United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/ROS-87/047
March 1987
Superfund
Record of Decision
New Brighton/Arden Hills/
St. Anthony, MN
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TECHNICAL REPORT DATA
(Pteaie read Instructions on the reverse before completing!
EPA/ROD/R05-87/047
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
SUPERFUND RECORD OF DECISION
New Btighton/Arden Hills/St. Anthony, MN
Fifth Remedial Action
7. AUTHORIS)
i. REPORT DATE
March 31. 1987
I. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
11. CONTnACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. TYPE OF REPORT AND PERIOD COVERED
Final ROD Report
14. SPONSORING AGENCY CODE
800/00
15. SUPPLEMENTARY NOTES
6. ABSTRACT -^
The New Brighton/Arden Hills/St. Anthony site is located approximately two miles
north of the Twin Cities of Minneapolis/St. Paul, Minnesota. The City of St. Anthony,
located directly north of the Twin Cities, is one of several communities which obtain
its municipal water supply from the Prairie due Chien-Jordan aquifer system. The City
of St. Anthony obtains its water supply from well numbers 4 and 5 and an interconnectior
to the City of Roseville's water distribution system. In June 1981, the Minnesota
Pollution Control Agency (MPCA) and the Minnesota Department of Health (MDH) detected
VOC contamination in the Praire du Chien-Jordan aquifer system used for municipal
drinking water in New Brighton. Subsequently, the City of St. Anthony has also detected
VOC contamination in their three Praire du Chien-Jordan aquifer wells; well number 3, 4
and 5. Well 4 is the city's major source of water. Well 5 and the Roseville
interconnection are used for summer, peak, or emergency situations. Well 3 was shut
down in early 1984 due to VOC contamination. As the number of contaminated wells within
the Praire due Chien-Jordan began increasing, EPA initiated several Initial Remedial
Measures. In 1983 granular activated carbon filters were installed on New Brighton
wells 5 and 6 and several private well users were connected to New Brighton and Arden
Hill's watermains. In 1984 the City of St. Anthony received a temporary water
connection to the City of Roseville due to water shortages resulting from subsequent
(See Attached Sheet)
7.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lOENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Record of Decision
New Brighton/Arden Hills/St. Anthony, MN
ifth Remedial Action
Contaminated Media: gw
Key contaminants: VOCs, TCE, DCE
8. DISTRIBUTION STATEMENT
19. SECURITY CLASS (This Report I
None
21. NO. OF PAGES
150
20. SECURITY CLASS (This page I
Nonp
22. PRICE
EPA Farm 2220-1 (R«v. 4-77) PNKVIOUS EDITION is OBIOUCTC
-------
EPA/ROD/R05-87/047
New Brighton/Arden Hills/St. Anthony, MN
Fifth Remedial Action
16. ABSTRACT (continued)
closure of a contaminated well. The primary contaminants of concern
affecting the ground water include: TCE, DCE, and other VOCs.
The selected remedial action for this site incudes: construction of
granular activated carbon (GAC) water treatment facilities to remove VOCs
from St. Anthony wells 3, 4, and 5 with discharge to the municipal water
treatment plant and distribution system; and construction of a pipeline to
connect St. Anthony well 5 with the GAC treatment facilities. Total capital
costs for the selected remedial action is estimated to be $1,100,500 with
annual 06M costs of $160,770. The MPCA plans to complete its evaluation of
final remedial actions in 1988.
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Record of Decision
Remedial Alternative Selection
Operable Unit for Provision of
Alternative Water Supply
Site: New Brighton/Arden Hills/St. Anthony
St. Anthony, Minnesota
DOCUMENTS REVIEWED
The following documents describing the analysis of the cost effectiveness
of the remedial action alternatives for the New Brighton/Arden Hills/St.
Anthony site have been reviewed:
- Phased Feasibility Study for St. Anthony, Minnesota, Camp Dresser
and McKee, December, 1986
- Summary of Remedial Alternative Selection
- Responsiveness Summary
DESCRIPTION OF SELECTED REMEDY
Construction of granular activated carbon (6AC) water treatment
facilities to remove volatile organic compounds from the contaminated
water from St. Anthony Wells 3, 4 and 5. The treated water will be
discharged into the municipal water treatment plant and distribution
system.
Construction of a pipeline connecting St. Anthony Well 5 to the GAC
treatment facilities.
DECLARATIONS
Consistent with the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (CERCLA), the Superfund Amendments and Reauthorization
Act of 1986 (SARA), and the National Contingency Plan (40 CFR Part 300),
I have determined that construction of GAC water treatment facilities to
treat contaminated water for water system treatment and distribution, and
construction of a pipeline connecting St. Anthony Well 5 to the GAC water
treatment facilities is a cost-effective remedial action (operable unit),
provides adequate protection of public health, welfare, and the environment,
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-2-
can attain applicable or relevant and appropriate requirements, and is
consistent with future remedial actions. The State of Minnesota has been
'consulted and. concurs with the approved remedy. The action will require
future operation and maintenance activities to assure the continued
effectiveness of the remedy. These activities will be considered part of
the approved action and eligible for Trust Fund monies for a period not to
exceed 10 years.
It has also been determined that the action being taken is appropriate when
balanced against the availability of trust monies for use at other sites.
The State of Minnesota, through the Minnesota Pollution Control Agency
(MPCA) is continuing its comprehensive Remedial Investigation/Feasibility
Study (RI/FS) for the entire New Brighton/Arden Hills/St. Anthony study
area through a cooperative agreement with the U.S. Environmental Protection
Agency. The U.S. Army/Department of Defense is also conducting studies to
define the contamination emanating from the Twin Cities Army Ammunition
Plant (TCAAP). Other identified potentially responsible parties are
performing studies both on and off the TCAAP within the study area. The
MPCA has already completed a preliminary remedial investigation (RI) charac-
terizing the site, major migration pathways, and preliminary identification
of significant sources. The MPCA is planning to complete the remaining
tasks of the comprehensive RI/FS in 1987-88 in order to evaluate potential
final remedial actions. If additional remedial actions are determined to
be necessary, a Record of Decision will be prepared for approval of the
future remedial actions. The St. Anthony municipal wells operable unit
will, to the extent practicable, contribute to the efficient performance of
any long-term remedial action.
31 MAR 1987 ___
Date Valdas V.~A"darnkus
Regional Administrator
United States Environmental
Protection Agency, Region V
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FIGURE 1
93'30'
p'
«'-v
>>
0°/
9**
y."1
; Ft
J-'
____ CARVSR
^a >
SCOTT
HENNSPIN
DAKOTA \
93*
20 MILES
10
20 30
-------
FIGURE 2
NEW BRIGHTON
t
TO^jljAjrEjSHTS ;/
VX ,"','"" |."-lasa:
i : - j>-
'. Is* J * .1
ROSEVILLE
ST. ANTHONY
NEW BRIGHTON/ARDEN HILLS
PFS ST. ANTHONY
MUNICIPAL WELLS
SITE LOCATION MAP
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FIGURE 3
, -
""V ' l* ^'rr^V-f-=r.;.ri
'r!* NEW BRIGHTON ll:: ~ <~^( -:t
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COLUMBIA
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xWELL
° I*"* * /
*
. ANTHONY
EXISTING ROSEVILLE
CONNECTION
RESIDENTS SUPPLIED BY
ROSEVILLE
i i '"*i'7S». _. . -/X .
f\\«M*-«^r'' W\\*r/+ ,K:-- ....-
Wl«.a-y^ K, r/. ^--^-
BRIGHTON/ARO£N HILLS
PFS ST. ANTHONY
MUNICIPAL WELLS
WELL LOCATION MAP
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FIGU3E
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a
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-------
Summary of Remedial Alternative Selection
St. Anthony Municipal Water Supply
Site Location and Description
The New Brighton/Arden Hills/St. Anthony Superfund National Priorities List
site is located immediately north of the Twin Cities of Minneapolis/St.
Paul, Minnesota. This "site" includes the majority of the New Brighton
Quadrangle, which includes parts of Anoka, Hennepin, and Ramsey counties
(Fig. 1).
The City of St. Anthony is located directly north of the Twin Cities of
Minneapolis/St. Paul, Minnesota, and is one of several communities in the
area which obtains its municipal water supply largely from groundwater
resources (Fig. 2).
At the present time, the City of St. Anthony obtains its water supply from
two municipal wells (well numbers 4 and 5) (Fig. 3) and an interconnection
to the City of Roseville's water distribution system. Of the three supplies,
well 4 is the major source of water. Well 5 and the Roseville interconnection
are used for summer, peak or emergency use. Well 3 has been shutdown since
early 1984 because of contamination by volatile organic compounds (VOC's).
Presently, the water treatment system at St. Anthony allows the groundwater
from wells 3 and 4 to be treated for manganese and iron removal and
chlorination while water from well 5 can only be chlorinated.
There are two major bedrock aquifers capable of large well yields within
the study area. These aquifers are the Prairie du Chien-Jordan and the Mt.
Simon-Hinckley systems (Fig. 4;. In addition, at some locations the
Platteville-St. Peter Sandstone and the Franconia-Ironton-Galesville
formations are reported to provide low to moderate yields of groundwater.
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-2-
However, in large areas of the New Brighton area, the Platteville and St.
Peter Sandstone aquifers have been eroded away.
The nost significant bedrock aquifer in the study area with regard to water
supply- is the Prairie du Chien-Jordan aquifer system. Approximately 75-80%
of all Twin Cities metropolitan area communities that obtain their water
from groundwater supplies, receive those supplies fron the Prairie du Chien-
Jordan aquifer system. The chief aquifer existing in the undifferentiated
glacial deposits is the Hillside Sand. Within the study area, the Hillside
Sand aquifer has historically served as a major aquifer for residential and .
light industrial use. Overlying the Hillside Sand (over most of the study
area) is the Twin Cities Formation. This formation -is a complex till unit
consisting of, in order of abundance, sand, silt, and clay mixed with gravel
and occasional boulders. The Twin Cities Formation is overlain by several
types of surficial deposits including various aeolian, fluvial and lacustrine
deposits.
The Twin Cities Formation, where present, generally serves as an aquitard
that limits vertical migration of water from the surficial deposits to the
underlying Hillside Sand. However, the Hillside Sand outcrops at several
locations in the New Brighton area, allowing direct recharge from the ground
surface. The most critical outcrop area is located at the Arsenal Kame
located at the Twin Cities Army Ammunition Plant (TCAAP). As the Platteville
and St. Peter Sandstone aquifers have been eroded away over much of the
study area, the Hillside Sand is in direct contact with the underlying
bedrock (Prairie du Chien and/or Jordan formations).
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-3-
SITE HISTORY
In June 1931, the Minnesota Pollution Control Agency (MPCA) and the Minnesota
Departnent of Health (MDH) detected VOC contamination in the Prairie du Chien-
Jordan aquifer system used for municipal drinking water in New Brighton.
Subsequently, the City of St. Anthony has also detected VOC contamination
in their three Prairie du Chien-Jordan aquifer wells; well numbers 3, 4
and 5.
From 1982 to 1984, the City of New Brighton shut down six Prairie du Chien-
Jorrian aquifer wells, deepened two municipal wells to the Mt. Simon-Hinckley
aquifer, and constructed three new wells into the Mt. Simon-Hinckley aquifer.
During this same period, VOC contamination levels in all three St. Anthony's
municipal wells were rising. Due to these increasing levels, well 3 was
taken out of service in early 1984.
Because of the increasing municipal well contamination being experienced in
the area, several Initial Remedial Measures (IRM's) were implemented at the
site under the Superfund program in 1983 and 1984. In 1983, the U.S. EPA
performed an IRM by installing granular activated carbon filters on two of New
Brighton's wells (5 and fi) to meet peak summertime demands.
Also in 1983, pipeline connections to New Brighton's and Arden Hills'
water mains were made for several private well users whose wells had
excessive levels of VOC contamination. This IRM was a state-lead project.
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-4-
Lastly in 1984, the City of St. Anthony, which is immediately south of New
Brighton, received a temporary water Connection to the City of Roseville.
This state-lead IRM was necessary because the City of St. Anthony was .exper-
iencing Water shortages due to the contamination and subsequent closure of
one of their three Prairie du Chien-Jordan aquifer municipal wells.
In June 1985, the U.S. EPA completed a Phased Feasibility Study (PFS) which
investigated alternative supply and treatment options for New Brighton well 7.
The VOC contamination levels in this standby and emergency-use well has
remained relatively low; however, no trend has been established as to whether
the levels will increase or decrease. Because of the need of this supply,
the lengthy implementation times of remedial alternatives and the uncertainty
of future contaminant levels, U.S. EPA plans' to install an alternative
water supply prior to contamination levels rising above health criteria
levels.
In 1983, the MPCA and U.S. EPA entered into a state-lead cooperative
agreement to conduct a remedial investigation (RI) of this site to determine
the extent of the contamination and to determine the source(s) of the contam-
ination.
Preliminary results from this study indicate that the groundwater flow in
the Prairie du Chien-Jordan aquifer is toward the southwest, while the
Hillside Sand aquifer generally flows in a west-southwest direction. Study
results also indicate that contamination in the New Brighton area is comprised
of separate eastern and western plumes, originating in the vicinity of the
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-5-
TCAAP, that are impacting New Brighton's eastern and western well fields.
Currently, there is little firm evidence as to the extent of the plumes in
the St. Anthony area.
Potential sites that may be contributing to the observed contamination were
assessed and it has been concluded that four significant source areas of
contamination may exist within the study area. These general source areas
are located either on the TCAAP or in the vicinity of the TCAAP and are
identified as follows:
1. An industrial area along Old Highway 8, north of Interstate 694.
2. A commercial/industrial area to the north of Rush Lake.
3. Sites located within the Twin Cities Army Ammunition Plant (TCAAP)
that lie above the Twin Cities till.
4. Sites located on the TCAAP that are located within the Kame deposit
(below which no till is present).
Major contaminants that have been identified in the groundwater system of
the study area are: trichloroethylene (TCE); 1,1-dichloroethylene; cis 1,2-
dichloroethylene; and 1,1,1-trichloroethane. Other contaminants include;
1,1-dichloroethane (1,1-DCA); trans 1,2-dichloroethylene; chloroform; 1,2-
dichloroethane; 1,1,2-trichloroethane; 1,1,2,2-tetrachloroethylene; and
benzene. Preliminary estimates of the extent of contamination in the
Hillside Sand and Prairie du Chien-Jordan aquifers are shown in figures 5
and 6, respectively. Since TCE was the most prevalent VOC found and generally
had the highest levels, it was used as the indicator chemical for these
studies.
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Lur ,* xj. A PB
' :* wr
*»V-. "J 2= ';
SOURCE: CAMP DRESSER t
NEW BRIGhTON/AROEN HILLS
HJLTI-P01NT SOURCE
REtSDIAL INVESTIGATION
HAT. 1985
PRAIRIE du CHIEN-JOROAN WULS
MT. SIKCS-HINCRLET «LLS
ft
M
. TCE CONC. GREATER THAN 10 ppS
1 * 1000 FEET
NEK BRI6HTOK/AROEK HILLS
Apppoiimate Eitent of known
TCE CoiH»min«tion in Hillside S«nfi
lUhlT 3)
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iN CfTiES
MUNITION
F - « i i -»- . .-, ."7. r ^_- v m \ Jf * ' "* I wt
-- frr^T'^i1: t'-V^vx- R&^ru-T--^- s '^ys.
