and City property. The City bas sold some of the property
and it is currently being used for industrial and commercial pUIpOSes. .
In order to fully explain the history of the Minnesota Pollution Control Agency (MPCA) actions on the
Site, it is necessary to discuss the history of the Waite Park Ground Water Contamination site. The
Site, as well as the EM site, is part of the Waite Park Ground Water Contamination site. The Waite
Park Ground Water Contamination site is listed on the U.S. Environmental Protection Agency's (EPA)
National Priorities List (NPL) with a Hazard Ranking Score (HRS) of32. Although the Site is
considered a part of the Waite Park Ground Water Contamination site, it is listed separately on the
state of Minnesota's Pennanent List of Priorities (PLP) with an HRS score of38.

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In December 1984, volatile organic compounds (VOCs) were found in the City's municipal water
supply wells. On January 28, 1985, the Minnesota Department of Health (MDH) informed the MPC.!\
staff that the City was being advised to discontinue use of its water supply as soon as possible due to
11I.1'lcceptable levels of hazardous substanc::es in its drinking water. Consequently on January 28, 1985,
the MPCA Commissioner determined that an emergency existed with regard to the Waite Park water
supply. The MPCA Commissioner issued a Determination of Emergency to allow use of the
Minnesota Environmental Response and Compensation Fund to take necessary actions to provide the
City \\;th a safe drinking water supply and to undertake an investigation and Feasibility Study (FS) to
determine.the most appropriate long-tenn drinking water alternative. InitiaJ provisions were mad~ for a
temporary supply of safe drinking water from nearby S1. Cloud businesses, and on February .4,1985, .
an emergency hookup between Waite Park and St: Cloud water systems was made to supply the '- ity .
with safe water until the most appropriate long-tenn water supply system, selected through the conduct
of an FS could be installed.
On October 22, 1985, after completion of an initial investigation and a Potential Responsible Party
Search, the MPCA issued a Request for Response Action (RFRA) to BN, citing BNas a source of
contamination of the City's water wells. On March 25 and September 26, 1986, the MPCA also
issued RFRAs to Brown Boveri & Compariy Limited, Cooper Industries, Inc., Dresser Industries, Inc.,
and Electric Machine~' Manufacturing (Responsible Parties) for the adjacent EM site, currently MEI
International. The RFRAs also cited the EM site as a source of contamination of the City wells.
The RFRAs requested both BN and EM Responsible Parties to conduct a Remedial
InvestigationIFeasibility Study (RIfFS) and implement a Remedial DesignlResponse Action (RDIRA)
Plan for a long-term water supply treatment system for the City. The RFRAs also requeSted BN and
EM Responsible Parties to conduct an R.IlFS and implement an RDIRA fo address the contamination at
their respective sites..
In September 1986, the MPCA staff approved the installation of an air stripping unit that would
remove the contaminants from the City water supply. BN and EM Responsible Parties jointly
implemented a water treatment system and the City wells were placed back into service in February
1988. This is the remedy that is currently in place, providing an acceptable long-tenn water supply to
the City. The City, MDH, and the MPCA staff regularly monitor the water ftom the wells before and
after treatment to ensure that the. treatment s}.stem is functioning properiy. . .
. .
The EM site investigation has been completed and a Record of Decision (ROD), was issued on
January 5, 1989. The remedy implemented at the EM site included the treatment of the shallow and
deep aquifers by installing pump out wells, packed.tower aeration treatment, and discharge of the
treated water to the Sauk River. The MPCA staff will be conducting a Comprehensive Environmental
Response, Compensation and Liability Act (CERCLA) five-year review in 1995 to determine if the
implemented remedy is adequately addressing the contamination at the EM site. This five-year review
will also include an evaluation of the Waite Park Water Supply treatment system.
Under the requirements of the RFRA, BN investigated and identified areas of contamination at the Site.
Appendix I summarizes the reports submitted for the major investigative activities at the Site which are
part of the Administrative Record. The investigations identified several areas that required remedial
action. To remain consistent with these reports the Site is divided into eight parcels (Area A

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through H) as sh~wn in Figure 2. The following summarizes general areas of concern along v.ith areas
of concern associated with Areas A through H. Figure 3 presents the area of concern to be addressed
by this ROD.
General.
Sandblast Sands: Paint containing high concentrations of lead was striPPeQ from railroad cars at a
sandblasting station located in Area H. Waste sandblast sand was spread throughout the Site and used
as fill in holes and lagoons. Several investigations have' been conducted to characterize and detennine
the eXtent of the sandblast sands. "In 1991, BN removed one pile of sandblast sands present west of
: 10th A venue and the City used the sand for a road bed underneath pavement. Although this pile did
not contain levels of lead above the allowable' levels in residential and playground areas, ~e pile was
removed because of evidence of children playing in the pile aDd the possible exposure to lead. In 1992,
the MDH began updating its public health assessment for the Waite Park Water Supply site, focusing
on the BN portion. During the assessment, the MDH discovered that children frequently played in
areas where lead contaminated sandblast sand was present. The MDH subsequently advised the
MPCA that an imminent health hazard existed as a result of the contaminated sandblast sands at the
Site. The MPCA notified BN of the imminent health hazard, and BN agreed to conduct an interim
response action to remove the health hazard. In addition, the Agency for Toxic Substances and
Disease Registry (A TSDR) funded free blood lead screening for the community which was conducted
with MDH and Stearns County Community Health Services (ATSDR 1992). The interim response
action consisted ofBN undertaking a major effon in consolidation of the sandblast Sands (BEl 1992).
The sandblast sarid consolidation effort began in the Spring of 1992 and was completed by the Summer
of 1992. Sandblast sands, identified in all of the areas of the Site, were removed and coll$olidated on
. the east end of the Site in Area H. Approximately 7,000 cubic yards of sandblast sand were' . .
consolidated. The consolidated piles were covered with plastic and a fenCe with warning signs was
placed around the piles. Sandplast sands located above the buried lagoons in Area A were not
removed. Instead a fence was placed around the exposed sands and warning signs were posted. These
sands will be removed as part of the lagoon remediation. In addition, the area of sandblast sands south
and west of Area A lagoons were overlooked during the consolidation effort. Test trenches Al through
A4 (ERT 1988) indicate the depth of these sandblast sands as well as the presence of crushed barrels
containing fibrous material that were disposed of along with the sands. This area will also be included
in the remediation of the sandblast Sands. .
. .
Du~g the course of the investigations, sandblast sands were sampled and analyzed.' The results of the
analysis show that the sandblast sands contain elevated concentrations of lead, arsenic, and cadmium. .
The maximum concentrations detected were 17,000 mglkg lead, 18 mglkg arsenic, and 2.8 mglkg
cadmium. Table 1 shows the contaminants of concern (COCs) in the sandblast sands, the minimum
and maximum concentrations detected as well as the remediation levels to be used for sandblast sand
remediation. In addition, several samples analyzed for Toxicity Characteristic Leaching Procedure
(TCLP) analysis show that the concentration oflead is above levels considered hazardous. Soil
samples collected below ~e sandblast sands have shown that the metals have not leached out of the
sandblast sands into the surrounding soils. In addition, there is no evidence to suggest that ground
water has been impacted by the contaminated sandblast sands.
Petroleum Contaminated Soils: In March 1989, BN removed 13 underground and above ground
storage tanks and 11 tanks from the basement of a building (JMA 1989). Contaminated soils
encountered during the tank removal were excavated and stockpiled on concrete and covered with
plastic in preparation for future treatment. Currently, all areas of the Site that are associated with soil
and ground water contamination from former underground and above ground storage tanks are being

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addressed under the MPCA's Tanks and Spills Section. In 1993, BN remediated the petroleum
contaminated soils, approximately 15,000 cubic yards, by thermaJ treatment in accordance with the
MPCA Tanks and Spills Section. According to the Tanks and Spills Section, aU petroleum
contaminated soil has been remediated; however, ground water has been contaminated in the vicinity of
several of the fonner underground storage tanks. In addition, petroleum product floating on the ground
wat-er was detected in the area around aboveground storage tank OS8. The Tanks and Spills Section
has required BN to conduct ground water monitoring to monitor-the- grour.q Water quality and for free
product to determine if ground water remedial actions are necessary.
Ground Water: . Shallow ground .water cOntamination has beel} noted in'several of the areas listed .
.. below as well as the underground storage tank areas. In several areas pf the Site, samples collected
from monitoring wells indicate the presence of cOntamination. Some of the areas are not assOCiated
with source areas; however,. continued ground water monitoring has indicated a trend in decreasing
contaminant concentration. In most cases, the contarn4tant concentrations have decreased to below
health based limits. The areas that have ground water contaminant concentrations at levels above.
. health based limits are mentioned below. ...
. In the deep aquifer, contamination has historically been limited to low concentrations ofVOCs,with
the highest levels recorded at monitoring well MPCA3d. This well is located between two City
pumpout wells, and it is downgradient from the much larger VOC contamination problem at EM (IOO
times greater than at BN). Further, levels of total VOCs have declined steadily since monitoring began
in 1985, to the point where most wells show nondetection for VOCs.
Miscellaneous: Large pieces of concrete, old railyard parts, railroad ties, old tank piping, abandoned
rail beds, and some heavy equipment are present in portions of the Site providing physical hazards. . .
The MPCA Solid Waste Section has indicated that storage ofwaste matenal and railroad ties is not in
compliance with ~. Rules part 7035.2855 Solid Waste Storage Standards. BN needs to prop~rly
. disposed of this material. .
Area A and C.
Laeoons: Historical aerial photographs show the presence of three lagoons west of 10th Avenue, in
Area A, and one lagoon east of 1 Oth Avenue, just north of 3rd Street, in Area C. An ~imated 17,500
cubic yards of contaminated .wastes are associated with the lagoons. The lagoons were used for the
disposal ofliquid waste (lubricating oils and greases, oils containing polychlorinated biphenols,
cooking oils, solvents, and paints). Area C lagoon was also used for the disposal of calcium hydroxide,
a lime sludge produced as a byproduct of acetylene production. Minor amounts of calcium hydroxide
are also present in Area A lagoons. The lagoons were filled with soil, sandblast sands, metal scrap,
slag, and hardened clumps of paint. In Area A lagoons, soil and sands were mounded on top of the
lagoon. A tar like liquid can be seen seeping ftom the mound of soil. In 1989, BN sampled the tar
seep and analysis indicated the presence oflead at 1,400 ppm and polychlorinated biphenols (PCBs) at
120 ppm (Wadsworth 1989). In November 1989, BN placed a fence around the tar seep area. In
1992, the fence was extended to include the exposed sandblast sands and warning signs were placed on
the fence. The analytical results from samples collected from the waste in the lagoons and the soil
contaminated by the lagoon waste detected elevated concentrations of PCBs, arsenic, c:admiwn, and
lead. The ma.ximum concentrations detected were 570 mg/kg PCBs, 42 mg/kg arsenic, 4.9 mglkg
cadmium, and 120,000 mglkg lead. Although samples were not analyzed for semi-volatile organic
compounds (SVOCs), SVOCs exist in the ground water and are expected robe in the waste and soils
as well. Table 1 shows the COCs in the lagoons, the minimum and maximum concentrations detected,
as well as the remediation levels to be used for remediation of the lagoons. .

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Shallow ground water in the vicinity of the lagoons has been contaminated above health based levels
with PCBs, Volatile Organic Compounds (VOCs), SVOCs, and metals. An oil containing high levels
of PCBs has also been detected on the ground water within the lagoon areas. Table 2 shows the COCs
in the 'ground \\'ater and the minimum and maximum concentrations detected. Available data. from
.ground water monitoring indicate that contaminants in the groun~ ~ter in Area A have not reached the
Sauk River. The ground \\'ater monitoring network in Area C is not adequa.te for determining if ground
\\'ater has migrated under Tenth Avenue. Ground water monitoring wells to the north of Area C
lagoon, in Area. B, have not detected contaminant migration from the Area. C lagoon.
Sauk River Sediment: The sediments in the Sauk River were sampled fot PCBs .upgradient,.a.dja.cent .
to, and downgradient of the Site. The results of the analysis have iD.dicated the presence of PCB .
contamination at all sampling locations at roughly the same con'centrations, indicating contamination of
the sediment from possible multiple sources. Due to the lack of supporting mfonnationconnecting
PCB contamination to BN, the MPCA staff did not pursue this investigarlon further and will not
require BN to remediate the river sediments. .
General: Former car shop employees described operations in the southwest end of Area. A where
obsolete railroad cars were stripped and burned and where paint waste was buried. Some trenching,
soil borings, and ground \\'ater sampling have been done in this area. Although the MPCA has received
tips about buried waste in this area, very little has been found in the investigations or sampling other
than the lagoons and buried sandblast sands south west of the lagoons. Some crushed barrels (both
empty and oozing tar like substance) and sandblast sands were encountered during trenching (ERT
1988) in the vicinity of the lagoons. BN shall remove all barrels' and sandblast sands associated with. .
the lagoons as part of their remediation efforts. . . ..' .
Area B.
Buried Tank Car: The MPCA received tips about a buried tank car in this area. Extensive
investigations, including electromagnetic induction sounding and trenching, were conducted to attempt
to locate the buried tank car (ERT 1986, 1988). However, the buried tank car was not found in the
investigations or sampling. Therefore, the MPCA staff did not pursue further investigation of this
area.. .
Sulfur: Sulfur has been found on the ground surface ~ of 10th Avenue on the north side of the Site.
Although the Sulfur is not a health hazard' in the solid state, it is a fire hazard and the fumes from
burning sulfur are a health bazard. BN shall either remove the sulfur or place clean soil over the sulfur
to reduce the potential fire bazard. .
Ground Water: Shallow ground water contamination above health based levels has been deteCted in
monitoring well MPCA 14S. The contaminants in this well do not have a waste source associated with
them. As indicated above, Table 2 shows the COCs in the ground water and the minimum and
maximum concentrations detected. BN shall continue ground water monitoring in this area.
Area D.
Paint Buildine: Spray painting, stenciling, and reclamations operations were performed in this area..
The 1986 RI Repon (ERT 1986) reported elevated levels ofmeta.ls in samples collected from the dirt
floor of the paint buildiIig. On May 15, 1992, the current owner of the paint building, Waite Park
Manufacturing Inc. (WPMI), collected samples and analyzed them for TCLP analysis. The results

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indicated the dirt floor contained hazardous levels of lead. On June 2, 1993, the MPCA staff collected
and analyzed soil, dust, and paint samples for lead. The results of the analysis showed that lead is
above acceptable human health risk limits. On June 24, 1993, the Occupational Safety and Health
Administration (OSHA) conducted an inspection of the paint building and collected soil, dust, and
ponded surface water samples for lead and cadmium analysis. The analysis showed that lead and
cadmium are above acceptable human health risk levels. The contaminant concentrations detected are
. shown in a footnote to the sandblast sands in Table I. On September 3, 1993, OSHA iss.ued a citation
to WPM! for violations of the Minnesota OSHA standards. WPM! performed abatement as required
by OSHA by October 4, 1993. The abatement consisted of securing access to the paint building,
posting si~ outSide the paint building, and infoiming and training employees. The abatement cli.d 1)ot ..
include the removal of the contaminated material in the building and contaminated dirt from the floor. of. .
. the building. WPM! ha:s agreed to clean and'remove the contaminated materials ~ the 'paint building' .
so. BN can remediate the dirt floor. BN shall include the contaminated dirt from the floor of the paint
building vo.ith the remediation of the consolidated sandblast sands.
Area E and F and G.
The concerns in this area are associated with petroleum contamination. As indicated above, petroleum
contamination is being addressed under the MPCA's Tanks and Spills program.
Area H.
Sandblastin2 Station: As indicated above, a Sandblasting station was located in this area.
Approximately 7,000 cubic yards of contaminated sandblast sands are consolidated in this area.
. .
. . .
Paint Waste: The MPCA ~as received tips that paint waste was buried ill this area in the 1960's. OnlY.
a small number of paint containers were found in one of 67 test trenches dug in the suspected burial
area. Due to the lack of positive results and supporting infonnatiori, the MPCA staff did not pursue
this investigation further. .
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The RIfFS and the Proposed Plan for the Site were released to the public for comment on May 3, 1994.
These two documents were made available to the public in the administrative record at the MPCA,
Saint Paul, Minnesota, office, Waite Park Community Library aild an infonnation repository
maintained at the EP A Docket Room in Region V. The notice of availability for these two documents
was published in the St. Cloud Times on May 2, 1994. A public comment period on the document was .
held from May 3, 1994, to June 2, 1994. In addition, a public meeting was held at McKinley .
Elementary School in Waite Park on May 18, 1994. Approximately 60 people attended the public
meeting. At this meeting representatives from the MPCA staffpresented an overview of the site
history, answered questions about problems at the site, and discussed the remedial alternatives under
. consideration. A response to the comments received during the public comment period is included in
the Responsiveness Summary, which is part of this ROD.

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SCOPE AND ROLE OF OPERABLE UNIT
. The Site History and Enforcement Activities section presented areas of contamination detected in the
Site investigations. This section lists the areas that have been identified as areas of concern to be
addressed as pan of the remedial actions for the Site. The following are the operable units (OU) for
this Site:
. -
. OUl: Lagoons (approximately 17,500 cubic yards of contaminated waste)
OU2: Sandblast Sand (includes 7,000 cubic yards of consolidated waste, the area south and ~
of Area A lagoons and the dirt floor of the paint building)
OU3: Shallow GroUnd Water
-
This ROD presents the selected remedial action for the three OUs. The contaminants present in the
first two OUs pose the principal threat ~ human health and the environment because of the risks from
. possible ingestion and dermal contact 'with the soils, sandblast sands and oily wastes. Also, there is.
the continued threat of contaminant migration from the wastes into the underlying ground water, which
is a source of drinking water for the City. The purpose of this response action is to prevent current or
future exposure to the contaminated soils and to reduce the contaminant migration into the ground
water. The soil remediation levels to be used in this response action are presented in Table 1.
The contaminants present in the third OU, shallow ground water, pose the principal threat to human
health and the environment because of the risks from possible ingestion of the contaminated ground
water. Ground water contaminants of concern are shown on Table 2. The removal of the source
material in the lagoons will reduce the impact of contaminants to the ground water so that ground water
remediation may not be necessary. Therefore, remediation levels have not been set for the ground
water at this time and ground water remediation will not be addressed in'this ROD. However, BN shall
implement an MPCA staff approved ground water monitoring plan after source removal has been
completed. Ground water sampleS shall be collected and analyzed in accOrdance with Table 2. If the
concentrations of contaminants increase, remain the same, or do not meet regulatory levels as specified
in Table 2 as a result of the removal, the MPCA staffwill evaluate whether ground water remediation
is necessary. The MPCA staff will make their detennination on ground water remediation within three
years after source removal is complete. If ground water remediation is determined to be necessary, the .
MPCA staff will prepare an addendum to this ROD describing the ground water remediation to. be
implemented." . .' .
SUMMARY OF SITE CHARACTERISTICS
This section summarizes the geology and hydrology of the Site as presented in the January 1994 Draft
FS (ENRS 1994a) as modified by the MPCA staff and accepted as a Final FS. Please refer to this .
repon for a detailed overview of the Site geology and hydrology.
The Site is underlain by Precambrian granite covered with a layer of glacial outwash and till that
ranges in thickness from zero to more than 100 feet. The granite outcrops on the west end of the
property. The overlying unconsolidated glacial deposits are interbedded with alluvium deposited by the
Sauk River, bordering the west side of the propeny. The glacial deposits consist offluvially deposited
sand and gravel and fine-grained till deposited in a lacustrian environment.
Depending upon the location on the Site, there are up to five different layers of sand and gravel and
fine-grained till consisting of silts and clays. Where five layers are found, the layers usually consist of
three sand units interbedded with two till units. In general, across both the Site and adjacent EM site, a

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single till unit separates an upper sand and gravel unit (Zone A) n-om a lower sand and gravel unit
(Zone B). Zones A and B sand and gravel units are v.'ater bearing units. The glacial till fonns the base
of Zone A and generally acts as an aquitard, which limits 'flow into the underlying Zone B and acts as a
barrier against the movement of contaminants between the upper and lower aquifers.
. "
Zone A is continuous across the Site and interfingers with the Sauk River alluvium on the west side of
the propert)'. Zone A forms the near-surface formation within Which any ~e or spilled material
n-om the surface or an underground storage tank will initially accumulate. Zone B is more complex
than Zone A in that it interfingers with the glacial till unit, forming several interconnected tongues, and
is absent in somCf locations. Zone B is an important aquifer in the area because it serves as a wate~ .
supply source for the City and for many surrounding &cilities. .
Investigative data completed to date reveals two 1000000DS where the glacial till is not present. In one
location, on the east side of the EM site, there is a "hole" through the glacial till where Zone A and
Zone B are in direct contact aIIowing the aquifers to be hydraulically cOnnected. The second location is
in the south central portion of the Site. In this area data suggest that although there is no glacial till
unit, Zone A sands lie directly on top of the granite bedrock and there is no connection between Zones
A and.B aquifers. Just south of the "hole" in the glacial till is an area where the surface of the glacial
tiII is above the water table in Zone A. 1bis mound impedes the northv.'aTd flow of ground water in
Zone A. This geology is illustrated in plan view and cross section on Figures 4 and 5.
The pumping of the City municipal weBs has an immediate effect on Zone B wells. In addition, the
pumping of the City municipal weIIs indirectly affects ground water flow in Zone A due to the "hole" in
the glacial till. Ground water flow direction in the Zone A is generally north, from the Site, towards the ,
EM site and the "hole" in the till' (Figure 6). Ground water flow in the Zone B is nonheast across the' ,
Site and is influenced by the municipal weII pumping (Figure 7). .
The upper sand unit soils have been contaminated as a result of the various wastes disposed ofin the
lagoons. Oily contamination n-om the lagoons has migrated into the surrounding soils due to its
semJviscous state and by transportation via ground water migration. Analysis of waste and soil
samples collected detected PCBs and metals above remediation goals (Tabl~ I). Although SVOC soil
contamination has not been documented due to lack of analysis, SVOCs are expected to be present in
the soils because they have been detected inground.water samples collected in the vicinity of the
lagoons. . Sandblast sand and soil analysis indicate that Contaminants n-om the sandblast sands have 110t
. migrated into the surtounding soils or the 'groUnd water. The analysis of sandblast sands indicate the
presence of metals above remediation goals (Table I).
Measurements taken in the Zone A ground water monitoring wells detected free product in the lagool1
areas and analysis of ground water samples detected PCBs, VOCs, SVOCs, and metals above levels of
concern (Table 2). The extent of ground water contamination appears to be localized to the lagoon
areas. This is most likely due to relatively shallow gradient in the lagoon areas (Figure S) and the
bydrophobic characteristics of PCBs, P AHs and metals. Therefore, it appears that contaminated
ground water has not significantly migrated away from the lagoons. However, the ground water
monitoring network is not complete and will have to be upgraded as part of the ground water
monitoring plan. The localized nature of contamination from the Site in the Zone A aquifer has not
affected the City municipal well's ground water quality at this time. Trace amounts ofVOC
contamination have been detected in the Zone B aquifer. The concentration ofVOCs has been
decreasing over the past several years. However, if the VOCs are drawn into the municipal water wells
they will be removed by the water treatment plant's air stripping unit.

