United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R05-89/117
August 1989
SEPA
Superfund
Record of Decision
New Brighton/Arden Hills, MN
(Amendment)
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50272-101
REPORT DOCUMENTATION 1'. REPORT NO. . I 2.
PAGE EPA/ROD/ROS-89/117
3. Reclplenta Accauion No.
4. TlII8 IIIId SUb1I1I8
SUPERFUND RECORD OF DECISION
New Brighton/Arden Hills, MN
'urth Remedial Action (Amendment)
,JIor(a)
5. Raport Da..
8/11/89
8.
a. P8rfonnlng Organlzallon Rept. No.
II. P8rfonnlng Orglllnlza1lon Nama IIIId Add....
10. ProjK1lTulllWortI Unit No.
11. Contrac1(C) or Grwd(G) No.
(C)
(G)
12. 5poMorIng Organization Name IIId AddrHa
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Typa 0' Report . Pariod Coverad
Agency
800/000
14.
15. SupplemanWy No-
18. Abatract (Umlt: 200 _Ida)
The New Brighton/Arden Hills site is an area of organic solvent contamination in ground
water northwest of Minneapolis, Minnesota. The site includes the citi~s of New
Brighton, Arden Hills, and St. Anthony as well as the Twin Cities Army Ammunition plant.
This Record of Decision (ROD) amends a June 1986 ROD calling for the installation of a
new well to provide part of the drinking water supply to New Brighton. Because of major
changes in site conditions, EPA has concluded that a new well is no longer necessary to
~ect human health in New Brighton. Originally it was anticipated that low
~ ~amination levels in Well #7 (one of nine municipal wells) could not be assured and
that a replacement well in a deeper aquifer was needed to provide an alternate supply of
water. However, further data from Well #7 indicate contamination is riot increasing.
Moreover, a large water supply will be provided by the U.S. Army to New Brighton as part
of a litigation settlement, and a system has been installed by the U..S. Army to prevent
further contamination from the suspected sources. Therefore, EPA believes it is no
longer. necessary or cost effective to complete the project. There are no contaminants
of concern affecting the ground water associated with Well #7.
The selected remedial action for this ROD amendment is no further action for the Well
#7 operable unit and ceasing the installation of a ground water supply well remedy
selected in a June 1986 ROD.
17. Document Analyala L DHcrIptora
Record of Decision - New Brighton/Arden
Fourth Remedial Action (Amendment)
Contaminated Media: None
Key Contaminants: None
Hills, MN
. .
b. IdenliflanlOpen-Endad Tenna
.
c. COSA TI FIeIdIGroup
18. AvllilablQty Sta1ement
111. Security CIa.. (Thia Report)
None
20. SecurIty CIa.. (Thla Page)
Non~
21. No. 0' Pagea
9
22. PrIce
See ANSl-Z311.18
See Imtrut:tiom on ~"'.,...
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~nto'ComnMWce
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fR'ol ~ra.tia1 of Amemed Recxmi of Decisiat
site Name ani I.ocatian
New Brighton/Arden Hills
City of New Brighton Alternate Water SUpply (Well #13)
New Brighton, Minnesota
Stat:em2nt of Basis am F.Urcose
'lhis decision dc:x:uIt'..snt changes a decision made on June 30, 1986 to
coru:.-truct a ne'il well (I1UI11bo--r 13) to replace an existj,n; well (nun;;;er 7)
in Na". Brighton, Minnesota. At the tirie, data in:licated that well mmu:-er
7 might becane contaminatsd.
TIris decision document arnerrls the 1986 ROD by revoking the decision to
build ~vell #13 and by reccm!nerrling that no lrore funds be spent on the
Well #13 project. 'Ihis decision decurrent was develcped in accordance
Hith the comprehensive, Environmental Response, COmpensation am
. Liability Act (CERC!A) as arnerx:1ed by ~A, and, to the extent
practicable, the National Oil arrl Hazardous SUbstances Pollution
Contin;ency Plan (NCP). '!his decision is based on the administrative
record for the site. '!he attached irrlex identifies the items that
cat1prise the administrative record lJPOn which the decision described in.
this document is based.