^m .-?ii "rl^^r^^-^^i
'^^i^Swi^^^
'^VC! ' 1-'C^t^^^i .<*v££4l£,/":-'i -'*^i!-UiK/
SOURCE: CA*- DR£Ss:*
PIU Ml 6HT*/M3fti MILLS
SOURCE
NEW BRISHTON/AROEN HILLS
8PWIRIE du CHIEH-J01CAN
KT
. SiMOi-HINCKLET
Hit. TCE CWC. 6REATIR THAN 10 ppb
1000 FEET
EXTENT OF
TCE
IN Pi^IRIE Cu
SYSTEM (UNIT 4)
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-6-
CURRENT SITE STATUS
Because of contanination by volatile organic compounds, the City of St.
Anthony shut down well 3 in early 1984. Wells 4 and 5 are showing increasing
levels of contanination (Table 1). In well 4, the levels of TCE have
exceeded the U.S. EPA's upper limit proposed maximum contaminant level
(MCL) for the protection of hunan health from contaminants in drinking water
(Table 2). Although other contaminants are present in measurable concentra-
tions, proposed MCL's for compounds other than TCE have not been exceeded.
However, if contamination levels increase further, wells 4 and 5 may have
to be shut down. The major contaminants found at St. Anthony and the
maximum contamination levels encountered are presented in Table 2.
Water use and demand information for the City of St. Anthony is presented
in Table 3. Rased on an evaluation of the data in Table 3, it was determined
that in order to meet the maximum day demands, it will be necessary to utilize
all three wells (3, 4 and 5). If it is assumed that wells 3 and 4 will be
used as the primary punping wells, well 5 wi11 need to be used for backup/
emergency purposes.
Since 1982, several VOC's including the suspected carcinogens: TCE; 1,1-OCE;
DCA; and benzene have been found in well 5. Some past contamination
levels for TCE in well 5 have approached the proposed MCL's (see Table 2),
however, the current levels found in well 5 are considered to pose only a
minimal health risk.
Because of the need for the supply of water from well 5 for emergency and
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TABLE 1 LEVELS OF COirTAMINATlON IN WILL -
Total
Date - TC££/- TCli' -VOCs
01/06/S2 -- 0.5 C.5
02/09/83 0.2 . 0.2
02/23/33- . -- 0.2 0.2
03/07/83 . 0.2 0.2
03/22/83 « 0.3 0.3
04/05/83 - . .0.* . O-4
05/11/83 - 0.2 0.2
05/25/83 -- -- 13.1
C5/10/83 -- 0-* °-4
' 03/17/33 " -- 1.5 .... .1.5
02/24/84 . 1.1 1.1
05/09/34 1.2 1.2
12/10/84 . 0.4 . 3.2 3.9
'08/07/85 0.4 3.7 . 4.1
03/23/85 0.5 4.0 4.5
09/09/85 O.S 5.3 6.8
09/30/85 0.6 5.9 6.8
10/07/85 0.6 3.4 4.5
10/15/85 U.7 5.5 6.3
10/30/85 1.6 7.8 10.7
11/14/85 0.85 4.3 6.0
11/27/85 1-2 4,6 11.5
12/20/85 -- 4-G 5-°
01/15/86 0,8 4.4 6.4
02/19/86 1.4 . 5.2 12.6
04/21/86 1.1 9-5 15.0
- Data Source: Minnesota Departnent cr Health/Pollution Cont-:-l Acency
files
Concentrations in parts pe" billion
S-J TCE-l,l,2-trichloroethylene
^-1,1,1-trichloroethane
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TA3L3 1 (cant.) LEVELS i- CONTAMINATION IN WELL S^-7-7. .... .
Tr-C/
I V'T.
01/06/S2
12/10/84
03/07/85 .
08/23/35
09/09/85
09/30/85
10/07/S5
10/16/85
13/20/85
11/14/35
11/27/85
12/20/85
01/15/85
02/19/35
--
._
0.2
0.2
0.4
0.4
0.2
1.2
0.4
0.4
0.3
03/20/S5
04/21/85
0.1 .
Total
VOCs
0.1
0.3
0.7
0.4
0.7
C.6
0.4
0.8 -
1.4
0.3
3.2
0.9
1.0
0.7
1.8
0.97
0.5
0.7
0.4
0.9
0.6
0.7
1.2
3.8
1.0
8.4
': 1.3
1.4
1.0
2.3
O.S7
Data Source: Minnesota Department of Haalth/Pollution Control Agency
files
Concentrations in pa^ts per billion
-/ TCE-l,l,2-trichloroethylene ..
TCA-l,l,l-trichloroethane
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TA:_i 3
ST. A'.THO'iY WATER USA3E.
Wall 3 1.65 49.3
Wall 4 1.65 ' '49.3
.Wall 5 ' 1.37" " 41.1 ' '
Avaraga De-a.-,: 1.20 35.0
Kaxlsun De-Enc: 3.3 (June/76) SO.Q (July/76)
D2ta Co^?i;2i fro-.:
o CK2(.« Hill, May 1933; Final Alternative Screening, Te~por=ry Water
Supply, St. Antnony, Minnesota (ref. 11).
o Short, Elliot, Hendrickson, Inc., nirch 19C4; Feasibility Report for
Temporary and Pe^ma ient Viat.er Supply from Roseville, St. Anthony,
Minnesota (ref. 10).
o Haner, Larry, June 6, 1G'34; City of 3t. Anthony Request for City
Council Action (ref. 17).
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-7-
standby use, the long lead times needed for implenentation of some of the
alternatives being considered and the uncertainty of what the contamination
levels will ultimately be in well 5.under continued use, it was decided by
U.S. EPA and MPCA to investigate options for well 5 before the contamination
levels rise above the proposed MCL's.
ENFORCEMENT - See Attachment 1
ALTERNATIVES EVALUATION
The major objective of the PFS conducted for St. Anthony's municipal wells
was to evaluate remedial alternatives using a cost-effective approach
consistent with the goals and objectives of the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA). The National
Oil and Hazardous Substances Contingency Plan (NCP), 40 CFR 300.68, outlines
the procedures and criteria to be used in selecting the cost-effective
remedial alternative that effectively mitigates and minimizes threats to,
and provides adequate protection of, public health and welfare and the
environment. The remedial alternatives have subsequently been reevaluated
to determine consistency with the goals and objectives of the Superfund
Amendments and Reauthorization Act of 1986 (SARA).
Response actions may be conducted as an operable unit. An operable unit is
a discrete response measure that may begin before selection of an appropriate
final remedial action. This is consistent with the practice of phasing
remedial actions at sites that present complex cleanup problems. The
primary objective of the St. Anthony operable unit is to protect public
health by providing a reliable supply of safe, potable water to consumers
currently dependent on St. Anthony's municipal wells.
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-8-
Numerous alternatives and options were identified and evaluated for potential
as an operable unit for St. Anthony's municipal wells in accordance with
the NCP and developmental EPA guidance for providing alternate drirrking
water-supplies. The alternatives evaluation for the primary water supply
is presented from page 8 to page 16. The emergency/standby supply options
evaluation is then discussed in pages 16 to 19.
The primary supply alternatives were grouped into seven general categories:
- no-action
- provide bottled water for potable use and maintain wells 4 and/or 5
for non-potable use
- connect to nearby municipal water supply systems
- develop new sources
- treatment of contaminated water
- provide additional storage capacity
- dilution.
The alternatives were screened and evaluated based on their ability to
protect public health, reliability, environmental impacts, speed of
implementation, complexity, technical feasibility, and cost. A summary of
the initial screening is presented in Table 4. The alternatives have been
reevaluated to consider additional factors such as cleanup levels required
under section 121 of SARA, and the ability to achieve permanent and signifi-
cant reduction in mobility, volume, or toxicity of the contaminants of concern.
During the initial screening stage, the no-action alternative for all of St.
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TABLE 4
SUMMARY OF INITIAL SCREENING OF ALTERNATIVES
TECHNICAL ASPECTS
EFFECTS OF ALTERNATIVE
LTERNATIVE
o Act ion
TIME RE-
FEASI- QUIRED TO
IIILIIT IMPLEMENT
Immediate
RELIA-
BILITr ENVIRONMENTAL IMPACT^'
Short term None
moderate
Long term
poor
AniLITV TO
PHOTI CT PUB-
LIC HEALTH
Short term
acceptable
Lomj term
poor
Hone
(low)
it tied Water for
atable Use
Ul i/e Adjacent
Her Systems
Poor
1 Month
Poor
None
Poor
RELATIVE COST REMILT OF INITIAL SO'CKMING
Eliminated -- Strong indication
contaminant levels will increase
above acceptable levels with time
Eliminated Expensive and un-
reliable for long-tern use,
still allows exposure to con-
taminants llirouijh non-potable
use.
High
Roseville/
St. Paul
Minneapolis
Good
Good
2-6 Months Good
2-6 Months Poor
Columbia Heights Good
2-6 Months Poor
New Brighton
Moderate 1-6 Months Poor
Temporary and Minor During
Construction
Temporary and Minor During
Construction
Temporary and Minor During
Construction
Temporary and Minor During
Construction
Good Moderate Consider further
Poor to Moderate to Eliminated -- MUNR hjs serious
Moderate High reservations on use of Minneapolis
based on water supplier as .1 oole source
Minneapolis' . since alternate supplies uuy not bo
capacity to available.
deliver ade-
quate supply.
Poor to Moderate to Eliminated -- Columbia Heights
Moderate High obtains water from Minneapolis
based on. and MiiN.< b.is serious reservations
Minneapolis' on ir..i_- of Minneapolis water
capacity to supplies as a sole source since
deliver ade- adei|>Mte supplies may not he
quate supply. available. . . .
Good .' Moderate Elininrited --Insufficient supply
to meet their own and
St. Anthony's needs
WUJ/U9
-------
TABLE 4 (Continued)
SUMMARY OF INITIAL SCREENING OF ALTERNATIVES
TECHNICAL ASPECTS
EFFECTS OF ALTERNATIVE
RELATIVE COST RESULT OF INITIAL
FEASI-
ALIERNAIIVE BILITY
Develop New Wells/ Moderate
Deepen Existing Wells to Good
TIME RE-
QUIRED TO RELIA-
IHPLEMENT BILITY
12 to 1U Moderate
Months to to Good
dri 1 1 new
wel 1. 6 to
10 months
to deepen
ox ist ing
we 1 1 s
4-6 months
for deep
aquifer
study
ABILITY TO
PKUTFCT PU:i-
ENVIRONMEHTAL IMPACT-7-' L1C HEALTH
Temporary and Minor During Good
Drilling
lilgh
Treat Waler from
Wells 3. 4. and
a. In Home
Water Treatment
b. Air Stripping-
Centrali/ed Treat-
ment Facility
C. Carbon Adsorp-
tion - Central-
ized Treatment
Facil ity
d. Combination
Stripping and
Carbon Adsorp-
t ionCentral i/ed
Treatment Fac iIity
Poor I Month Poor
Good 2-4 Months Good
Good 2-4 Months Good
Good 2-4 Months Good
None
Poor to Moder-
ate (unproven
over long
term)
Temporary and Minor During Good
Construct ion
Temporary and Minor During Good
Construction
Temporary and Minor During Good
Construction
Moderate
to High
Moderate
Hiijh
Moderate
to hiijli
Eliminated -- MUNH hjs strong con-
cern1; regarding potential of Ioxer
aquifer lor long-term sole-source
SU|>|ilies; long implement-It inn time;
may 'eq.iiire temporary action before
wells come on-line; because of re-
duced well yields nny require four
now wells to replace current sup-
ply; deepen inn w'lls 4 and '>
infe.isible because well diameters
are too snull; it new HI.. Simon-
Ilinckley wells are located within
St. Anthony lily limit.-,, l.here Is a
potential ior r«"lucl i«ni <>f MI>||
yields due lo well interference.
Eliminated - UnroliaMe, expen-
sive and impractical over long
term
Consider further
Consider further
Eliminated - additional costs for
carluin unit not justified since
only volatile organic* are
present and combination doesn't
provide significant cost savings
over the carbon adsorption alter-
native described above
108U//09
-------
TABLE 4 (Continued)
SUMMARY OF INITIAL SCREENING OF ALTERNATIVES
TECHNICAL ASPECTS
EFFECTS OF ALTERNATIVE
LTERNATIVE
lending Contaminated
'ater with Non-
ontaminateil Supply
FEASI-
BILITY
Poor to
Moderate
TIHE RE-
QUIRED TO
IMPLEMENT
1 Month
RELIA-
BILITY
Poor
ENVIRONMENTAL IMPACT-'-'
Temporary and Minor
During Construction
ABILITY TO
PHOTIC T PUB-
LIC III AlIM
Poor
rov ide Add it ional
toraye
Poor to 1? to 24 Good Temporary and Minor
Moderate Months During Construction
Good
RClAllvr COST RESULT OF INI MAI SOUTHING
Moderate Eliminated -- Unreliable over
long term since m.mimun con-
centrations unknown and avail-
ability of non-cont .immjt od
Miller for mixing is liuiled
High El iminatud--hi(jhest cost
alternative considered,
impler.'.enlation would require
development of one of the other
alternatives to supply an ad
amount of water
- None of the alternatives considered are designed to permanently mitigate the region-wide contamination problem in thr New Urighton/Arden Ilills/St.
Anthony area.
This column refers to the environmental impact of the alternative if it Is Implemented.
10807/09
-------
-9-
Anthony's municipal wells (3, 4 and 5) was eliminated from further consider-
ation. The decision was based on a limited scope public health evaluation
which stated that the lifetime consumption of water (from well 3 OP well 4)
containing contaminants at current levels may pose health risks to the
residents of St. Anthony. Additionally, because of the need for the supply
of water from well 5 for emergency and standby use, the uncertainty of
what the contamination levels will ultimately be in well 5 under continued
use, and the long lead times needed for implementation of some of the
alternatives being considered, the no-action alternative for well 5 was
considered to be not reliable over the long term.
Three of the original alternatives passed the initial screening and detailed
studies were conducted. The alternatives for which detailed studies were
conducted are:
0 Connect to the Roseville/S.t. Paul System
0 Treat wells 3, 4 and 5 at centralized location using an air stripper
0 Treat wells 3, 4 and 5 at centralized location using carbon adsorption.
These three alternatives were evaluated on their ability to protect the
public health, technical feasibility, environmental impacts, institutional
requirements, and costs assuming a 30-year project life. All three of the
alternatives considered in detail are comparable for most of these evaluation
criteria. The main areas of divergence are in institutional issues and
cost comparisons. A summary of this evaluation is presented in Table 5.