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SUMMARY 'OF SITE RISKS
In 1988, MDH conducted a Health Assessment (MDH 1988) of the Waite Park Ground Water
Contamination site. Because data for the BN portion of the Waite Park Ground Water Contamination
site were largely unavailable at that time, the assessment focused on the EM portion of the site, for
which the investigation was nearly complete. The assessment i4ent#Jed the Site (as indicated
previously, "Site" refers to the BN portion of the Waite Park Ground Wate.r Contamination site) as a
potential public health hazard. In September 1991, when additional data for the Site became available,
MDH began a new health Assessment for the Site.
Ip November 1991, representatives from the A TSDR Lead Initiative program visited the Site. Their,
conclusions, presented in the ATSDR Lead Iniili:.tive Sumrniry Report, September 24, 1992, (ATSDR,
1992) were that the Site may pose a potential health concern and recommended additional sampling and
follow-up investigation to evaluate the potential for exposure to Site-related contaminants.
On March 25, 1992, MDH staffheld an availability session and public meeting. MDH and MPCA
staff distributed fact sheets to the citizens attending the meeting. Due to concerns about the public and
,children using some areas of the Site, where surficial deposits of lead contaminated sandblast sands
were present exceeding soil guidelines established for residential or playground soils, the MDH
informed the MPCA that it considered the Site an imminent health hazard. In response to this
characterization by MDH, the MPCA requested BN to undertake emergency removal actions of lead
contaminated sandblast sands. With the help of the Steams County Community Heaith Services and
staff from the City of St. Cloud, the MDH also infonned the communities near the Site of the need to
, stay off the Site until the emergency actions have been completed,. '
. ,
MDH, in cooperation v.ith ATSDR and the Steams County Community Health Services, arranged for
free blood-lead screening for re,sidents living near the Site. This was not intended to be a study of
community lead exposure or a mechanism for relating blood-lead or health concerns to any particular
source of lead. Instead, the free screening was offered as a means to ensure that people had an
opportunity to be screened for lead, because a source of high lead concentrations was known in the
area, and that the cost of being tested elsewhere did not prevent them from following advice for routine
screening. Because the individuals screened through this effort were self-selected by their own interest
and motivation, the results of the screening program merely reflect the blood-lead status of the , , '
individuals' tested at the time they were screened. Appendix II presents the statistical rC$ults of the
blood,Iead screening. In summary, of the 108 persons screened, there were no elevated (>10 ug/dl)
blood lead levels detected (MDH 1993).
On December 1, 1993, the.MDH, in cooperation with ATSDR, completed a Public Health Assessment
(MDH 1993) for the Waite Park Ground Water Contamination site that focused on the Site. The
Assessment concluded that "Because available information indicates: I) in the past, people ,may have
been exposed to contaminants in surface soil; 2) physical hazards on the property pose a risk of
accidental injury; 3) there are data gaps concerning contaminants which may have reached the Sauk
River and can be taken up by fish and then eaten by humans; 4) there are data gaps regarding the air
pathway; and 5) during past operations at the Site, workers were likely exposed to contaminated media,
MDH considers the Site a public health hazard."

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10
The Assessment also provided a summary of relevant exposure routes and toxicity of chemicals
determined to be of potential public health concern. The chemicals evaluated were l~ arsenic,
VOCs, petroleum products, polynuclear aromatic hydr~bons (PAHs, a subset of SVOCs), and
PCBs. The following is a brief summar)':
Lead. Lead i~ the major contaminant in the sandblast sands-. The relevant exposure route is dennal
contact and ingestion. The end points of greatest concern nom hWl13n health are hemoglobin synthesis
and erythropoiesis, neurobehavioral deficits (central and peripheral nervous system effects on behavior,
inteIlig~nce, and locomotion), cardiovascular toxicity (hypertension in adult males), and vitamin D
metabolism and growth. Neurological symptoms have been observed in adult workers exposed to lead. "
.,In children, subtle neurobehavioral impairment (decreased learning abiljty and memory, IQ de~c:it,. .
elevated hearing threshold) and growth retardation are associated ".jth blood lead levels' below those
causing overt signs of lead poisoning. Lead has not been shown to cause cancer in humans, but is
considered a probable human carcinogen based on animal studies.
Arsenic. Inorganic, water soluble arsenic compounds are readily absorbed (77 to 99 percent of
administered dose) folIo\\1ng ingestion. Distribution is to the liver, kidney, lung, spleen, skin, and hair.
, The primary effects produced by ingestion are nausea, vomiting, and diarrhea. Ingestion of high levels
of arsenic have been reported to cause anemia, peripheral and centtaI neuropathy, and damage to celIs
or function of the kidney, liver, and heart. Arsenic compounds can also irritate eyes, mucous,
membranes, and skin via inhalation and dennal contact. The EP A has designated arsenic a knOVl.'l1
human carcinogen via the oral route.
VOCs. Some of the VOCs found in area ground water or in past samples of the City municipal wells
, are considered to be'carcinogenic or possibly carcinogenic. Trichloroeth~e and tetrachloroethane are
not classified in terms of carcinogenic potential.
Petroleum Products. Inhalation and skin contact are the primar)' routes of exposure for petroleum
products. Petroleum constituents with high volatility and low viscosity penetrate the lung$ most
deeply. SmaIl amounts of inhaled product can lead to respiratory problems. In contrast, large
quantities must be swallowed to produce symptoms. A range of symptoms is possible, including
flushing of face, mental confusion, slurred speech, severe pulmonary toxicity, convulsions, coma, and
respiratory or cardiac .arrest. ' ,
P AHs. P AHs a,re, a group of chemicals formed by combustion of coal, oil and gas, organic
compounds, and garbage. Other common sources of P AHs include petroleum products (i.e. oils,
creosote, gasoline, and tars), automobile exhaust, cigarette smoke, and grilled or charred foods. P AHs
also result from natural sources and human exposure is common. P AHs can be absorbed weD by skin
lungs, and the gastrointestinal tract. Inhalation of particulates followed by absorption of bound P AHs
is the principal route of human exposure. Inhalation of high levels ofPAHs can produce h~daches,
nausea, and vomiting. Many P AHs are carcinogenic to animals and humans, including some of those
detected in ground water samples collected from the Site.
PCBs. PCBs are a large group of related compounds. Because PCBs are persistent and pervasive, the
general population is regularly exposed to very low-levels. Ingested PCBs are well absorbed (>90
percent) in the gastrointestinal system. Dermal absorption can occur nom skin contact with PCB
vapor, or dust, or surfaces to which PCBs are bound. Because PCBs bioaccwnulate in the body, the
level and duration of exposure are both imponant. Acute effects are typically mild, the most common
symptoms being irritation of the skin (chloracne) and eyes, and nausea and vomiting. At high doses,
liver damage, skin irritation, productive and developmental interference, immunosuppression, stomach

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11
and thyroid alterations, and cancer have been observe4. Based on evidence from animal studies, the
EP A considers PCBs probable human carcinogens.
The MPCA and EP A staff agreed to aUow BN to develop a draft Baseline Risk Assessment for the
Site. The MPCA and EP A staff determined that BN's Risk Assessment dId not meet the requirements
. of the EPA Risk Assessment Guidance for Superfund (EPA 1989). Therefore, with EPA approval, the
MPCA staff developed remediation goals and presented them to-BN in a S~ptember 10, 1993, letter.
The remediation goals were developed based on available site data and the EP A Risk Assessment
Guidance for Superfund (EPA 1989). The supporting documentation for developing the remediation
goals is included in Appendix m. The MPCA staffhas further refined the remediation goals to reflect -.
.. Site characteristics and has developed the soil remediation levels presented in Table 1. Alth~ugh there
are currently human health and ecological risks associated with groundwmer, these J .sks are expected
to decrease once source removal has occurred. Therefore, ground water remediation levels will not be
developed unless ground water monitoring after source removal shows that ground water remediation is
necessary. The ground water monitoring shal1 be conducted in accordance with Table 2. If ground
water remediation is necessary, an amendment to this ROD will present ground water remediation
levels. The foUowing sections summarize the MPCA staffprocess used to develop the human health
and ecological risk based soil remediation levels for the Site:
Human Health-Risks. The ground water and soil at the Site are contaminated with VOCs, SVOCs,
PCBs, and metals. Table I and 2 identify COCs in each of these categories along with the minimum
and maximum concentrations detected. Human health-based soil reference values (acceptable
contaminant concentrations to remain on-site) were calculated for the soil COCs based on direct
contact (i.e., incidental ingestion and dennal contact) to detennine the acceptable risk levels to h~ .
health in current and future land use sCenarios. The current and future 1an~ use scenarios were initially
evaluated for unrestricted future land use, current and future recreational land use, and current and
future commerciallindustrialland use. The final evaluations as presented in Appendix ill are based on
unrestricted future land use and current and future limited land use (commerciaVindustrialland use).
Health-based soil reference values were calculated for both of these scenarios.
For unrestricted future land use, a residential exposure scenario was utilized as a surrogate land use
with the assumption that if it is safe for an individual to live on the Site, it will be safe for unrestricted
human land use. . . .
A 'worker and a trespasser were evaluated under the ~urrent and future commerciaUindustrialland use
scenario. A commercial office worker would represent a low exposure scenario where as an industrial
worker with outdoor activities would represent a higher exposure scenario. Therefore, the more
conservative approach, an industrial worker with outdoor activities, was used in calculating the health-
based soil reference values.
The exposure frequencieS and durations for the respective scenarios are presented in Appendix m. The
cancer potency &ctors (CPFs) and the reference doses (RIDs) for the contaminants of concern that
have carcinogenic and noncarcinogenic effects were obtained ftom the October 1993 Integrated Risk
Information System (IRIS) and 1993 Health Effects Assessment Summary Tables (HEAST) data
bases. Under a fixed exposure scenario and specific target risk ofIE-5, soil reference values were
calculated. The calculated soil reference values were compared to the conCentrations detected at the
Site to detennine the final COCs. .

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The CPFs have been developed by EP A's Carcinoge~c Assessment Group for estimating excess
lifetime cancer ri~ks associated with exposure to potentially carcinogenic chemicals. CPFs, which are
expressed in units of (mglkg-day)-I, are multiplied by the estimated intake of a potential carcinogen, in
mglkg-day, to provide an upper-bound estimate of the excess lifetime cancer risk associated with
exposure at that intake level. The tenn "upper bound" reflects the conservative estimate of the risks
calculated from the CPFs. Use of this approach makes underestimation of the actual cancer risk highly
. unlikely. CPFs are derived from the results ofhwrian epidemiologiCal stuc!ies or chronic animal
bioassays to which animal-to-human extrapolation and uncertainty factors have been applied.
Th~ RIDs have been developed by EP A for indicating the potential for adverse health 'effects from .,' ,.
exposure.to chemicals exhibiting noncarcinogenic effects. RIDs, which are expressed in units of.' .
~glkg-day, are estima:tes of lifetime daily exposure levels for humans, including .sensitive individuals. ..
Estimated intakes of chemicals from environmental media (e.g., the amount of a chemical ingested from
,contaminated drinking water) can be cOmpared to the RID. RIDs are derived from human
epidemiological studies or animal studies to which uncertainty factors have been applied (e.g., to
account for the use of animal data to predict effects on humans). These uncertainty factors help ensure
that the RIDs \\i.11 not underestimate the potential for adverse noncarcinogenic effects to occur. '
Excess lifetime cancer risks are detennined by multiplying the intake level with the CPFs. These risks
are probabilities that are generally expressed in scientific notation (e.g., lx10-5 or IE-S). An excess
lifetime cancer risk of IE-S indicates that, as a plausible upp~r bound, an individual has a one in one
hundred thousand chance of developing cancer as a result of site related exposure to a carcinogen over
a 70-year lifetime under the specific exposure conditions at a site.
. ,
Potential concern for nOncarcinogenic effects of a single contamiDant in a single medium is expressed
as the hazard quotient (HQ) (or the ratio of the estimated intake derived from the contaminant.
concentration in a given medium to the contaminant's reference dose). By adding the HQs for all
contaminants within a medium or across all media to which a given population may reasonably be
exposed, the Hazard Index (HI) can be generated. The HI provides a useful reference point for gauging
the potential significance of multiple contaminant exposures within a single medium or across media.
For the purposes of this document, a HI was not generated due to the lack of contaminants effecting
like target organs. Instead, an individual HQ of 0.2 (0.1 was used in Appendix ID) was used to
calculate the final. soil reference values. .
As indicated above, Table 1 identifies the minimum and maximum concentrations detected in the soils
at the Site. The final soil reference values were used to set the soil remediation levels, also presented in
Table 1. As shown in Table 1, there is a potential threat to human health in the unrestricted and .
commerciallindustrialland use scenarios if remediation of the contaminated soil does not o<:cur because,
the maxim:um contaminant concentrations exceed the remediation levels. In addition, as shown in
Table 2, contaminant concentrations in the 'ground water have been detected at concentrations above
the acceptable allowable limits for drinking water. As indicated previously, the contaminant.
concentrations are expected to decrease after source removal occurs. If source removal does not occur,
there is a potential threat to human health by ingestion of contaminated ground water.
Environmental Risks. In addition to human health risks, the risks to the environment were also
evaluated and used in the final determination of remediation levels. The soils pathway, through direct
contact, soil ingestion. or food chain transfer exposure routes, is of primary concern for terrestrial plant
and animal species at the Site. Unfortunately, there are no soil criteria values and there is little
infonnation available regarding maximum allowable soil contamination levels for evaluating risk to
terrestrial ecological receptors. The absence of tissue residue information for the Site also precluded

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development of Site-specifi~ bioaccUmulation factors which would reflect the actual bioavaila~ility of
the COCs on the Site. Therefore, literature values were used to determine a best estimate of soil
reference values that would be protective for most ecological receptors on the Site. In addition, a Site
visit.and evaluation was conducted to characterize the ecological resources of the area.
The Site is located in the North Central hardwoods ecoregion. The original presettlement vegetation in
this area was predominantly oak woodland and brushland with scattered prairie openings, and
floodplain forest (silver maple, elm, cottonwood., willow) along the river mi.rgins. The Site contains
four distinct habitat types: the southern part of Area A is a reCreatlonal park containing mowed grass,
baseball fields and a hockey area. Parkland is also present along Third Street in Areas C, D; and F; .
the area between Area A 1cJ.goons and the Sauk River consists of a mixture of river margin/floodplain ~
. forest and maple-bass\\;ood forest with many large trees and well-developed .shrub understory. This
area is relatively high quality habitat as indicated by the diversity of plant and wildlife species
observed; north of the Area A lagoons is ~ area that was previously fannland and is now thick with
ash and elm saplings forming a potential habitat for forest edge species and songbirds; the rest of the .
Site is old field habitat vegetated with grasses and forbs typical of disturbed soil. Rabbit and
woodchuck dens as well as vole runways were observed inside the fence surrounding Area A lagoons.
Well used trails are noted throughout the Site indicating substantial human traffic especially in Area A
between the trailer park, north of the Site and the ball park.
The Site visit and evaluation concluded that no endangered species are knO\\l1 to occur in the vicinity,
but two threatened species (bald eagle and loggerhead shrike) and several special concern animal
species have been documented in Steams County.
In summar)', human health and ecological risks, current land use, and City zoning ordinances were.
used to determine acceptable future land use for the Site. The unrestricted land use remediation levels
shall be applied to Area A while industrial/commercial remediation levels shall be applied to Area;s B
. through H. Actual or threatened releases of hazardous substances from tm!> Site, if not addressed by
implementing the response action selected in this ROD, may present an imminent and substantial
endangennent to the public health, welfare, .and the environment.
DESCRIPTION OF AL TERNA TIVES
The January 1994 FS (ENSR, 1994a) and February 1994, FS Addendum (EN'SR 1994b) identified and
Cva1uated 10 response action alternatives and their combinations' (Table 3) that could be used to
address current or potential health and environmental threats at the Site. Five response action
alternatives were evaluated for OUI: Lagoons and five for OU2: Sandblast Sands. For the purposes of
this ROD, the two operable units and associated response action alternatives were combined to fonn
five alternatives. The purpose for this is that most of the alternatives evaluated for the lagoons were
also evaluated for sandblast sands. In addition, by combining the operable units" there is an overall
reduction in costs. The following alternatives were evaluated:
Alternative A: No Action. The DO action alternative is considered at all Superfund Sites to piovide a
baseline comparison to the other alternatives considered. With respect to the no action alternative for
the lagoons, no technical controls would be implemented other than the existing fencing around the "
Area A lagoons, thereby limiting acce.ss to the waste materials in this area'. Inspection and maintenance
of this fence over the long tenn would be Decessary as well as continued ground water monitoring~ The
consolidated sandblast sands would remain on-site in their cunent location; covered to prevent
movement from the pile. Maintenance of the cover and fencing around the pile would be required.
Deed restrictions would be placed on the portions of the property where waste is present limiting

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future activities including construction to prevent contact with waste materials. A ground water
monitoring network would be installed or upgraded in the vicinity of the lagoons. A ground water
monitoring plan would be developed to monitor ground water quality for the parameters listed in
Table 2. Ground water remediation would be detennined based on the ground "'ater sampling and
analysis results.
As indicated above in the Summary of Site Risks section, there is a potential threat to human health
and the environment because the maximum concentration of contaminants oil the Site exceeds the
remediation levels as. presented in Table I. In addition, not all sandblast sands have restricted access.
If the soil contamination is not addressed, human health and environmental exposure is likely. .
Therefore, the no action alternative is not acceptable because it is not proteCtive ofhwnan h~th and .
. the environment. In addition, no action for the lagoon is not practical in Area C because scheduled .
road construction includes the excavation of approximately one half of the Area C lagoon. Also, the no
action alternative does not meet our objective of source removal to reduce contaminant concentrations
in the ground water. Currently, contaminants are located in the saturated zone and therefore already in
contact with the ground water. As a result, Alternative A does not comply with Applicable or Relevant
and Appropriate Requirements (ARARs) (ARARs are listed in Appendix IV) that apply to ground.
\\'ater.. Therefore, this alternative will not be considered further.
Alternative B: In-Place Containment ofLa2oons and Reuse as Road Base/Solidification and
On site Containment of Sandblast Sands. This alternative consists of containing the lagoon material
in place to prevent potential direct contact with and continued leaching of contaminants to the ground
wateJ;'. This would be accomplished through the use of capping, deed restrictions, and fencing. The
caps would reduce the penneability by covering the lagoon areas with an impermeable layer thereby
reducing the leaching of contaminants into the ground water. This alternative also consists of .
incorporating the non-hazardous sandblast sand in road construction as base material for roads to be.
constructed in the City or surrounding ar~. The hazardous portion of the sandblast sands would be
solidified/stabilized to non-hazardous levels and placed in an on-site containment facility. This
alternative also includes a ground water monitoring network as required in Alternative A.
Capping of the lagoon is not practical in Area C because scheduled road construction includes the
excavation of approximately one half of the Area C lagoon. In addition, capping does not meet our
objective of source removal to reduce contaminant concentrations in the ground water. Currently,.
contaminants are located in the saturated zone. and therefore alleady in contaCt.with the ground water.
. Although capping would prevent potential direct contact with the waste, the potential for ingestion of
contaminated ground water exists. Therefore, capping is not acceptable because it is not protective of
human health and the environment and does not comply with ARARs that apply to ground water. As a
result., this portion of Alternative B will not be considered further.
Placing the non-hazardous sandblast sands below the road is essentia1Iy equal to constructing a
concrete or asphalt cap over the sand, which limits the mobility of the lead by eliminating infiltration of
precipitation. Although this portion of Alternative B bas been used in the past, segregating the .
hazardous from non-hazardous sand blast sands may not be velY effective. Therefore, this portion of
Alternative B will not be considered further. Solidification/stabilization and on-site containment of
sandblast sands are acceptable and are discussed in Alternatives C and D. Therefore, Alternative B
will not be considered further.
Alternative C: Solidification/Stabilization and On-site Containment. This alliterative includes the
excavation of lagoon waste, sandbl~ sands, and the contaminated dirt floor of the paint building (now
a portion of the WPMI property~, and incorporation of the consolidated sandblast sands. Excavation

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of the contaminated waste would continue until analytical results of selected sidewall and bottom
samples pass the remediation levels as specified in Table 1. Any visible oil in the excavations floating
on the ground water would be removed by pumping or using sorbent pads. Excavations would be
backfilled with clean fill, compacted, covered with topsoil, and seeded. The waste would then be
solidified/stabilized. The purpose of solidification/stabilization is to reduce the concentration of
contaminants to below hazardous waste levels as specified in Table 4 and to minimize the mobility of
the contaminants in the waste material. Solidification/stabilization,'while ~nplemented as a single
technology, actually consists of two processes. Solidification consists of entrapping materials in a solid
matrix with .a high structural integrity, thereby minimizing the potential for constituents to leach from
the waste. Stabilization methods involve the. use of materials that limit the solubility and thus, the
. bioavailability and mobility of waste constit1:Ients. Several SolidificatioDtStabilization techniques ar~ .
available, depending on the type of contaminants. However; Portland and Pozzolana cements are the
most widely used with thermoplastic resins and organic polymers less common due to their high costs.
Treatability studies would be conducted to determine the most appropriate method to use. The treated
waste would be placed in a containment mility constructed on-site in Area E in accordance with the
Minn. Rules Chapter 7035 pt~ 2815. Contingency action plans and post closure requirements would be
conducted in accordance with Minn. Rules Chapter 7035 pt. 2615 and 2645. The facility design would
include: I) a liner system consisting oflayers of synthetic material and/or clay and sand~ 2) a leachate
collec~ion and detection system; 3) a cover system consisting of layers of synthetic material and/or clay
and sand~ 4) a ground water monitoring system~ and 5) a gas collection system.
Deed restrictions would be placed on any area that is not remediated to unrestricted land use
remediation levels and on the property containing the facility. This alternative also includes a ground
water monitoring network as required in Alternative A. .
Alternative D. Solidification/Stabilization and OfT-Site Landfill. This alternative includes
excavation, oil removal, backfilling, and solidification/stabilization of wasTL. materials as described in
Alternative C. Once the waste is solidified/stabilized to below hazardous levels the waste can be
disposed of off-site at an industrial waste landfill. Treated waste would be transponed to an industrial
waste landfill in trucks.
Deed restrictions would be placed on any area that is not remedjated to unrestricted land use
remediation levels. This alternative also includes a ground water monitoring network as required in
Alternative A. . .
Alternative E. Soil WashiDl~lExtraction. This alternative includes excavation as described in
Alternatives C and D. The excavated and consolidated material would go through a soil
washing/extraction process consisting of a treatment train that includes three major steps:
-soil washing for volume reduction~ .
-acid extraction for lead removal; and
-solvent extraction for PCB and oil removal.
Soil washing is a water-based process for mechanically scrubbing soils. This process either dissolves
or suspends the contaminants in a wash solution or concentrates them into a smaller volume of soil
through panicle size separation techniques. This process, conducted on the lagoon waste, is expected
to be ineffective due to the various types of soils and waste materials present. However, this process
has been shown to be effective on the sandblast sand. Wastewater may need to be treated before .
discharge for lead, PCBs, and oil contamination. Potentially hazardous ~ter treatment sludges
would be generated. .