Tne state of Minnesota has concurred with this decision ani has indicated
that u.s. EPA's decision is consistent with its policy ani rules.
e.:!SCcictian of Am?ooerl Remedy.
Tne operable unit proposed in the June 30, 1986 decision document was to
provide an alternate water supply due to irxiications that municipal Hell
#7 for thG City of New Brighton could beccme contaminated. At that time
t.'1s city Miter supply capacity \Vas approxilI1ately 7..9 million -';allons per
c.ay (lr.GD) (inclt:.di.nq 1 n;o f:..-cm ~~-t Well *7). It was C~:::::.7~~-.2d tha-t
it was.~ to ensure this capacity be I'i'aintained.
'!he 1986 Record of Decision provided for this assurance by consu-uction
of a new m.mi.cipal Well #13 in the uncontaminated Mt. Simon-Hinckley
aquifer. Because of long lead tim=>...s for implementation, the decision was
to i.1rplement .:.:he new well before the suspect cont.ami11ated Well #7 reached
levels. of c:art:amil1ation that. required iImnediate agency action. .
. .
']. d.s Amerrled Record of Decision revokes the June 30, 1986 decisio!1.
u.s. EPA no longer believes tll.at constroction of Well #13 is r.ece-.c:.sary to
protect. human ~lsalth because: .
1)
Further data from the suspect vIel1 #7 in:licates cOntami.nation is
not increasing; .
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2)
A large water supply will be provided by the U. s. Arrrr:l to the
City of New Brighton as part of a litigation settleIl'eIlt; arrl.
A system has been mstalled by the u.s. Arrrq to prevent further
ccntamination fran the SUSI=Ected source.
3)
Under the National COntir. :rcy Plan, a response action may be conducted
as an operable unit prior to the selection of an overall remedy, provided
E;uch action is cost-effective a.Y'rl consistent with a pernanent remedy (40
CFR 300.68). Because of the chan;e since 1986, U.S. EPA no longer .
1:eli~ves Hell #13 is a cost effectiv~ response.
Declaration
'!his decision to halt .ilnplementation prior to actual constnlction of Well
#13 as originally proposed in the June 30, 1986 Record of Decision is
protective of human hsalt.~ and the environment. Because this decision
affects an q::erable unit of the overall site reu..dy and because the
obj octi ve of the operable uni t \~'aS to provide an al ternati ve vTater
supply, rather than to clean-up the site, statutory requirements
concerni.rB cleanup standards and treatment technology do not apply.
These statutory requirements will be met by the overall remedy for the
New Bt"ightonjArden Hills site.
ftOO I I 1989
aldas V. Adamkus
Regional Administrator
Region V
Ii-
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~j sial Sl1rmAry
Int:roductim
'!he New' Brighton/Arden Hills SUperfund site is located Northwest of
1.1inneapolis ani includes the cities of New Brighton, Arden Hills, ani
st. Anthony as well as the Twin cities Arrrrj Ammunition plant. On Jun~
30, 1986, U.S. EPA signed a Record of Decision (ROD) calling for the
installation of a new well to provide part of the drinking water supply
to the City of NeT.v Brighton, Minnesota. CUe to lac.1c of reauthoriGation
of the SUperfund law fram October 1985 to October 1986, funding for this
p:::-oject was not available until l>f.ay 1987. 'Ihe remedial design for the
project is now complete. If the conditionS which brought about the ROD
had continued to apply, u.s. EPA w'ould, at this point, have ProceeC.E:d
with the rexr.edial action phase of the project am installed the ne~... well,
as planned. HO\ve:ver, because th~e have been major changes in these
conditions, u.s. EPA has concluded that a new well is no longer necP-ssary
to protect h1.II!\:U1 health in New Brighton am that completing the proj ect
T,-;culd be inconsistent with the CERCIA requirement that response actions
be cost-effective. u.s. EPA has therefore decided to amend the ROD and
reverse its decision to install a new T.vell.