After the passage of SARA, these three alternatives were reevaluated for
their ability to attain cleanup levels cited in section 121 of SARA; or to
-------
TABLE 5. WATER SUPPLY ALTERNATIVES FOR ST. ANTHONY
AJternatt_ye Capital
_Co_st_Jll,000)
Total FreVent Worth
Public
Health Concerns
Communitya/
Environmental Response
Concerns Technical Concerns Concerns Others
SX 8 3/8t lOt
1. Connection to Roseville/
St. Paul water system
442.0 8.947 6.460 5,665
Reduces/elimin-
ates public
health threat
Does not mitigate Two connections necessary Moderate Current water rate
2. Pump well 3 and 4 treat
with air stripper
contamination Two pipelines required. resistance
problem Hydraulic engineering due to odor
Study of Roseville system and taste
required prior to imple- problems
mentation
861.8 3,664 2,900 2,656 Reduces public Does not mitigate Mixture of contaminants Low to
3. Pump well 3 and 4 treat
by carbon adsorption
725.8 3,246 2,553 2,331
health threat to contamination
less than pro-
posed MCL risk
level
Reduces public
health threat to
less than pro-
posed MCL risk
level
problem. May
cause the spread
of contamination
to the Jordan
Aquifer. Possible
air qua!tty impacts.
may change. Non-volatile Moderate
contaminants may render resistance
stripper ineffective
Does not mitigate
contamination
problem. Used
carbon may be
considered
hazardous waste.
May cause the
spread of con-
tamination to the
Jordan Aquifer
If contaminant levels Low to
increase significantly Moderate
carbon replacement costs resistance
may be high
structure does not
at low alI water
charges to be passed
on to residents.
City must absorb
additional costs.
Noise reduction
techniques may havo
to be used. Emission
controls may he
required if current
regulations change.
Both treatment
options may he com-
patible with state
implemented Remedial
Actions.
a/
Community response as indicated in meeting with city officials (Mayor, City Manager. Director of Public Works).
10807/h
-------
-10-
achieve permanent and significant reduction in volume, toxicity, or mobility
of'the contaminants of concern. The two alternatives which use treatment of
groundwater from wells 3, 4 and 5 should significantly and permanently
reduce the volume of the contaminants of concern. Additionally, these
alternatives can attain the applicable or relevant and appropriate
requirements as cited in section 121 of SARA.
The most important factors to consider in determining which requirements are
applicable or relevant and appropriate for remedial actions involving con-
taminated groundwater are the uses of the water and the purposes for which
the potential requirements are intended.
For water that is intended to be used for drinking, Maximum Contaminant Levels
(MCL's) set under the Safe Drinking Water Act are the applicable or relevant
and appropriate standards. In situations where the groundwater being
cleaned up will be supplied directly to 25 or more people, or 15 or more
service connections, the MCL's are applicable. Therefore, for this site,
MCL's are applicable.
At present, the MCL's for the contaminants of concern are only proposed,
however, the final MCL's should be promulgated in June, 1987 (with the
exception of the contaminant 1,2-dichloroethylene, which will be promulgated
in June, 1988). Because the MCL's are applicable in.this situation, the
proposed MCL's set the target drinking water concentrations by which the
alternatives were evaluated. The final target drinking water concentrations
required by the remedial action will reflect the MCL's as promulgated.
-------
-11-
ALTERNATIVE 1
CONNECT TO THE ROSEVILLE/ST. PAUL SYSTEM
This alternative utilizes an interconnection with the Roseville water supply
system to meet the objectives of the operable unit. Previous studies and
discussions with the water department directors of both Roseville and St.
Paul have indicated that the feasibility of the Roseville/St. Paul connection
alternative is good and that the Roseville/St. Paul system has an adequate
supply of uncontaminated water to satisfy St. Anthony's water needs in
addition to its own needs. Detailed hydraulic/engineering and computer
studies of the Roseville distribution systen will be necessary prior to
implementation. Water supply agreements (St. Paul/Roseville/St. Anthony)
will also be required.
Two interconnections would be required. The primary connection would be
2300 feet long. The second connection, which would serve as a backup to
the primary connection, can be made by upgrading the existing Roseville/St.
Anthony connection. This connection was constructed in 1984 and is currently
used to provide water to residents in the southern part of the city during
peak water demand periods.
Water from the Roseville distribution system would flow via connection into
the St. Anthony ground storage reservoir. From this reservoir, water would
flow into the St. Anthony water distribution system as before. Because the
Roseville water system static level is higher than the St. Anthony ground
storage reservoir, a pump would not be required for either of the two
interconnections.
-------
TABLE 2
U.S. EPA SUGGESTED CRITERIA FOR THE PROTECTION OF HUMAN HEALTH
Concentratinsn
Contaminant
1,1,2-trtchloroethylene
1 ,1 ,1-trichloroethane
1,1-dichloroethylene
1 ,2-dichloroethylene
Benzene
Upper Limit
Proposed
MCLs
5C/
200f/
7£/
70d/
(proposed
RMCL)
5.c/
MCLfic/
0
200
7
70d/
(proposed
MCLG)
0
1 x 10-5
Lifetime
Cancer Risksb/
28.0
--
2.3
--
6.7
Office of Drinking
Mater Health Advisories*/
Conger Term LTTeTlme
IPK^AT ]M«OJO' TAdiil tj WuVt)
- -- ?60 -' "
35.000 125.000 l.OOO// 200?/
1.000 3.500 350JV 70£/
1.000 3,500 350// 70?/
Target Drinking
Water Concentration Maximum Contaminant
for Protection of Level Detected (19H2-I986)
_Human^ Health.9/ Mel I 3 Mel 14 Well 5
200
7
70
4.9
1.7
.
1.6
0.8
0.7
1.2
1.2
0.8
7.5
3.9
MCL - Maximum Contaminant Level
RMCL - Recommended Maximum Contaminant Level
MCLG - Maximum Contaminant Level Goal
-- U.S. EPA, Health Advisories for Carbon Tetrachlorlde, 1 ,2-Dichloroethylene, Tetrachloroethylene. 1 ,1 ,1-Trichloroethane, and
Trichloroethylene. Office of Drinking Mater. September 30. 1985.
-
-
-
Concentration In drinking water resulting in a projected upper 95 percent confidence limit excess lifetime cancer risk of 10-5. (Values are
calculated by the U.S. EPA Carcinogen Assessment Group and published in 49 Federal Register 114:24340) (ref. 4)
U.S. EPA. 1985b. National Primary Drinking Mater Regulations; Volatile Synthetic Organic Chemicals. Federal Register 40:46880-46933,
November 13.
U.S. EPA, 1985b. National Primary Drinking Mater Regulations; Synthetic Organic Chemicals, Inorganic Chemicals and Microorganisms; Proposed
Rule. Federal Register 40: 46936-47022. November 13.
Lifetime Health Advisories Assuming a Relative Source Contribution Factor (i.e.. a certain percentage of exposure is from drinking water).
]J Lifetime Health Advisories Assuming Total Exposure is from Drinking Water.
"
Set based on the Proposed MCLs. Target concentrations also result in cancer risk levels within the suggested acceptable range for
ground-water treatment of between 10"* to 10"'. The proposed MCLs, specifically result in cancer risk levels in the 10"^ to 10~6 range.
10802/24
-------
-12-
This alternative has two major drawbacks. The Roseville/St. Paul connection
is the most expensive alternative out "of the three alternatives which were
considered for detailed study. Additionally, there may be some community
resistance to this alternative. The main concern is due to taste and odor
problems that are a result of using Roseville/St. Paul surface water supplies.
ALTERNATIVE 2
TREAT WELLS 3 AND 4 AT CENTRALIZED LOCATION USING AN AIR STRIPPER
This alternative utilizes a packed tower air stripper to meet the objectives .
of the operable unit. Due to the uncertainty of what the levels of
contamination will ultimately be in wells 3 and 4 under continued use, the
air stripper will be sized to achieve the high removal efficiencies required
to remove VOC's found at the maximum concentrations observed in this area's
municipal wells [approximately 300 parts per billion (pph) of total VOC's
were detected in New Brighton well 3 in mid-1982]. Because of the relatively
low levels of contaminants in wells 3 and 4 water at the present time, and
the high removal efficiencies achieved by air stripper systems (99 percent
and higher if contariination reaches the 300 pph level), there should be no
problem in meeting the target drinking water concentrations.
The proposed location of the air stripping facility is in an area which is
largely residential, with athletic fields, parks and a school nearby. For
this reason, noise abatement equipment may be required. The proposed design
parameters have not been run through an air contaminant dispersion model.
Even if modelling results indicate that all Minnesota guidelines for air
-------
-13-
discharges can be met, the air emissions from the stripping tower would
probably require treatment before discharge to the atmosphere, as a result
of expected adverse community concerns. Recause of the close proximity of
the air stripper towers to residences, parks, and especially the school, the
community would perceive a significant health risk due to the air emissions
regardless of what the model indicated. Without an air emissions treatment
systen for the air stripper, the community objections would probably be
strong enough to make implementation of this alternative impossible.
A vapor phase carbon adsorption system is a feasible method of treating the
air emissions to ensure that ambient air quality would be maintained.
Adverse environmental impacts may occur if contaminated St. Anthony wells
continue to be pumped, as pumping may influence the rate and direction of
movement of the contaminant plume within the radius of influence of the
well. Currently, there is little firm evidence as to the extent of the
plune in the St. Anthony area; therefore, little quantification can be made
regarding the effects of continued pumping of wells 3, 4 and 5.
The major problems regarding the air stripper alternative would be associated
with the noise levels of the system and the air emissions from the unit.
Noise abatement equipment and emission control equipment can mitigate
these problems, however, the addition of this equipment to an air stripper
system substantially increases the cost of the overall treatment system.
-------
-14-
ALTERNATIVE 3
TREAT WELLS 3 AND 4 AT CENTRALIZED LOCATION USING CARBON ADSORPTION
This alternative utilizes granular activated carbon (GAC) media to meet the
ohjectives of the operable unit. As with the previous alternative, because
the future contamination levels of wells 3 and 4 are unknown, the GAC unit
will be sized to achieved the high removal efficiencies required to remove
VOC's at levels up to 300 ppb.
The effectiveness of carbon adsorption depends on the type and concentration
of the contaminants present. In 1983, the neighboring City of New Brighton
had two municipal wells in the Prairie du Chien/Jordan aquifer which had
similar types of contamination as St. Anthony is presently experiencing.
Granular activated carbon technology was successfully used to reduce the
contamination levels at New Brighton to acceptable levels. Therefore, the
GAC system proposed for St. Anthony should have the removal capabilities to
sufficiently lower the contaminant concentrations in wells 3 and 4 so that
the. target drinking water concentrations can be met.
The proposed location of the carbon adsorption facilities would be adjacent
to the present St. Anthony municipal water treatment facilities. These
are located in St. Anthony Central Park near wells 3 and 4.
As with the previous alternative, there may be an environmental concern that
if contaminated St. Anthony wells continue to be pumped, the rate and
direction of the movement of the contaminant plume in the study area may be
influenced. However, as in the previous alternative, because there is
-------
-15-
little evidence as to the extent of the plume in the St. Anthony area,
this concern cannot presently be substantiated.
All three of these alternatives are based on simple, proven technologies
and can meet or exceed the target drinking water concentrations. As was
previously stated, these alternatives ranked relatively equal in terms of
technical feasibility and ability to protect public health. None of the
alternatives are planned to mitigate the overall regional contamination
problem, neither, however, are the alternatives inconsistent with the final
remedial action. The two treatment alternatives will he consistent with
the final remedial action if the final remedy involves treatment of the
contaminated groundwater.
The two primary criteria regarding the alternatives which had the most impact
in determining which alternative to recommend are community response and
costs. For both Alternative 1 (Roseville/St. Paul connection) and Alternative
2 (air stripper), there may be adverse community response.
Residents may object to the taste and odor problems associated with Alter-
native 1. Additionally, because future water rates (costs) will be controlled
by Roseville and St. Paul and not by St. Anthony, the community may be
resistant to this alternative for economic reasons.
The proposed location of the air stripper tower for Alternative 2 is within
1,000'feet of a public school. Even if noise abatement equipment and air
emission treatment systems were used, the community may still be opposed to
this alternative.
-------
-16-
The present worth cost of implementing each alternative was estimated
assuming a 30-year project life with discount rates of 5, 8 3/8, and 10
percent. These costs are summarized in Table 6. At a discount
rate of 10%, present worth costs for the three alternatives range from in
excess of $5,600,000 for the Roseville/St. Paul connection alternative, to
the lowest figure of about $2,331,000 for treating water from wells 3 and 4
by carbon adsorption.
For St. Anthony's standby and emergency water source, four options were
considered. The standby/emergency requirements, .assuming wells 3 and 4
would be the primary water supply, are to provide 1,000 gallons per minute
(gpm) for a maximum of 30 days per year. The options considered were:
0 Construct a transmission line between well 5 and the proposed
central treatment facility;
0 Treat water from well 5 at the wellhead (carbon adsorption);
0 Treat water from well 5 at the wellhead (air stripper);
0 Construct a new deep well to the Mt. Simon-Hinckley aquifer.
These four options were evaluated using the same criteria developed for the
analysis of the wells 3 and 4 alternative. Similar environmental, institutional
and health issues discussed during wells 3 and 4 alternative development
are likewise applicable to the analysis of the emergency/standby options.
The main areas of divergence are in institutional issues and cost comparisons.
Table 7 summarizes the costs associated with the standby/emergency
source options.
-------
TABLE 6 . . COST SUMMARY TABLE
Alternative
Rosevilla
Discount
Present Worth at
Cost Estimates (Dollars) Discount Rate ($1.000)
Annualized .
Annual Equip. Re-
C&M
Rate (%) Capital
"5 442,000 552,500
placement _5p/ 8_3/3'
830 8,947
8 3/8 442,000 552,500 1,170 6.450
10 442,COO 552,500 1,350
Carbon
. Adsorption
5 725,800 154,070 9,880
8 3/3 725,800. 154,070 13,980
1C 725,800 154,070 16,110
3,246 ..
2,553
5,665
Air Stripper 5 851,800 169,720 12,590 3,664
3 3/3 861,800 169,720' 17,810 . ' 2,SCO. .
' . 10 851,SCO 163,720 20,520 . 2,655
2,331
Present Worth of Am-ity Factor fo- 30 yr. = 15.37
£/ Present Worth of Ani-ity Facto." fo- 30 yr. = 10.37
- Present Wo-tr. cf A-^jity Facto- for 30 yr. = 9.43
I/-Use of 1U% Discount .-.ate Reccrr-.e-defl &y U.S. E?A (-ef. 26)
-------
BuI 7
COST COMPARISON FOR EMERGENCY/STANDBY OPTIONS
Discount
Ootion Rate Capital OSM AERC 5% S 2/8% 10%
Pipeline 5 374,700 6,703 1,950 503 . ....