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Acid extraction removes the metals from the soils by a three stage process. The metal is first converted
into a soluble salt, the soluble salt is then extracted with an acidic solution, and then the metal is
removed from solution by precipitating or electrowinning. Calcium hydroxide present in a large
volume of the lagoon waste is not expected to be compatible with an acid washing process. In addition,
oily soils present in the lagoons are expected to reduce the success of acid leaching. Acid e~:traction
has been proven to be effective on the sandblast sand. Large ~~~ts of wastewater are generated
through this process. '
Solvent extraction for PCB removal includes several extraction steps to achieve the required percent
recovery. Solvent extraction is cOnducted by mixing soils with the solvent. The solvent containing, '
.PCBs is then removed from the soil and separated into oil, water, and $olvent fractionS. Solvents '~' ,
oe regenerated for reuse. The constituents in the oil fraction then must be thermally or Chemlc:ally
deStroyed.' .
A treatability study would have to be conducted to determine the most appropriate methods for'
treatment. Treated soils would be placed back into the excavations as they are treated. Once treatment
is completed, the soil would be covered \\ith six inches of topsoil and vegf'tated. Any remaining
treatment residual would require treatment or disposal, including waste fractions not treated in the
process, sludges, treatment solutions, wastewater, and activated carbon. This alternative also includes
a ground water monitoring network as required in Alternative A.
As indicated above, the mixture of PCBs, oils, and lead in the lagoons makes the soil washing/extraction
treatment of the lagoon waste not technically feasible. Solvent extraction would not be required for the
sandblast sand, as no PCBs are present. Treatment of the sandb.ast sands is technically feasible;
however, it has not been successful at all sandblast sand remediation sites. In addition, the Cost of .
treating the sandblast sands is approximately double the cost 9fthe secona most expensive alternative
evaluated; therefore, Alternative E \\;11 not be considered further. .
SUMMARY OF THE COMPARATIVE ANALYSIS OF AL TERNA TIVES
The following is a comparative analysis of the Alternatives based on nine evaluation criteria presented
in the National Contingency Plan (NCP). These nine criteria are grouped into three categories:
threshold criteria, primary balancing criteria, and modifying criteria. The criteria and ~e comparative
analysis of alternatives are presented in the following sectionS and summarized on Table 5. As
indicated above, #t the Description of Alternatives section, only two alternatives, Alternatives C and D,
will be evaluated further.
A. Threshold Criteria. The threshold criteria include the first two criteIi~, which are: 1) overall
protection of human health and the environment, and 2) compliance with ARARs. The ARAb used
for the Site are based on the requirements of CERCLA and the NCP as adopted by EP A in March
1990, as well as state requirements under the Minnesota Environmental Response and Liability Act
(MERLA). In addition, remediation of the Site shall adhere to criteria established in other Minnesota
statutes and rules. "As indicated above, Alternatives A and B did not meet the threshold Criteria of
overall protection of human health and the environment and do not comply with ARARs. Therefore,
Alternatives A and B were not evaluated further.

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,
B. Primary Balancinl! Criteria. The five primary balancing criteria are: 1) long-tenn effectiveness
and permanence; 2) reduction of toxicity, mobility, or volume through treatment; 3) short-tenn
effectiveness; 4) implementability; and 5) cost. Of these, the first two, long-tenn effectiveness and
pennanence and reduction of toxicity, mobility, or volume through treatment, receive the most
emphasis of the balancing criteria in evaluating remedial alternatives. Alternative E, as indicated
above, was not technically feasible for the lagoon waste and as a result would not provide long tenn
effectiveness and pennanence. In addition., Alternative E is coSt prohibitive. Therefore, Alternative E
was not evaluated further. -
C. Modifvin2 Criteria. Two modifying criteria were used to evaIuateAlternatives C and D: .1) .'
" . community acceptance and 2) state acceptance. The analysis of.community acceptance is based on the.
community conus .:ots to the Proposed Plan during the public comment period and at the public,
meeting. State acceptance is based on the position of the MPCA.
Alternatives C and D were evaluated using the Threshold, Primary Balancing, and Modifying Criteria.
The following summarizes this evaluation:
Alternative C: Solidification/Stabilization and On-Site Containment.
Overall Protection of Human Health and the Environment. This alternative would protect human
health and the environment, in both the short and long tenn, from unacceptable risks posed by
hazardous substances, pollutants, or contaminants present' at the Site. This would be achieved by
excavating the contaminated material, treating the contaminated material by stabilizing/solidifying to
significantly ,reduce the contaminant mobility and toxicity, and placing the stabilized/solidified waste in
a pennanent containment facility on-site, further reducing the mobility. Because the contaminants of .
concern would be inunobilized and contained, potential risks would be J1Iinimized. Some potential risk
exists for exposure to contaminants during excavation., handling and mixing, arid containment on-site,
but these risks would be cOntrolled though effective engineering and implementation of the alternative.
The remedial action objectives would be achieved by this alternative. The !"ontainment facility would
be monitored in accordance with an approved gI:ound water monitoring plan. , A ground water
monitoring plan would be implemented after removal of the contaminant source to detennirie whether
ground water remediation is necessary. '
, Compliance with ARARs. .Resource Conseivation Recovery Act (RCRA) Land Disposal RestIjctions
(LDRs) would apply to the on-site placement of excavated untreated waste exceeding the TCLP
regulatory limits for lead as well as PCBs exceeding 50 ppm. However, a Corrective Action.
Management Unit (CAMU) can be designated to allow the implementation of a response action that
fonnerly would have been restricted by LDRs (40 CPR Parts 260, 264, 268, 270 and 271). Once the:
waste is treated,by solidification/stabilization techniques, the waste can be disposed ofin an on-site
containment facility constructed to meet Minn. Rules Chapter 7035 pt. 2815, Without triggering LDRs.
Excavation, treatment, and construction would be implemented in a manner to keep fugitive dust .
emissions below federal and state air quality standards for particulate matter and lead. This alternative is .
expected to comply with ARARs associated with ground water by removing the contaminant source.
However, ground water monitoring will be required and a review of the ground water monitoring data
will be conducted after three years of data has been collected to determine if ground \\-ater remediation is
necessary. If ground water remediation is necessary, an amendment to this ROD will be developed by the
MPCA and implemented by BN. .

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Long- T erm Effectiveness and Permanence. This c~terion assesses the rimgnitude of residual risk
remaining from untreated waste or treatment residuals remaining at the completion of remedial
activities and assesses the adequacy and reliability of controls such as containment systems and
institutional controls that are necessary to manage treatment residuals and untreated waste. This
alternative pennanently removes soil contamination, thereby eliminating a continued source of .
contamination t6 the ground water. Therefore, no residual soil contamination will be left in place.
. Ground water monitoring would continue after source removal lias been completed. . If the
concentrations of contaminants in the ground water increase, remain the same, or do not meet
regulatory levels as specified in Table 2 as a result of the removal, the MPCA staffwould eValuate
whl;:ther ground Water remediation is necessary.
. Minimal potential risk .would be ass:;ciated With the solidified/stabilized soils pla.ced in. an on-site .
containment facility. No risk from direct contact would exist as the materials would be covered with a
synthetic and/or clay cap, and the area' would be fenced. Ground water monitoring wells located near
the containment facility would be monitored to determine ifany coritaminants were .leaching into
shallow ground water. Eight years of ground water monitoring indicate that lead has only been
detected twice, once above acceptable limits in drinking water; otherwise it is not present in ground
water at levels that pose unacceptable risks. An even lower level of risk would be present after
treatment and placement of the waste material into the containment facility. Regular maintenance of
the cap and deed restrictions on the property would also enhance the long-term effectiveness of this
alternative. A contingency plan and post closure requirements, in accordance with Minn. Rules.
Chapter 7035 pt. 2615 and 2645, would be developed in order to have a good response in the unlikely
event a release occurs. .
.Reduction of Toxicit)., Mobility or Volume Through T..utment. Contaminants ofconcem would
undergo treatment by solidification/stabilization to reduce their mobility and toxicity, such that the
contaminated material would no longer be characteristically hazardous. The treatment of the soils is
designed to be irreversible. The mobility would also be reduced by placement in a secure containment
facility on-site. The volume of contaminants would not be increased. However, the volume of waste
once it has been treated will increase due to the addition of treatment reagents.
Short-Term Effectiveness. This criterion assesses any potential risks, including risks to the workerS
and commwrity, associated with construction and implementation of the alternative up to the point
where remedial action objectives are achieved; The remedial time ftame is estimated at one year and
includes the time required to excavate and treat the waste materials and construct the. on-site
containment facility.
Potential shon-term risks to the community could result due to dust emissions during excavation and
handling of the soils on-site. This risk would be controlled by proper design and implementation of the
alternative, including dust control measureS. Other potential effects on the community are the
increased vehicle traffic from delivery of cement and other treatment agen+.s to the Site. Access to the
Site would be restricted to prevent potential contact by members of the community.
Potential risks to workers involved in implementation of the remedial action are also associated with the
excavation and handling of contaminated soils. All workers on-site would be required to be certified in
hazardous materials safety training and to comply with procedures included in a site health and safety
plan.

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Minimal impacts to the enviromnent are expected during the implementation of this altemativ~.
Potential runoff from temporarily stockpiled waste materials on-site would be prevented and controUed
by placing the stockpiled material in a lined, covered, and benned area.
. Implementability. Excavation of contaminated materials in the vicinity of 10th Avenue would require
coordination with the Steams County Highway Department for rerouting of traffic.
Solidification/stabilization is a common treannent technology for lead that ~ been successfully
implemented at other Superfund sites. Stabilization agents for organics also have been used
successfully at other sites. Mixing of oily soils with non-oily soils will provide a more homogeneous
soil with a lower, overall oil content that can be treated effective.y. Solidification will act to bind the
oils and PCBs in the treated matrix. Treatability studies would be conducted to determine the proper ~
. mixture of the appropnate treatment reagents. GrOUIt~1 water monitoring wells wouid be used to .
monitor potential leaching of contaminants to groUnd water once the waste has been
solidified/stabilized and placed in the con~ent facility.
Cost. The MPCA staff developed estimated costs that exceeded BN's estimated costs for this
alternative as presented in the Proposed plan. However, BN has provided additional information and
the MPCA staffhave reevaluated the costs for this alternative and determined that BN's costs as
presented in the FS Addendum are appropriate. Therefore, the total cost for this alternative, including
long-tenn operation and maintenance, is $2,800,000.
State Acceptance. Thisaltemative is acceptable to the State since it allows compliance with state and
federal statutes and rules and meets the nine evaluation criteria for remedy selection.
CommunitY Acceptance. This alternative is acceptable to the Community. Please refer to the
responsiveness summar)' for the community comments on the proposed plan.
Alternative D: Solidification/Stabilization and Off-Site Landfill.
Overall Protection of Human Health and the Environment. This alternative would protect human
health and the enviromnent, in both the short and long term, from unacceptable risks posed by
hazardous substances, poUutants, or contaminants present at the Site. This would be achieved by
removing the contaminated material, treating the contaminated material by stabilizing/solidifying to
significantly reduce the contaminant mobility and toxicity, and disposing of the treated waste in an
Industrial Waste landfiU. Because the treated waste would be disposed of off-site, potential risks would
be eliminated. Some potential risk exists for exposure to contaminants during eXcavation, handling and
mixing, and transportation for off-site disposal, but the on-site risks would be controlled though
effective engineering and implementation of the alternative. The remedial action objectives would be
achieved by this alternative. A ground water monitoring plan would be implemented after removal of
the contaminant source to determine whether ground water remediation is necessary.
Compliance with ARARs. RCRA LDRs would apply to the on-site placement of excavated untreated
waste exceeding the TCLP regulatory limits for lead as well as PCBs exceeding 50 ppm. HoWever, a
CAMU can be designated to allow the implementation of a response action that formerly would have
been restricted by LDRS. Once the waste is treated by solidification/stabilization techniques the waste
can be disposed of in an off-site industrial waste landfill, without triggering LDRs. Excavation,
treatment, .and construction would be implemented in a manner to keep fugitive dust emissions below
federal and state air quality standards for particulate matter and lead. This alternative would also
comply with ARARs associated with ground water by removing the contaminant source. However,
ground water monitoring .

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20
would be required and a review of ground water monitoring data will be conducted after two to five
years of data has been collected to detennine if ground water remediation.!~ necessary. If ground water
remediation is necessary, an amendment to this ROD will be developed by the MPCA and implemented
byBNo
LOong-Term Effectiveness and Permanence. This criterion assesses the magnitude of residual risk
remaining from untreated waste or treatment residuals remaining at -the co~pletion of remedial
activities and assesses the adequacy and reliability of controls such as containment systems and
institutional controls that are necessary to manage trea~ent residuals and untrea~ waste. This
alternative permanently removes soil contamination, thereby removing a ~ntinued source of .
Contamination to the ground water. Therefore, no residual soil contamination will be left in place.
Ground water monitoring would continue after source removal has been 0 'Ompleted. If the
concentrations of contaminants increase, remain the same, or do not meet regulatory levels as specified
in Table 2 as a result of the removal, the MPCA staffwill evaluate whether ground water ~ediation
1S necessary.
Reduction of Toxicity, Mobility or Volume Through Treatment. Contaminants of concern would
undergo treatment by solidification/stabilization to reduce their mobility and toxicity. The treatment of
the soils is designed to be irreversible. The mobility would also be reduced by placement in a secure
industrial landfill off-site. The volume of contaminants would not be increased. However, the volume
of waste once it has been treated will increase due to the ~dition of treatment reagents.
Short-Term Effectiveness. This criterion assesses any potential risks, inciuding risks to the workers
and community, associated with construction and implementation of the alternative up to the point
where remedial action objectives are achieved. The remedia1 time fr3me is estimated at less than one
year and includes the time required to excavate and treat the waste materials and dispose of them in an
off-site industrial waste landfill. . \ .
Potential short-term risks to the community could result due to dust emissions during excavation and
handling of the soils on-site. This risk would be controlled by proper design and implementation of the
alternative, including dust control measures. Other potential effects on the community. are the .
increased vehicle traffic from delivery of cement and other treatment agents to the Site and
transponation of the treated material off-site. Access to the Site would be restricted during remediation
to prevent potential contact by members of the community. . . .
Potential risks to workers involved in implementation of the remedial action are also associated with the
excavation and handling of contaminated soils. All workers on-site would be required to be certified in
hazardous materials safety training and to comply with procedures included in a site health and safety .
plan.
Minimal impacts to the environment are expected during the implementation of this alternative.
. Potential runoff ftom temporarily stockpiled waste materials on-site would be prevented and controlled.
Implementability. Excavation of contaminated materials in the vicinity of 10th Avenue would require
coordination with the Steams County Highway Department for rerouting of traffic.
Solidification/stabilization is a common treatment technology for lead that has been successfully
implemented at other Superfund sites. Stabilization agents for organics also have been used
successfully at other sites. Mixing of oily soils with non-oily soils will provide a more homogeneous
soil with a lower overall oil content tbat can be treated effectively. Solidification will act to bind the

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21
oils and PCBs in the treated matrix. Treatability studies would be conducted to detennine the proper
mi~"tUre of the appropriate treattnent reagents.
Cost. The total cost for this alternative, including long-tenn operation and maintenance costs, would
be $4,500,000. .
State Acceptance. This alternative is acceptable to the state smce It alIow~ compliance \\ith state and
federal statutes and rules and meets the nine evaluation criteria for remedy selection. However, the
cost of this alternative is significantly greater than Alternative C.

~Community. A~ceptance. This alternative is accCptable to the Commmrity. However; the community . .
has indicated their preference for an on-site containment facility. Please refer to the respCl.&L.:;jvei1ess
summary for the community comments on the proposed plan.
Summary of the Comparative Analvsis of Alternatives.
Based on the Comparative Analysis of Alternatives, both Alternative C and D meet the nine evaluation
criteria. However, Alternative C is lower in cost and the community has indicated its preference for an
on-site c;ontainment facility. Therefore, the recommended remedial alternative for implementation at
the Site is Alternative C: Solidification/Stabilization and On-site Containment.
SELECTED REMEDY
The selected remedial alternative for implementation at the Site is Alternative C:.
. Solidification/Stabilization and On-site Containment as described above in the Description of
Alternatives Section. BN shall implement this alternative in accordance With Exhibit C of the
October 25, 1985, RFRA, and BN shall also follow the Minnesota generic RFRA guidelines for the
development ofRDIRA Plans as presented in Appendix IV. In addition, BN shall include the following
in development and implementation of the remedial actions:
BN shall excavate the lagoon waste, sandblast sands, and the dirt floor of the WPMI paint building,
and incorporate the consolidated sandblast sands. BN shall excavate contaminated waste until all
visible oily soils ~d sandblast sands are removed. BN shall also remove and treat any visible oil
floa~ing on'the ground water. BN shall also collect samples from the nativ~ soils on the sidewalls and .
bottom of the excavations and analyze the samples to detennine if the native soils left in place pass the.
remediation levels as specified in Table 1. Area A shall be remediated to unrestricted land use levels, .
while Areas B through H shall be remediated to commercial/industrial land use levels. However, the
MPCA staff believes that once all the sandblast.sands and oily waste are removed, unrestricted land
use will be achieved in all areas. Once the analytical results show that the concentration of
contaminaIits in the native soils achieve the remediation levels, excavations shall be backfilled with
clean fill, compacted, covered with topsoil, and seeded. . .
BN shall solidify/stabilize the waste to reduce the concentration of contaminants to belOw hazardous
waste levels as specified in Table 4 and to minimize the mobility of the contaminants in the waste
material. BN shall submit a treatability studies work plan for detennining the most appropriate method
for solidification/stabilization of the waste. Once the MPCA staffhas approved the treatability study
work plan., BN shall conduct treatability studies in acCordance with that plan. BN shall submit a report .
on the results of the treatability studies for MPCA staff approval. BN shall solidify/stabilize the Waste
in accordance \\ith an MPCA staff approved solidification/stabilization method.

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22
The treated waste shall be placed in a containment facility constructed on-site in accordance with the
Minn. Rules Chapter 7035 pt. 2815. The facility design shall include: I) a liner system; 2) a leachate
collection and detection system; 3) a cover system; 4) a ground water monitoring system; and 5) a gas
collection system. Prior to placement of the treated waste, 'BN shall install a ground water monitoring
system for long-term monitoring of the containment. facility and collect at least one set of ground water
samples for ba~ground evaluation. BN shall develop a contingency action plan and post-closure
requirements in accordance with Minn. Rules Chapter 7035 pt. 2615 and 2~5. BN shall submit an
RA completion report that includes certified as built plans and specifications and COnstruCtiOD
documents .
-
.. BN shall submit a ground water monitoring plan that includes a monitoring program for the ' I
containment facility as well as upgrading the ground water monitoring network in the vicinity ,of the
lagoons and monitoring well MPCA 14s.
Deed restrictions shall be placed on any area that is not remediated to unrestricted land use remediation
levels and on the property containing the containment facility. BN shall develop proposed deed
restriction language and shall be responsible for ensuring that an MPCA approved deed restriction is
, placed on appropriate properties.
STATUTORY DETERMINATIONS
Overall Protection of Public Health, Welfare, and the Environment. The selected remedy will
provide protection of human health and the environment from unacceptable risks posed by hazardous
substances, pollutants, or contaminants present at the Site. This will be achieved by removing the ,
, contaminated material, treating the contaminated material by stabilizing/solidifying to signi:ficantly
reduce the contaminant mobility and toxicity, and placing the stabilized/solidified waste in a permanent
containment facility on-site. Because the contaminants of concern will be excavated and treated and
will be immobilized and contained, potential risks such as ingestion and deimal contact will be
eliminated. Tne remedial action objective of source removal and remediation levels will be achieved by
this alternative. The containment facility will be monitored in accordance with an approved ground,
water monitoring plan to ensure the containment facility is providing maximum protection. A ground
water monitoring plan will be implemented after removal of the contaminant source to deteimine
whether ground water remediation is necessary.
Compliance ~th ~pplicable and Relevant and Appropriate Requirements. , The selected remedy
will comply with the requirements of federal and state statutes and rules. The federal statutes that the
remedy must be in compliance with.include CERCLA and SARA, which added Section 121 to
CERCLA to provide specific cleanup requirements. Federal ARARs that the remedy will satisfy
include the NCP, to the extent practicable, as adopted by the EP A in March 1990. This remedy will
also comply with Minnesota Statutes, including MERLA, Minn. Stat. ~ 115B (1992). A list of
ARARsthat the remedy will comply with are listed in Appendix IV.
Cost-Effectiveness. Except for the No Action Alternative and the Capping Alternative (Alternatives A
and B), the selected remedy provides treatment for the least amount of cost as well as the lowest net
present worth of all the alternatives evaluated, and is cost-effective in meeting the remediation
objectives.