Under Section 117 (c) of the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCIA) (42 U.S. C. 9617 (c)), if u.s.
EPA takes any remedial action which differs in any significant respect
from a final remedial action plan, the Agercj is required to publish an
explanation of the significant differences am the reasons such changes
were made. '!he decision by U.S. EPA to cancel its plans to install a net...
well in New Brighton constitutes such a significant difference.
Accordingly, u.s. EPA presented its explanation of the significant
differences and its rationale for the proposed changes. '!his notice for
the proposed change was published on November 28, 1988 in a major local
newspaper of general circulation. COmrr.ents from the public were accepted
through January 28, 1989. A public meeting was held to present t.'1e
proposed amendment on December 13, 1988. After reviewing public
cornrnents, t.~e Agency has decided to issue an Amended Record of Decision.
A respcnsiver:ess summar] addressing all significant ~r.-:ments recei'/ed on
the proposed changes is issued with this document.
'!his document is part of the administrative record which is available for
public inspection at the Neo;V' Brighton City Hall vault area, 803 5th
Avenue New Brighton, between 8:00 a.m. to 4:30 p.m. on weekdays; at the
Twin cities 1u:rrr:/ Arrmunition Plant, wbby of Building 105, fram 7:30 a.m
to 3:30 p.m.; ani at U.S. EPA, 230 S. Deart>orn street, Chicago, Illinois~
8:30 A.M. to 4:00 P.M.
2.0 SITE IITSroRY
In June 1981, the Minnesota Pollution Control Agency (MR:A) ani the Minnesota
Department of Health (MrH) detected organic solvent contamination in the
grourrlwater used for municipal drink.irq water in New Brighton. At the time,
the City of New Brighton was operating nine municipal wells, each of which
tapped the shallower Prairie du OUen;Jordan aquifer. .
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2
Several initial ~;;:tl measures (mMs) were brplemented at the site under
the SUperfurI1 PL~ldJD. In 1983, the U.S. EPA ins"'.alled granular. activated
carbon filters on two ImJnicipal wells (5 ani 6) tn meet peak demarrls. Urrler a
state-lead Interim Remedial ~ (mM) in 1983, residents depen:1ent upon
contaminated private wells were connected to nv.m.icipal 'Water mains.
Between 1982 ani 1984, New Brighton shut d~ six of its municipal wells (1-
6), deepened bvo municipal wells (8 ani 9) to tap the Mt. Si1rcn-Hinckley'
aquifer, ani constructed three ne/l wells (10-12) which also TPlfF the Ht.
SiIron-Hinckley aquifer. '!he sole remaining municipal well tapping the Prairie
du Chien aquifer was Well #7 ,whidl \.laS capable of supplying 1100 gallons per
minute or approxbrately 1.3 million gallons per day (1.3 ~D).
In its June 30, 1986 ROD, U.S. EPA prcposed to drill an additional well into
the Ht. Silnon-Hinckley aquifer to replace Well #7. At the time of the ROD,
water from Well #7 contained levels of carcinogens below the 10-6 excess
cancer risk level and met all enforceable drinki.rq water standards. HCM'ever,
because of the history of rapid changes in contaminant levels in the other
municipal wells tapping the Prairie du chien/Jordan aquifer, U.S. EPA
concluded that continued lc.w contarnir.ation levels in Well #7 could not be
assured. U.S. EPA also concluded that to protect huzran health in New
Brighton, New Brighton needed the amOunt of water supplied by Well #7 to
supplement the city's total capacity at the time. In other words, Well #7
could not silrply be shut da..m, but had to be replaced in order to assure Ne,.;
Brighton the minimum al1'CU11t of water necessary to protect ~lic health an:1
welfare. '!herefore, because of the need for a supply of 'Water equivalent to
'Well #7 for emergency anj stan:llJy use, the uncertainty corx:erni.ng the 10rq-
term purity of Well #7, ani the IOn;J lead times required for response acticns,
U.S. EPA ani ~ decided to investigate supply ani treatment options capable
of replacin;)' Well #7' s capacity before Well #7 became contaminated above
levels of concern. '!his investigation resulted in the June 30, 1986 Recor'd of
Decision to replace Well #7 with a new well, Well #13, tappinq the Mt. Si..::1On-
Hinckley aquifer.