8 3/8 374,700 6,700 2,760 473
10 374,703 6,700 3,ISO -53
Air Stripper 5 645,100 19,550 62,603 1,903
8 3/8 645,100 19,500 88,600 1,820
10 645,103 19,550 102,100 1,792
Ca-bon Adsorption 5 310,503 13,690 17,700 793
8 3/8 310,500 13,690 25,100 732
10 310,500 13,690 28,900 712
New Well b 601,700 7,020 3,900 770
83/8 601,700 7,020 5,520 733
10 601,700 7,020 6,360 "23
-------
-17-
Option 1
CONSTRUCT TRANSMISSION LINE FROM WELL 5 TO PROPOSED CENTRAL TREATMENT
FACILITY
This option would require construction of a 12-inch diameter transmission
main from well 5 south to the existing iron treatment facility near wells 3
and 4. After manganese and iron removal, the water would be treated to
remove VOC's and piped back into the existing distribution system. The
existing pump at well 5 has sufficient capacity to convey the water to the
treatment plant without the aid of booster pumps. This option would alleviate
the need for disinfection at well 5.
Option 2
TREAT WATER FROM WELL 5 AT WELLHEAD RY CARBON ADSORPTION
If gravity flow carbon technology is employed, four carbon contactors,
each with 250 gpm capacity, are required. Construction of a heated building
or building addition at the existing well 5 wellhouse would be required to
prevent freezing of the units in the winter.
Option 3
TREAT UATER FROM WELL 5 AT UELLHEAD BY AIR STRIPPING
Treatment by air stripping would require two stripping towers, each capable
of treating 500 gpm. Construction of a heated building or building addition
at the existing well 5 wellhouse would be required. There nay be community
resistance to this option because of noise levels and low levels of contam-
ination in the air discharged from the .air stripper. Due to community
-------
-18-
concerns, an air emissions treatment system may be required. With an
air emissions treatment system, the present worth cost of this option
is approximately twice that of the next highest cost option (carbon.
adsorption treatment at well 5).
Option 4
CONSTRUCT NEW WELL INTO THE MT. SIMON-HINCKLEY AQUIFER
As the Mt. Simon-Hinckley aquifer is not currently contaminated, it can be
utilized as a supply for standby or emergency purposes. As stated earlier,
water from this aquifer requires treatment to remove iron. Thus, to utilize
the existing iron treatment facility and minimize piping requirements, a
new deep well should be located as close to the existing iron treatment
facilities as practicable. A small pump house would be constructed which
would be heated in the winter months.
The Minnesota Department of Natural Resources (MDNR) present policy
discourages use of the Mt. Simon-Hinckley aquifer by cities for meeting
peak water demands because of'the aquifer's limited potential.
Each of these four options are based on simple, proven technologies and can
meet all applicable Federal and State drinking water standards. The options
ranked equally in terms of technical feasibility and ability to protect
public health.
The present worth costs, assuming a 30-year project life and a 10% discount
rate, for the options considered for the standby/emergency water source
ranges from a low of $468,000 for the construction of a pipeline to connect
-------
-19-
well 5 with the proposed central treatment facility to a high of $1,792,000
for treatment of well 5 water by air stripping.
COMMUNITY RELATIONS
The Superfund activities at the New Rrighton/Arden Hills/St. Anthony site
have been followed closely and consistently by the local press. Interest
in Superfund activities has been high, and news accounts of the activities
have been responsible. Residents and locally elected officials have
maintained a constant and serious interest in the Superfund activities.
Copies of the PFS were made available to the community on June 11, 1986.
The St. Anthony Rranch of the Hennepin County Public Library served as the
information repository. The U.S. EPA issued a press release on June 9,
1986, announcing the availability of the PFS, location of the repository,
the June 12-July 2, 1986 public comment period, and the June 23, 1986 public
meeting at St. Anthony City Hall in St. Anthony, Minnesota.
The public meeting was attended hy approximately 60 people including repre-
sentatives from MPCA, U.S. EPA, U.S. Army and local officials. At this
meeting, the U.S. EPA presented results of the PFS, recommended construction
of granular activated carbon (GAC) water treatment facilities to treat well
3 and 4 as the preferred alternative, answered questions regarding the New
Brighton/Arden Hills/St. Anthony site, and accepted public comments.
The Responsiveness Summary to the public comments is attached to this summary
(see Attachment 2). As a result of the public comments, the public comment
-------
-20-
period was officially extended by two weeks and the recommended alternative
was amended to include the construction of a pipeline connecting St. Anthony
well 5 to the proposed GAC treatment facilities.
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
The proposed alternatives and options to address St. Anthony municipal
wells 3 and 4, and St. Anthony's standby/emergency water source are required
to be consistent with other Federal and State environmental laws.
For remedial actions involving contaminated groundwater, the use of the water*
and the manner in which it is used will determine what kinds of requirements
or laws may be applicable or relevant and appropriate.
For water that is intended to be used for drinking, the applicable or relevant
and appropriate standards are the MCL's established under the Safe Drinking
Water Act. The MCL's are applicable in situations where the groundwater
cleaned up will be directly supplied to 25 or more people, or to 15 or more
service connections. Therefore, the MCL's are applicable for this site.
At present, the MCL's for the contaminants of concern (Table 2) are only pro-
posed. These MCL's should be finalized and promulgated in June, 1987 (except
for the contaminant 1,2-dichloroethylene which will be promulgated in June,
1988). The final target drinking water concentrations required by the remedial
action will reflect the MCL's as promulgated.
The MCL's are the basis for the target drinking water concentration used to
evaluate the alternatives, because the MCL's are the relevant and appropriate
standards and are applicable. All of the proposed alternatives and options
-------
-21-
will supply drinking water that will attain these target drinking water
concentrations.
None of the proposed alternatives and options are inconsistent with the
final remedial action. Additionally, all of the alternatives and options
which incorporate treatment of water from wells 3, 4 and 5 should permanently
and significantly reduce the volume of the contaminants of concern. These
treatment alternatives and options may very likely be a part of the final
remedial action at this site. The Roseville/St. Paul interconnection
alternative for the primary water supply and the new deep well option for
the standby/emergency water supply do not reduce the volume of contaminants.
The MPCA (Division of Air Quality) regulates the discharge of contaminants
to the atmosphere from air strippers. The Division evaluates each case
individually, but has not adopted a set of rules to date. The accepted
criterion is 1% of the threshold limit value (TLV) of a contaminant over an
8-hour period. This is determined by running the physical parameters of the
stripperstack height, diameter, water pumping rate, influent contaminant
levels, distance to property lines, etc., through a model to determine if
the proposed alternative will meet all Minnesota regulations. The exhaust
gases created from the air stripper alternative may have an impact on
ambient air quality. While the proposed parameters for air strippers at
wells 3, 4 and/or 5 were not run through a model, because of the relatively
low levels of contaminants in the well water and therefore, in the exhaust
air, and because the contaminant levels in the stripper exhaust would have
been further reduced by an air emission treatment system, there should not
be a problem with meeting all Minnesota guidelines for air discharges.
-------
-22-
V/ith regards to the spent activated carbon from the proposed GAC treatnent
systems, the U.S. EPA (Region V - Soltd Waste Rranch) has made the determination
that this material is not a regulated Resource Conservation and Recovery Act
(RCRA) material.
RECOMMENDED ALTERNATIVE
The National Oil and Hazardous Substances Contingency Plan (NCP)[40 CFR
Part 300.68(i)] states that the appropriate extent of remedy shall be
determined by the lead agency's selection of a cost-effective remedial
alternative that effectively mitigates and minimizes threats to and provides
adequate protection of public health and welfare and the environment.
SARA provides a further requirement that the alternative selected should,
to the maximum extent practicable, also utilize permanent solutions and
alternative treatment technologies.
Based on the evaluation of cost, effectiveness and other concerns of each
proposed alternative, the preference for permanent solutions, the comments
received from the public and the Minnesota Pollution Control Agency, and
the State and Federal environmental requirements, Alternative 3 in conjunction
with Option 1 has been determined to be the most cost-effective alternative.
The recommended alternative is considered an operable unit remedial action.
The objective of this action is to provide those consumers currently dependent
on the St. Anthony municipal water supply for drinking water with a reliable
supply of safe, potable water until the final remedial measure(s) may be im-
plemented. The RI/F5 currently underway will examine appropriate final response
action(s). Implementation of the operable unit will return St. Anthony's
water system to pre-contamination levels in terms of quality and quantity.
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The recommended alternative provides for both granular activated carbon
treatment of the contaminated groundwater from St. Anthony wells 3, 4 and
5, and a pipeline connecting St. Anthony well 5 to the GAC treatment
facilities. The GAC treatment system would be sized to be capable of
treating St. Anthony's peak water demand of 3.3 million gallons per day
(mgd). The pipeline connecting St. Anthony well 5 to the GAC system would
be sized to provide 1,000 gpm (1.4 mgd).
The GAC treatment system would be designed to treat water with influent
VOC's of up to 300 ppb (300 ppb is the maximum concentration of VOC's observed
in any of the study area's municipal wells). The GAC treatment system
would be designed to achieve removal efficiencies sufficient to lower the
contamination concentrations to acceptable levels. The pipeline from well 5
to supply St. Anthony with a reliable standby/ emergency water source would
be designed to operate for 30 days per year and provide 1,000 gpm only when
either well 3 or 4 was unable to be used.
A final remedy at this site can be approached by two means; minimization and
mitigation of groundwater contamination, and use of an alternative water
supply. Although the final remedy for this site has not been determined, it
appears likely that some type of response to minimize and mitigate the current
groundwater contamination will be the final remedy. Currently, there is
little firm evidence as to the extent of the plume in the St. Anthony area;
therefore, little quantification can be made regarding the effects of
continued pumping of wells 3, 4 and 5.
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In terns of the final site remedy, the recommended alternative nay possibly be
incorporated into a final remedy selected, as part of minimization and miti-
gation of the grbundwater contamination, depending on results of th.e ongoing
RI/FS. The agency may utilize the GAC system in a treatment-type final renedy
to address contamination. If the ongoing RI/FS indicates that the groundwater
contamination in the St. Anthony area is extensive and dilute, the only way to
minimize and mitigate the groundwater contamination in this area would be
through utilization of a treatment system, which would clean up the groundwater.
This would possibly be in conjunction with the GAC treatment system.
Although the GAC treatment system may not eliminate the contamination of the
t
Prairie du Chien-Jordan aquifer, the operable unit will minimize the threat
posed by the contamination until the time a final remedy is selected by U.S. EPA.
An RI/FS is currently underway to determine and evaluate the extent of ground-
water contamination. Until the evaluation is completed, it is not technically
feasible to develop a cost-effective, long term remedy for the site.
The capital cost of the recommended alternative is estimated to be 51,100,500.
The total operation and maintenance (0AM) costs are estimated to be $160,770
per year of which $43,900 is for the operation of wells 3, 4 and 5 and the
remaining $116,870 are costs associated with the GAC treatment system and
the pipeline. The thirty-year present worth value for the recommended
alternative is $2,799,000 at a discount rate of 10 percent. The capital and
annual costs of the recommended alternative are summarized in tables 8 and 9.
The Superfund Amendments and Reauthorization Act of 19S6 (SARA), specifically
amendment (i)(6) to section 104 (c)(3) of CERCLA states that for groundwater
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TABLE 8
CAPITAL COSTS - CARBON ADSORPTION
Item . Cost
1. Purchase adsorption units @ $20,000, need 9 units., 5180,000
(includes wet wells, piping, circulating pumps, etc.)
2. Re-pressurizing Pump, Starter, Controls 16,000
3. Construct New Buildina, Plumbing, Heating, Earthwork 203,000
(26 x 100 feet)
4. Pipe and Fittings 20,000
5.' Installation S2,000/unit 18,000
5. Well Rehabilitation for One St. Anthony Well 35,000
Purip Bowls 5,000
Punp Motor 20,000
Che~ical Feed Equipment 10,000
SUBTOTAL 512,000
Contingency (25%) 123,CCO
Construction Engineering (5%) 32-,uCO
Engineering Design Costs (8*) 53,800
TOTAL 725;5CQ
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TABLE g(;epnt.)
CAPITAL C03TS - PIPELINE CONSTRUCTION FROM
WELL 5 TO CENTRAL TREATMENT FACILITY
Ite~ - Total
1. Construct 12" Transmissio- Main from Well 5 to 251.300
Proceed Treatment Facility (includes Watermains, Valves,
Street/Turf Restoration)
2. Electrical/Control Improvements 3,000
3. Mobilization, Contractor Fees 10,000
Subtotal ' 264,300
Contingency (25%) 66,100
Construction Enginesring (5%) 16,500
Engineering Design (8%) 27,800
TOTAL 374,700
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ANNUAL COSTS - CARBON ADSORP' ION
I ten Cost
1. Labor (3hrs/wk @ S17. = 0/hr)(12mcs}(iwks/r.o} - 2,520
2. $3"vice contract - maintenance, system check 2.500
5 days @ SSOO/day '
3. Pcwsr - 1 boosts" p-r.p - SOhp - 37kW
9 circulation pu~.ps - 45hp - 33kW
Demand: (7QkW)(S5.25/no)(12n-,cr) 5,260
Energy: (705;W) (24h-s/day) (SOcays/mo) (12mo) (S0.039/kW) 17,690
(7z'» systs.i use on annual bcsis)
4. Cpsrat2 Wells 3 and 4 - (43c f!3) (53i.32/f,3)l' 40,000
5. Laboratory analyses (Ifj/yr 0 S150)-7 . 25,600
6. f-'ainterance of building 5500/year 500
7. Carbon - 10,C001b/unit, (60,000) (SI. 00/1 b)^ 60,000
ANh'JAL OiM 154, C7C
8. Anr.uali zed equipment replacement costs (AERC)-
At 5% Rate, $152,000 x 0.065 = 9,880
At 8 3/8% Rats, $152,000 x 0.022 = 13,931)
At 10% Rate, $152,000 x 0.1C6 = 15,110
9. SUBTOTALS (O&M Plus AERC)
5%, 154,070
9,880
153,950
8 3/8r,, 15£,070
13.980
ic i .
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TABLE- .' (Continued)
ANNUAL COSTS - CARBON ADSORPTION
10%," 15-.070
15,110
170,180 '
10. Present Worth -
Present Worth at 5% = 2,520,000
Present Worth at 8 3/8% = 1,827,000
Present: Worth at IGi = 1,505,000
Based on operating costs of St. Anthony Wells in 1985. '
J2/ Priority Pollutant Volatile 0-ganics Scan. The proposed monitoring
schedule is:
Influent: Once every 2 weeks (26 samples)
Composite Effluent: Once eve-y 2 weeks (26 samples) ' '
Ccr,t.-:tcr Effluent: One per rcrth per unit (103)
zJ Carbor. costs includes SO.bO/lb for purchase end 50.20/lb for
disposal, assures carbon is delivered to the site and installed in the
contactor, and used carbon is removed. Total ccsts are estimated
assuming thct on average, the carbon bee's of only 6 contactors will be
changed par year.