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Utilization of Penn anent Solutions and Alternative Treatment (or Resource Recovery)
Technologies to the Maximum Extent Practicable. The selected remedy uses treatment technologies
to the maximum extent practicable. The removal of contaminated material will provide a permanent,
reduction of a source of contamination to the ground water. The excavated soils will be treated by
solidification/stabilization and placed in a permanent containment cell constructed on-site. The
,containment cell will confine the contaminants, providing additional protection against continued
ground water contamination. If the MPCA staff determines that the performance monitoring data show
that this alternative does not adequately address ground water contamination, BN shall implement a
ground water treattnent system as specified in an Addendum to this ROD. The MPCA staff will make
the detenninatio~ whether a treattnent system is necessary three ,years after source removal is Complete. -
Preference for Treatment that Reduces ToXicity, Mobility, or VoluiDe as a Principal Element.
Contaminants of concern would undergo treatment by solidification/stabilization to reduce their
mobility and toxicity. The treatment of the soils is designed to be irreversible. The mobility would
also be reduced by placement ofthesolidifiedlstabilized waste in a on-site containment facility. The
volume of contaminants would not be increased. However, the volume of \'.'3Ste once it has been
treated will increase due to the addition oftreattnent reagents. '

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References
Wadsworth 1989. Analytical Repon; WadsworthlAlen Laboratories Inc.; October 10, 1989
ERT 1986. Remedial Investigation Repon for the Burlington Northern Waite Park Site, Waite Park,
Minnesota; Environmental Resources and Technology, Inc.; November 1986
ERT 1988. Fina1 Remedial Investigation Repon for the Burlington Northern Site, Waite Park,
Minnesota., Volume I and Volume D; Environmental Resources and Technology, Inc.; August 1988
MDH 1989. Health Assessment for Waite Park Ground Water Contamination Site, Waite Park,
Minnesota; Minnesota I;>epanment of Health 1~89.
BFA 1989. Risk Assessment Guidanc:e fo;r Superfund Volume I Human Health Evaluation Manual, (part
A) Interim Final; U.S. Environmental Protection Agency; December 1989.
EPA 1989. Risk Assessment Guidance for Superfund Volume II, Environmental Evaluation Manual,
Interim Final; U.S. Environmental Protection Agency; March 1989
JMA 1989. Removal of Storage Tanks, 51. Cloud Car Shop, Waite Park, Minnesota., Volume I and II;
John Mathes and Associates; March 1989.
BEl 1992. Consolidation of Sandblast Sand Piles in Areas A, B, and H, St. Cloud Car Shop, Waite Park,
Minnesota; Burlington Environmental Inc.; JuI)' 1992
. ATSDR 1992. .Lead Initiative Summary Report, Waite Park Wells, Waite Park, Steams CoWlt)',
Minnesota; Agency for Toxic Substances and Disease Regisuy; September 24, 1992
MDH 1993. Public Health Assessment, Minnesota Depanment of Health; December 1, 1993

ENSR 1994a. Draft Feasibility Study Car Shop Site, Waite Park, Minnesota; ENSR Consulting and
Engineering; January 1994;
ENSR 1994b. Feasibility .Study CoSt Comparison; ENSR Consulting and Engineering; February 1994;

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RESPONSIVENESS SUMMARY FOR THE RECORD OF DECISION
Burlington Northern Car Shop Superfund Site
Waite Park, Stearns County, Minnesota
This community responsiveness summary documents community involvement during the Remedial
InvestigationlFeasibility Study (RlIFS) and Proposed Plan phases of the Su.perfund cleanup of the
Burlington Northern Car Shop Superfund site (Site) in Waite Park, Minnesota. It documents the
Minnesota Pollution Control Agency (MPCA) staff response to comments made by interested parties
during the public comment period. . .

.The RI/FS and the Proposed Pian for the Site were released to the publicfor.comment on May 3, 1993.
These two documents were made available to the public in the administrative record at the MPCA,.
Saint Paul, Minnesota, office, Waite Park Community Library and an infonnation repository .
maintained at the U. S Environmental Protection AgencY (EP A) Docket Room in Region V. The notice
of availability for these two documents was published in the S1. Cloud Times on May 2, 1994. A
public comment period on the document "..as held from May 3, 1994, to June 2, 1994. In addition, a
public meeting was held on at the McKinley Elementary School in Waite Park on May 18, 1994.
Approximately 60 people attended the meeting. At this meeting, representatives from the MPCA staff
presented an overview of the site history, answered questions about problems at the Site, and discussed
the remedial alternatives under consideration. A response to the comments received during this period
is included below.
Background on Community Involvement
The Site is located on industrial property on the northern border of the citY of Waite Park (City), a
smaller city of 5,248 residents adjacent to the much larger city. of St. Cloud (population 49,376). ;Part
. of the City's distinctive character is directly related to its identity as a railroad town. The Great.
Northern Railroad and, later, the Burlington Northern Railroad Company (BN) employed many City
residents over the years. Because so many l~l residents have lived, worked, or played on or near the
Site, they have not felt particularly threatened by hazardous wastes located there. Several additional
features related to the location of the Site play an important role in the complexity of community
opinion. These include the following: . .
.
The MPCA and the EP A see two distinctly different things when looking at the areas of
contamination. EP A considers a larger area, consisting of the Site, Electric Machinery (EM) site,
and Waite Park Municipal Wells, as one site, listed on the National Priority List (NPL) as the
Waite Park Ground Water Contamination site. The MPCA sees three distinct state Superfund
sites. .
.
The industrial area located on the Site contains Waite Park's municipal wells. In retrospect, an
industrial area such as this is not the most suitable location for a municipal well field; however, the
risks of such placement were not known when these wells were instaIled. .
.
The sediments in the Sauk River were sampled for PCBs upgradient, adjacent to, and downgradient
of the Site. The results of the analysis have indicated the presence of PCB contamination at all
sampling locations at roughly the same concentrations, indicating contamination of the sediments
from possible multiple sourceS. Due to the lack of supporting information connecting PCB

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2
contamination to BN, the MPCA staff did not pursue this investigation further and will not require
BN to remediate the river sediments. However, Southeast Asian families, many of whom live in a.
St. Cloud trailer park close to the Site, fish in the river and consume the fish. Therefore, there is a
community concern with the Sauk Ri~er.
.
Industrial development in the S1. Cloud area has overtaken the availabl~ locations for such activity.
The land left unused over the years because of the contamination problems is prime development
land. Many good developments have gone elsewhere, and inquiries about the Site are ftequent.
.
An imponant project for local development is the expansion of 1 Oth Avenue, which runS -through .
t1..;: Site. This project has been in the planning for years. However, work cannot go forward until.
one of the waste lagoons is . cleaned up because a part of the liew road would go through the lagoon.
,
.
Despite the fact that the majority of the Site is zoned industrial, the Site has been used often as a .
play area for children. The west end of the Site includes baU fields within relativ~ly close
proximity to areas of contamination. Children from a nearby school, McKinley Elementary, cut
across the Site or used it as a play areabefore an MDH advisory in 1992. Several families used
the area to exercise their pets.
All of these complicating factors have made the community relations at the Site difficult over the past
10 or so years since the MPCA staff have worked on the Site.
The MPCA involvement with the Site began in December 1984, when volatile organic compounds.
(VOCs) were found in the City's muniCipal water supply wells. On January 28, 1985, the MDH
informed the MPCA staff that the City was being advised to discontinue use of its water supply as
soon as possible due to unacceptable levels of hazardous substances in its drinking water. .
Consequently on January 28, 1985, the MPCA Director determined that an emergency existed with
regard to the Waite Park water supply. The MPCA Director issued a Determination of Emergency
to allow use of the Minnesota Environmental Response and Compensation Fund to take necessary
actions to provide the City with a safe drinking water supply and to undertake an investigation and
Feasibility Study (FS) to determine the most appropriate long-tem drinking water alternative.
Initial provisions were made for temporary supply of safe drinking water from.nearby S1.: Cloud.
businesses, and on. February 4, 1985, an emergency hookup between Waite Park and St. Cloud
. water systems was Made to supply the City With safe water until the most appropriate long-term
water supply system, selected through the conduct of a FS, could be installed.
On October 22, 1985, after completion of an initial investigation and a Pct:ntial Responsible Party .
Search, the MPCA issued a Request for Response Action (RFRA) to BN citing BN as a source of
contamination of the City's water wells. On March 25, 1986, and September 26, 1986, the MPCA
also issued RFRAs to Brown Boveri &. Company Limited, Cooper Industries, Inc., Dresser
Industries, Inc., and Electric Machinery Manufacturing (Responsible Parties) for the adjacent EM
site, currently MEI International. The RFRAs also cited the EM site as a source of contamination
of the City wells. .
The RFRAs requested both BN and EM Responsible Parties to conduct a RIlFS and implement a
Remedial DesignlResponse Action (RDIRA) Plan for a long-term water supply treatment system

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3
for the City. The RFRAs also requested BN and EM Responsible Parties to conduct an RI/FS and
implement an RDIRA to address the contamination at their respective sites.
In September 1986, the MPCA staff approved the installation of an' air stripping unit that would
remove the contaminants from the municipal "\Iater supply. BN and EM Responsible Parties
jointly implemented the ground ....ater treatment system and the rn~cipal wells were placed back
into service in February 1988. This is the remedy that is currently in place,. providing an
acceptable long-term water supply to the City.
In 1992, the MPH began updating'its public health assessment for the Waite Park Water Supply site, .
: focusing on. the BN portion. Between the discovery of the contaminated municipal wells and the 1992 .
health assessment, MIJ! I had very little involvement in the Site. During the assessment, ~e MDH
discovered that children frequently played in areas where lead contaminated sandblast sand was
present. The MDH subsequently advised the MPCA that an imminent health hazard existed as a result
of the contaminated sandblast sands at the Site. In additio~ the MDH conducted a public meeting and
availability session on March 25, 1993, and followed up by attending a public meeting held by the city
of Waite Park on April 9, 1992. Citizens were concerned about the potential for their children to be
exposed to lead contamination and about potential effects. In addition, they were concerned about the
delay in addressing the Site problems.
In response, the MPCA staff notified BN of the imminent health hazard, and BN agreed to conduct an
interim response action to remove the health hazard. The interim response action cOnsisted of BN
undertaking a major effort in consolidation, fencing and covering the sandblast sands. In addition, the
Agency for Toxic Substances and Disease Registry (ATSDR) funded free blood lead scr~g for the
'community, which was conducted with assistance from the MDH and Steams County Community
Health Services. .
The City council also passed a resolution creating the Waite Park Community Advisory Panel
(wpCAP) to aid in achieving a number of both MPCA's and BN's major objectives. In addition, the
once-a-month dialogue between MPCA and BN staff allowed the commUDlty members to become more
sophisticated in their understanding of the compl.exity of environmental protection. It also allowed
MPCA and BN staff to develop consistent relationships. ,During much of the discussion about the
proposed cleanup plan, MPCA and 'BN staff have had an opportunity to ascertain community
preferences., This helped MPCA staff understand the community's needs and priorities.,
As mdicated above, a public comment period on the proposed cleanup for the Site was held from
May 3, 1994, to June 2, 1994. In addition, a public meeting was held at McKinley Elementary School
on May 18, 1994. At this meeting representatives from the MPCA presented an overview of the site
history, answered questions about problems at the Site, and discussed the remedial alternatives under
consideration. Along with the citizens were a group of students from St. Cloud State University
(SCSU) assigned to study the real-life issues involved at the Site. By participating in the public
comment process, the students aired many environmentalist views. They also helped the City residents
to see the Site from a different perspective, guaranteeing that all possible objections to the cleanup
remedy were aired. A response to the comments received during this period is included below.

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4
Public Comments and Responses
The comments received during the public meeting and comment period feU into several categories.
General Superfund program issues, petroleum contamination issues, on-site containment cell issues,
ground water issues, and miscellaneous issues. The comments received in each area are listed below
along with the MPCA staff response.
General SUDerfund Pronam Issues
Comment: One resident wanted to make sure that the public .would not be paying for the c:leanup .
. actions.
Response: The state and federal Superfund laws require those parties whose actions have resulted in
releases of hazardous substances, pollutants or contaJrri.nants to pay for investigation and, if necessary,
cleanup of sites where those releases pose a threat or potential threat to public health, welfare and the
environment. BN has paid all investigation costs and will pay for the cost of cleaning up co~taminants
at the Site.
Comment: One resident was concerned about how proximity to a Superfund site would affect
property values. He also wanted to know whether MPCA had calculated the effects of the Site on.
residential real estate. .
Response: The MPCA staff did not investigate the impacts of the Site on residential housing prices
because the state and federal Superfund laws do not require the MPCA staff to do so: The MPCA
staff experiences with a wide range of sites indicate that there is no clear pattern seen in property' .
values near Superfund sites. The only predictable occurrence is a dip in property values shortly after
more inflammatory types of publicity. But longer term trends are very difficult to predict. .
It is unlikely that the Site would have substantial impact on residential property values because the
most affected area is an industrial zone. However, if any local residents who have been required to sell
property (i.e., through a job transfer or other situation) have incurred a property value loss, the
Hannful Substances Injury Compensation Board may reimburse residents for up to three-fourths of1he
loss. .
Comment: Sey~ra1. residents commented that they app'roved of the cleanup plan and thought it should
go forward inunediately.
Response: Once a cleanup plan has been approved and established in the Site Record of Decision
(ROD), the MPCA staff will proceed with Site cleanup and ifpossible expedite the process.
Comment: BN strongly disagrees with the MPCA's cost estimates for off-::ite disposal at an industrial
landfill and on-site containment. .
Response: Originally the MPCA staff and BN did disagree on the cost estimates. BN has since
provided the MPCA staff with additional estimates for on-site containment that indicate BN's original
estimation was correct. The MPCA ~taff still disagree with BN's estimate for off-site disposal.
However, with the new estimated figures, it appears that on-site containment will cost less than off-site
industriallandfill. In addition, the fact that the MPCA staff and BN have disagreed on the cost

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5
estimates is unimportant. Whether the on-site containment option costs more or less than off-site
landfilling, BN will still pay the bill.
Petroleum Contamination Issues
Comment: After the 1993 cleanup of petroleum contaminated soil on the Site, one resident saw an
. oily sheen on puddles on the property and was concerned that BN lWi not qone a thorough enough job
of cleaning up the petroleum.
Response: The. cleanup of the petroleum contamination was completed under the supervision cifthe .
. MPCA Tanks and Spills staff. These staffmembers, who are MPCA's most experienced in, terms of'
petroleum contamination cleanups, approved the final res\i~t::. Before the). sign off on a cleanup; soil
samples are taken from the sides and bottom of the excavation area and must be at acceptable levels.
Comment: SCSU students who visited the Site after the 1993 petroleum cleanup said they
encountered strong petroleum odors in the area. They were concerned that adequate cleanup had not
taken place.
Response: Creosote-covered railroad ties, piping and miscellaneous debris taken from the excavation
and stockpiled in this area are a source of odor problems. BN has indicated that this material will be
removed as part of the cleanup.
On-site Containment Cell Issues
. . .
Comment: Several community members wanted to know how big the containment cell would be and
how much contaminated soil it would hold. They were skeptical about whether such a small
containment cell could hold all of the wastes after they were solidifi~stabilized.
Response: The proposed on-site containment cell is small, approximately one and one-half acres, or
20' x 360' x 150', about the size of a football field. It is being designed to contain more than. the
estimated 25,000 cubic yards of contaminated soil. (It could hold as much as 33,000, if additional .
wastes are discovered upon excavation.) However, it will not contain wa..c;t~o; brought from any other
location. .
Comment: One student expressed concern about the possibility of the containment cell leaking over.
time. He wanted to know whether the design characteristics were sufficient to prevent any. .
contamination to ground water.
Response: The containment cell will be built to the specifications of the state's Solid Waste Rules and .
will be a state-of-the-art facility. However, no engineering design can be guaranteed to last into the
indefinite future. That is why there are several factors of protection regarding the treatment of the
. waste, the design of the containment cell, and long-tenn monitoring requirements.
These protections include: 1) the wastes, lead and PCBs do not easily move from soil into the ground
water; 2) the hazardous components will be solidified/stabilized so that they are even less able to leach
from the cement-like substance that will contain them; 3) the containment cell cover will assure that 95
percent of the rain and snow falling on the containment cell will run off instead of going through the
\\'a51es; 4) a synthetic and clay liner will prevent any contaminants that may leach from reaching the

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6
soils; 5) the clay belleath the synthetic liner will restri~ movement of contaminants that might escape
through the synthetic liner; 6) a leachate collection and monitoring system will be installed; 7) ground
water monitoring wells will be installed around the Containment cell to dC!C'Ct potential releases from
the containment cell; and 8) EP A conducts a five-year review of all Superfund cleanups to assure that
the actions are still protective of human health and the environment.
Comment: Two residents and the SCSU students strongly preferred off-s~te disposal of the
contaminated waste as a means to assure the safety of the municipal water supply.
R~sponse: The MPCA staffis confident that the design of the containment cell, along with the. series . . . .
of safety "factors listed in the previous response, provide adequate protection for the City wa~r supply:'
, .
Comment: The students commented that by storing the wastes, the MPCA was just postponing the
problem of waste disposal for future generations. They felt that the on-site containment was not a good
long-tenn solution. . .
Response: The oily wastes contain a diversity of different components, and no knOV.'I1 fonn of soil
washing can deal with these wastes effectively. Lead could feasibly be extracted from the sandblast
sands, but the cost of this treatment is approximately double the cost of the second most expensive
alternative evaluated. It is the MPCA's preference to reduce the toxicity, mobility or volume through
treatment. Solidification/stabilization is a fonn of treatment where solidification consists of entrapping
materials in a solid matrix with a high structural integrity, thereby minimizing the potential for
constituents to leach from the waste, resulting in the reduction in mobility Stabilization involves the
use of materials that limit the solubility and, thus, the bioavailability and mobility of ~e
. constituents. The solidification/stabilization process will also reduce the toxicity to below hazardous
waste levels. The volume of contaminants would not be increased. However, the volwne of waste once
it has been treated will increase due to the addition of treatment reagents.
Comment: One resident was concerned that oil-site containment of the wastes would adversely affect
development in the area.
Response: One of the MPCA's primary concerns with the on-site containment option was that it
would prohibit use of the property upon which the containment was built and a certain amount of1and
around the penmeter of the facilitY. However, there are some realities about land use in the area that
include, I) the land prohibited from use belongs to BN, and there is no indication that BN would sell
the property for development; 2) concerns among bankers, developers, buyers, and sellers ofland about
contamination would not necessarily be removed by the removal of the several known areas of
contamination; 3) the majority of the affected community did not seem particularly concerned about the
adverse effects a containment cell will hav~ on development.
Comment: An SCSU student asked whether the liner and cover of the containment cell would be
tested for strength or would be affected by heat or frost.
Response: The synthetic and clay material used to line and cover the containment cell is commonIy
and successfully used at landfills throughout Minnesota. It will be tested throughout the installation
process. The MPCA staff is confident that the materials will hold up under Minnesota's challenging
weather conditions. .

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7
Comment: An SCSU student asked what would happen if the containment cell liner leaked ~d how
BN would repair the problem.
Response: As part of the containment cell requirements, BN is required to provide a contingency
action plan to be implemented in the unlikely event that a release occurs. This plan will describe
methods to be implemented in the event of a release. One possi~jli~ is BN could install a slurry v..all
around the containment cell to stop ground v\:ater migration towards the m~cipal wells and install a
ground water pump out system and treat the ground water prior to disposal.