Althcugh the OOD was signed in June 1986, ~'1e proje=t could not be funded at
that time. F\.u1d.:ing had to wait until after Congress r'2authorized SUperfurd jJ1
October 1986. Initial partial furxiinq was made available in May 1987 arrl was
followed by additional furxiinq in July and October 1987. Mere furds were
allocated for the project in Mard1 1988.
3.0 ~l'.1'l'.1m Pm RE.VJEol
On August 24, 1988, the United states Ar:rrr:f officially requested that u. S. EPA
review its R:)[) of June 30, 1986, in view of char'ges in circumstances affectirq
New Brighten's 'Water supply. '!his request -was the latest in a series .
subnitted by the ArrI.r:l, aski.rq the l>,gency to susperrl work on Well #13.
'!he h;Jercy had refused to review its OOD until the Arrfrj formally committed
itself, through an . agreement signed both by the ArrI.r:l am the City of New
Brighton, to r:-cvide New Brighton with clean dr:inJd.n] 'Water. '!his con::tition
havirx] been ]let on August 4,. 1988, the h;Jercy agreed to review the 1986 R)D as
requested in the Anrrj's petition of August 24, 1988.
.
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4.0 RE16:RS PtR AMEmJIR; '!HE ROD
'!here have been major c.h.an;es in circ:umstanc:es since the ROD was signed in
June 1986. '!he IOOSt important change is that the City of New Brighton am the
U . 5. ~ signed an a~~Ulent, un.ier whidl the Arrrrj will provide New Brighton
with four million gallons of drinki.rq water per day (4 M:;D). '!he Arrrry.is
currently provicliI:g Ne;.r Brighton with water fran a t.e!Irporary system am has
assured that supply in its Record of Decision, dated May 10, 1988, am the
settlement agreem2I1t. . '!he water will be p~ fran wells that New Brighton
previously shut down (Wells 3-6) am will be treated with granular activated
c.a:rbon to a point where it :meets federal am state drinkirq water starrlards.
At the time U. 5. EPA signed the ROD for Well #7, the provision of this amount
of potable water fram wells NaY' Brighton had smzt down was not anticipated.
A secon::l c::h.ange is that more data is ncN available conce.rning ccntaInination in
Well #7. For the past two years, the water quality of Well #7 has changed
very little. As a result, the AgfanC'j is new less concerned that a sudden
:increase in contaInination in Well #7 will occur.
Fil1ally, since october 1987, the U. 5. ArrI¥ has been operating a bcurxiary\
groundwater reo::Nery SYStem which minimizes contamination migration from the
'!Win cities Arrrry Ammunition Plant ('IQAP) fran reaching New Brighton's
. municipal wells.
.
Under the provisions of the <:ant>rehensive Environmental Response, Compensation
ani Liability Act (CERCIA), U.5. EPA is authorized to urxie.rtake response
actions to protect hmnan health or the envil:onment. Section 121 of CERCIA
states that response actions should be in accord with the National contingency
Plan and "provide for cost-effective response." tJrx:ler the National
Contingency Plan, a response action may be oonmcted as an operable unit prior
to the selection of an overall remedy, provided that such action is cost-
effective an:l consistent with a permanent remedy. (40 CFR 300.68 (c) (3».
At the time the ROD was. signed, U. 5. EPA concluded that all of the above
conditions \Y'ere satisfied. !:n June 1986, New Brighton's municipal water
system was capable of producing 7.6 million gallons of clean drinking water
per day, 1.3 million gallons of which were contril::uted by Well #7. U. 5. EPA
determine:i that a minimum capacity of approximately 7.5 million gallons per
day of potable water was nec.essary to protect human health in New Brighton.
