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

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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
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____  CARVSR
                  ^a  >

                       SCOTT
                         HENNSPIN
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                                                          93*
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         10
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                                                           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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                                                        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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                 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.

-------
                                    -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.

-------
                                                                        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 ion—Central 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

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                                    -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

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                                    -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

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                                    -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

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                                    -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

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                                    -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
stripper—stack 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.

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                                    -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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                                    -23-





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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                                    -24-


 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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                                    -25-

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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                                 -27-





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.

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                               (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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                                   -3-
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

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 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

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                             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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                              -2-
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

-------
                            -3-

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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                            -4-
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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                            -5-
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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                            -6-
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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                            -7-
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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                            -8-
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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                            -9-
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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                            -10-
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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                            -11-
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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                            -12-
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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