Comment: One resident wondered whether the material to build the coniainment cell would be taken
from the City area or outside of the City. . ,
Response: Some of the natural soil on Site may be used to cover the containment cell, but much of the
materials come from off-site, possibly oUt$ide of the City area.
Comment: Several residents wanted to know what the on-site containment cell would look like, once
completed. One additional resident wanted to know the projected height and slope of the containment
cell.
Response: The containment cell would look like a gently-sloped hill. It would rise approximately 20
feet from the ground surface, but gradually enough to make it more of a pillow-like shape than a
mound shape. The slope of the containment cell would be five-t(H)ne.
Comment: . One SCSU student commented on the comparative costs of the on-site containment cell
and off-site industrial landfill. iie commented that 'he felt off-site would be less expensive, as well as.
better environmentally. .
Response: As indicated in a previous response, the MPCA staff and BN did disagree on the cost
estimates for off-site industrial landfill and on-site containmeIit cell. BN has since provided the MPCA
staff with additional estimates for on-site containment cell that indicate BN's original estimation was
correct. The MPCA staff still disagrees with BN's estimate for off-site industrial landfill. However.
with the new estimated figures, it appears that on-site containment cell will cost less than off-site
industrial landfill. With on-site containment and off-site industrial landfill comparable in
~nvironmental protection. the deciding factors became 1) BN's willingness to perfonn one remedy over
the other without additional delay; and; 2) the expressed preferences of the community. BN maintained
throughout the process an unwillingness to undertake any remedy except on-site containment. And the
community preference was strongly in favor of the remedy which could be accomplished with no delay
to the 10th Avenue construction. Therefore. the balance fell in favor of on-site containment.
Comment: One SCSU student expressed concern that the MPCA staff initially expressed a preference
for off-site industrial landfill, but changed its opinion later for an undetennined reason. He wanted to
know whythe.MPCA had backed off from its initial position.
Response: The MPCA did prefer off-site industrial landfill. but the following developments altered the
agency's views: BN's commitment in writing to construct an on-site containment cell that complied
with the state of Minnesota's Solid Waste Rules, BN's additional information on costs for an on-site
containment cell, and discussions with MPCA Solid Waste Section engineers who believed that such a

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8
facility could be constructed quickly and "'lith "environmental protection equal to the off-site remedy.
Once these developments took place, MPCA staff fonnally selected on-site containment.
Ground Water Issues
Comment: Several residents wanted to know how quickly any'_col!taminants leaking £Tom the
containment cell could move into the lower aquifer from which the municipal water supply is drawn.
Response: If contamination were to emerge from the containment cell's base, it wquld be collected by
the leacliate collection system and pumped out of the system by BN. If the collection system fai)ed, a
ieak detection system, located below the leachate collection system, would trigger an alarm and warn
BN that a release in the liner has occurred. If a release occurred, contamlnation would first come in
contact "ith unsaturated sands and eventually reach ground water. Because the contaminants of
concern (P AHs, Lead & PCBs) are hydrophobic they would very slowly dissolve into ground water.
At this. point the monitoring wells that are required to surround the containment cell would reveal the
presence of contamination in ground water. BN would then be required to investigate andlor repair the
facility to correct this problem. .
Because of the design of the containment cell and its leachate collection system, the MPCA considers it
unlikely that contamination will ever reach ground water. But, in order to ensure that the public health
is safe-guarded, BN will be required to maintain this ~ for as long as the containment cell exists.
Comment: Representatives of Brown Boven and Cooper Industries (responsible parties for the EM
site) did not feel that BN had established an acceptable monitoring network for the ground water. They
commented that the network on the northern boUndary of the BN property wasinsufflcient to detennine '.
whether there are any contaminantS migrating £Tom BN to the EM site. .'
. .
Response: BN and the responsible parties for the adjoining EM site do not always agree on what
constitutes adequate investigation of contamination problems. The MPCA staffhas felt that the
monitoring system was adequate for the detennination of contaminant sources. However, the MPCA
staffwill be evaluating the long-tenn monitoring network to detennine if the monitoring network oi1the
north side of the Site is adequate. This evaluation mayor may not indicate the need for additional
monitoring, wells to detennine whether contaminants are migrating from one site to the other.
Comment': Representatives of the EM "responsible parties also commented that BN's sampling
program should include total petrolewn hydrocarbons and aromatic hydrocarbons because EM's pump-
out system does not remove some of the potential contaminants.'
Response: Ground water monitoring will be required for BN boundary wells MPCA 3s & d, MPCA
13s & d, MPCA l4s & d, ERT 28s and ERT 29s, for both VOCs and P AHs. This follows the
complete sampling of the BN site twice for P AH Compounds. In contrast, very little is known about
P AH contamination on the EM site. One sampling of two wells in the fall of 1992 revealed only that
PAH contamination in wells EM35s and EM22d was below a Practical Quanitation Limit (PQL) of 10
ppb. This is at a level above the detection of most PAH compounds at the BN site and therefore is
inconclusive. In order to develop this idea further, EM would have to agr~ to more analytical testing
of ground water and effluent of the EM site.

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9
Comment: The EM responsible parties also wondered what evidence the MPCA had to show that
another hole in the till unit was not allowing a more direct route for contaminated shallow ground water
to move to the deeper aquifer from which the municipal water supply is drav.n.
Response: Ground water paths can be detected in two ways, either through direct geologic evidence
from the placement of a boring in the "hole", or by studying the ground water flow directions from
contour maps. Since there is no evidence that borings have intersected a hole south of the EM site, and
since ground water flow in the surficial aquifer at the BN site is clearly towards the known hole directly
east of.the EM building, there is D:0 evidence that a more direct ground water path exists. ""

. . . , .
Comment: . BN commented that it was incorrect for MPCA to state that "residual VOCs are removed
by the. municipal ~ell treatment plant." BN's' comments implied that there' are no VOCs migrating from
BN's propeny to the municipal wells. .
Response: While the MPCA staff believes that the investigation conducted by BN's conSultants is
adequate to characterize the major problems on the Site, it in no way guarantees that the Site is free of
all additional contamination. Nor does it guarantee that every molecule ofVOCs removed from the
municipal water treatment system comes from EM alone. The MP<;:A stated, accurately, that any
residual VOCs are removed by the municipal well treatment plant - no matter where such VOCs
would be coming from, including the BN Site.
Comment: BN commented that there was no risk ofleaching of materials in the lagoons to the ground
water because lead and PCBs are insoluble; 20 years of exposure of the contaminants to ground water
have not produced contamination; and there is no hydraulic connection between the upper and lower
. aquifers. .
Response: Lagoon C - Though lead and PCBs have low solubilities, they have both been detected in
ground water in wells constructed in the lagoon. These compounds have not been detected in other
wells, but this is likely due to the lack of wells immediately downgradient of the lagoon. There is no
evidence to support the statement that these compounds have not moved off-site. There is a fully
documented hydraulic connection between the upper and lower aquifers just east of the EM building.
Lagoon A ~ Grotmd water flow in this region is contJ:olled by'the Sauk River and is perhaps best"
characterized as stagnant.' There is little movement of contamination. There is no clear hydraulic
connection between ground water in the vicinity .ofthis lagoon and the lower aquifer.
Miscellaneous Issues
Comment: One SCSU student wanted to know if the land use for the Site's immediate area would
always be industrial.
Response: The Site is situated in land zoned for industrial use and recreational use. Whether it would
or could be changed in the future is a local matter and at this point the City has indicated that it bas no
" intention of changing the zoning. However, the MPCA requires land use restrictions be applied to
areas not remediated to unlimited land use.
"

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10
Comment: The Stearns County Board commented that it is concerned about the completion of the
10th Avenue construction project and wants to make sure that the cleanup actions happen in time to
allow that project to go forward.
Response: Once a c1eanupplan has been approved and established in the Site Record of Decision
(ROD), the MPCA staff will proceed with Site cleanup and ifpossible expedite the process. While the
MPCA staff can't guarantee that actions will go forward in a timely manner, .BN has publicly
expressed itS intention to complete the work on time and MPCA staff will provide all approvals as
exp~ditiously as possible to make sure the appropriate work starts on time. The MPCA staff also has
suggested to BN or Steams Cotinty that they have the option of-moving forward with an interim..
response action to make sure that 1 Oth Avenue mo:ves forward.
Comment: The Stearns County Board also commented that whatever decision was made on the
cleanup plan that it be protective for public health and the environment
Response: The recommended action protects public health and the environment.
. Comment: BN commented that the MPCA's '5 estimate that 10,000 gallons of oil, paint, and solvents
were disposed of on Site is without substantiation, since there are no written records about disposal
practices from that time. .
Response: The American Heritage Dictionary defines the term "estimate" as: I) to calculate
approximately the extent or amount of; 2) to fOIm an opinion about; and 3) a judgment based upon
one's impressions; opinion. The MPCA staff estimate that 10,000 gallons ofwastes were disposed of ..
on Site came from discussions with former employees, iriformation about. past operations, and other
infonnation. Without written records from disposal practices at that time, any figures given by the
MPCA staff or BN would be estimates. .
. Comment: BNcommented thatMPCA's characterization of tile heavy metal contamination on-site
was not accurate. Its preferred language would have been "a mixture of materials with low lead
concentrations and some higher lead concentrations."
Response: While such distinctions mightbe meaningful to scientific and technical minds, tPey are not
meaningful in publications directed at the general public. Also, it is unclear whether. such a langua.ge
replacement would be helpful even if appropriately explained. What BN believes to be "low lead
concentrations" would not necessarily be what MPCA, EPA, or MDH would consider "low lead
concentrations.". .
Comment: BN commented that the numerical standards set by MPCA do not represent health-based
standards but "are more conservative standards selected by MPCA based on criteria other than the risk
assessment process."
Response: The numerical standards set by the MPCA are based on both health and ecological risk.
They were set in accordance with the EP A Risk Assessment Guidance for Superfund and in
consultation with the EP A's and MDHs Health Risk Assessment staff and MPCA's risk assessment
expert, who holds a Ph.D. in toxicology.

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11
Comment: BN commented that it is unknown whether PCB oils were disposed of on the Site, and that
the PCBs found in the lagoon could have been associated with other materials found in the lagoon.
Response: The PCBs detected in the oily lagoon wastes could have been associated with other
materials found in the lagoon, although it is much more likely that there came from PCB oils disposed
,of on Site. '
Comment: BN commented that a table should have been included showing average concentrations of
on-site contaminants rather than minimum and maximum concentrations. BN representatives felt that
" MPCA iDformation did not present a realistic perspective,ofthe.true risks associated with the Site. "
, ,

Res'porise: The MPCA staff give minimUm and maximum concentrations of contaminants of cOncern
detected on Site because this data is commonly requested by the public. Also, the MPCA staff does not
have an accurate figure showing average concentrations on Site. The MPCA staff could only have
provided the average concentrations of those samples taken, not of Site contaminants as a whole.
Comment: BN commented that the MPCA staff did not give sufficient credit to the company for its'
thorough investigation of rumors about a buried tank car on the property.
Response: Since the information about the buried tank care came from former BN employees and BN
investigated the allegations at the MPCA's request, no particular kudos are in order for either the
MPCA staff or BN. Both did their required duties.
Comment: BN,does not believe that lead cOntaminated wastes pose an immediate health risk to ,Wai~e
Park residents. The two' foundations for this belief: that blood-lead testing performed by MDH found
no levels above detection limits for lead and the sands are covered and fenced.
MPCA: The lead-contaminated wastes that are now consolidated. contained. and covered do not pose
an immediate health risk to Waite Park residents. However, before these actions were taken at
MPCA's request, the lead-contaminated soils did pose an immediate health risk to Waite Park residents.
Substantial public health and medical documentation is available to support lead's adverse health
effects, particularly on children. The MDH would be happy to provide a list of such scientifically
, conclusive documents or. studies upon request. '
The blood-lead testing performed by MD,H (in cooperation with A TSDR and the Stearns County
Health Department) found no lead levels above detection limits. However, none of the health agencies
involved in this investigation concluded that exposure to this lead-contaminated soil was safe. Nor did
they conclude that exposure to the wastes on-site caused no hann to Waite Park or S1. Cloud residents.
Blood lead levels 'V.ary depending upon how recent exposure has been to the lead source. Those
residents who came in for the testing were not a scientific sample of the population. No other'
indicators of lead exposure or poisoning were evaluated. For BN ,to claim that the levels of lead found
on the Site never posed an imminent health risk on the basis of the blood-lead testing is misleading in
the extreme and directly contradicts the evidence of public health officials at the county, state, and
federalleveI.
Comment: BN commented that the MPCA's initial preference for soil washingllead extraction should
have been eliminated from consideration not just by its cost but because it is technically unfeasible.
BN claims that the technology would not work on BN wastes.

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12
MPCA: The lead-extraction technology has been used successfully at sites in Minnesota, and the
MPCA has requested responsible parties to evaluate it at s~tes where it migh~ be practical. Although
the soil washing is expected to be successful on the sandblast sands, soil wdShing is not expected to be
successful on the lagoon wastes.
. Summary
In summary, the most affected community members, consisting of Waite Park residents and public .
officials and.businesses located on or near the property, approved of the cleanup recQmmendation. :. .
. This group's primary ~essage is best refleCted by Mayor's Ringsmuth's final comment at the proposed .
plan publIc ~neeting: "Get the job done." AS indicated in the above comments, once a. cleanup plan has
been approved and established in the Site ROD, the MPCA staffwill proceed with Site cleanup and if
possible expedite the process. While the MPCA staff can not guarantee that actions will go forward in
a timely manner, BN has publicly expressed its intention to complete the .work on ~e and MPCA staff
will provide all approvals as expeditiously as possible to make sure the appropriate work starts on
tbnne. .
The .1 Oth Avenue project is of crucial importance to the communitY as a whole. While both BN and the
MPCA staff have the best intentions of completing the requisite removal from the road-construction
area on tbnne, both regulator and regulated know that large remediation projects have glitches.
Successful completion will require everyone's best efforts. The MPCA staff also have suggested to BN
and Stean1s County that they have the option of moving forward with an interim response action to
make sure that 10th Avenue moves forward.. . . .
The SCSU students who commented at the public meeting oppose the cleanup recommendati~n and
prefer off-site industrial landfill. The fact that the SCSU students are not the community directly
affected by the Site does not alter the value of their participation. Their many questions and thorough
study of technical documents allowed them to give affected community members another way to look at
Site issues. They raised many of the concerns that agency staff discussed internally and guaranteed
that all sides of the cleanup recommendation were examined.

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Figures
Figure ~: Site Location Map.
Figure 2: Site Features .
Figure 3: Areas of Concern to. be Addressed by this ROD
Figure ,4: Structural Contour Map of Glacial Till .
Figure 5: North-South Cross Section
. Figure 6: Water Table Elevations for Zone A, May 26,1993
Figure 7: Potentiometric Surface for Zone B, May 26,1993

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. .------- ---....
'. _.
'''''i~-
~ ..~
[~~'.~~~-i
I j
1-.----1 ..-J
- ---...--.--....--
.-.....-J t=:::J
LEGEND
~ S\A.rUR- CONTAINING SOILS
~ SandblaJl!l8nd
~ SHALLOIJ GROUNDIJATER CONTAMINATION
.. LAGOONS
rENCE
r1
.r=:
. .
....--
Ii
; !
NOTE'
CONTAMINATION RELATED
TO rORNER UNDERGROUND
STORAGE TANKS TO BE
IIDDRESSED UNDER HPCA'S
US T PROGRAH,
.1--'
-
,~
~
" .-
t:::!

,.,~
!,j-I..I,II!,
, '.
....'
I',: .!"',:.:
[:!
."
..,;
--
. -_.. ...- -
o 500
~-J';
. SCALE IN fEET
a
1.000
.
19M
Areu or Conum 10 lie Addressed b, tJli. ROD
BurlinJlOR Northern Car Shop Sitt
WAIl{ PARK, II1NNESOTA figure 3

-------
"
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102'

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, '! ~-
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I BUILDING
IQQQQI AREA or nLL
ABOVE WATER TABLE
BVRUNGTON NORTHERN SITE BOUNDARY
[II SIT[ BOUNDARY
AREA BOUNDARY
COEr/NED BT ERT ~'B8)
o 500
~
SCALE IN FEET

Modified from Sile Drntnp In the
DnfI Feasibili SIUdy, ~anU8l]' 1994

STRUCTURE CONTOUR ~AP
TOP OF GLACiAl TILL
1.000
I
o
E:XPLANATION
----
"
I

-------
~
~
(~~~~~f
rzza
H~A:~.~<1
~
NORTH
.....
EM SITE
BN SITE
JRD
Sf.
I 1

_I I
HOlt THROUGH
, fill
,----,



~';:l~,iL~'.-:""'-"'-
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:. ~ .
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. .
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. .
..
.:.- '.. "~'..". :.~
GRANITE BEDROCK
LEGEND
INDEX
MAP
.APPROXIMATE
LOCATION or
NORTH - SOUTH
. CROSS SECTION
NORTH
ZONE A
--
GlACiAl TILL
ZONE B
-_. ---
GRANITE
SOUTH
...-
SOUTH
CITY or
WAITE PARK
NOT TO 'SCALE
ModiRed from Silo Drawin..ln the
Draft FeasibilitY Sludy. ~!.an"!'Y 1994

CONCEPTUAl
. NORTH-SOUT!!. CROSS SECTION
InliOll Northern Car Shop SUo
. wAITt: PARK. MINNESOTA Figure 5

-------
=.~. . t.:....~->~~:. -

1-.., .tAJUo - - . t~,o; .
~_.-I' I.==r tlb38.Q: c:::J ....."

~;.-~~~<
.'~:~..~~~...~..'


; : i l' '0 500
~-
SCAlE IN FEET
Modified fIom Sire Dnwina In lhe
Draft Feasiblll S . ENSR. 18IttWJ 1994
WATERTABLE ElEVATIONS
fOR ZONE A
, MAY 26, 1993
. BurlinRlon NorthenI Cu Shoo Si
.. ''''J,~ .p-.. YI8Iaor" Figure 6
...-'.. ".
.~..., .-
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'017.10. .
".n.tS. to», tl
to».1I
.-L..,
'....
-- -... -
EXPlANATION
IIIUIUIIHO
...............-
IIURUNGTON NORIHERH SIT[ BOUNDARY
DI SII'[ ~
NIU. IIOUNDARv
(1U'IN[D.n [lU 1981)
f:::J ":.:..''''
, t.
n
'"Or ~"".. .
I' '(
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I
....I
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. . -=: .
D tC>JU8
loa17
.
--
1.000
J
o

-------
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if<: \~"j .
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sOJa.28 -- ..~.~-- ... -.----:: ~~ -, .,.... -
i 0
.023.58 "
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1111<.1'
.
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---
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....
o 500
P""\-"-"-- "
SCAlE IN rEET
1,000
.
a
EXPLANATION
r--'IIIUIUIINO

IIURUNGT'OH NORntERN SITE 80UHDNtf
EN SITE 8OUNCM'I'
MEA IIOUNIWI't
(DUINED IT ERT (988)
MocIiIIed from Site Drawinp In
Q?!tfeasibilily S!!>dY. ENSR. January 1994
. f)OTENllOMETRIC SURFACE
F'OR ZONE B
MAY 26. 1993

"B..liri~on Northern Car Shop Site
WN1t PNIIe. laMNE50TA
Figure 7
'''''''''''''.'-''.''''

-------
Tables
Table 1: Soil Contaminants of Concern;
Soil Remediation Levels
Table 2: Ground Water Contaminants of Concern;
Ground Water Monitoring Requirements
Table 3: Response Action Alternatives
Table 4: Soil Contaminants of Concern;
Treated Soil Remediation Levels
Table S: Nine Evaluation Criteria and
Comparative Analysis of Alternative
"
. ..~,

-------
Table 1
7/11/94
Soil Contaminants of Concern
Soil Remediation Levels
for Lagoons and Sandblast Sands
Burlington Northern Car Shop Site. Waite Park, Minnesota
.. mMmm:~6Wi_::AJN~.J~H~::,iWa;ntiJl}H: . :titjW....:PWBiftt: n' h" .-. ..... ..
.
:11~~i~~11~!1::~\ii~~i!:iii!:~i~i::: .i!:i~:i!iiM~.lri_tll~~:i::iiii::: . .
~:tgMflMmM_f:@tt:t@}:::: :JJ::::::l}lI@Mf_i;@t:::::~:n:}:I;; lill::~:lr@d':~::i::i
::tl::::::::tt::::::~tJriaJkiLt~::::;tt:~;:~t::::t:: t;;;ttt::::~f;itt:mtJika::~:~~:::::::::;it:;::::f::
Mete"                            
Ar.enlc (c)     0.8/42 0.53/ 1 8 1 .2/5.7 (3 .51   }}!:}::iJn«::n:}::t: .ffftTi&.:lJt::~: 80 1 017080
Cedmlum     0 .9/4.9 0 .5/2 .8   ND     :::t:ttt':::~ijr]wt:~ .rtlli1.&ttrt 80 1 01706 1
                      -........................... "::lffj:~l;ff    
Leed     8.5/1 20,000 5.3/1 7,000 1 4/1 70 138 .51   :~~tl~~~~ria~~~~flf 60 1 017062
Seml-VoIetlle Or,enlc Compounch ISVOCel                     
Anthrecene      NA   NA   0.065/1 10.2271  t::~:tt:N' " ':I~t~;~ilimr ::m:~:::fN~Xtt~t~:  8270 
BenzolahilDervtene   NA   NA     ND     ......... ... 'ii::~::t::tt ~ti::~::tNolt::::~::::::  8270 
Ruorenthene      NA   NA   0.094/4.6 10.8341 .. .. ~t~ttt :tt::::~:~N~x:trt:  8 270 
         :.:.:.:-:.:.:.:.:.;   
Ruorene      NA   NA   0.062/0. 1 2 10.0331 =::::::::;:::;:;:;: "":&:::ftt~: {:t@i~NoAt:t:fi  8 270 
Neohthelene      NA   NA   0.027/0.03 1 10.0 1 11  .. ~?lff .:'::::tt::NGXttt:  8 270 
         '....,'.'.'.'.'.",'   
Phenenthrene      NA   NA   0.058/3 10.5431  '''''''' .....:&t:::tti; :::tt:tNOA'ttt;:  8270 
Pvrene       NA   NA   0.068/2.710.4991  " ';.:::mt:::: tn:~t~t.lCJ.~:~tr~~:  8 270 
          .....,-,-   
totel ePAH. Ie)   NA   NA    ND/23 14.0)   {t{:;~:~;N4.jt;i:t~~:::. 'ftttNoA//:;:~::: 8270 mod
Polychlorineted Ilphen. (PClleJ                       
PCB., tot81 (0) I ND1570 I NA I NA     ':':::::::::tt;:J~{:fttr::ttltli:::.'ttt:::::t  8080 
111 Pr- minimum ..... malmum numben detected d..1ng 1"".llOltlv. Itudlee.
121 Oper"" UnIt 2 .. 1ncIu1188 !he c8nllmln81ed dirt n- ollhe Pel'" 8u1ldlng. .
The mINmumIm..lmum _l1li- of 18ed detected In !he 80118 from lhe dirt fl- of !he Pel'" 8u1ldlna ... 800/28.000 "'1111<0. The delected c_olt- r... TClP";' enoIyM r"',18811 18 4../O.e.
The ...,..,..."",8Idmum _,811- of cedmlum detected In tho duol .......... r,om lhe Point 8u1lcllna ... NO/leo "'II/kg. The detected conc.nt,ltl.,. '01 TClP 0011 ......yoIo ror codmlum .. <0.001.
131 ......- SIt_ltlc l18cq,ound c_OII- developed d",lng Sli. 1"".110011_. .
141 Unr88trtCied ,..... 188 _188 10 Ar.. A. IndUltrlIlI..... i8I _lee 10 At.. 8 IlYouah H.
lei. c.elneoon!c
ND . NOI Detected
Nil. - NOI """,aed .
NOli. - No 0011 A8oIOn8d. A 11011 w. not 811Qn8d It lhie 11m. do 10 ,.ck 0' .,,.ly,lo. A 0011 ",oy be -Igned b888d on lhe ,.ulto of conflrmltlon ,"",piing.
, -