'!he kJercy ncte::i that if Well #7 became contaminated an:l New Brighton was
forced to shut down the well, the city ~d be faced with a potentially
dan;JeraJS shortage of dri.nJd..n] water, absent arrj new source. u.s. EPA decided
that a cost~fective response in advance of a permanent temedy at TeMP would
be to drill a "f'eW well to replace Well #7.
Today, the corrlitions which provided the statutory am regulatory bases . for
u.s. EPA's originc:.1 ROD 00 lOn;Jer exist. U.S. EPA assumed in 1986 that a
capacity of C1R>roximately 7.5 million gallons of drinkin;J water per day would
be ~ to protect human health. With the iDplementation of the Arrcrj's
cazbJn treatJrent system, New Brighton will have a capacity of 10.9 million
gallons of drinkin;J water per day, sane 3 million gallons per day mre than
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4
U. S. EPA ::U::r:11111a(i was necessary to prctect p.1blic health am welfare.
Moreover, Well #7 ]'X) lorqer seems threatened with a ~vYkon influx of
contaminatiat. Hence, the m:Jtive for the original R:>D, Le., the threat to
public health and 'Nelfare caused by insufficient clean drinkin:J water, no
larger exists. U.S. EPA has spent ~tely $100,000 to date on this
project, DXStly for ~ial design~. We estimate that to CCII1plete the
project 'NOUld ccst an additional $840,000. Given that a pmlic health threat
no lorger exists, the}qercy believes that it wculd net be ccst-effective" to
cx::uplete the project.
5.0 CXMPARATIVE ~
'!he options available to U.S. EPA are (1) a.1i.1d the 1986 proposed Well #13 in
the uncontaminata:l Mt.Sim:m/Hinckley Aquifer am (2) Not build the 1986
proposed Well #13. 'Ihese options are c:x::rrpared, usin; nine criteria: "
1. OVerall Prctectian of Human Health am the EnvircnJ:ert:
U. S. EPA has considered the water supply needs of the City of New "
Brighton (population 23,000). At the time of the 1986 ROD, a supply of "
approximately 7.5 lG) was judged adequate for protection of human health. \
No infonnation has been received that d1an1es that estimate fran the 1986
ROD. Urxier the teJ:ms of a City of New Brighton-U.S. ArnrI agreement the
capacity will increase to aR,Jroximately 10.9 lG), a capacity sufficient to
prratect human health. consequently arrj qrt:ion to provide still greater
capacity is not needed for protection of human health.
2. Cc1:rDl.iarx:e With ARARs
section 121 (d) of CERCtA requires that where hazardcus substances,
pollutants or contaminants remain onsite, I'PtN='Oial action should attain a
level or starx:lard of control of such materials which at least attains
legally applicable or relevant an:l apprqriate requirement (ARARs).
However, un:ier section U1(d) (4) (A), where a ~jal action is only part
of a total remedial action, the partial L~W:S.ly need not achieve the
cleanup starrlards required for the. overall LCU-=ly.
In 1986, the kJercy decided to construct Well #13 as an operable unit of
the overall l:emedy. 'Ihis resp::>nse actia1 was inten:led not to clean up the
site, bIt to prctect p,lblic health by ~lYin:J additional drinking water.
As such, it did not have to meet the cleanup starrlards of section 121(d).
Nor does the revocation of the 1986 decision need to meet ARARs. Rather,
the obligatia\ to attain the required de;ree of cleanup applies' to the
overall l:~. u. S. EPA i.nterrls to make sure that the total remedial
action meets ARARs. "
3. laJ;J TenD Effectiveness and Pe1:mmer1ce
A 'Nell in the Mt. SiD:n-Hinck1ey Aquifer sUdt as that pl~ in 1986 is
pm;manent. '!he Minnesota Department of Natural Resa1rces notes continued
iJIplemelrt:atiat of such remedies may lead to CXI1tamination of the
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u
5
Mt. s1mcn-H:inck1ey Aquifer. Further the City of New Brighton nates that
c::art:irm8:l pmp~, of Mt. s.imcn Wells causes c:::a1tinua1 draw dcwn requ:irirg
redI~ );Imp~ rates, makin;J such wells unreliable in the lorq-run. SUdl
yield decreases are not: seen in ~ly rated Prairie du Olien Wells.