Equipr.o-,t Replacement Costs
I. Cat-ben Units
a. Re-pressurizing booster p'jrps every 10 years (2)(1500) 3,000
b. Circulation pumps eve~y 10 yea-s (9 @ 500)(2) 9,000
v»i, ii '^-- vc'. c~ i cc~ .'"c i r. j iX w~t2rs j '-*.. rc.~.~^c \*s , . ««
eve"y 10 years (3500)(2) 7,000
d. Contingency (20%) A.OOP
- SUBTOTAL CARBON IT IT 23,000
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TABLE ;;
AN,'JAL COSTS - CAR3DN ADSORPTION (Continued)
II. Wells 3 and 4
a. Replacement of column pipe, some shaft, bearings, 5100,003
... couplings, etc., every 5 years (SlO.OOO/replacement)
(2 wans) (5 rep! ace.-ents)
b. Filtration plant: genaral annual equipment 7,500
replacement costs
Contingency (20%) 21,500
SUBTOTAL 129,000
TOTAL (I plus II) 152,000
I/ See Table 2-6 for Present Worth and Annualized equipment replacement
equations.
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ANNUAL COSTS - PIPELINE CONSTRUCTION FROM
WELL 5 TO CENTRAL TREATMENT FACILITY
Itei - Total
1. Labor
2 hr. per week ? 17.50/hr. 1,630
2. Well 5 Oparatlng Costs^-7 3,900
(43 ng/yr) x (S91.32/-=)
3. Maintenance on Valves, Cor.trcllers
Subtotal
w I r I
;. Annual1Z3d Equipment Replacement Costs (AERC)--
At 5% Rate, (S30,000)( .055) 1,950
At 8 3/3 Rate, ($3C,COO)(.CS2) . 2,750
At 10% Rate, 3,130
5. Subtotals (Annual O&M Plus AEP.C) "'
At 5%, 6,700 + 1,950 = 8,650
At S 3/8, 6,700 + 2,750 = S.450
At 10%, 6,700 + 3,130 = 3,£30
5. Present -Worth^-7
Af5S, 133,003
At 8 3/8X. 102,8'JO
At 10%, 93,200
£' Based on Ope-atln; Costs of St. Anthony Uells In 1935.
Equipment Reola-:="3rt Costs Th-ougncut Project Life
a. Well 5 Rehabilitation 25,000
. (Approx. 15 y.) Contingency (20%) 5.000
- See Table 3-6 fc- Present Ws-Vr *r.i A-.-.ua1. Ized TOTAL 30,000
Equipment Rep" acenent Eq'j = t'c."s
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contami nation, a completed remedial action includes the completion of treat-
ment or other measure(s) necessary to restore groundwater quality to a level
that assures protection of human health and the environment. The operation
of such measures for up to 10 years after the construction or installation
and commencement of operation shall be considered remedial action. Also,
under the amendment, operation and maintenance shall be considered to be
any activities required to maintain the effectiveness of the treatment or
measure following the initial 10 year period.
For this operable unit remedial action, only the construction or installation
and operation of the GAC treatment system and the pipeline will be considered
the remedial action. Therefore, operation of wells 3, 4 and 5 are not
considered part of the remedial action.
It is recommended that the U.S. EPA fund 90% of the remedial action costs
for a period not to exceed ten years after completion of construction. Based
on an anticipated agreement with the State of Minnesota, the State will fund
10% of the capital costs of the remedial action and the City of St. Anthony
will provide the 10% State share of the annual operation cost of the remedial
action for up to ten years. The City will then assume all O&M costs for the
life of the project. The City assumes all the costs associated with the
operation of wells 3, 4 and 5.
STATE AGREEMENTS
Section 104(c)(3) of CERCLA sets forth the State financial responsibilities
in remedial actions provided under CERCLA. The State financial responsi-
bilities in the proposed remedial action would include payment or assurance
of payment of 10% of the costs of remedial action, and assurance of all
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-26-
future 0AM costs after the initial 10 year period of the remedial action.
The State anticipates receiving a connitment from the City of St. Anthony to
assume all costs for the operation of wells 3, 4 and 5, all 0AM costs of the
operable-unit after the initial 10 year period, and to provide the 10% State
share of the annual operation costs of the remedial action for the initial 10
year period.
The capital costs of the remedial action will be covered under a State Super-
fund Contract between the State and the U.S. EPA at the completion of design
of the operable unit. The annual operation and future O&M costs will be
covered under a Cooperative Agreement between the State and the U.S. EPA at
the completion of design of the operable unit.
SCHEDULE*
Approval of Remedial Action
(sign ROD)
Minnesota Pollution Control Agency Board
Meeting-State Superfund Contract approval
March, 1987
April, 1987
Complete Design
Contract Award
Notice to Proceed
Construction Complete
Estimated Construction Period
* This schedule is contingent on the availability of funding by April 15,
1987.
October, 1987
November, 1987
December, 1987
June, 1988
5-9 months
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FUTURE ACTIONS
The MPCA is continuing its conprehensive PI/FS for the site. MPCA has
already completed a prelininary remedial investigation characterizing the
site, najor migration pathways, and preliminary identification of significant
sources. MPCA is planning to complete the remaining tasks of the conprehensive
RI/FS in 1988 in order to evaluate potential final remedial action(s). The
feasibility study will recommend the most cost-effective remedial action(s)
for the site. Consistent with section 120 of SARA, U.S. EPA and the Department
of Amy will enter into an interagency agreement concerning remedial action(s)
for contamination arising as a result of the TCAAP activities.
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[Attachment 1]
ENFORCEMENT
Past Federal and State enforcement ac-tivities have focused on up to twelve
identified potentially responsible parties (PRP's). Each PRP had some involvement
at either of the identified potential contamination source areas: the Twin
Cities Army Ammunition Plant (TCAAP) or the Butcher Spur/Trio Solvents/Northwest
Petroleum Refinery location.
In 1983 and 1984, the EPA issued notice letters to these PRP's requesting
participation in the conduct of the three Initial Remedial Measures (IRM's)
and the comprehensive regional remedial investigation/ feasibility study
(RI/FS) for the New Brighton/Arden Hills/St. Anthony study area. None of
the PRP's indicated willingness to undertake or participate in any of the IRM's
or studies which EPA had requested. Therefore, EPA and MPCA proceeded with
funding and undertaking of these remedial activities.
Preliminary results of the state-lead comprehensive regional RI/FS indicate
that the TCAAP is a major source of groundwater contamination in the study
area. Based on these results, in January, 1986, the EPA offered the U.S.
Army/Department of Defense (DOD) the opportunity to participate in the
regional RI/FS and in the TCAAP sewer!ine force main study being conducted
by EPA off of the TCAAP. The Army/DOD steadfastly refused to undertake work
outside of the base.
Notice letters, as required under section 122(a) of SARA, will be issued to
all identified PRP's indicating the Agency's intent to proceed with the
selected alternative for tb» operable unit remedial action without additional
opportunity for the PRP's to negotiate a settlement.
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[Attachment 2]
Community Relations Responsiveness Sumnary
St. Anthony Municipal Water Supply
INTRODUCTION
This "Community Relations Responsiveness Summary" documents citizens'
reactions and concerns raised in reference to the Phased Feasibility
Study (PFS) for an operable unit remedial action for the St. Anthony
municipal water supply, St. Anthony, Minnesota. It also documents, for
the public record, the United States Environmental Protection Agency's
(U.S. EPA) responses to the comments presented during the public comment
period for the PFS.
The U.S. EPA conducted the PFS to evaluate an operable unit for an'
alternative water supply for the City of St. Anthony. The PFS was
completed on June 9, 1936, under the authority of the Comprehensive
Environmental Response. Compensation, and Liability Act of 1980 (CERCLA),
42 U.S.C. 9601 et_ sjeq. , and in accordance with the National Contingency
Plan (NCP). 40 CFR Part 300. The U.S. EPA recommended that construction
of granular activated carbon (GAC) water treatment facilities and a
pipeline connecting St. Anthony well 5 to the proposed GAC treatment
facilities was the appropriate operable unit for St. Anthony.
BACKGROUND _OJN _C 0_MMU N_I_T Y _ I N_V 0_L V E_M E_NT jWD _C 0_N C E R_NS
Residents and locally elected officials have maintained a constant and
serious interest in the Superfund activities at this site. Community
relations has been a cooperative effort with the EPA funding the Minnesota
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-2-
Pollution Control Agency (MPCA) to conduct the majority of the community
relations work. EPA community relations staff participates in the Twin
Cities Army Ammunition Plant (TCAAP) public affairs steering committee.
Other participants in this committee are staff from the MPCA, the U.S.
Army, Honeywell Inc., and Federal Cartridge Corporation.
The public has been kept informed of the activities at this site by various
means. Four public meetings have been held in the area between the time
contamination was first detected in New Brighton (June, 1981) and the June.
23, 1986 public meeting for the PFS. EPA and MPCA technical staff have kept
St. Anthony's city manager apprised of any new developments regarding this
site and specifically this operable unit. Both local newspapers, the weekly
St. Anthony Bulletin and the biweekly Northeaster, regularly report on new
information regarding, the site.
The concerns expressed by the citizens are equally divided between health
and financial issues, the latter manifested in a lawsuit filed by the City
and local citizens to recover the City's costs associated with replacing
its water supply system. Media interest regarding this site has remained
very constant.
CDMMENT PEIOD
The public comment period to review the PFS and recommended alternative
was opened on June 12, 1986. In compliance with CERCLA, a public meeting
was held in St. Anthony on June 23, 1986. The results of the PFS were
presented and questions about the findings answered. The meeting was
attended by approximately 60 people, consisting of interested members of
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-3-
the public, representatives from MPCA. U.S. EPA. U.S. Army and local
officials. Comments about the recommended alternative were duly recorded.
During the public comment period, eleven comments -- four written and
seven oral" at the public meeting -- were received by the U.S. EpA. The
public 'comment period was originally scheduled to close on July 2, 1986,
however, one of the public comments requested a two-week extension of the
comment period. The extension was granted and the community was notified
that the public comment period would officially closed on July 16, 1986.
In general, the comnentors were pleased the problem was being addressed
and raised questions that requested additional information about alternatives
that were not recommended. Concerns were also expressed about losing St.
Anthony well 5 as a backup water source. EPA performed additional studies
addressing this concern and has amended its recommendation to include
construction of a pipeline connecting St. Anthony well 5 to the proposed
GAC treatment facilities.
OFPU BLIC COMMENTS NDRESPONSES
The public comments received during the comment period were complex and
in many cases, duplicative. To facilitate presentation of the comments
and the Agency's responses, the comments and responses are listed in
appendices 1 and 2 respectively. Appendix 1 contains the public comments,
listing the seven oral comments first, followed by the four written comments.
Appendix 2, using a tabular format, contains the Agency's responses to the
public comments.
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-4-
The Agency's responses to the comnents resulted in some changes to the
draft PFS. The major revisions to the PFS incorporated none detailed
discussion and additional information concerning topics that commentors
felt were hot fully addressed. An attempt was made to paraphrase the
oral comments as accurately as possible, thereby, retaining the commentors
original intent. The written comments are photocopies of the actual
documents as received by the Agency.
Each comment is assigned a nunber (1 to 11) and each comment may be
further divided by assigning a letter(s), found on the right hand margin.
to separate paragraphs or ideas within each comment. This format should
4
simplify presentation of the comnents and responses and ease cross-referencing
of similar comments and responses.
-------
(APPENDIX 1)
PUBLIC COMMENTS
ST. ANTHONY MUNICIPAL WELLS
ST. ANTHONY, MINNESOTA
The EPA's responses to the public comments are presented in Appendix 2,
Comment No. 1
The city manager of St. Anthony, Mr. David Childs, expressed on
behalf of the citizens of St. Anthony, the following comments.
He commended EPA and MPCA for being helpful, thus allowing the
City of St. Anthony adequate time to plan, with regards to
the groundwater contamination problem affecting their municipal
water supply. He wished the U.S. Army and the Department of
Defense (DOD) were as responsive and felt that Army/DOD prefers
litigation to negotiation.
Regarding the PFS, he was concerned about the absence of some
information and cost data pertaining to both the deep well
alternative and the Roseville/St. Paul connection alternative.
He stated that the Roseville/St. Paul connection alternative cost
estimate could be reduced by 25% to $4,200,000. However, he had
some reservations regarding this alternative because his office
normally receives a large number of phone calls complaining about
the taste, smell and odor of the water whenever the temporary
Roseville connection is used.
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-2-
He is concerned that the fate of St. Anthony well 5 (the
city's backup well) has not been properly addressed. Because
well 5 is diesel-driven, it is a dependable backup well
when St. Anthony experiences power outages (during electrical
storms, tornadoes, etc.).
With regard to the air stripper alternative, he expressed
concerns about the noise and the air emissions generated from
the unit(s). He stated that there would probably be a need for
a rate increase with all of the alternatives and particularly
with the Roseville/St. Paul connection alternative. The City
and the staff of St. Anthony would probably recommend selecting
the carbon filtration alternative.
Comment No. 2
Mayor Robert Sundland thanked the U.S. EPA and MPCA for
maintaining an open exchange of information regarding this
project even though there may not be agreement among all
parties with all aspects of the project. He has written to
the congressional delegation with regards to the need for
Superfund reauthorization. He stated that his concern and
his goal is to have a clean, fresh water supply for the city.
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He is glad that St. Anthony has had the time to plan, with
regard to the groundwater contamination problem, and not
have to immediately react to the problem as New Brighton has
had to do.. He is aware of the proposed reduction for the a (cont.)
maximum contaminant level for trichloroethylene (TCE). At
this point, he agrees with the selection of the carbon
filtration alternative.
Comment No. 3
Mr. DuWayne Mitkie, a resident of St. Anthony and an engineer,
is pleased that the city can plan ahead with regard to the .
a
groundwater contamination problem. He believes carbon filtration
is a good system.
Comment No. 4
Ms. Cathy Daniels, a resident of St. Anthony, agrees that a
carbon filtration system should be the recommended alternative.
She states that even though water from the Roseville connection
may get many complaints, she would rather drink rusty water
a
than TCE-contaminated water. She is angry that the source of
the groundwater contamination problem is not being attacked and
she believes St. Anthony needs to take the risk and bring suit
(against the Army) as the City of New Brighton has done.
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-4-
Comment No. 5
A resident of St. Anthony raised the concern that if an inter-
city connection alternative was selected, there exists a strong
possibility that the rates (costs) charged by the nearby
municipality could escalate in the future.
Comment No. 6
Mr. David McDonald, an attorney representing the City of St.
Anthony, requested an extension (2 weeks) of the- public comment
period. The City needed additional time to analyze and comment
on the Phased Feasibility Study.
Comment No. 7
A resident of St. Anthony questioned whether there was sufficient
notification to the public regarding the June 23, 1986 public
meeting.
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git 1 4 193C
-.ljL Minnesota pplluiion Control Agency
' ^ 7
July 11, 1936
i'ii. Juoy
Office of Public Affairs
U.S. Environmental Protection Agency
Region V
23-0 South Dearborn Street
'Chicago, Illinois 60604
^
Dear Ms. Beck: -.
This letter provides the Minnesota Pollution Control Agency (MPCA) staff
cor.-.ents to the U.S. Environmental Protection Agency's (EPA) recently completed
St. Anthony water supply system Phased Feasibility Study (PFS). As was stated
by "?CA staff at the public meeting field at St. Anthony City Hall on June 23,
1926 regarding the PFS, we concur with the EPA recommended alternative of
installing a carbon treatment system to the St. Anthony water supply system at
municipal wells 3 and 4.