-------
Table 2
7/11/94
Ground Water Contaminants of Concern
Ground Water Monltloring Requirements
Burlington Northern Car St'!op Site, Waite Park, Minnesota
~== . I ::::~::~:::::::::::::::::::::: ;':';';';':';':';';':':';';':':" """"'''''''''''''''''' [[[
::::::::::~:::::::::::::::::::::::::::::::::::;:::;: """"""""""""""
I I :il!:!:!!illl!!!!i:!: -
iIII11;t:", ii:i!lfMTdll::::':
itJJalJt:: .::\!!t:r!~r::II':'!.
Metele. .                                 
Arsenic (cl    7.0/1 7    NO     NO   1 to  56   0.2  50 171    360    7060  
Cadmium      NO     NO     NO   0.005 to 2 1  4  5  4  1 33  7 1 3 1 /60 1 0
lead        NO    3 1 /3 1    NO   1 to 1 900  20  1 5    388    742 1  
Vol.tile Ora.nlc ComDOunde. (VOC.I                                       
Tetrechloroethene (PCE' I  1 /1     NO   I, O. 1 16 1 I  ..     7 1 5 I  1 428 I   4650  
Trlchloroethene CTCE' I 0.2/3.0 1   NO   1 0.1 11 00 1  ..    I 30 1 5 I  1 8988 1   4850  
Seml.YoI.til. Ora.nlc Compound.laYOCeI                                      
Anthrecene      NO     NO    O. 1 5/1 9   ..     2000     2000  1 .6    8270  
Ruorenthene    0.38/0.38  O. 1 5/0.48  O. 1  /4.0   ..     300       1 99    8270  
Auor.n.      NO   0.2/1 .3  0.25/49   ..     300            8270  
NIPhthelene    1 .7/1 .7    NO    0.71740   ..     30            8270  
Phenlnthr.ne      NO   0.42/1 .4  0.27/40   .-            59    8270  
[Pvrene    0.34/0.34  .34/2.2  O. 1 5/1 4   ..     200     200       8270  
ot81 cPAH, (c,   ND/3.Z  NDI1 8. 1  ND173.8   ..     0.03  0.3(BePI      8270mod
ot81 nPAH,    NDI5.8  NOn 6.2  NO/1 425   ..     0.3          8270mod
Polychlorln.ted I..,henol. PCIe'                                       
PCB.. totel (e'  I N0/3.3 I 2.8/220 1  ND  1  ..    I 1 0.5 I  1  2 I 8080  
Footnot..:
111 Wher. mInInun .... mulmum I'Uftber8 - IIw -. the compound w. onI, cltt8Ct. _. .
12' M,",-. 8ecq,owod C-.8II- "em IIw ~ N.tWork. 1812, cleve/oped b, the MPCA, C1WSW Prog.em D.vllopment Section.
131 M'"'-I 0.,...- ., HI8ItIIIMDHI ft8c_od8d ""-81118llml'.IIIAI.8' for o.1nkIng Wet.. "Al..1 hellth b888d .... eppI, p,'m.lly to prlvetl wet.. luppIIee.
for which thorl .. no ...,.,.. 'ooIA8IInI18¥8I8 of drtrItJng w.... eonlornlnont.. .
14' MOIII- C:ontornlnlnll..." MOIIImI.m I*l!\l8lllIIol8Yof of I conlornlnnin WII. which 10 doIIvOI'. 10 '"' u... of I ,,*,Ie wet.. 1,lIorn. The MC1.8 moy not '" hellih 11888d.
1111 H88Ith IVoIIlImIt numllero .. oppII8d 1.Il8ol- found 10 --- MlnnotIOI. ,.-.1 wolor. HRloOI" hellth b888d ond win IUPO'''''. RAlI whor. OJIIM'oprf....
181 Actuelle llf. St....... Mnlrnum Stondord. ..III 8JIIIIy to IIw point whor. lurl- wltor - 1'-.1 WII... For Ihie 511.. lhe ,round WII.. monilorlng
woll ct- 10 the 8M ""or W.~. A now woII,li101o11od It lhepolnt whore I'ound wet. mlllllurflCl Willi. II on ecceplobl. .eptlc.ment.
171 The MC," for ArMnIe Ie eo III". According to c:hortoo Ab8rnllhy, (Poll, lhe 60 III" 10 biNd on on Incorreci -lIIlon 01 800 ug/dl' diet., Inl"., lhe enurnPllon 8hetAd "'.01060 ug/doy.
lei - eorelnogenle

-------
Table 3
6/28/94
Response Action Alternatives
Burlington Northern Car Shop Site
Waite Park, Minnesota ..
 Area A and C Lagoons (OU1)  Sandblast Sands (OU2) 
   . 
1A: No Action 2A: No Action. f
1 B: In Place Containment 2B: Reuse as Road Base 
1C: Solidification/On-Site Landfill 2C: . Solidification IOn-Site Landfill 
1D: SolidificationlOff-Site Landfill 2D: SolidificationlOff-Site Landfill 
1 E: Soil Washing/Extraction 2E: Soil WashinglExtraction 
. COl'J1bined Alternatives
Area A and C Lagoons/Sandblast Sands (OU1 and OU2)
A: No Action
B: In Place Containment of Lagoons and Reuse as Road Basel
Solidification and On-Site Containment of Sandblast Sands
C: Solidification/On~Site Landfill
D: Solidification/Off-Site Landfill
E: Soil Washing/Extraction'

-------
Table 4
7/12/94
Soil Contaminants of Concern
Treated Soil Remediation levels
for Containment Cell
Burlington Northern Car Shop Site
Waite Park. Minnesota.
.. t~ti~~~~~!~~~~)~~~~~i~it~~~~~~~~l~~i~~~il~~~i!i~~f~~I~~~j -
-
Met"Ie                     
Arsenic 'cl      5.0 EPA 1 3  1 1 IEPA 1 3 1 2
C8dmiu~      1 .0 EPA 1 3  1 1 /EPA 1 3 1 2
Lead       5.0 EPA 1 3  1 1 IEPA 1 3 1 2
Seml.Voletlle Orgenlc Compounda ISVOCal             
Anthracene      NGA EPA  1 3 1 1 /8270 
Benlo(ohilDervlene    NGA EPA  1 3 1 1 18270 
Fluorenthitne      NGA EPA  1 3 1 1 /8270 
Fluorene       NGA EPA  1 3 1 1 /8270 
NeDhtheleM      NGA EPA  1 3 1 1 /8270 
Phenllnthrenll      NGA EPA  1 3 1 1 18270 
Pvrene       NGA EPA  1 3 1 1 18270 
totlll nPAH.      NGA EPA 1 3 1  1 /8270 mod
totel ePAHs leI    NGA EPA 1 3 1  1 /8270 mod
Polychlorinatad Blphenole IPChl               
PCBs, totel leI I 50.0 mglkg    8080    
EPA 1311, lClP - Towletl, Cher8Cllflltlclo""'!ICI P,oc:ed...
EPA 1312 - S,nthellc procipll8llon ...ch ,., lor 00118
leI - e.eiftOtlonlc
NOA - No 0081 "-Ionod. A cro81 w. not -Ionod 81 thIo II.... do 10 I.ck 01 onll,....
. A cro81 m., be -Ionod bMOd on lhe rftlJII 01 eonfirmltlon .ompling.

-------
Table 5
6/28/94
Nine Evaluation Criteria and
Comparative Analysis Numerical Ranking
Burlington Northern Car Shop Site, Waite Park. Minnesota.
renking!lln eech cetegory with 111eest setisfactory) to Simost setisfectory)
  C: SolidificBtlonl D: SolidificBtlonl
Evaluation Criteria On-Site Containment Off-Site lendfill
Overall Protection of  4 4
Human Health and ,  
the Environment   
Compllence with ARARs   
Long-Term  4 4
Effectiveness   
Reduction of Toxicity, Mobility 3 3
or Volume Through TreBtment  
Short-Term Risks  3 3
Implementebility  4 4
Totel Costs  4 3
State Acceptance  4 4
   ,
Community Acceptance  4 3
T otal8  30 28

-------
Appendices
Appendix I: Summary of Major Investigative Activities
. .
Appendix n: Blood Lead Screening Results
Appendix m: SuppDrting. Information for Remediation Levels
Appendix IV: Applicable or Relevant and Appropriate
Requirements .
Appendix V: Generic Request for Response Action Guidelines
.for Remedial DesignlResponse Action Plans
<,
...-.
/
\

-------
Appendix I
Summary of Major Investigative Activiti~

-------
Summary of Major IDvestigative Activities
Burlington Northern Car Shop Site,
Waite Park, MiDDesota
Limited Remedial Investigation; Minnesota Pollution Control Agency; Febnwy 1985
Remedial Investigation Report for the Burlington Northern Waite Park: ~ite, Waite Park, Minnesota;
Environmental Resources and Technology, Inc.; November 1986
El~magnetic Investigation of ~eged Buried Tank Car Area, the Municipal Well Area, and the
Calcium HydroXide Disposal Area; Minnesota Department of Natural Resources; 1987 ' ,
PCBs in Sauk River, Minnesota Department of Health; June 1988

Final Remedial Investigation Report for the Burlington Northern Site, Waite Park, Minnesota, Volume I
and Volume IT; Environmental Resources and Technology, Inc.; August 1988 " ,
Removal of Storage Tanks, St. Cloud Car Shop, Waite Park, Minnesota, Volume I and U; John Mathes,
and Associates; March 1989.
Analytical Repon; WadswonhlAlen Laboratories Inc.; October la, ]989
Fourth Quaner 1989 Ground Water Monitoring and Sand Assessment, St. Cloud Car Shop, Waite Park,
Minnesota; lohn Mathes and Associates; March 1990
Sand Accumulations and Metals Analysis, Sl Cloud Car Shop Site, Waite Park, Minnesota; John ~thes
, and Associates;' August-l990 . '.'
Evaluation of Extent of Oily Soils in Area A, St Cloud Car Shop, Waite Park, Minnesota; John Mathes
and Associates; January 1991 '
Burlington Northern Railroad; 'John Mathes and Associates; July 19, 1991
Consolidation of Sandblast Sand Piles in Areas A, B, and H, St. Cloud Car Shop, Waite Park, Minnesota;
Burlington Environmental Inc.; July 1992 '
March 1992 Ground Water Monitoring Summary Report, St Cloud Car Shop, Waite Park; Minnesota;
Burlington En~ronmental, Inc.; September 1992

September 1992 Ground Water Monitoring Summary Report, St cloUd Car Shop, Waite Park,
Minnesota; Burlington Environmental, Inc.; February 1993
Lead Initiative SUUUDaJy Report, Waite Park Wells, Waite Park, Minnesota; Agency for Toxic Substances
and DiscaseRegisuy; September 24, 1992 . .

Tenth Avenue Expazision Investigation Report, Waite Park, Minnesota; ENSR Consulting and
Engineering; August 1993
Public Health Assessment for the Waite Park Ground Water Contamination Site, Waite Park, Minnesota; ,
Minnesota Department of Health; December 1, 1993
Soil Characterization Report, Burlington Northern Waite Park Site, Waite Park, t..{innesota; ENSR
Consulting and Engineering; March 1993 .

-------
Response Action Objectives and Cleanup Goals; Minnesota Pollution Control Agency; 1992-1994
Draft Feasibility Study Car Shop Site, Waite Park, Minnesota; ENSR Consulting and Engineering;
January 1994

Feasibility Study Cost Comparison; ENSR Consulting and Engineering; February 1994
./

-------
Appendix n
Blood Lead Screening Results
. .

-------
Appendix II
Statistical results of the blood lead scn.:ening
Taken from the Agency for Toxic Subst:U1ces and Disease Registry (ATSDR) Public Health
Assessement for Waite PJrk Wells. December I. 1993, prepared by the Minnesota Depanment of
. Health.
1. Total number of clients screened: lOX
2. Number of males: . 60 (56%)
. . -
3.. Number of females' 48 (44%)
4. Number of clients reporting symptoms: 47 (44%) .
5. Number of persons using BN Sitc: (,I (561%)
6. Age:
](I years and youngcr :
11-15 ycars:
16-19 years:
20-25 years:
26-30 years:
.31 + ye:1rs:
1~
17
(,
(,
5
~()
7. Number of pcrsons wilh clc\':!\cd.blood .Ic\d (> I 0 IIg/dl): 0
8. Interpreter necdcd. 2<)
"A comprehensive rcferrral and follow-up plan was followed by the Steams County Community Health
Services starr or contract st:1rr hired for tile lead testing program. Steams Conty Community Health
Services staff was a\'ailable for follow-up discussions. Referral to ph~'sicians was not necessary since no
one showcd elevated blood lead Ic\'cls.
2()

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Appendix ill
Supporting Information for Remediation Levels
-..,\

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INTEROFFICE
MEMORANDUM
TO:
BRENDA YINKLER
FROM:
HELEN GOEDEN

SOIL REFERENCE VALUES FOR DIRECT SOIL CONTACT (INCIDENTAL INGESTION
AND DERMAL CONTACT) .
RE:
DATE:
August 18, .:.993
=========================================================================== .
Based on the information supplied by Brenda and Andrew as well as
information contained in the Human Health and Ecological Risk Assessment.
report prepared by ENSR and BN I have calculated direct contact (i.e.
. incidental ingestion and dermal contact) human health-based soil reference
values for the following CPCs: . .
Arsenic
Cadmium
Chromi um III
Chromium VI
Nickel
Lead
Carcinogenic PAHs
Noncarcinogenic PAHs
PCBs' .
NOTE: The evaluation for lead was conducted separately from the other
contaminants. A blood lead level of less than 10 ug/dl for 95% of the
exposed population was set as the health based target for children under
the age of 6 years. Please keep in mind that a blood lead of 10 ug/dl
does not reflect a no-effect level. A clear no-effect level has not been
established for lead-related endpoints such as birth weight, gestation
period,. heme synthesis and neurobehavioral development in children and
fetuses, and blood pressure in middle-aged men.
LAND USE SCENARIOS
Three land use scenarios were initially evaluated: 1) unrestricted future
land use; 2) current and future recreational land use; and current and
future commercial/industrial land use.
During subsequent discussions it was decided to utilize unrestricted
future land use and commercial/industrial land use in the calculation of
health-based soil reference values.

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1) Unrestricted future land use
A residential exposure scenario is utilized as a surrogate land use
in this evaluation, with the assumption that if it is safe for an
individual to live on the site it will be safe for unrestricted
, hliman land use.
2) Current and Future Limited Land'Use - CommercialiIndustrial
Two receptors, a worker arid a trespasser, were evaluated under this
,scenario. The curreQt use and zoning of the site would allow for a
variety of exposure levels. A commercial office worker would" "
represent a low exposure scenario whereas an" industrial worker with
outdoor activities would represent a ~igher exposure scenar~o.
'Through discussions it was decided that since the current land use
could include an industrial worker with outdoor activities this
exposure scenario was utilized in calculating the health-based soil
reference values. " " "
A potential trespasser receptor was also evaluated since the site
is accessible to trespassers and there is evidence that individuals
do cross the site.
NOTE:
EPA has also requested a construction worker scenario assessment.
I have conducted a quick evaluation utilizing the incidental soil
ingestion "rate suggested by EPA (480 mg/d) and an exposure
frequency of 5 days per week for a. 9 month period. The results of
this evaluation are presented at the end of this memo for'
comparison to, the unrestricted and commercial/industrial land use
based reference values.
EXPOSURE ASSUMPTIONS
Exposure Pathways -

1) Incidental soil and dust ingestion
Please not~ that the ingestion rate for incidental ingestion includes
incidental ingestion of indoor dust and inhalation and subsequent
ingestion of resuspended outdoor soil/dust and indoor dust. Therefore,
an exposure frequency of 350 days/year was utilized.
2) Dermal Contact
Please note that I have not evaluated the inhalation pathway. If the
potential for inhalation of particulate or vapor is of concern the
following soil reference values may not be health protective, particularly
for the contaminants which are much more toxic by inhalation than
ingestion. This would include arsenic, cadmium, chromium VI, and nickel.
The following values should also be compared to the cleanup goals based on
-
/"
~

-------
potential leaching to ground water to make sure that the direct contact
based values are adequately protective of ground water. Ecological
concerns should also be examined, i.e. are the direct contact and ground
water based values protective of ecological receptors?
, "
Exposure Assumptions
Exposure assessment should ,be based on an est~mate of the reasonable
maximum exposure (RME) expected to occur under both ,current and futu~e
land':'use conditions. The RME is defined as the highest exposure tha.
is 'reasonably expected to occur at the site (RAGS 1989).' Use of '
central tendency values for each parameter would produce a central
value scenario which would underestimate , exposure for a large portion'
of the 'population. Use of all upper bound or high end values for each
parameter would produce an upper bound estimate that is usually above
the high end of the population exposure distribution. A mix of upper
, bound and central values is probably the best way to create a RME
scenario. A mix of central and upper bound values, combined with
climatic considerations, were utilized to produce RME estimates for the
BNYP site.
Since I am not as intimate with the site and the surrounding area as
you are I have attached the exposure variable tables for your
,information. Please review the ass\lmpdons I have utilized in
estimating the RME. Note, you will not be able to dup~icate my values
based on the exposure assumptions attached and available toxicity
values. My calculations also include adjustments for differences in
absorption efficiencies.
TARGET RISK VALUES
Carcinogens:, '
The cumulative target. cancer risk' applied in Minnesota has been' 1.E-5.
In light of the uncertainty surrounding the incidence and level of
contamination from organics I have calc-ulated reference soil values
which correspond to a cancer risk of lE-5 for each contaminant. If
multiple carcinogenic contaminants occur, the soil values need to be
pro~rated downward so that the cumulative incremental cancer risk'
equals 1E-5. .
, '
Given current risk assessment methodology, direct dermal toxicity
resulting from direct contact with PABs, as opposed to systemic effects
from absorbed PABs, cannot be assessed~ Although the potential dermal
cancer risk from dermal contact with PADs can not be quantified the
potential risk should be considered in the final risk management
decision and in setting cleanup levels. .
Noncarcinogens:
The soil concentration corresponding to a hazard quotient (80) of 0.1
.3

-------
was determined based on noncarcinogenic effects. A HQ of 0.1 was
utilized to account, in part, for other sources of exposure (e.g. air,
food, water) and to reflect the level of certainty under which risk
calculations for noncarcinogens are calculated. Utilizing a HQ of 1
for each chemical would not be health protective since it would allow
the exposure from a single source (i.e." the site) to account for 100%
of what is considered safe and does not account for the fact that there
are multipl~ sources of exposure. The use of 0.1 for chemical specific
HQ is also re,commended by Region V (personal communication from Pat "VaD .
Leeuven). The cumula t i ve HI should be < 1 .for ch.emi cals wi th ~ imilar .
toxic. endpoints. The soil valueslnay need to. be pro-rated "dovnward" so
that the cumulative HI for similar toxic endpoints is < 1.
./,
c..{

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UNRESTRICTIVE FtTl1JR.E LAND USE
A residential exposure scenario is utilized as a surrogate land use in
this evaluation, vith the assumption that if it is safe for an individual
to. live on the site it viII be safe for unrestricted human land use.
  Reference   Critical Oral
Contaminant. Soil Con. BQ  Noncancer Cancer
 . . (mg/kg)   Endpoint Risk.
Metals:   
Arsenic 5 0.1 SKIN, CNS ,CV 0.5E-5
Cadmium 17 0.1 KIDN  NA
Chromium III 12500 0.1 KIDN, LIV NA
Chromium VI 83 0.1 " " NA
Nickel 250 0.1 VHOLE BODY NA
Lead 300 - 500   
Semi-volatiles     
cPABs 1 NA   1E-5
acenaphthene 640 0.1 LIV  NA
acenaphthylene 640 0.1 LIV  NA
anthracene 3170 0.1  NA NA
benz(ghi)perylene 320 0,1 KIDN  NA
f;Luoranthene 425. 0.1 LIV,KIDN,BLD NA
fluorene 425 0.1 BLD  NA
naphthalene 425 0.1 IMHUNE,LIV NA
phenanthrene 3170 0.1  NA NA
pyrene 320 0.1 KIDN  NA
PCBs 2 NA   1E-5
NA - not available
Endpoints: . .
CV/BLD - cardiov~scular/blood system; CNS - central nervous system;
KIDN - kidney and renal system; LIV - li~r; IHMUN - immune system;
REP -' reproductive system including developmental'
NOTE:
Utilized RfD of acenaphthene for acenaphthylene
Utilized RfD of pyrene for Benz(ghi)perylene
Util.ized RfD of anthracene for phenanthrene
Lead - 500 ppm (OSVER Memorandum, August 29, 1991), based on UBK model. .
Note: Assumes exposure from air, diet, vater, and leaded paint are at
general background or are nonexistent:
Air - assumes air concentration of 0.2 ug Pb/m3
Vater - assumes vater concentration of 4 ug Pb/l
Diet - assumes approximately 6.5 ug Pb/day
Leaded Paint - assumes 0 ug Pb/day
, .
-
~