4. RedIJct.iat of '!hYicltv. K':j)illtv or ValUlll!
,'!his criterion is not ~licable directly. ~,the decision to '
terminate the Well #13 project is basEd at New Brighton receivirq water
iran an Arnrj system designed to treat a:ntaminated Prairie du alien ani
Jordan aquifer grc:un:i water.
5. Shart TeJ:m Effectiveness
Because the options facirg U.S. EPA do not directly address the
contamination of the aquifers but rather address the question of an
adequate supply of drinkin;J water for the City of New Brighton this
criterion is not applicable. '!he Minnesota Depa.rbnent of Natural
Resources ani -the Minnesota Pollution control kJercy note that
installation am pmpirq of Mt. SiJIcn Wells may have the affect of
iniucirq a:ntamination in this deeper aquifer.
6. T1Ir)1emeutability
Either option-blildin;J Well #13 as pI'q)OSEd, or cancellin.; the Well #13
project - is nrplementable.
7. costs
Builciin; Well #13 as originally pI'q)OSEd 'NO.1ld cost an additional $850,000
for construction. Approximately $100,000 has been spent on c:::crrpletion of
design of the well. Not buildi.rq Well #13 'NO.1ld not require ~ture of
this $850,000.
8. State AcceDtance
'!he Minnesota Pollution control kJercy (MECA) has ccmnented favorably ard
ccnc:urred with U.s. EPA's decision (letter dated January 26, 1989 -
Appendix C of the Responsiveness SUImmy). In brief, the MPCA concluded '
that:
1)
2)
u.s. EPA's arguments for hal~ Well '13 were convincirq;
awt~la~ water fran the !bmt SiJD::IVHin::kley Aquifer is ccunter
to state policy;
3)
better alternatives may exist if aa:u.tia1al. water is needed or
desired by the City of New Brigh't:m.
"
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b
6
'n1e policy of the Minnesota Department of Natural Resources (MOOR) is to
conse1:Ve th8.Mt. s.imcn-H:in::kley Aquifer (A{:pn:tix C of the Responsiveness
SlmIDary). M!Jm's ~1'1ts suwort the u.s. EPA's decisia1 to oot build Well
#13.
9. ~mitv ~l4me
'n1e City of New Brighton believes that Well '13 sha.1ld be ccnstructed..
'n1e City's position is oot that CX3'1Structia1 of Well #13 is necessary for
protection of the residents'health; b.zt rather, that the City's capacity
has been diminished by contamination of the regional gromd water. '!he
City argues that, because Mount -sboon;H:inck1ey \Wells do oot yield as Imlch
water as Prairie du Orlen wells at high pmpilq rates dur:i.n; the d1:y
~!:In11, an:! because it was hard to replace Prairie du Orlen with Mount
Swn wells, the City needs additional capacity to assure the same an-ount
of water it had before its wells became contaminated. '!he u.s. EPA
maintains its goal is not to restore the City's historical water capacity
but to provide for the protection of human health. u.s. EPA maintains
that Well #13 ,is not needed to do this since the New Brighton-U.S. Ar!rrf
Agreement rrM assures an adequate 5lJt:.Ply of water. '!his treatJnent system
is r'I:1« be:i.n; designed an:! built by the City of New Brighton.
6.0 ~ u::nHfiNM'IC'.R)
'!be U.S. EPA 1IIJSt make its decision based on consideration of the
statutory requirements of Section 121 of <::ERCIA. '!he folla.iin; summarizes
that consideration; . .