K?CA staff believes that the air stripping treatment, Roseville interconnection
and new deep well alternatives also given consideration by EPA were
appropriately rejected. The public perceotion of the air stripping emissions,
proximity of a public school to the operations, and additional costs of an air
purification system, make the air stripping alternative less cost-effective than
the carbon treatment option. The interconnection alternative to Roseville,
while being the least expensive for initial capital costs, would have excessive
annual operating costs due to purchase of the water from Roseville. The new
well alternative involving Mt. Simon-Hinckley aquifer wells may not provide an
adequate yield for St. Anthony's needs and the high construction costs of those
wells along with the probable need for an iron treatment system and installation
of a new distribution system would require excessive capital cost expenditures.
While we support the carbon alternative, we would like to make several
additional comments if the recommended carbon treatment alternative is finalized
by the EPA. : .
i -sola ij5l 1?-?7£5
Marshall Hoi.i-.-sVr
-------
Ms. Judy Beck
paqe 2 All 14 ISftf
1. The selection of carbon treatment is currently based on a gravity flow
system. MPCA staff would encourage a detailed assessment (advantages,
disadvantages, and costs) between the gravity and pressurized flow carbon
treatment technologies. A selection of the appropriate carbon technology
now could speed up the Remedial Design phase and response action
implementation.
2. The carbon cost in the PFS is set at one dollar per pound for the disposal
of spent carbon and the purchase of replacement carbon. Additional
discussion of the purchase price of the appropriate carbon grade and of
disposal of the carbon is necessary to provide information on the initial
PFS cost estimates for carbon treatment operations and maintenance (0 & M)
costs. We would also recommend that thought be given to long term purchase
and disposal contracts to potentially lower annual costs and provide the
city with assurances of carbon availability and disposal at reasonable
costs.
'3. A determination of the future of St. Anthony's wells as well as the
temporary Rosevil le-St. Anthony partial interconnection should be made. The
City has expressed an interest to MPCA staff in maintaining St. Anthony well
5 within the city's distribution system for use during peaking periods and
as an alternative when maintenance is being performed on the other wells.
In addition, MPCA staff is using the well as part of regional monitoring
network. MPCA staff would, therefore, recommend that the. PFS assess the
feasibility of continued use of well 5 with no treatment, treatment at the
well head and treatment at the central plant to determine if the well can
remain in the distribution system. In addition to well 5, MPCA staff would
recommend the PFS assess the continued use of the Roseville-St. Anthony
interconnection. We believe if long-term 0 & M costs are low, the
interconnection should be maintained to provide the City with a partial
water supply in case of emergency.
Thank you for your consideration of our commpnts. If you have any questions
regarding this letter, please contact. Mr. Douglas Day, Project Manager at
29'5-7388 or Mr. David Crisman, Hydrologist, at 296-7299.
Sine
Gary A. Pulfor/dl Chief
Cite Response Infection
Division of Solid and Hazardous Waste
GAPimec
cc: David Childs, City of St. Anthony
David McDonald, Attorney at Law
- Gene Wong, U.S. EPA, Chicago
Gary Englund, Minnesota 0-}pa>'tm?nt of Health
Media Adelsman, Minnesota Department of Natural Resources
-------
Administrative Offices
3301 Silver Lake Road. St Anthony, Minnesota 55418
(612) 789-8881
June 26, 1936
Judy Bee):
U.S. Environmental Protection Agency,
Region V
230 South Dearborn Street
Chicago, IL 60604
Dear Judy,
Please accent this letter as the official request from the
City of St. Anthcr.y for ar. extension (2 weeks) in the official
comment period on the "Phased Feasibility Study for St. Anthony,
Minnesota June, 1986", as prepared by Camp, Dresser, and McKee, Inc
under the USEPA Contract Nol"68-01-6939.
As we stated at the public hearing, we have found several areas
in the report which we need additional time to analyze prior to
forwarding detailed comments to your office. To assist in our
analysis, we have enraged th-3 engineering form of Rieke, Carroll,
Muller Associates, Inc. of Hopkins, Minnesota to do the work. We
expect to receive their report by July Sth and we will forward our
comments immediately thereafter.
Thank you in advance for your consideration in this matter of
vital importance to our community.
U2T
id M. Chi Ids
City Manager
DMC/cjk
cc: Doug Day, MPCA
David McDonald, Briggs and Morgan
Lawrence Anderson, Rieke, Carroll,
St. Anthony City Council
Wong, EPA
Muller Associates
Robert (Bob) Sun. '..a
V
.-.yor P. \v\-i
RirharH A Fnrnoth .liMv.-
v Citv Mana.j*"
ra.' Marks Cl«rt?nc» Ranallo
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?:?C! S'Kvr !_..! . F.o.-.i ^\ A-.-.rr^r.y. Minnesota 554 If.
July 15, 1986
U.s". Environmental Protection Agency,
Region V
23C South Dearborn Street
Chi cat-c, IL 60504
The City of St. Anthony appreciates the tiir.e extension which
allcv.-s us to corr_-.ent on the St. Anthony Phased Feasibility Study
(PFS) and also the understanding on the part of U.S. EPA concerning
the critical ir.pcrtanca to cur corr.-unity and its citizens that the'
correct choice be made regarding cur long range water supply alter-
natives.
Our ccr.-ents on the Camp, Dresser' and McKee (CDM) Report follow:
1. The Phased Feasibility Study (PFS) addresses replacement of
capacity for only two-thirds of our water supply system. Our
system was originally designed to handle most eventualities
and re~=dial action relating to only two of our three wells
will leave us without a back-up supply which has been so
critical to us, especially during the last two years. In
April of 1934, a tornado devastated our community, causing
$15,000,000 to $20,000,000 in damage. Power was out for
several days. Th3 only source of water was Well #5 - a water
supply source largely ignored by the CDM Report. In the
suiter of 1936, V.'ell 25 also became the only source of supply
for St. Anthony after lightning struck Well #4.. The water
rationing ban in our City lasted only one week, but could
ha'.*G been much longer if the damage had been more severe.
It is absolutely essential to our community that the supply
system available prior to contamination of our drinking water
be maintained for our residents on into the future.
2. The City of St. Anthony., has commissioned Rieke, Carroll and
Holler .".ssociatcs (HCn") to evaluate the PFS submitted by CDM U
based en our comments ar.d concerns, many of which were ex- *-
pressed at the June 23, 1086 public meeting. We have attached
M....,.: I >.ivnt (''.«\ I < ':lv M.<
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their report and risk that it. b'.- considered on behalf of the
City of St. Anthony as official corr-i^nt regarding the
St. Anthony PFS.
3. The RCM Report rr.ises a nur.ihdr of questions and concerns about
- . the PFS which we would like to see addressed prior to final
action, and I will not attempt to repeat all of them here.
There are, however, some pertinent items which should be
emphasized.
a. The COM Report anticipates that the existing "Roseville
Connection" is available as back-up water supply. Vve
strongly disagree and feel that the RCM Report addresses
that concern.
b. We have also asked RCM to respond to statements in the
PFS regarding deep wells as an alternative water source
for the City. Although it may indeed prove to be
unfeasible in the final analysis, we feel that the
alternative was rejected too early in the process.
4. V.'e believe that the concept of carbon filtration of Wells S3
and £4 nay have r.erit as a preferred alternative but are
unable to give final concurrence until concerns raised at
the public meeting,, in the RCM Report, and in this letter are
properly addressed.
3. The RCM suggestion about drilling one new deep well (Mt. Sir.on/
Hinckley) as a back-up well for carbon filtered V\'ells £3 and
= 4, appears to have true merit and deserves further study.
The alternative would envision placement of this deep well
near Wells S3 and M, allowing all three wells to use the £
existing manganese and iron removal plant and the current '
punping and storage system. The additional capital cost of
a single new deep well would be comparable to a carbon filter
on Well *5 and the Operation and Maintenance costs would be
substantially lower for the dee? well.
These comments are certainly not exhaustive and with only a few
v;eeks having elapsed since our receipt of the final COM Report, we
feel that we have taken swift action to study the report and to
develop a preliminary position relating to the City's alternatives and
UPA and MPCA's recommendations.
We are extremely pleased with the cooperation of U.S. EPA and
MPCA to date and send our thanks to both staffs for their responsive-
ness .
On the other hand, we have-found the U.S. Army and others
extremely uncooperative and resent the stonewalling presented in a
situation involving two public agencies (the City and the Army), both
of \:hich are taxpayer supported. It is a tremendous waste of public
h
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r .,,;,. ;: rs,->
J u - . . V- . .
J,::v 15, 19f-.G
;^:rc 3
monies and we call on. the i!i'Ca and U.S. EP7i to "tighten the screws"
on the Army and ether alleged responsible parties to head off what
will otherwise be a highly contested and bitterly fought lawsuit
between the City and the responsible parties. Our resolve in prevail-
ing in such a lawsuit will regain ur.dunned, while our willingness for
sensible negotiation remains foremost in our minds.
Than]; you again for the opportunity to comment on the PFS.
Kith levels of contamination continuing to rise, we request early and
speedy action so that our residents can enjoy safe drinking water
v:ithcjt interim emergency (tciv.porary) measures being required, which
v:ill inevitably cost more in the long run.
Please do not hesitate to call me if you have any questions.
Sincerely,
David M. Childs
City Manager
DMC/cjk
St. Anthony City Council
Gene U:ong, U.S. EPA
Doug Day, r.PCA
David IlcDonnld, Brings anu Morgan
/.ttorney General Hubert H. Humphrey III
Representative John Rose
Congressman Martin Sabo
Congressman Gerry Sikorski
Congressman Bruce Vento
Congressman Arlan Stanceland
Senator David Durenberger
Senator Rudy Boschwitz
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n
REVIZW OF THE PHASED FEASIBILITY STUDY
REPORT FOR ST. ANTHONY VILLAGE WATER SUPPLY
Prepared for
St. Anthony Village, Minnesota
3uly 9, 1986
by
Rieke Carroll Muller Associates, Inc.
I hereby certify that this report wa-, prepared by me or under my direct supervision
and that I am a duly Registered Pr Sessional Engineer under the laws of the State of
Minnesota.
Dale A. Watson, P.E.
MN Reg. No. 12U1
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REVIEW OF THE PHASED FEASIBILITY STUDY REPORT
FOR ST. ANTHONY VILLAGE WATER SUPPLY
by Rieke Carroll Mufler Associates, Inc.
July S, 19S6
Introduction
The U.S. Environmental Protection Agency, through one of its hazardous waste sites
remedial response consultant, Camp Dresser and McKee, Inc., has prepared a Phased
Feasibility Study for the Saint Anthony Village water supply. The study was conducted
to identify and evaluate alternatives to replace or treat the contaminated water from
the City's existing wells.
Saint Anthony Village desires to have meaningful input into the Federal/State
decision-making process because those decisions will directly affect the City. To
assist them, the City retained Rieke Carroll Muller Associates (RCM) to provide
engineering advice related to the review of the Phased Feasibility Study.
The scope of services consisted of the review of the Phased Feasibility Study (PFS)
report for purposes of identifying engineering aspects of the report that appeared
weak, flawed, insufficiently documented, or possibly counter to City interests.
As a part of the review, we obtained and reviewed the following documents:
a) "Phased Feasibility Study for St. Anthony;" June 19S6; by Camp Dresser and
McKee, Inc. for the U.S. EPA.
b) "Feasibility Report for Temporary and Permanent Water Service from
Roseville"; March 27, 19S^; by Short-Elliott-Hendrickson, Inc.
c) "Report on Water Supply System, for St. Anthony, Minnesota" (with supplement);
by Bcnestroo, Rosene, Anderlik -k Associates, Inc. and Sarr Engineering
Company.
a
Page 1
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d) "Alternative Screening Temporary \Vater Supply - St. Anthony, Minnesota"; June
27, 1933; by CH2M HILL.
e) Various project notes and worksheets provided by Camp Dresser and McKee, Inc.
Our review of the Phased Feasibility Study (PFS) report was conducted as a three part
evaluation. The first part consisted of a review of the thirteen alternatives which the
report considered. In that investigation we determined whether all potentially viable
alternatives had been considered. The second part of the investigation consisted of a
review of the treatment and/or supply alternatives which the PFS report eliminated as
being not potentially feasible. Here, we judged whether or not adequate justification
was developed and presented for excluding certain alternatives from further
consideration. The third part consisted of a review of the three treatment/supply
alternatives which the PFS report investigated in detail. A critique of the information
presented follows.
Alternative Screening
\Ve generally concur with the PFS report regarding the indentification of initial
potentially feasible alternatives for supply and/or treatment. Other supply/treatment
alternatives that could have been mentioned include:
A. -New shallow wells (i.e. drift wells) with subsequent treatment: Glacial
drift material can sometimes be found that provides good well yields. Such
wells do tend to be susceptible to contamination.
B. Volatile organic compound (VOC) removal by different aeration or
oxidation techniques. These techniques are generally considered
experimental at this time.
C. Combinations of the various alternatives.
Although these are possible alternatives, we do not anticipate that any will provide a
viable treatment or supply option and,..therefore, we suggest no further consideration
be given to these at this time.
Page 2
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Dismissed Alternatives
Under the review of the treatment alternatives which were dismissed as being non-
viable, we offer the following comments:
A. The. Minneapolis connection is a potentially viable solution and should "have been
discussed in more detail. The treatment capability of the Minneapolis \Vater
Treatment Plant is approximately 200 rngd. St. Anthony's average daily
consumption is 1.2 mgd, or approximately 0.5/o of the capability of the
Minneapolis facility. The Minneapolis Water Department staff has indicated that -^
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asked D. A. Liesch Associates, Inc. to provide us with an assessment of the
potential for Mt. Simon-Hincklcy wells. Their comments are appended to this
document.
D. The combined air stripping and liq'jjd-phase-carbon-adsorption alternative should
not have been'dismissed without further evaluation. This alternative may also be
attractive from an operation and maintenance standpoint. The report evaluation T
considers the cost of removing 300 parts per billion of VOC. If a combined air
stripping carbon adsorption system is utilized, the cost of carbon replacement
may be significantly reduced by first removing a major portion of the volatiles
through air stripping.
Review of Detailed Alternatives
Part three of our review consisted of evaluating the discussion- of the three detailed
alternatives.
Roseville Permanent Connection;
A. In the PFS report, much discussion is devoted to the standby connection to
Roseville. We would recommend that, if a booster pump and/or automatic valve
system were constructed, they should be built within a building and not a valve
vault. Also, we do not understand the value of the valving arrangement as
presented. It would appear to be more reasonable to have two manually
operating valves feeding the system. Also, if a standby supply is needed, it may
be more desirable to make that connection directly to the St. Anthony
distribution system in the area of 29th Avenue and Silver Lake Road rather than
locating it north along Rankin to 33rd Avenue.
x
B. Since the existing iron removal filters would not be needed, would they be
abandoned and what would be the removal cost. Also, proper abandonment or
other disposition of the wells would be required.