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If the contribution from "nonsoil" pathway(s) is or potentially is
significantly greater than what is listed above the 500 ppm value may need
to be decreased to offset the increased intake from other sources.
It is recommended that the cleanup goal for a residential setting be set
at 300 - 500 pp'm depending on the potential for exposure from "nonsoil"
sources.
(~)

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c
FUTURE UNRESTRICTIVE LAND USE
Unrestricted Future land Use (Residential! Exposure Assumptions - Ingestion of chemicals in soil.
   Intake 1"'Olleg-dayl = ICsxIRxCFxFh,EFxEDIIIBWxATI 
 Variable Definition Value Utilized Percentile
 Cs Soil Concentretion 1"'Ollegi  0.8 Cs 
 IR Ingestion Rate 1"'0 aoil/dayl  100 I < 6 vrl 
    50 (> 6 . 30 yrl C
    60 (age.adjustedl 
 CF Conversion Fector Ikg/"'Ol  1.00E-06 
 FI Fraction ingested from  1.00 U
r--.    
-.1  conteminated aree   
-----     
 EF Exposure Frequencv (dav/vrl  350 U
 ED Exposure duretion lye8rsl  6 (child < 6 vrl 
    24 I> 6 - 30 vrl U
    30 Itota' durationl 
 BW Body weight (kg I   15 Ichild < 6 yrl C
    57 I> 6.30 vrl C
    50 h,oa.adjustedl C
 AT Averaging Tima (deysl  2190 Ichild < 6 vrl 
    9760 I> 6 - 30 vrl 
    109$0 Ito~at durationl 
    25550 
Rationale/Raferenca
adjusted for dust exposura only 5 mon/yr
IAssumed dust concentration = 0.5 soil concentrationl
Davis et al. 1990; Calabresa and Stanek 1991
Includes indoor dust and outdoor soillEPA 19Bgel
EPA 19898
EPA 1989b
Noncancar Evaluation AT = a"I'o8u,e dur..tion
Cancar EV81u8tion AT. = 70 year lifetima
NA = Not aveilable
C = Cantrel Tendency VelU8
U = Upper Bound VelU8

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FUTURE UNRESTRICTIVE lAND USE
Unrestrictive Future Land Use fResldentialJ Exposure Assumptions. Dermal contact with chemicals in soil.
Doselmg/kg-dey' = ICsxCFxSAxAFxABSxEF)(EDIIIBWxAT' .
V.riabla
Definition
Veriable U,ilized
Percentile
Rationale/Reference
Cs
Soil Concentration
Cs
CF
Conversion Factor (kg/mol
1.00E-06
SA
Skin surface area in contect
VVilh soil Icm21
2000 1< 6 vr'
4100 I> 6 - 30 yr' .
3680 lage-adjusted'
U/C
U/C
" 25% IUI of ave total body surtace eree ICI
17:100 cm2 1<6 yrl end 16364_cm2 I> 6 yr'
IEPA. 1992'
AF
Skin Adherence tector Img/cm2'
0.6
M
between centrel tendency 10.2 mg/cm21and Ullper
bound value 11 mg/cm211EPA 19921 .
----
~
--./
AilS
Absorption tector
Chemic.' Specific
EPA 1992. Wester et e'. and professional judgement
EF
Exposure Frequency (deylyrl
U
Assumes derme' exposure negligible during 5 mons/yr
lave. 5 d/wk for 7 mon~/yrl
15 d/wk for 3 mon + 2 d/wk for 4 mon'
(3 d/wk for 3 mon + 2 d/wk for 4 mons'
150 1< 6 yr'
100"1> 6. 18 yr'
741>18.30yr'
100 lage-adjustedl
ED
Exposure Durlltion Iyears'
6 Ichild <. 6 yrl
24 I> 6 . 30 yr'
30 Itota' duration'
U
EPA 19B9a
BW
80dy Weight Ikgl
.15 Ichild < 6 yrl
57 I> 6.30 yr'

50 lage.adjustedl
C
C
C
EPA 1989b
AT
Averaging time Idays'
2190 Ichild < 6 yrl
8760 (:> 6.30 vrl
10950 ftotel duretionl
Noncancer Evaluation AT = exposure duration
25550
Canee. EVllluation AT.. 70 yelll' lifetime
NA .. Not Iveilllble
C .. Centrel Tendency Velue
U . upplll'r Velue
M .. between Centrel Tendency end Upper Bound Velues

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LIMITED CURRENT USE - COKHERCIAL/INDUSTRIAL
o
Two receptors, a worker and a trespasser, were evaluated under this
scenario. The current use and zoning of .the site would allow for a variety
of exposure levels. A commercial office worker would represent a low
exposure scenario whereas an industrial worker wfth -outdoor activities
would represent a higher exposure scenario. Through discussions it was
decided that since the current land use could include an industrial worker
with outdoor activities this exposure scenario was utilized. in calcula~ing
. tbe health-based soil refe~ence values.
. .
A potential trespasser receptor was also evaluated since the site is
accessible to trespassers and there is evidence that individuals do cross
the site. A great deal of uncertainty is a~sociated with the exposure.
assumptions since it is difficult to determine the frequency and extent of
contact with the site. . .
The trespasser was assumed to be greater than 6 years of age. Ve
requested that BN and ENSR in the baseline risk assessment to include
children less than the age of 6 because of the potential for older
siblings taking younger siblings with them. If it is likely tbat children
younger than the age of 6 may trespass on a commercial site tbe following
values may not be health protective.
_.-
(9 )

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Commercial/Industrial (cont)  
 Reference. Oral 
Contaminant Soil Con BQ Cancer
 (mg/kg)  Risk
H~ta1s:   
Arsenic 20(Y) 0~1 lE-5
 40(T) ,0.05 lE-5
Cadmium 136(Y) 0.1 NA
 350(T)  
Chromium III 100000(V) 0.1 NA
 NCPC(T)  
Chromium VI 686(V) 0.1 NA
 1750(T)  
Nickel 2025(V) 0.1 NA
 3800(T)  
Lead lOOO(V)  
 NA (T)  
Semi-volatiles:   
cPABs 3(V) NA lE-5
 4(T) .  
acenaphthene 5077(V) 0.1 NA
 8500(T)  
acenaphthylene 5077(V) 0.1 NA
 8500(T)  
anthracene 25700(V) 0.1 NA
 39000(T)  
benz(ghi)perylene 2570(V) 0.1 NA
 3900(T)  
fluoranthene . 3385(V) 0.1 NA
 5200.(T)  
. . f.luorene 3385(V) 0..1 NA
 5200(T)  
naphthalene 3385(V) 0.1 NA
 5200(T)  
phenanthrene 25700(V) 0.1 NA
 39000(T)  
pyrene 2570(V) 0.1 NA
 3900(T)  
PCBs 4(Y) NA lE-5
 B(T)  
(V) = industrial yorker  
(T) = trespasser   
NOTE:
The above commercial/industrial setting does not address the
potential existence of a day-care or preschool. It is not uncommon

-------
for these facilities to exist in "mini-malls or strip malls". If
current or future zoning would allow this type of facility some type
of land use restriction is recommended.
Utilization of restricted land use based cleanup goals would require
some type of institutional control in place to ensur~ that the land
use remained restricted. Tbe proximity of residential land use.
should also be considered in tbe determination of appropriate cleanup
goals. .
, .
. Lead: 1000 ppm valu~ bas~d on discussions with ~egion V S~perfund
personnel, Region V.RCRA personnel, and Toxics Integration Branch
(Vashington D.C.) personnel. EPA has initiated research on adult
sensitive receptors (e.g. middle-aged hypertensive men; pregnant women)
however, it is not knoWn at this time whether the proposed value is .
protective of these receptors. Note: contacts with RCRA indicate that for
clean closure lead levels of 300 - 400 ppm have been utilized.
NOTE: this value may not be adequately protective of a child who
frequently trespasses/visits the site.
(I i)

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limited Current lend Use (lndunri.t) exposure Assumpdons . Ingeadon of chemicels in soil.
LIMITED CURRENT lAND USE (INDUSTRIAl)
'nteke (maJko-deyl .= (CSI 6 yr'
(Industria' Workerl
Worker. Adjusted for indoor exposure during 5 mon/yr
(assumed indoor dust concenlralion = 0.5 Csi
EPA 19Bge
0.8Cs
Il1g"slion Rate (1110 soil/davl
50 !Trespasser, > 6 yr!
80 IIndustrial Worker'
C
NA
essumes 50 mgd for 5 mon end 100 mg/d for 7 mon
Conversion Faclor (kg/mgl
Fraction ingested 'rom site
1 .00E.06
1
u
Exposure Frequency (day/yr'
75 !TrespAsser, > 6 yrl
250 IIndustrial Worker'
NA
u
Ave. 2.5 d/wk for 7 mon period
EPA 1991 - includes indoor dust exposure
Exposure Duretion (yr'
30 !Tresplr,lser, > 6 yrl
25 IIndustria' Worker'
u
u
EPA 1991
Body Weight (kg'
60 (Trespasser, > 6 yrl
70 (lndustrilil Worker'
C
C
EPA 1989b
Averaging Time (day.'
10950 !Trespasser, > 6 yrl
91 25 IIndustria' Worker'
25550
Noncencer Eveluetion AT = EO
Cancer Evelu..t,"n AT = 70 yeer Ii'etime
NA = not aveileble
C = Central Tendency Velue
U = Upper Bound Velue
M = Midpoint between Central Tendency end Upper Boun6 Values
. '

-------
limited Current land Usa IIndu.trla'l Expo.ure A..umptlon. . Dermal contact with chemical. In .oil.
LIMITED CURRENT lAND USE IINDUSTRIAl)
Dosa (mglkg-dayl = (CsICCFICSAxAFICABSICEFICEDIIIBWICATI
Variable
Ralionale/Ra'erence
Da'inilion
Valua Utilized
Percentile
Cs
CF
SA
 AF
 ABS
-----.. EF
VJ 
--- 
 ED
BW
Soil Concentretion (mglkgl
.CS
Conversion Factor (kg/nigl
1.00E.06
Surface ere a (cm2/eventl
2500 (Trespasser I
C
15'11. o'ave tota' body surface 116364 cm21
(10% . 2 mon period end 25% . 3 mon summer periodl
15'11. 0' ,ave total body sur'ace
3000 IIndustrial Workerl
C
Adherence Fector (mg/cm21
0.6
M
between centra' tendency velue(0.2 mg/cm21
upper bound value (1 mg/cm211EPA 19921
Absorption Factor
Chemica' specific
EPA 1992. ""tester et e'.. pro'esa. ludgement
Exposure Frequency (day/yr)
55 !Trespasser I
65 IIndustriel Workerl
NA
2.5 daYlwk fC!r 5 mon period (Mey . Sept!
3 dey/wk 'or 5 mon period IMay . Sepll
Exposure duretion Iyr'
30 (Trespesser'
25 (Industrial Worker)
U
lJ
EPA 1989a
EPA 1991
Body Weight Ikg}
60 ITrespasser}
, 70 (Industrial Workat)
C
C
EPA 19Mb
AT = Averaging Tlmaldays}
10950 !T respesser'
9125 IIndustrial Workerl
Noncancer e\/'eluatic:m AT = ED
25550
Center evaluation AT = 70 veer lifetime
NA = Not Availeble
C = Centra' Tendency Valua
U = Upper Bound Value
M = Midpoint between Centra' Tendency and Upper Bound Values

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LIMITED SHORT-TERM LAND USE - CONSTRUCTION
, Region V EPA has requested a construction scenario evaluation to determine
if the reference values would be adequately protective of construction
workers who may have much higher incidental soil ingestion rates but
shorter exposure duration. Since the exposure duration assumed was 9
months I have utilized the subchronic RfD values for the noncarcinogenic
endpoints. Please note that a subchronic RfD did not exist for cadmium
and therefore I was unable. to calculate a reference value for this
contaminant. '
Contaminant
Reference
Soil Con
(m~/kg)
Oral
Subchronic
HQ
Cancer
Risk
Metals:
Arsenic
Cadmium
Chromium III
Chromium VI
Nickel
Lead
4
No Toxici ty
10000
260
210
NA
0.1
Value
0.1
0.1
0.1
3.2E-7
NA
NA
NA
Semi-volatiles: ' ,
, cPAHs 22
acenaphthene 5500
acenaphthylene 5500
anthracene 27200
benz(ghi)perylene 2760
fluoranthene 3600
fluorene 3600
naphthalene 360
phenanthrene 27200
, pyren,e 276Q
NA
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
1E-5
NA
NA
NA
NA
NA
NA
NA
NA
NA
PCBs
. 30
NA
lE-5
(14)

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LIMITED lAND USE - SHORT-TERM 'CONSTRUCTION)
Limited Short.term lend Us. (Conetructlon) Exposure Assumption. - 'nlleetlon of chemlcels In soil.
Inteke'mg/kg-dey) = ICsxlRxCFxFlxEFxEDlflBWxATI
 Verieble Definition
 Cs Soil Concentration (mg/kg)
 IR Ingestion Rete (mg 8oil/d!ly)
 CF Conversion Fector 'kg/mg)
 FI Frection ingested from site
 EF EXposure Frequencv 'dey/yr)
 ED EXposure Duretion (Vr)
=='  
U, BW Body Weight (kg)
-
 AT . Averaging Time (deVI)
Velue Utilized
Percentile
Retionale/Raference
Cs
480
U
EPA 198ge
1.00E-06
1
U
196
NA
5 day/week for 9 mon/yr
0.75
9 monlyr
70
C
EPA 1989b
196
Noncencer Eveluetio~ AT .. ED
25550
Cancer Eveluetion AT .. 70 yeer li'~time
. NA .. not. .vai'abl.
C .. Centre' Tendency Ve'ue
U .. Upper Bound Velue
M .. Midpoint between Centrel Tendencv end Upper Bound Velues
/'

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.1
LIMITED LAND USE. SHORT.TERM (CONSTRUCTION)
Limited Short-term L.nd U.e IConatructlon) Expo.ur. A..umptlon. . Dermal contect with chemic.'. In .oil.
Dose Img/kg-devl = ICs"C~"SAxA~xABSxEFxED"IBWxATI
V.rieble
Oefinition
Velue Utilized
Percentile
RationalelRelerence
Cs Soil Concentretlon Img/kgl Cs  
CF Con vera ion Fector Ikg/mgl 1 .OOE-06  
SA Surface erea Icm2/event' 3000 C , 5% of eve totel body surlece
 AF Adherence ~actor Img/cm21 0.6
 ABS Absorption Factor Chemical spacific
~ EF Exposure Frequencv (davlvr' 196
~  
 ED Exposure duration (Vr' 0.75
 BW Body Weight (kg' 70
 AT ." Averaging Time (day.' 196
M
between central tendency I/elue 10.2 mg/cm21
upper bound value 11 mgicm211EPA 19921
EPA 1992, Westi" et el., profess. judgement
NA
5 day/week for 9 mon/yr
C
EPA 1989b
Noncencer el/aluetion AT = ED
25550
.Cencer el/eluation AT = 70 vear li(etime
NA = Not Available
C = Centrel Tendency Velue
M .. Midpoint between.Centrel Tendency end Upper Bound V..luIIB
U = Upper Bound Value

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Appendix IV
Applicable or Relevant and Appropriate Requirements

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o
Appendix IV
Applicable or Relevant and Appropriate Requirements
State ARARs.
Minnesota Statues.
.
Minn: Stat. 9115B (1992). The Minnesota Environmental Response and Liability Act (MERLA)
identifies remedial actions as response to a release to the environment and states that such actions
be "consistent \\ith a permanent remedy taken... to prevent, minimize, or eliminate the release in
order to piotect the public ~ealth or welfare or the environment" (Minn. Stat. ~ 115B.02, .'
subd 16). Burlington Northern Railroad Company (~N) has.been identified as the Responsible
Party (Minn. Stat. 9 1158.03) for the releases on the Burlington Northern Car Shop site (Site).
Therefore. BN is responsible for completing remedial actions in order to protect the public health
or welfare or the environment
.
Minn. Stat. 9 115.061 (1992 ). .The Minnesota Water Pollution Control Act provides for
protection of the waters of the State by requiring the responsible person to "recover as rapidly and
as thoroughly as possible such subSW'lce or material and take inunediately such other action as
may be reasonably possible to minimize or abate pollution of waters of the state caused thereby"
.
Minn. Stat. 9 I 15.03 (1992). MPCA may require and enforce a pennit for any discharge to the
waters of the state. Discharge of extracted waters shall be conducted in accordance with a
National.Pollutant Discharge Elimination System (NPDES) pennit if it is discharged to the Sauk
River via a .~OfJTl sewer. . Discharge of extracted waters to the MWCC sanitary sewer system for
final treatmein shall be subject to the discretion and approval of MWCC, \\:hicb must adhere to
Minnesota statutes and rules for discharge to the Mississippi River.
.
Minn. Stat. ~ 144.98. Applies to the Mumesota Department of Health authority to certify
environmental laboratories.
Minnesota Rules.
.
Minn. Rules ch. 4717. Health Risk LinUts (HRLs) are promulgated by the MDH as Minn. Rules
p~s. .4 717.7100 to 4717.7800. HRLs are. applicable to ground water cleanup and are based on the
risk associated with ingestion of water from a private well. HRLs replace Recommended
Allowable LinUts for Drinking Water (RALs) where both exist for a contaminant as HRLs are
based on more recent risk information and are promulgated. Also, HRLs, at present, are based
only on risk data available in the Integrated Risk Infonnation System (IRIS) data base. The
shallow aquifer is hydraulically connected to the deep aquifer where the City municipal wells are
located. Therefore, the shallow ground water may be considered a drinking water source.
AJthough ground water remediation is not part of the remedial action at this time, ground water
monitoring is a requirement and HRLs \\ill be used to determine if ground water remediation is
necessary. .
.
Minn. Rules ch. 7007 and 7009. Air Emissions and Ambient Air Quality Standards apply during
excavation. treatment and construction activities.
.
Mmn Rules ch 70 I 1. Odorous emissions, petroleum and volatile organic compound storage
vessels apply during excavation. treatment and construction activities. .

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2
.
MilU1 Rul~s ch. 7030. Noise Enussions. This rule applies during excavation. treatment and
construction activities.
.
Minn. Rule ch. 7035. Solid Waste Management Rule pt 7035.2815 applies to the construction and
monitoring requirements of an on-Site containment facility. A contingency action plan and post
closure requirements shall be conducted in accordance with MiM. Rule pts. -7035.2615.
7035.2645. and 7035.2655. subd 1.
..
Minn. Rule 7045. Applies to listed and characteristically hazardous w~e.' Ifa waste exhibits. on"
analysis. any of the characteristics of a hazat:dous waste. such as ignitabili~. corrosivity.
reactivity. toxicity. or Minnesota lethality. or is an oxidizer as de~ed in Minn. Rules pt. 7045.03.1
it is considered a characteriStically hazardous waste. Waste materials on the Site do meet the
toxicit~ requirements and therefore is considered a characteristically hazardous waste.
.
. Minn. Rule ch. 7050. Standards for water classifies surface v\:aters of the state and provides water
quality Standards for these classified waters. Water quality standards are to be obtained if
extracted ground water is discharged to the Sauk River. Additionally. direct discharge via storm
sewer shall be regulated under an NPDES permit. Discharge to the sanitary sewer system will
require that pr~treatment standards prior to discharge to ensure that final treatment is compatible
with the discharge standards.
.
Minn. Rules ch. 7060 (199 I). Under its broad statutory authority to protect the quality of water of
the state. the MPCA has adopted general policies and Standards for the protection of ground water
fro'm pollution under ~. Rules ch: 7060. which were promulgated "to 'p.reserVe and protect the
underground water of the state by preventing any new pollution and abating existing pollution"
(Minn. Rules pI. 7060.0100). Minn. Rules pI. 7060.0200 states. "It is the policy of the agency to
consider the actual or potential use of the underground waters for potable water supply as
constituting the highest priority use and as such to provide maximum protection to all underground
waters. The ready availability nearly statewide of underground water conStitutes a natural
resource of immeasurable value which must be protected as nearly as possible in its natural
condition. For the conservation of underground water supplies for present and future generations
~d prevention of possible health hazards. it is necessa1')~ and proper that the agency employ a
nondegradation policy to prevent pollution to ~e underground waters of the state."
Minn. Rules pI. 7060.0400 provides that "all underground waters are best classified for use as
potable water supply in order to preserve high quality waters by minimizing spreading of
pollutants. by prohibiting further discharges of wastes thereto. and to maximize the possibility of
rehabilitating degraded waters for their priority use." Minn. Rules pI. 7060.0600 provides
standards relevant to contamination of the saturated and unsaturated zones. Subpart 1 prohibits
discharge of pollutants to the saturated zone and Subpart 2 prohibits the discharge of pollutants to
the unsaturated zone. Subpan 2 states that. "No sewage. industrial waste, other waste. or other'
pollutants shall be allowed to be discharged to the unsaturated zone or deposited in such place,
manner. or quantity that the effluent or residue therefTom. upon reaching the water table. may
actually or potentially preclude or limit the use of the underground water as a potable water
supply. nor shall any such discharge or deposit be allowed which may pollute the underground
waters." Finally. Subpan 3 provides that, "T reannent, safeguards, or other control measures shall
be provided by the person responsible for any sewage. industrial waste. other waste, or other
poJlutants which are to be or have been discharged to the unsaturated zone or deposited there. or

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(,
3
which have been discharged to the zone of saturation. to the extent necessary to ensure that the.
same will not constitute or continue to be a source of pollution of the underground waters or impair
the natural quality thereof"
.
Mum Rules ch. 4725. The Water We)) Code provides standards for the construction. maintenance
and sealing of wells. environmental boreholes and exploratory bor:mg_s.
.
Mirm. Rule 4740. Applies to the certificatjon procedures and standards for laboratories.
.
Mirm. Rule 5205. Health and safety standards' for worker health and safety and training as defined
py the Mirmesota Deparunent of Labor and Industry. .
F ederaJ ARARs.
.
Comprehensive Environmental Response. Compensation: and Liability Act (CERCLA) was
amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA), which added
Section 111 to CERCLA. which provides some specific cleanup requirements. Among the changes
is the preference for permanence In selecting a remedy and.the use of applicable or relevant and
appropri.att: requirements. The NCP implements the requirements of CERCLA Section 121 for
using ARARs. as we)) as other standards and critena, to guide cleanup decisions at Superfund
Sites where EP A or the state under a cooperative agreement with EP A exercises cleanup authority.
The NCP defines the "relevant and appropriate requirements" portion of the ARARs as being
"those cleanup standards. standards of control. and other substantive requIrements. criteri~ or
limitations promulgated under federal environmental or state environment or facility citing laws'
that. .while not "applicable" to. a hazardous substance, pollutant. contam.ina:nr. remedial action.
location. or other circumstances at a CERCLA site, address problems or situations sufficiently
similar to those encountered at the CERCLA site that their use is well-suited to the particular site. .
Only those state standards that are identified In a timely manner and are more stringent than federal
requirement may be relevant and appropriate:' (40 CFR 300.5 [1990)).
.
40 CFR 258 Post closure care and monitoring must continued for 30 years unless a decrease
period can be approved by the MPCA. . .
.
Safe'Drinking Water Act. 1'Jational Primary Drinking Water Standards (40 CFR part 141-143)
Ma.ximum Contaminant Levels (MCLs) and Maximum Contaminant Level Goals (MCLGs) are
health and treannent based numbers for regulating public water supplies. Although the shallow
aquifer is not used for a drinking water supply. it is hydraulically connected to the deep aquifer.' In
addition. although ground water remediation is not part of the remedial action at this time. ground
water monitoring is a requirement and the MCLs and MCLGs will be used in evaluating whether
ground water remediation is necessary.
.
Clean Water Act Water. Water Quality Criteria (40 CFR Part 131 Quality Criteria for Water'
1976. 1980, 1986) are to be attained if ground water remediation is necessary and treated ground
water is discharged to the Sauk River.
Toxic Pollutant Effluent Standards (40 CFR Part 129) Effluent standards are to be attained for
PCBs if treated ground water is discharged to the Sauk River.