1. Prctective of Human Health an:! the ErlviLu;'IDe!'£
un:ier the system agreed upon by the u.s. Arr1¥, the City will have a total
dri.nk:irq water capacity of 10.9 lG). '!he 1986 R:>D ~d have reclaced
approximately 1lG) of water but not excarrled the water SUt=Ply beyoni the,
then, existin; 7.9 M:;D. 'n1us the City of New Brighton has tOOre water
available today than was forecasted in 1986 withcut such a settlement with
the Ar!rrf. '!he existin; deep 'w'ells plus the treated water fran the Army
settlement provides a supply that even the City of New Brighton says is
adequate (See t'Ym1IP-'1t in Responsiveness SlmIDary).
'!he SUWly will meet drinki.rq water st:.amams. '!he water fran
Well '7 has not exceeded drinki.rq water st:.amams an:! has had only la.i
levels of'la.
2. A~;n ARARS
ARARs are generally cleanup st.ardards. since a cleanup is not at issue
here, ARARs are not pertinent. With respect to the water quality
stan:Iards to be met by the City water SUJ;Ply system, the Dri.nki.n.J water
stan:::lards under the Safe Drinkin:J water Act ig)ly. '1he City's system
a.u:-rently meets those stan:Iards an:! will do so in the future.
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7
u
3. Be cast F.ff~
To date, $100,000 has been spent at the Well #13 project. Cr.IIq;)letion of
the project would cost an additional $840,000. Because t11.e TNe1l is no
longer ~M to protect p.Jblic health, the most cost eff~ve response
is to forego aIr:! additional expemiture at the TNe1l #13 project.
4. Utilize Pe1:mment SOluticns am A11:e1:native ~Jt Te.cbmlcxrles or .
~ Rec:cverv Tt::dl1clcxrles to the Mi:tYi1nl1l'll Extent Practicable.
While the decision to not build the new \Veil does net address this
criterion, neither did the proposed blildin;J of Well #13. The water frcm
the GAC treatment system provided by the Arrr¥ does use treatment arrl does
provide a limited degree of c1earnJP. 'Ibe original proposed action would
have. provided no degree of clean-up and wculd have posed a small
possibility of contaminatin; a clean aquifer by drillin; a well th.i-ough
the contam:i.nated aquifer into a deeper clean aquifer.
5. A.Ut~ ~ the Prefe.re.n::e for Trea'bDent '!hat ~~ Taxicitv.
Mcbilitv or Volune as PrinciDal Element is Satisfied.
R.elyin; on the treatment system provided by the u.s. kt:nrj instead of .
build.inq Well #13 which draws fram an uncontaminated aquifer is more in
the spirit of this criterion. The Arrr.rf GAC system will use water
extracted fran the ccntaminated Prairie du Chien/Jordan aquifer(s)aro .
provide treated water'to the citizens of New Brighton. '!his treatment
system will contribute to the cleanup of the Prairie du Olien aquifer.
. .
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"
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION V .
<;
DATE:
SUBJECT:
S E P 2 7 198~
Request for Concurrence on the Record of Decision Amendment
for Remedial Action at the New Brighton/Arden Hills Site,
~1i nnesota
FROM:
Basil G. Constantelos
Waste Management Division
Bertram C. Frey
Acting Regional Counsel
TO:
Valdas V. Adamkus
Regional Administrator
By this memorandum we are recommending that you authorize an amendment to.
the remedial action for the New Brighton/Arden Hills (Twin Cities Army
Ammunition Plant (TCAAP)) site by executing the attach~d Record of Decision
(ROD) amendment for an operable unit. This document reverses a decision
made on June 30, 1986 to construct a new drinking water well in New
Brighton that would replace the existing Well '7. As stated in the ROD,
the decision to construct ~~ell #13, is being reversed because of stabilized
conditions at the site and the provision of additi~nal drinking water to
New Brighton by the U.S. Army.
The ROD Amendment was prepared in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act, 42 U.S.C. Section
9601 et seq., \s Public Law 99-499, the National Contingency Plan, 4Q CFR .
Part 300:-and Agency Dolicy. We have reviewed the attached document~and c'~
have concluded that the ROD Amendment is both legally and technicallJ\:.~
sufficient. -
. .
/'
/ Please feel
( Attachment
free to contact either of us should you have any questions.
.
/
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