C. For consistent comparison of the alternatives, costs for operating the high
service pumps (and building heating) should be included in the Roseville
e k
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alternative, since these costs also appear in the treatment alternatives
(combined in the estimate for operating wells 3 and t).
D. The annualized eqj.p-nent replacement cost is incorrectly calculated and is j
overstated.
E. In the report, constructability of the Roseville connection is judged to be
moderately difficult compared to moderately easy for the treatment |^
alternatives. This seems to us to be an inaccurate qualification.
F. A water rate change will be required for whatever alternative St. Anthony
pursues. The cost of a rate study should be included in the total costs of each |
alternative.
Air stripping with vapor phase carbon adsorber for air purification:
G. The air stripping system as proposed will just meet maximum day capacity with
all equipment in service. For achieving good reliability, the design flow
(maximum day rate) should be met with the largest individual unit of a giver. ["fl
process out of service (called firm capacity). Preferably, an additional air
stripper, or at least a standby blower, should be provided.
H. The need for an emergency power supply has not been discussed. M
I. The design of the air purification system is not well documented. Since these
systems are not commonly used on air strippers, the design, operation, msts. and (J
need should be more fully considered and discussed.
3. A 30 percent contingency allowance has been used for all alternatives. This
seems overly generous and could tend to bias the cost estimates in favor of the p
less-capital-intensive alternatives.
K. Computation of the a-.nuali^ed equipment replacement costs is not correct. Q
L. Energy costs appear over-esti.-nried because all three stripping tower blower? _»
and both air purifici:io-i system '.- s were assumed to run continuously.
?i :e 5
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M. The air purification system carbon d:sposal cost appears to be miscalculated. O
Carbon Adsorption System (Liquid Phase):
N. Comments made previously regarding annual equivalent replacement costs,
contingencies, rate study costs, emergency power, and firm capacity apply to I
this alternative as well.
O. The square-foot cost of the new building is higher in this alternative than for the . .
air stripping alternative. Why? Also the building maintenance cost is higher.
P. The energy use seems to be overestimated. It appears that an extra stage of ..
pumping has been assumed and that all pumps are as-sumed to run continuously.
Q. The City should realize that carbon costs are a major operating expense and may-
Vary greatly. The carbon replacement cost is estimated to be $6Q,QOO/yr. based
on a carbon purchase price of $O.SC/lb. and a disposal cost of $0.20/lb. Recent
vendor information shows a purchase price of $0.95/lb and disposal costs could be ...
=is high as $1.10/lb. The carbon usage could also change greatly (perhaps by an
order of magnitude) depending on the concentrations and types of organics in the
water. With VOC levels in the wells apparently increasing with time, it is
difficult to accurately predict carbon usage.
R The cost estimate for liquid phase carbon adsorption is based on equipment
normally used for temporary treatment situations. \Vhen considering a y
permanent facility, as will be required under this alt°-native, capital costs may
be $150,000 greater than indicated.
Reserve Water Supply Requirements
A. The entire treatment discussion in the report assumes that wells 3 and '4 wiil.be ..
utilized to supply the maximum daily demand and that the existing temporary . .
connection would provide standby capabilities, if necessary. We think the City '
should have at least the same supply capabilities in the future as they had prior .
Page 6
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to the contamination. \Vith wells 3, ^ and 5, there was the capability of
providing the maximum daily demand with one well out of service. The system
proposed by the PFS report would not provide that capability.
From the report by Short Elliott and Hendrickson Associates, it is obvious that
the temporary connection was never intended to serve as a backup to the entire
City. In fact, their report states that it would serve 15-2C"o of the City and
wells '4 and 5 would serve the remainder of the City. If the entire St. Anthony
system were directly operated off the Roseville system, W.'a of St. Anthony's
elevated storage and all of its ground storage would be rendered useless. \Vhen
only a portion of St. Anthony's system is isolated and served by the temporary
Roseville connection, the remainder of the City has no reserve supply at all.
Reiving on the Roseviile temporary connection for standby capacity is not
viable. \
\Ve suggest that if a backup supply connection is made to Rosevilie, it should be
made sirr.Uar to the so-called permanent connection which has been evaluated in
one of the other alternatives of the report. Any cost of supply and/or treatment
of the water from wells 3 and '4 would then have to include the cost of the so-
called permanent Roseville connection. It should be noted that the system may
have interface problems with two waters of different hardness, which is part of
the reason the temporary connection serves only a section of the system that is
valved off from the rest.
3. A better reserve supply alternative is to have a third well. The PFS report
recommends elimination of well number 5 because it "operates with an older
diesel engine". It is our feeling that since the City is investigating a long-term
water supply problem, use of an existing well should not be eliminated just
because of an inadequate existing well pump. The report also mentions high iron
concentrations in well number 5 and no treatment available for removal of that
iron. Treatment could be provided. Further analysis should be made to
determine the cost-effectiveness of separate treatment at the well head versus
piping of the well 5 raw water to a centra! treatment plant.
Also a combination cf VOC treatment for weils 3 and k plus drilling a new \U.
Simon-Hinckley well should be given serious consideration. Placement of the
Pase?
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new well near wells 3 and 4 wo-!d permit utilization of tne existing iron removal
capability, would eliminate lon^-distance piping of raw water, and would not
cause interference with wells 3 and tt in the Prairie Du Chien/3ordan aquifer.
Such an alternative would provide adequate standby capacity perhaps at less
expense than other methods considered.
Conclusion
As a result of our review and critique of the PFS report, we have commented on
numerous concepts and details which the City may wish to consider in preparing its
response to EPA.
U'e have major reservations concerning the report's failure to adequately address the
\U. Simon-Hinkiey wells alternative and the reserve supply issue for the treatment Q «
alternatives. Furthermore, there are some areas related to the preliminary design and
cost-effectiveness analysis of the alternatives that could be improved if necessary.
Finally, we believe that consideration should be given to an alternative consisting of
VOC treatment of water from wells 3 and 4, with construction of a new V,t. Simon-
Hinckley well near the existing treatment plant. This alternative has a number of
advantages and may be a cost-effective way of providing an adequate water supply.
Page S
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MT. SIMON - HINKLEY ACU1FER ASSESSMENT
bb
ST. ANTHONY, MINNESOTA
JULY 9, 1966
PREPARED BY
BRUCE A. LIESCH ASSOCIATES, INC,
2131 FERNBROOK LANE
MINNEAPOLIS, MINNESOTA 55441
(£12) 539-1422
THIS REPORT WAS PREPARED EY:
KENNETH P. OLSON
.P.G.S. 7053
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DAi'
L BRUCE A. LIESCH ASSOCIATES, INC.
. ..>v.s CONSULTING HYDGOlOGiSTS P:7C?ESSlOr;AL GEG.OGT; ENVlRONY.EVA: SC'EVT.S'S
..'. . '.< 3131 Fernbrcok Lane / Minneapolis. Minnesota 55^-1 / 612-55?-1^22
<*_Ai»*.*tuX'*
Mt. Samon-Hinkley Aquifer Assessment
St. Anthony, Minnesota
Introduction
As part of the review of the Camp Dresser d. McKee, Inc.
(CDM) phased feasibility study for St. Anthony (June, 1966),
BAL conducted a preliminary assessment of the potential of
the Mount Sinon-Hinkley aquifer as a replacement Water
Supply Source for the City of St. Anthony. As part of the
review BAL collected and reviewed the following documents:
- CDM Phased Feasibility Study (June 1966)
- New Brighton Well Construction and Pumping Records
- DNR Water Appropriations Permits
- Discussion with DN'R regarding permittability of
Mt. Siir.on-Hinkley Wells
- Water well records from the Minnesota Geciccical
Survey
- Pertinent, publications on Mt. Simon-Hinkley Aquifer
The U.S. Geological Survey has conducted studies of the Mt.
Simon-Hinkley Aquifer in the Twin Cities Area tut that
information was not available for review owing to the
vacationing of the U.S.G.S. staff person responsible for the
study.
CDM Findings
CDM concluded in their June, 19S6 report that development of
the Mt. Simon-Hinkley aquifer as an alternative water supply
source was not feasible for the City of St. Anthony. CEM
identified four limiting factors in the use of the Mt.
Simon-Hinkley Aquifer as follows:
-The Mt. Simon-Hinkley is a tightly confined aquifer
with little local recharge. It is for this reason
that the DN'R would like to see the Mt. Siir.on-Hinkley
aquifer developed only as a last resort.
-It would be difficult to site wells in the St.
Anthony area due -o the spacing requirements needed to
minimize well interference and maintain well yields.
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-.-.11 water supplies would need to be treated with
rer.oval. The raw water would need to either be
transmitted to a centralized treatment facility which
would entail installation of transmission line to the
treatment plant cr treated at the water head through
construction of individualized treatment plants.
-The Mt. Simon-Hinkley water supply alternati-ve was
' calculated to be associated with the second highest
capital costs of all alternatives evaluated.
CD'.X also concluded that cnly Well No. 3 has a sufficient
well diameter to be reconstructed as a Mt. Sim.cn-Hi nklev
well.
Mt. Simon-Hinkley Aquifer Availability and Feasibility.
New Brighten »vater System
N.ew Brighton experienced similar water supply contamination
from volatile organics, with the contaminant levels observed
in the New Brightor. wells much higher than those observed in
the St. Anthony wells. In 1962 Mew Brighton selected the
deep well alternative as the most feasible approach to
mitigating the contamination of the Prairie du Chien-Jordan
aquifer. The deep well alternative was selected as the nest
feasible in large part because of the unknown reliability of
both carbon treatment and air stripping in 1982. The City
reports that the Minnesota Department of Health reccmr.ended
that the deep well alternative be selected apparently
because of this unknown reliability of other alternatives.
The City of New Brighton presently operates five Mt.
Simcn-Hinkley wells and one Prairie du Chien-Jorcan well.
New Brighton plans on installing one additional Mt.
Simcn-Hinkley well this sur.r.er . Of the five existing Mt.
Simen-Hinkley wells, two are reconstructed Prairie du
Chien-Jcrdan wells which were drilled and cased into the Mt.
Simon formation.
The Mt. Simcr.-Hir.kiey wells presently pump from "CO to 1100
gallons per minute (gpm). During the initial testing of the
wells, pumping rates of up to 1600 gpm were recorded. One of
the limitations to higher pumping rates is that at the
higher pumping rates increasing amounts of sand are pumped
from the well. The City reports that a very fine grained
sand was removed during, development and observed during
pumping. Over time with continued pumping the sand levels
decrease. According to City staff, sand has not caused an
abrasion problem with the well pumps and has not caused
appreciable operational problems. The City estimates the
sand content to ze 2-4 ppm.
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Testing and observation of the Mt. Sinon-Hinkley wells has
indicated that the wells are associated with a specific
capacity of 10 qpn per foot of drawdown (gpm/ft). Because
the well field cannot be shut down to test individual wells,
this specific capacity takes into account the interference
between wells. The distances from the centralized well to
the other wells ranee from 7,COO to 10,000 feet. Static
water levels observed at the City wells range from 280 feet
below the surface in the southern parts of New Brighton to
220 .feet below the surface in the northern parts of the
City.
Water from the Mt. Simcr.-Hir.kley aquifer is generally soft
with a hardness reported to be 9-10 grains per caller..
Manganese is generally low with iron reported to be in the
area of 0.7 ppn. The water is reported to be associated
with hydrogen sulfide with an odor present at the well head.
After treatment for iron, hydrogen sulfide is no longer a
problem. The water is also reported to be slightly
aggressive with piping but has not caused any operational
problems.
Area Mt. Simon-Kinkley Water Use
In addition to the City of Uew Brighton, there are other Mt.
Simon-Kinkley water users in the area. The City of Fridley
is reported to have four Mt. Siinon-Hinkley wells located
over two miles northwest of St. Antr.cny. The Soo Line
Railroad has a well one mile west of the City and was
reported to have a 1984 water appropriation of 9.4 million
gallons. The Burlington Northern Railroad has a Mt.
Sinicr.-H ink ley well approximately 1-1/2 miles southwest of
the City. This well was reported to have no water
appropriation in 1984 and may not be used at present. There
are four other high capacity wells within two miles cf the
City which are not identified as tc which aquifer they draw
from. Those wells are; Midland Hills golf course and Paper
Calmenson & Co. located southeast of the City, Incianheac
Truck Lines east of the City, and Feinberg Distributing
south of the City.
DNR Position
The DNR was contacted to discuss the potential for the use
of the Mt. Simon-Kink ley Aquifer in the Ci'ty of St. Anthony.
The DNR indicated that the Mt. Simon-Hinkley Aquifer could
be used as an alternative water supply source but that it
must be shown to be the most feasible of all alternatives.
The DNR policy is to attempt to stay away from use cf the
Mt. Simon-Hinkley Aquifer if possible.
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If the Me. Simon-Kink ley aquifer was proposed as the
mitigation alternative, the selection would have to be
justified before the DNP would issue appropriation permits.
In reviewing this alternative, operations and maintenance
costs will be considered as or.ly one of many factors in the
review of this alternative. The DNR would also require that
a water conservation program be implemented to minimize
water use.
Mt. Simon-Kink ley Potential
he Mt . Si-cn-Hinkley Aquifer appears to be a suitable
alternative water supply source for the City of St. Anthony.
The selection of this alternative also has seme inherent
short tern and long term potential limitations.
Eased en the experience of the City of New Brighton, a Mt.
Sinon-Hinkley well in St. Anthony could be expected to have
a specific capacity of 10 cpm/ft. This means that a well
pumped at 1000 gpm would experience 100 feet of drawdown.
Recall that the specific capacity of 10 gpm/ft observed in
New Brighten includes the drawdown interference caused by
the other area wells pumping.
A static water level ranging from 250 to 300 feet below the
surface could be anticipated at Mt. Simon-Hinkiey wells.
Static water levels would be highest in the northern areas
if . the City with static water levels declining in a
southerly direction.
Well No. 3 is the only well in the St. Anthony well field
that could be reconstructed as a deep well. At present Well
No. 3 has a 24 inch diameter inner casing with a 30 inch
diameter outer casing. A 23 inch borehole could be drilled
to the Mt. Simon formation and an IS inch diameter liner
casing installed. The casing would be grouted in place to
isolate the contaminated Prairie du Chien-Jordan Aquifer.
Similar procedures were successfully used on wells no & and
9 in the City of New Brighton in 19S2. Reconstruction c:
well no. 3 would provide a deep well centrally located in
the City and near the existing iron treatment facility.
Weils no. 4 and 5 do not appear to be suited for
reconstruction. Both wells are reported to be constructed
with a 16 inch inner casing. To drill and install an inner
liner casing a 10 inch diameter casing would need to be
installed to meet the requirements of the Minnesota
Department of Health. A 10 inch casing would limit the
yield that the well could_ produce .
If the Mt. Sinon-Hinkley Aquifer is developed, additional
wells could be installed near Gross Golf Course in the
southern end 'of the City and near well no. 5 near Silver
Lake. General distances to ether area wells from the
proposed location are provided bel'ew.