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4
.
The:: Rc:source ConservatIon and Reco\'ery Act (RCRA). passed in 1976 and amended by the
Hazardous and Solid Waste Amendments in 1984. is an amendment to the Solid Waste Disposal
Act of 1965. and is intended to ensure that solid wastes are managed in an environmentalI) sound
mannc:r. The objectIves of RCRA are to protect human health and the environment. reduce waste
and conserve energy and natural resources. and reduce or ehminate the generation of hazardous
waste as expeditiously as possible. -- -
Identification and Listing of Hazardous Waste (40 CFR Part 261), defines solid wastes which are
subject to Tegulation as hazardo~s waste under 40 CFR Parts ~62-265 and Pans 124. 270, and
271. . .
Subtitle C of RCRA establishes Land Disposal Restrictions (LDRs) (40 CFR Part 268), which
restrict the land disposal of RCRA hazardous wastes. and would apply to the characteristic
hazardous waste or medIum that is moved off-Site for treatment. disposal. or storage. The waste
generated at the Site contains lead and PCBs at levels considered charactenstically hazardous.
Subtitle C also allows the use of CorrectIve Action Management Units (CAMUs) to be'
imple~ented for a response action that fomerly would have been restncted by LDRs (40 CFR
Parts 260. 264. 268. 270. and 271).
Ground Water Monitoring Response Requirements (40 CFR 264.94). regulate the concentration of
a compound that may not exceed background. or Standards for 14 toxic compounds or an alternate
level and \\ill be applied to determine if ground water remediation is necessary.
.
Clean Air Act. National Prima1') and Secondary Ambient Air Quality Standards (40 CFR .
Part 50). establishes Standards to ambient air quality to protect public health and welfare inCluding
standards for paniculate maneI' and lead. Fugitive dust emissions from any excavation, .
construction or treatment must not exceed NAAQS requirements for particulate matter or lead.
To Be Considered.
.
RALs. The RALs. Minnesota Department of Health (MDH). Release No.3, lanuary 1991. are
not promu.lgated Stand,ards and. therefore. are not considered ARARs. However" the RALs may be,
included. in the category of "to be considered" guidance. This category includes criteria. adVisories.
, and proposed standards issued by federal.or state governments that are relevant because they
address circumstai1ces sufficiently similar to those at this Site and their application is well suited in
detennining whether response actions are reasonable and necessa1')' to prot~ the public health and
welfare. or the environment. RALs use infomtation from the IRIS and HEAST data bases as well
as other references and are used for determining the risk associated with ingestion of water from a
private well. Although ground water remediation is not part of the remedial action at this time,
ground water monitoring is a requirement to determine if ground water remediation is necessary.
Water quality cleanup levels if necessary will be consistent with MCLs and HRLslRALs.
whichever is lower for a specific contaminant. .
.
10-5 Risk Level. Unpublished September 1985 Minnesota Department of Health Report on
tolerable risk levels/exposures

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Appendix V
Generic Request for Response Action Guidefines
for Remedial DesignlResponse Action Plans

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1.
II.
III.
rv.
v.
J
EXHIBIT B
Table of Contents
IN'l'RD.CI'Irn . . . .
~ CIH5ULTANI'.
. . . . .
.........
. . . . . . ~1
. . . .
. . . . .
. . . ~1
.................
REMEDIAL IESI~/RESP(H)E N:TI~ PLAN . . . . .'. . . . . . . . . . . B-1
IILA. 'ro/RA Plan Sutmittal .. " . . . . . . . . . . . . . . .'. . B-1 '
III.B., RD/RA Plan Contents. . . . . . . . . . . . . . . . . . . . ~ B-1
IILB.l. Renedial Design. . . . . . . . .' . . . . . . . . . B-2 '
I11.B.2. Monitoring Plan. . . . . . . . . . . . . . . . . . B-2
III.B.2.a. EnvriroJlrllelltal Madia and Analytical
:ParameterList . . . . . . '. . . . . . 'S-3
IILB:o;2.b.-Monitoring'Facility,I.ccation and

Design. . . . . . . . . . . . . . . . B-- 3

III.B.2.c. Sampling Schedule. . . . . . . . . . . ~3
IILB.2.d. Reporting Plan. . ~ . .'. . . . . . . B-3
RBnedi.al D:!sig:nl,~.<)use ktion Plan Inplarentation. . . . . B-4
RA IJrpIEllE!l'1tation' .Jepol.t . . . .' . . . . . . . . . . . . . . B-4
1ILC.
III.D.
~. 00 ~~ m' RA . . '. . . . . . . . . . . . . .' . . .
. . B-5
. ,
liPCA.cx:liMISS1aoER .AC'1'I~. . . .,.'. '. . . '. . . . . . . . . . . . . B-5
V.A. . Approval of the RD/RA Plan, RA Inplarentatj,on ~rt,
and Carpletion of RA Report. . . . . . . . . . . . . . . . . B-S
--

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J
I.
II.
III.
III.A.
II1.B.
Exhibit B
REMEDIAL IESI~ AND RESPCH;E ACTIOO IMPlEHENrATIOO
nma:u:TIOO
.
Part II.B. of the Request for ~nse Action (RFRA), to wtUch this'
Exhibit is, appended; requests the Responsible Party (RP) to prepare a.
Ranedial ,Design/Response Action Plan (RD/RA Plan) and iJrplerrent ' "
Response Actions (RAs) at the Site. This Exhibit sets forth the
requ.i..ratents for preparing the RD/RA Plan and implenenting the RAs,
which have been selected by the Minnesota Pollution Con1:J:ol Aqency
(MPCA) Carmissioner pUrsuant to Part IV.D. of Exhibit A to the RFRA,
and is appended to and'made an integral part of the RFRA.
RETAIN a:KSULTANl'
~
The RP shall retain' a consultant qualified to undertake and c~lete
the, requirerrents of this Exhibit. If the RP retains the same
consultant used to canplete EXhibit A to the RFRA, the RP shall
proceed .iJmedi.ately with preparation of the RD/RA Plan. If the RP
chooses to retain a different consultant, the RP shall retain the ','
consul tant and notify the MPCA project ma.nager of the nane of that
consul tant within thirty (30) days of notification of approval of the
FS Report by the MPCA Catrnissioner. ' ,
REMEDIAL IESlc.;w/~ lCl'IOO PLAN
RD/RA Plan Subnittal
, ,
Within sixty (60) days of notification of approval' of the FS'Report
by the MPCA Ccmnissioner, the RP shall p~ and sul:rnit to the MPCA
Ccmnissioner for review and- apprOval a RD/RA Plan which shall be
based on the approved RI/FS repJrts and the Record of Decision (ROO)
issued by the MPCA Carmissioner under Exhibit A to the RFRA.

RD/RA Plan Ccntents
The purpose of the RD/RA Plan is to' provide a detailed design, an
iJrplerrentation schedule, and a J'lDnitoring plan for the RAs specified
in the ROD which, up:m .i.rrq:>lerrentation, will protect the public health
and welfare, and the environnent fran the release or threateried '
'release of hazardous substances, pollutants or contaminants, at or
fran the Site.
The RD/RA Plan shall set forth in detail the steps necessary to
inplem:mt the Site Lt2I.edy specified in ROD. The RD/RA Plan shall
include a restaterrent of the response action objectives and cleanup
levels specified in the ROD. The RD/RA Plan shall include, at a
minimum, the following: '

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III .B.1.
III.B.2.
-B-2-
Remedial Design. The purpose of the rem:dial design is to specify
detailed nethods and tine schedules for the inplanentation of the
RAs specified in the ROD. This section shall include, at a minimum,
the following elements:
o design criteria and rationale;
o a plan view drawing of the overall Site, showing general locations
for response ~ctioll> carp:>ner1ts;
o technical and operational pl;ms and engineering designs for I ,
iJrplenentation of the response action including plan and cJ:oss
sectional views for the individual carponents to be installed or
actions to be iJrplmented; ,

o a description of the types of equipnent to be employed, including
capacity, size, and materials or construction;
o an operational description of process units or other RA ccmponents;

o process flow sheets, including process material (e.g., chanica! or
activated carbon) consurrption rates, and a description of the
process;
(I a discussion of potential eonsb:uction problems and respective
contingency plans;
',-~_.'
o a schedule for .iJtplenenting the,construction phase;
o a Site-specific hazardous waste transportation plan (if necessary);

o the identity of all contractors, transporters, or other persons
conducting raroval or response actions at the Site;
'0 a description of any peImits or licenses required to .inp~enent the
RA; .
'. ,

, 0 a description of the p:>st RA operation. and maintenance .proceciures
and schedules; and ,
o a description of activities to be undertaken by the RPs during M
inplenentation to fulfill the reguiranents of Part III, Sections .
C.l. (Project Management), C.3. (Sanpling and Investigations), C.S.
(Record Retention), C.B. (Site Security and Safety Plan), and C.9.
(Ccmmm.i ty Relations) of Exhibit A to the RFRA as they pertain to
the reroval or response actions and operation and maintenance
activities.
~
RA Jobnitorinq Plan. The RD/RA Plan, shall prop:>se an RA m::>nitoriJ1g
plan for the Site. The purpose of post RA inplanentation nonltoring
is to detezmine the status and effectiveness of the implemented RAs.
The RA nonitoring plan shall, at a min.i.murn, contain the follCMing in
order to deteDnine that the cleanup levels specified .in the ROD are
achieved:

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-8-3-
J
Enviionmental M:!di.a and Analytical Parameter List. 'n1e
environmental ne::ii.a (soil, ground water, surface water and air) and a
corresFOrxling list of analytes to be nonitored shall be proposed, .
ala>ng with the selection rationale, and a corresponding list of
chanical analytical nethodologies (including EPA or Standard l-Ethod
numbers am detection limits) to be perfoDled.

III.B.2.b. M:>nitorinq Facility location and Desiqn. The design and location of
.all nonitoring facilities/locations shall be propoSed.
III.B.2.a.
Sanq:>linq Schedule. A sanpling. schec:fule for the enalytical paramet~rs
proposed in the RA m:mitoring plan for all mnitoring locations shall
be proposed. Sarrpling shall ~ at a minimum, be conducted on a
quarterly basis. . .

III.B.2.d. Reportinq Plan. A schedule for reporting the results of long-term
nonitoring to the MPCA shall ~ proposed. The sc~le shall, at a
minirmJrn, contain the following: .
III.B.2.c.
1. Quarterly M:mitoring Reports. The RP shall su1:rnit analytical
results to the MPCA Ccmnissioner quarterly by [specify date]
follCMing the sartFling catpleted during the pxevious quarter.
2. Annual M:mi torinq Reports. The RP shall su1:rni t an Annual.
M:mitoring Report. to the MPCA Ccmnissioner ~ or before January 1,
[year] and each January.1 thereafter. Any rened.ial technology
anployed in implanentation of the RD/RA Plan shall be left in place
and operated by the RP until the MPCA Ccmnissioner authorizes t.he RP
in writing to discontinue, nove, or m:xii.fy SCJ1le or all of the .
retedial technology. The RP may request discontinuation of the
rerredial technologies in the aImual report., when the cleanup levels
set forth in the RJD have been achieved. ':Ote RP shall nDVe or mxtify
the ~ial technology when the JrDVaI1Bnt or JlCdifications, as
approved by the MPCA Ccmnissioner, nay better achieVe the rBnedial
action o:pjecti ves set forth in the RJD. .
,
The Annual M::>ni t.oring Report shall contain the follQ\7ing:
o a Site map S)1CMing all nonitoring locations;
o the results of all parameter analyses for the previous year;
o the. results of all water level neasuranents for the previous year;
;)
o regional am Site specific ground water piezaretric maps for each
aquifer including surface water elevat.ions;

o cross section(s) indicating relative carmun.i.cation between
aquifers;
o a map for each sanpling event showing each m:mitoring location with
contaminant concentrations and isoconcentration lines for selected
parameters ;

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. III.C'.
III.D.
-8-4-
o graphs and tables illustrating the' concentrations over tine using
data fran each salli'ling event (these graphs and tables shall be
cumulative showing parameter analyses' for all previous years as
well as the reporting year); and

o a sampling plan for the next year with an asseSsnent of the
m:mitoring parameters, sarJi>ling frequencies, and the need for the
ad<:ti:-tion or deletion of ncnitoring locations and parameters.
mIRA Plan Inplerrentation'

Within thirty (30) days of the ~ Ccmnissioner approval of the
RD/RA plan, the RP shall initiate the RA. The pu.rp:>se of RA
implementation is to take those actions which will protect the public
health and welfare, and the environment fran the release or .
threatened x:elease of hazardous substances or pollutants or
contaminants at or fran the Site.
The IID/RA Plan, as approved or m:x:iified by the MPCA Ccmnissioner
shall be implemented in accordance with the tine schedules set forth
in Part III of the RFRA and Part III.B. of this Exhibit. The
.iJ1planentation of RAs shall be conducted in accordance with all
applicable federal and state MARs, and local laws, rules,
regulations, and .ordinances. . .

During implementation of the IID/RA Plan, the MPc-A Carmissioner may
specify such additions and/or revisions .to the RD/RA Plan as the
Ccmnissioner deems necessary to protect public health and welfare,
and the environment.
. .
RA IJrplEm!ntation ~rt

Wi thin sixty (60) days of the catpletion of . implementation of the RAs
specified in the approved RD/AA Plan, a RA Inplanentation Report
Which' includes the following .elements, shall be subni tted to the MPcA
Ccmnis.sioner: . .
o the data and results of the RA jrnplanentation;

o the follCM-up actions, if any, to be taken in the follCMing
one. year period;
o a certification that all work plans, specifications, and schedules
have been implanented andcanpleted in accordance with the RD/RA
Plan as approved or m:xiified by the MPCA Carmissioner:

o discussion of difficulti-es encountered during the jnpletentation
that may alter and/or iJtp3ir or otherwise reduce the effectiveness
of the AA iJlIplementation to prevent, eliminate, or minimize the
release or threatened release of hazardous substances or pollutants
or contaminants, at or f:ran the Site, or which may require
unanticipated operational or maintenance actions to naint.ain the
effectiveness of any of the iItq)lerrented RA5; and

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IV.
u
V.
V.A.
..;
-8-5-
o a discussion of any necessary m:xlifications to the operation and
naintenance procedures as approved.
~. 00 aK'IETI~ OF RA
" .
Wi thin sixty (60) days. of notification, by the MPCA Ccmnissioner,
that all Site-specific Response Action Cbjectives and Cleanup levels
(ExtUbit A, Part. IV .-A.) have been. net, "a Report on CClTpletion of. RA, . .
which includes the follCMing elarents, shall be subnitted to the MPCA: .
Ccrrmissioner. '. -
. 0 a surmary of the response action objectives and cleanup levels and
a history of how they were net;

o certification that all RAs have been properly dismantled, including
supporting documentation (e. g., ncnitoring \Io1e11 abanc.1onnEnt logs);
o a surtmary of any ongoing institutional controls (e.g"., deed
restrictions);
o a final cost surrmary.
MPCA CD!MISSIcm:R N:rICN;
The RP shall subnit to the MPCA Camdssioner all plans, reports, or
other docunents (subnittals) required by this Exhibit. The review
and approval, approval with m:d.ifications and! or a request for
additional info:anation, or rejection of sub'nittals shall be in
accordance with this section and Part IV of the RFRA. The Site
Safety and Security- Plan does not require MPCA. Ccmnissioner appxoval.

~ Of '!he mIRA Plan, RA' IIIplsrentation ~rt, Alxf Report On
. .Carpletibn Of RA .' .
The MPCA Ccmn.issioner shall review and approve, approve with ..
JrCX1ifications and/or a reqUest for additional infoD11ation, or reject
the RD/RA Plan, RA Irrplatentation Report, and the Report on
Carrpletion of RA based on the requirenents of Parts III.B, III .D, arXi
'IV respectively. Mxlifications by the MPCA Ccmnissioner are. final.

If the MPCA Ccmnissioner approves the RD/RA Plan, ~ Implanentation
Report, or the Report on Catpletion of RA with a requirement to
provide addi tienal info:anation, the Carmi.ssioner will: I) specify
the deficiencies in the RD/RA Plan, RA Inplal1entation Report, or the
Report on Catpletion of RA that necessitate the need for additional
infoDnation; 2) provide direction to address the deficiencies;
3) specify the manner in which the RP shall document or otherwise
convey the additional infoDnation; and 4) specify the t.iJre frane for
sUDnission or conveyance of Ole requested adili.lional infoDI1at.iol1.

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-B-6-
If the MPCA Ccmnissioner rejects the RD/RA Plan, RA Implenentation
Report, or the Rep:>rt on Cati>letion of RA, the Ccmnissioner will:
1) specify the deficiencies in the RD/RA Plan, RA Inplementation
Report, or Canpletion of RA Rep:>rt that necessitate the rejection;
2) p~ide direction to address the deficiencies; 3) specify the
manner in which the RP shall document or othe%Wise convey the
infoDnation necessary to correct the deficiencies; and 4) specify the
time frame for subnission or conveyance of the infonnation necessary
to correct the deficiencies. .

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. .


'.'.-\. Minnesota Pollution Control Agency
July. 20, 1994
. Mr. Mark Stromberg,
Remedial Technologies, Inc.
8700 Monro,ia, Ste. 300
Lenexz,~as 66215
RE: Re: Record of Decision for the Burlington Northern Car Shop, Waite Park, Minnesota.
Dear Mr. Stromberg:
Enclosed is a copy of the Record of Decision (ROD) for the Burlington Northern Car Shop site
(Site), Waite Park, Minnesota. This ROD presents the selected remedial action for lagoon waste
and sandblast sand remediation. and the ground \\'ater monitoring at the Site. The ROD \\'as
developed in accordance with Minnesota Pollution Control Agency October 22, 1985, R:equeSt for
Response Action, the Minnesota Environmental Response and Liability Act, Comprehensive
Environmental Response, Compensation, and Liability Act. (CERCLA), as amended by the
Superfund Amendments Reauthorization Act and, to the extent practicable, the National .
Cont~gen(:y Plan. . . . .
The MPCA staffhas reviewed and is reviewing.the June 1994, Design Report and Specifications.
The MPCA staff will provide Burlington Northern Railroad Company (BN) with their comments
to the Design Report and SpecificatioD9 by July 22, 1994. It is our understanding that BN has
already began treatability studies on the waste. The MPCA staff request BN to submit their
treatability study work plan by July 25, 1994. BN sball also submit a proposed schedule for
. implementation of the ROD by Ju]y 25, 1994.
520 Lafayette Rd. N.; 51. Paul. MN 55155-4194; (612) 296-6300 (voice); (612) 282.5332 (TTY)
Regional Offices: Duluth. Brainerd. Detroit Lakes. Marshall. Rochester
Equal Opportunity Empl"oyer. Printed on recycled paper containing at least 10'\0 fibers from paper recycled by consumers.

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Mr. Mark Stromberg
Page 2
.July 20, 1994
The MPCA staff look forward to the timely completions of the ~~ctions of the remedy and
your continued cooperation. If you have any questions regarding this letter .or the enclosed ROD
please cOntact me at (612) 296-7813.
Sincerely,

~~tAJ~A . .

BrenU' J~er, Project Manager
Responsible Party Unit I
Site Response Section
Ground Water and Solid Waste Division
enclosure
cc:
Joe Aiken, ENSR Consulting and Engineering, Ft. Collins, Colorado
Sheila Sullivan, U. S. Environmental Protection Agency
Steve Poissant, Waite Park City Council
Mayor Al Ringsmuth, City of Waite Park
Doug Connell, Barr Engineering
John Knoepfler, Robins, Kaplan, Miller & Ciresi
Alan Williams, Attorney General's Office
James Brandt, Waite Park Manufacturing, Inc.
Katherine Carlson, Public Infonnration Office

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