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Well No. 3 (St. Anthony) (ft)
- proposed deep well (Gross Golf Course) 7,000
- Proposed deep well (Silver Lake) 5,000
- Soo Line Railroad 10,000
- Well 10 (New Brighton) 6,500
- Well 9 ( " ) 8,500
- Indian Head Trucking 9,000
Proposed Deep Well (Gross Golf Course)
- Well 3 (St. Anthony) 7,000
- Burlington-Northern Railroad 10,000
- Soo Line Railroad 10,000
- Paper Calminson 2,500
- Feinstein Distributors 6,000
- Indian Head Trucking 9,000
Proposed Deep Well (Silver Lake)
- Well 3 . 5,000
- Well 9 (New Brighton) 5/500
- Well 10 (New Brighton) 6.500
Under a well installation scenario as presented, Well No. 3
and the Proposed Deep Well (Gross Golf Course) could be the
primary pumping wells with Proposed Deep Well (Silver Lake)
as the backup well. This would help maximize the distance
between area Mt. Simon-Hinkley wells. This scenario nay
also increase operational costs owing to the anticipated
deeper static and pumping levels in the southern end of the
City.
Well construction of the wells would be similar to the well
construction of the New Brighton wells. A 30-inch surface
casing would be driven to rock with a 29-inch borehole
advanced to the top of the St Lawrence Formation. 24-inch
casing would be installed and grouted in place with neat
cement grout. A 23-inch borehole would be advanced into the
top of the Mt. Simon Formation and an 18-inch casing would
be installed and grouted into place with neat cement grout.
A 17-inch borehole would be advanced into the Mt. Simon and
Hinkley Formation and the well developed.
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There are some limiting factors associated with the Mt.
Simon alternative.
1) The DNR may not permit the use of the Mt. Simon-
Hinkley Aquifer if other water" supply sources are available.
Capital, and 0 & M cost will be only one of the factors in
the review of the various alternatives.
'2) Water levels in the Mt. Simon-Hinkley Aquifer have
historically been declining since the use of the aquifer
began. The Eau Claire formation overlying the Mt. Simon
formation acts as an effective aquitard limiting the amount
of vertical recharge reaching the aquifer. Recharge occurs
predominantly in the areas north of the Twin Cities where
the Mt. Simon and Hinkley formations subcrop and are in
direct contact with glacial materials.
The City of New Brighton has not experienced a decline in
static water levels over the almost 4 years of record which
suggests that the City is not "mining" groundwater. This is
an insufficient record to assess long tern groundwater
trends or the response of the aquifer to short term or
prolonged drought. Intuitively, we would expect to see
water levels slowly decline through the increased usage of
the aquifer.
3) It is important that any new deep wells are
adequately constructed so as not to provide a conduit for
downward migration of contaminants into the Mt. Simon-
Hinkley Aqu i f er.
4) The cost of well construction and operation will be
higher for wells located in the southern end of the City
when compared to northern areas. The formations and
potentionetric surface slope in a southerly direction. This
will require the installation of deeper wells and will
required more lift at the southern wells.
5) High iron and hydrogen sulfide levels will require
iron treatment prior to distribution. The water is also
reported to be slighlty aggressive though New Brighton has
not reported operational or equipment problems to date.
6) The fine grained nature of areas of the Mt.. Siror.
-Hinkley Aquifer will require additional development time
during well installation. Sand may also be a '.continuing
problem through the operation of deep wells.
7) The existing Pra-irie du Chien-Jordan Wells may need
to be abandoned if they are not deepened or used as part of
an aquifer clean-up program. .. :
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If the wells are not to be used as either water supply
sources or as clean-up wells, the Minnesota Department of
Health may require that they be permanently abandoned.
Abandonment of the wells may consist of grouting the wells
from the base to the surface using neat cement grout.
The existing wells may be usable in what ever aquifer
clean-up program is developed. The wells could be used as
is, or reconstructed to draw water from a select horizon in
the. aquifer to act as either removal or monitoring wells.
Costs for Mt. Simon-Kink ley Alternative
Well Construction
Mt. Simon-Hinkley wells drilled and constructed as presented
within this report (30 inch X 24 inch X 18 inch) should cost
between $ 250,000.00 to S 300,000.00 per well. This cost
covers drilling, installation, and development of the well
but does not cover puir.p costs, controls, well house, and any
transmission line or treatment costs.
Well Abandonment . '
Well abandonment cost, are difficult to estimate because of
the unknown nature oi the borehole characteristics. Beth
large cavities in the Jcrdan Sandstone as well as r.ajor
fractures or solution cavities within the Prairie du Chien
dolomites can require large quantities of grout and, as
such, increase the well abandonment costs.
Wells No. 4 and 5 are Jordan Sandstone wells with the
Prairie du Chien dolomites cased off. In developing costs
for abandonment we assumed the open borehole was not much
larger than the casing I.D.. We also assumed the well would
need to be grouted using neat cement grout so as not to
provide a conduit for deeper migration of contaminants.
The anticipated costs to abandon the wells is $ 6,000.00
each. If the borehole in the Jordan Sandstone is
appreciably enlarged during development and operation, the
cost could increase to SIC, 000 or more per well. This is
based on an installed cost for neat cement grout of
$200/c.y. which was provided by an area drilling contractor.
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(APPENDIX 2)
AGENCY'S RESPONSE TO PUBLIC COMMENTS
ST. ANTHONY MUNICIPAL WELLS
ST. ANTHONY,. MINNESOTA
The public comments are presented in Appendix 1.
PUBLIC COMMENT EPA RESPONSE
la The U.S. EPA acknowledges the support of Mr. Childs.
Ib Additional information addressing the deep well
alternative (see Sec. 2.2.4) has been incorporated
into the Final Phased Feasibility Study (PFS).
The primary reason the deep well alternative was
not considered for detailed study was because of
the Minnesota Department of Natural Resources'
(MDNR's) concern about the long term adequacy of
the Mt. Simon-Hinckley aquifer system as a sole-
source supply. Other important reasons were the
technical difficulty in locating the required number
of deep wells, the long implementation times, and
the high costs.
Ic With regards to the Roseville/St. Paul connection
alternative, even with a 25% reduction in the cost
estimate, this alternative would still be the least
cost effective of the alternatives considered for
detailed study. Additionally, there may be community
resistance to the alternative due to taste and odor
problems associated with the water.
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Id The PFS has been amended to include detailed
analysis of St. Anthony's need for a standby/
emergency water source (see Sec. 3.1.1.4).
After the determination was made that the city
required a new standby/emergency source, options
were developed and evaluated to address this need.
As a result of this evaluation, the recommended
alternative was amended to include construction
of a pipeline connecting St. Anthony well 5 to the
proposed granular activated carbon (GAC) treatment
facilities to provide the city with a dependable
standby/emergency source of water.
le At the time this comment was made, Section 104(c)
(3) of the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA)
stated that the State had the financial respons-
ibility to assure payment of 10% of the operation
and maintenance (O&M) costs of the first year and
all future O&M costs for the life of the project.
The State would have most likely passed these
costs on to the City of St. Anthony. Under the
new Superfund Amendments and Reauthorization
Act of 1986 (SARA), specifically amendment (i)(6)
to Section 104(c)(3) of CERCLA, the U.S. EPA
will assume 90% of the annual operation cost of
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le(cont) the remedial action for a period of up to 10
years. The State will fund the remaining 10%
of the annual operations costs and all future
O&M costs after the initial 10 year period. "
The City of St. Anthony, through an anticipated
agreement with the State may still have to
assure the State share of the operational
costs, however, under the new law, the State's
share of O&M costs would be substantially reduced
from previously anticipated levels.
2a The U.S. EPA acknowledges the comments and the
support of Mayor Sundland.
3a The U.S. EPA acknowledges the comments and the
support of Mr. Mitkie.
4a The U.S. EPA acknowledges the comments and the
support of Ms. Daniels. The City of St. Anthony
has filed a complaint (suit) in March, 1986
against the U.S. Army for injunctive relief and
damages resulting from the groundwater
contamination problem.
5a No response required.
6a A two-week extension of the public comment period
was granted, therefore, the public comment period
officially closed on July 16, 1986.
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7a U.S. EPA, through a press release issued on
June 9, 1986 and a display ad, notified the
public of the June 23, 1986 public meeting.
Additionally, the local press provided notification
through recent articles regarding the site.
8a The U.S. EPA acknowledges the support from the
Minnesota Pollution Control Agency (MPCA) and
look forward to working with the MPCA in a
cooperative effort to conduct this operable unit.
8b No response required.
8c ' The PFS has been revised to include a more
detailed discussion of the gravity and pressurized
flow carbon treatment technologies (see Sec.
3.1.1.3). EPA believes detailed assessment
between the gravity and pressure GAC treatment
systems is more appropriately considered during
the remedial design phase than the feasibility
study phase. Additional information regarding
both GAC systems will be obtained and applicability
testing will be performed in the early stages of
the remedial design.
8d Cost information on all remedial action
technologu-s was obtained from vendors of
these services as well as from the published
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8d(cont) literature. Cost estimates of the remedial
action including O&M costs will be further
refined in the design phase.
8e Please refer to EPA's response to comment Id.
With regards to the existing Roseville-St. Anthony
interconnection, water from this connection is
not needed if the recommended alternative is
implemented. However, abandonment of the
connection is not warranted as the associated
maintenance costs are far less than abandonment
costs. As a consequence, it is recommended
that the existing remain connection serviceable.
9a Please refer to EPA's response to comment 6a.
lOa Please refer to EPA's response to comment Id.
lOb No response required.
lOc Please refer to EPA's responses to comments Id
and 8e.
lOd Please refer to EPA's response to comment Ib.
lOe EPA believes that revisions incorporated into
the PFS have addressed all of the City of St.
Anthony's concerns.
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lOf Section 3.1.1.4. which addresses the standby/
emergency water source, has been added to the
PFS. Based on the cost analysis of the standby/
emergency source options, the pipeline option
was determined to be the most cost effective.
The O&M costs between the pipeline option and
the new well option are comparable, however,
the capital cost of the new option is $227,003
greater than that of the pipeline option.
lOg The U.S. EPA acknowledges the support and cooper-
ation from the City of St. Anthony and look
forward to working with the City in a cooperative
effort to conduct this operable unit.
lOh Please refer to attachment 1 which provides
information regarding Federal enforcement
activities at this site.
lOi No response required.
lla No response required.
lib As was recommended, no additional potentially
feasible alternatives were considered.
lie Section 2.2.3.2 of the PFS has been revised to
include a detailed discussion regarding the
reasons for dismissal of the Minneapolis
connection alternative. The primary reason, for
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llc (cont) dismissal is still because of MDNR's serious
reservation about the adequacy of the Minneapolis
system to supply water on a sole-source basis
to additional users especially during an
extended drought or under emergency situations.
lid Section 2.2.3.3 of the PFS has been revised to
include further discussion regarding the reasons
for dismissal of the Columbia Heights connection
alternative. Since the community of Columbia
Heights receives water from the City of
Minneapolis, the same MDNR concerns exist.
lie Please refer to EPA's responses to comments Ib
and le.
llf Preliminary cost estimates of a combination air
stripper and carbon absorption system indicate
that any reduction in carbon usage in the liquid
adsorber would be offset by the added carbon
use in the vapor phase adsorber. Capital and
O&M costs would also be increased.
llg Technical justification in support of the
comments is absent. Attention would have been
given to these design considerations in the
design phase if the Roseville/St. Paul connection
alternative was recommended.
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llh Currently, it cannot be determined whether
abandonment of the iron filters and/or the
wells is or is not consistent with the final
remedy. Since the regional RI/FS has not been
completed, no determination can be made at this
time. Additionally, since this alternative was
not the recommended alternative, a detailed
cost analysis regarding iron filter/well
abandonment was not performed.
Hi Table 3-6 (Annual Costs - Roseville/St. Paul
Alternative) has been revised to include the
costs for building heating and for operating
the high service pumps.
llj Upon reviewing our annualized equipment
replacement cost (AERC) calculations, we find
that they are correct. The vagueness of the
term "overstated" is such that no changes in
the AERC calculation are warranted.
Ilk It is unclear from reading the comment which
alternative the commentor perceives is
"inaccurate" in terms of constructability,
therefore,, no response could be given.
Ill EPA believes the City of St. Anthony should
assume the performance and the costs of any
water rate studies deemed necessary as a
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111 (cont) result of using any of the alternatives.
llm With the proposed air stripping system, essential
demand would have been met. The additional cost
of a backup tower is not warranted due to the
ready availability of the air stripper system's
moving components (motors, fans, etc.). In
addition, for all alternatives which do not
incorporate the existing Roseville-St. Anthony
interconnection as part of the alternative, EPA
recommends that this connection remain serviceable,
thereby, maintaining a limited emergency water
source.
lln The integration of an emergency power supply
would have constituted an improvement to the
St. Anthony water supply system beyond what
existed prior to well contamination, therefore,
an emergency water supply was not considered.
llo Since an air stripping system was not the
recommended alternative, a detailed design, as
requested in the comment, was not performed.
Detailed discussion of design, operation, and
costs are part of the design phase. EPA
believes the need for the air purification
system would have been dictated by community
concern.
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llp ' The typical contingency allowances specified in
the U.S. EPA'guidance document. "Remedial Action
Costing Procedures Manual", fall in a range
from 15 to 25 percent of total capital costs.
Cost estimates in the PFS have been revised to
reflect usage of a conservative contingency
allowance of 25'percent.
llq AERC computations have been reviewed and no
errors were found.
llr Table 3-8 (Annual Costs - Air Stripping) has
neen revised to reflect normal (assumed)
operating conditions.
11s The air purification system carbon disposal
cost was recalulated and the line item was
corrected in Table 3-8.
lit Please refer to EPA's responses to comments
111, llm, lln, lip and llq.
llu The higher square-foot cost for the carbon
adsorption system building in comparison to the
air stripping system building is warranted due
to the requirement of large access doors to
allow the carbon contactors to be removed/installed
by truck. The minimally higher annual maintenance
cost for the carbon adsorption system building is
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llu (cont) warranted because the air stripper system may
generate grea-ter amounts of dust/particulate
matter during operation.
llv Table 3-10 (Annual Costs - Carbon Absorption)
has been revised to reflect normal (assumed)
operating conditions.
llw EPA agrees with this comment. Cost estimates
in the PFS are based on vendor's quotes and
published literature. Cost estimates will be
refined during the remedial design phase.
llx Supporting statements/technical justification
for the $150,000 increase in capital costs is
absent.
lly Please refer to EPA's responses to comments Id
and 8e.
llz Please refer to EPA's responses to comments Id
and lOf.
llaa EPA believes that revisions incorporated into
the PFS have addressed all of the City of St.
Anthony's concerns.
llbb The report prepared by Bruce A. Liesch Associates,
Inc. titled "Mt. Simon-Hinckley Assessment" is
a support document specifically for comment lie.
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llbb(cont) For discussions regarding Mt. Simon-Hinckley
aquifer well(s), please refer to EPA's responses
to comments Ib and lOf and to Sections 2.2.-4
and 3.1.1.4 of the PFS.
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